EFTA00611628.pdf

Case 9:08-cv-80736-KAM Document 360 Entered on FLSD Docket 02/05/2016 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08.80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES NOTICE OF WITHDRAWAL OF JANE DOE NO. 1 AND JANE DOE NO. 2'S MOTION FOR DEPOSITIONS OF GOVERNMENT WITNESSES COME NOW Jane Doe No. 1 and Jane Doe No. 2 (the "victims"), by and through undersigned counsel, to file this notice that, with the agreement of the Government, they are withdrawing motion for court permission to take the depositions of six important Government witnesses in this action (DE 344). The Government has now responded to the motion (DE 359). After receiving the Government's response, victims' counsel and government counsel have conferred and have jointly agreed that it would be most efficient if the victims withdraw their motion at this time. The withdrawal is without prejudice to victims re-filing their motion, if they believe it is necessary, after the Government responds to the victims' soon-to-be-filed summary judgment motion. This will permit the parties to litigate the issue on the need for depositions based on the matters in dispute once the summary judgment and response thereto have been filed. CONCLUSION With the agreement of the Government, the victims are withdrawing their motion for depositions without prejudice to later refiling. DATED: February 5, 2016 I EFTA00611628 Case 9:08-cv-80736-KAM Document 360 Entered on FLSD Docket 02/05/2016 Page 2 of 3 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, ■. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile±9541524-2822 E-mail: 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 Does No. 1, 2, 3 and 4 'This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah 2 EFTA00611629 Case 9:08-cv-80736-KAM Document 360 Entered on FLSD Docket 02/05/2016 Page 3 of 3 CERTIFICATE OF SERVICE I certify that the foregoing document was served on February 5. 2016. on the following using the Court's CM/ECF system: Dexter Lee A. Marie Villafafia 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.Marie.C.Villafana@usdoj.gov Attorneys for the Government Roy Eric Black Jacqueline Perczek Black Srebnick Kornspan & Stumpf 201 S Biscayne Boulevard Suite 1300 Miami, FL 33131 305-371-6421 Fax: 358-2006 Email: Attorneys for Jeffrey Epstein /s/ Bradley J. Edwards 3 EFTA00611630