UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA¶
Case No. 08-80736-Civ-Marraa¶
JANE DOE #1 and JANE DOE #2¶
v.¶
UNITED STATES¶
JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO ASSERT OBJECTIONS TO GOVERNMENT'S ASSERTION OF PRIVILEGE and OTHEWISE COMPLY WITH COURT ORDER DE 257¶
COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move this Court for an additional week extension of time in which to assert Objections to Government's Assertion of Privilege and Otherwise Comply with this Honorable Court's Order (DE 257).¶
This Court's Order [DE 257] granted Petitioners' Motion for Ordinary Briefing Schedule and Ordinary Page Limits to Respnd to the Government's Privilege Assertions [DE 218], stating that Petitioners may file their motion re-asserting the objections to the government's assertions of privilege within 21 days from September 21, 2014, which would be October 13, 2014.¶
The victims are represented by two attorneys, J. and Paul G. Cassell. Both have scheduling conflicts that take them outside of their offices during the time in which they would need to prepare a response.¶
The victims request that their time to Assert Objections and otherwise comply with Court Order be due on or before October 20, 2014.¶
The Government does not oppose this motion.¶
A proposed order to this effect is attached to this motion.¶
For all these reasons, the Court should extend the victim's time to Assert Objections to the Government's Assertion of Privilege and otherwise comply with Court Order (DE 257), to due on or before October 20, 2014.¶
DATED: October 9.2014¶
Respectfully Submitted,¶
/s/ JAFFE, WEISSING, 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¶
CERTIFICATE OF SERVICE¶
I certify that the foregoing document was served on October 9, 2014, on the following using the Court's CM/ECF system:¶
Dexter Lee A. Villafafia 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: 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 Email: pleading@royblack.com (305) 37106421 (305) 358-2006¶
Jay P. Lefkowitz Kirkland & Ellis, LLP 601 Lexington Avenue New York, NY 10022 Email: lefkowitz@kirkland.com (212) 446-4970¶
G. Weinberg, P.C. 20 Park Plaza Suite 1000 Boston,. 02116 Email: owlmgw@att.net (617) 227-3700 (617) 338-9538 Criminal Defense Counsel for Jeffrey Epstein¶
/s/ J.¶