EFTA00617971.pdf

Case 9:08-cv-80736-KAM Document 394 Entered on FLSD Docket 06/23/2016 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Matthewman JANE DOE #1 AND JANE DOE #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent, PARTIES' JOINT MOTION TO CONTINUE SETTLEMENT CONFERENCE AND FOR EXTENSION OF TIME TO FILE STATUS REPORT The parties, by and through undersigned counsel, hereby file this joint motion to continue the settlement conference in this matter and for an extension of time to file a status report on the state of settlement negotiations. In support thereof, the parties state: 1. On May 23, 2016, the parties appeared before the Hon. Dave Lee Brannon for a settlement conference (DE392). Progress was made towards settlement, and it was agreed that the parties would continue working on their own towards settlement and re-convene for a second settlement conference on June 28, 2016 (id.). In accordance with that schedule, U.S. Magistrate Judge Brannon ordered the parties to file a joint status report by noon on June 24, 2016 (DE393). 2. The parties have continued to discuss the matter and progress has been made towards settlement. However, additional time is needed to gather all necessary information and to allow adequate time for petitioners' counsel to confer with their client. 3. The parties believe that a short continuance is required to allow further negotiations and conferral and, accordingly, request that the Court re-set the settlement conference and also re-set the time for filing a status report. EFTA00617971 Case 9:08-cv-80736-KAM Document 394 Entered on FLSD Docket 06/23/2016 Page 2 of 3 4. The parties are available for a settlement conference on July 6, 19, 20, or 21, 2016. If the Court is unavailable on those dates, additional dates in August are available. CONCLUSION For the foregoing reasons, the parties respectfully request that the Court continue the settlement conference currently set for June 28, 2016, and grant a corresponding extension of time to file the parties' joint status report. For Petitioners: For Respondent: Respectfully submitted, 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 (954) 524-2822 E-mail: WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/A. Marie Villafaiia A. MARIE VILLAFARA Assistant United States Attorney Florida Bar No. 0018255 500 South Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephone: 561-820-8711 Facsimile: 561-820-8777 ann.marie.c.villafana@usdoj.gov CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 23, 2016, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. According to the Court's website, counsel for all parties are able to receive notice via the CM/ECF system. s/A. Marie Villafaiia A. MARIE VILLAFARA Assistant United States Attorney 2 EFTA00617972 Case 9:08-cv-80736-KAM Document 394 Entered on FLSD Docket 06/23/2016 Page 3 of 3 SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos & Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale FL 33301-3268 954-524-2820 Fax: 954-524-2822 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 casselp@law.utah.edu Attorneys for Jane Doe # 1 and Jane Doe # 2 3 Dexter Lee, Esq. Assistant U.S. Attorney U.S. Attorney's Office for the Southern District of Florida 99 ■. 4th Street Miami, FL 33131 (305) 961-9320 Fax: (305) 530-7139 dexter.lee@usdoi.gov A Marie Villafafia Assistant U.S. Attorney U.S. Attorney's Office for the Southern District of Florida 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 Ann.marie.c.villafana@usdoj.gov Attorneys for Respondent United States of America EFTA00617973