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Record

Draft: efta02755596

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 08-80736-CIV-MARRA

JANE DOE #1 and JANE DOE #2,

Petitioners,

vs.

UNITED STATES OF AMERICA,

Respondent.

I

RESPONDENT'S UNOPPOSED MOTION FOR LEAVE OF COURT TO FILE OPPOSITION TO JANE DOE NO. 1 AND JANE DOE NO. 2's PROTECTIVE MOTION TO AMEND PETITION AND ADD JANE DOE NO. 3 AND JANE DOE NO. 4, IN EXCESS OF TWENTY PAGES

Respondent, by and through its undersigned counsel, files its Unopposed Motion for Leave of Court to File Opposition to Jane Doe No. 1 and Jane Doe No. 2's Protective Motion Pursuant to Rule 15 to Amend Their Petition to Conform to Existing Evidence, and to Add Jane Doe No. 3 and Jane Doe No. 4 as Petitioners, In Excess of Twenty Pages, and state:

I. Respondent United States of America has prepared its Opposition to Jane Doe No.1 and Jane Doe No. 2's Protective Motion Pursuant to Rule 15 to Amend Their Petition to Conform to Existing Evidence and to Add Jane Doe No. 3 and Jane Doe No. 4 as Petitioners (D.E. 311). Respondent's opposition number twenty-four (24) pages, and is attached as Exhibit A.

  1. Under S.D.IFIa.L.R. 7.1(c)(2), "[a]bsent prior permission of the Court, neither a motion and its incorporated memorandum of law nor the opposing memorandum of law shall exceed twenty (20) pages." Respondent respectfully requests leave of the Court to file its opposition to petitioners' motion, which numbers 24 pages in length.

  2. On February 23, 2015, respondent's undersigned counsel contacted petitioners' counsel regarding their position on this motion. Petitioners graciously did not oppose this motion.

WHEREFORE, respondent respectfully requests leave of this Court to file their Opposition to Jane Doe No. 1 and Jane Doe No. 2's Protective Motion Pursuant to Rule 15 to Amend Their Petition to Conform to Existing Evidence and to Add Jane Doe No. 3 and Jane Doe No. 4 as Petitioners, which numbers twenty-four (24) pages.

DATED: February 23, 2015 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. 4'h Street, Suite 300 Miami, Florida 33132 (305) 961-9320 Fax: (305) 530-7139 E-mail: dexter.lee@usdoj.gov

ATTORNEY FOR RESPONDENT

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on February 23, 2015, 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

SERVICE LIST

Jane Does 1 and 2 v. United Sates Case No. 08-80736-CIV-MARRa

United States District Court, Southern District of Florida

• J. Esq. , Jaffe, Weissing, 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 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 # I and Jane Doe # 2

Roy Black Jackie Perczek Black, Srebnick, Kornspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 (305) 371-6421 Fax: (305) 358-2006 E-mail: rblack@royblack.com jperczek@ royblack.com

Attorneys for Intervenors

Draft: efta02755596

Other records

Prepared source

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. I RESPONDENT'S UNOPPOSED MOTION FOR LEAVE OF COURT TO FILE OPPOSITION TO JANE DOE NO. 1 AND JANE DOE NO. 2's PROTECTIVE MOTION TO AMEND PETITION AND ADD JANE DOE NO. 3 AND JANE DOE NO. 4, IN EXCESS OF TWENTY PAGES Respondent, by and through its undersigned counsel, files its Unopposed Motion for Leave of Court to File Opposition to Jane Doe No. 1 and Jane Doe No. 2's Protective Motion Pursuant to Rule 15 to Amend Their Petition …