## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case No. 08-80736-Civ-Marraa

JANE DOE #1 and JANE DOE #2

v.

UNITED STATES

## UNOPPOSED MOTION BY THE VICTIMS FOR EXTENSION OF TIME TO FILE REPLY IN SUPPORT OF MOTION PURSUANT TO RULE 21 FOR JOINDER IN ACTION

COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as "the new victims"), by and through undersigned counsel, to file this unopposed motion for a short extension of time to file their reply in support of their motion for joinder in this action.

On January 2, 2015, the new victims filed a (corrected) motion for joinder in this action (DE 280). On January 20, 2015, the Government filed an opposition to the new victims' motion (DE 290). The opposition raised several complicated issues, including issues surrounding a heretofore unmentioned statute of limitations: 28 U.S.C. § 2401(a). Counsel for the new victims wishes to carefully research issues related to the statute of limitations, as well as coordinate an additional filing that is related to the statute of limitations. Given counsel's schedule, concluding this research and preparing the additional filing will require additional time. Accordingly, the new victims seek a nine-day extension of time to file their reply until Friday, February 6, 2015.

Jane Doe No. 1 and Jane Doe No. 2 support this motion. The Government does not oppose this request.

Accordingly, the Court should grant the new victims an extension of time to prepare their reply.

DATED: January 28. 2014

Respectfully Submitted,

/s/ JAFFE, WE1SSING, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 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 Does Nos. I, 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

## CERTIFICATE OF SERVICE

I certify that the foregoing document was served on January 28, 2015, on the following using the Court's CM/ECF system:

Dexter Lee

A. Villafana

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

/s/