EFTA00605842.pdf

CM/ ECE - Live Database - fisd 11/14/11 5:57 PM Limited Intervention by Jeffrey Epstein. (Perczek, Jacqueline) (Entered: 10/14/2011) 10/14/2011 110 MOTION for Extension of Time to File Response/Reply as to .11)¢ Response in Opposition to Motion, 24 Supplement by Roy Black. (Perczek, Jacqueline) (Entered: 10/14/2011) 10/16/2011 111 NOTICE by Roy Black re In MOTION for Extension of Time to File Response/Reply as to n& Response in Opposition to Motion, 24 Supplement Notice of No Objection By Government (Perczek, Jacqueline) (Entered: 10/16/2011) 10/16/2011 112 NOTICE by Jeffrey Epstein relt12 MOTION for Leave to File Excess Pages in Omnibus Reply In Support of Motion For Limited Intervention Notice of No Objection From Government (Perczek, Jacqueline) (Entered: 10/16/2011) 10/17/2011 113 ENDORSED ORDER grantingllp Motion for Extension of Time to File Response/Reply re a MOTION to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz. Replies due by 10/31/2011. Signed by Judge Kenneth A. Marra on 10/17/2011. (ir) (Entered: 10/17/2011) 10/17/2011 114 ENDORSED ORDER granting i(12 Motion for Leave to File Excess Pages. Signed by Judge Kenneth A. Marra on 10/17/2011. (ir) (Entered: 10/17/2011) 10/31/2011 Di REPLY to Response to Motion re 1€ MOTION to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz filed by Roy Black, Jay Lefkowitz, Martin G. Weinberg. (Perczek, Jacqueline) (Entered: 10/31/2011) 10/31/2011 11¢ Unopposed MOTION for Leave to File Excess Pages by Roy Black, Jay Lefkowitz, Martin G. Weinberg. (Perczek, Jacqueline) (Entered: 10/31/2011) 11/01/2011 117 ENDORSED ORDER granting .11€ Motion for Leave to File Excess Pages. Signed by Judge Kenneth A. Marra on 11/1/2011. (ir) (Entered: 11/01/2011) 11/08/2011 SYSTEM ENTRY - Docket Entry 118 [motion] restricted/sealed until further notice. (dj) (Entered: 11/08/2011) 11/08/2011 SYSTEM ENTRY - Docket Entry 119 [motion] restricted/sealed until further notice. (dj) (Entered: 11/08/2011) 11/08/2011 SYSTEM ENTRY - Docket Entry 120 [motion] restricted/sealed until further notice. (dj) (Entered: 11/08/2011) 11/08/2011 SYSTEM ENTRY - Docket Entry 121 [motion] restricted/sealed until further notice. (dj) (Entered: 11/08/2011) 11/09/2011 SYSTEM ENTRY - Docket Entry 122 [order] restricted/sealed until further notice. (dj) (Entered: 11/09/2011) 11/09/2011 SYSTEM ENTRY - Docket Entry 123 [order] restricted/sealed until further notice. (dj) (Entered: 11/09/2011) 11/16/2011 VA MOTION for Extension of Time to File Response/Reply Jane Doe #1 and Jane Doe #2 Unopposed Motion for 10-day Extension of time to Respond to Government's Motion to Dismiss and Motion for Stay of Discovery by Jane Doe. (Attachments: # .1. https://ectfisd.uscouns.govicgl-bln/DktRpt.pR409366001252042-1._1_0-1 Page 14 of 15 EFTA00605842 CM/ECF - Live Database - 1Usd Text of Proposed Order)(Edwards, Bradley) (Entered: 11/16/2011) 11/15/11 5:57 PM 11/16/2011 125 ENDORSED ORDER granting 124 Motion for Extension of Time to File Response/Reply re 119 SEALED MOTION to dismiss for lack of subject matter jurisdiction. Responses due by 12/5/2011. Signed by Judge Kenneth A. Marra on 11/16/2011. (ir) (Entered: 11/16/2011) PACER Service Center Transaction Receipt 11/16/2011 17:54:04 PACER Login: di0569 Client Code: Description: Docket Report [Search Criteria: 9:08-cv-80736-KAN1 Billable Pages: I I (Cost: 0.88 hilps:/fecf.fled.ustouns.govicgl-bin/DktRpt.$7409366001252042-1-1_0-1 Page 15 of 15 EFTA00605843 Case 9:08-cv-80736-KAM Document 124 Entered on FLSD Docket 11/16/2011 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR 10-DAY EXTENSION OF TIME TO RESPONSE TO GOVERNMENT'S MOTION TO DISMISS AND MOTION FOR STAY OF DISCOVERY COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to file an unopposed motion for extension of time to respond to the Government's motion to dismiss and motion to stay proceedings. The victims' response to these two motions is currently due on Friday, November 25, 2011 — the Friday immediately following Thanksgiving. One of the victims' counsel, Bradley J. Edwards, has just completed a multi-week jury trial that has prevented him from turning to the pending motion until today. The other of the victims' counsel, Paul G. Cassell, has a brief due in the Fifth Circuit on November 23, 2011, and also long-scheduled vacation the week of Thanksgiving. Accordingly, victims' counsel seek a 10-day extension to Monday, December 5, 2011, to file their responses to the Government's two pending motions. Counsel have conferred and the Government does not oppose the motion. DATED: November 16, 2011 1 EFTA00605844 Case 9:08-cv-80736-KAM Document 124 Entered on FLSD Docket 11/16/2011 Page 2 of 3 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah. edu Attorneys for Jane Doe #1 and Jane Doe #2 2 EFTA00605845 Case 9:08-cv-80736-KAM Document 124 Entered on FLSD Docket 11/16/2011 Page 3 of 3 CERTIFICATE OF SERVICE The foregoing document was served on November 16, 2011, on the following using the Court's CM/ECF system: Dexter Lee A. Marie Villafatla Assistant U.S. Attorneys 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: Dexter.Lee©usdoj.gov E-mail: ann.maric.c.villafanana Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, FL 33131 (305) 37106421 (305) 358-2006 Martin G. Weinberg, P.C. 20 Park Plaza Suite 1000 Boston, MA 02116 (617) 227-3700 (617) 338-9538 Joseph L. Ackerman, Jr. Fowler White Burnett PA 777 S. Flagler Drive, West Tower, Suite 901 West Palm Beach, FL 33401 Criminal Defense Counsel for Jeffrey Epstei (courtesy copy of pleading via U.S. mail) 3 EFTA00605846 Case 9:08-cv-80736-KAM Document 124-1 Entered on FLSD Docket 11/16/2011 Page 1 of 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES [PROPOSED] ORDER GRANTING JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR 10-DAY EXTENSION OF TIME TO RESPONSE TO GOVERNMENT'S MOTION TO DISMISS AND MOTION FOR STAY OF DISCOVERY THIS CAUSE comes before the Court on Jane Doe #1 and Jane Doe #2's Unopposed Motion for 10-Day Extension Of Time To Response To Government's Motion To Dismiss And Motion For Stay Of Discovery. Having reviewed the Motion and the Court file, and good cause having been shown, It is ORDERED AND ADJUDGED that the Motion is GRANTED. The Court shall allow Jane Doe #1 and Jane Doe #2 a 10-day extension to Monday, December 5, 2011, to file their responses to the Government's two pending motions. DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida, this day of 2011. KENNETH A. MARRA United States District Judge 1 EFTA00605847