EFTA00212569.pdf

Case 9:08-cv-80736-KAM Document 57 Entered on FLSD Docket 04/07/2011 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, Petitioners, vs. UNITED STATES, Respondent. RESPONDENT'S MOTION FOR LEAVE OF COURT TO FILE MEMORANDUM OF LAW IN EXCESS OF TWENTY PAGES Respondent, United States, by and through its undersigned counsel, files its Motion for Leave of Court to File Memorandum of Law in Excess of Twenty Pages, and states: I. Under S.D.Fla.L.R. 7.1(c)(2), no party shall file any legal memorandum exceeding twenty (20) pages in length, absent prior permission of the Court. 2. Respondent has prepared its Response to Jane Doe #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victims Rights Act and Request for a Hearing on Appropriate Remedies, which numbers fifty-three (53) pages. A copy is attached as Exhibit A. The additional length of the Response was necessary to adequately respond to the forty-two (42) page motion filed by petitioners. 3. On April 7, 2011, the undersigned asked petitioners' co-counsel, Brad Edwards, Esq., for their position on the instant motion. Mr. Edwards graciously did not oppose the instant motion. WHEREFORE, respondent respectfully requests leave of the Court to file its Response to EFTA00212569 Case 9:08-cv-80736-KAM Document 57 Entered on FLSD Docket 04/07/2011 Page 2 of 3 Jane Does #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victims Rights Act and Request for a Hearing on Appropriate Remedies, numbering fifty-three (53) pages. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. 4ih Street Miami, Florida 33132 (305) 961-9320 Fax: (305) 530-7139 E-mail: dexterlee@usdoj.gov Attorney for Respondent CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 7, 2011, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. s/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney 2 EFTA00212570 Case 9:08-cv-80736-KAM Document 57 Entered on FLSD Docket 04/07/2011 Page 3 of 3 SERVICE LIST Jane Does 1 and 21. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: brad@pathtojustice.com 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 E-mail: casselp@law.utah.edu Attorneys for Jane Doe # 1 and Jane Doe # 2 3 EFTA00212571