EFTA00622813.pdf

Case 9:08-cv-80736-KAM Document 351 Entered on FLSD Docket 01/11/2016 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE NO. 1 AND JANE DOE NO. 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. RESPONDENT'S SECOND UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE RESPONSE TO PETMONERS' MOTION FOR DEPOSITIONS OF GOVERNMENT WITNESSES Respondent United States of America, by and through its undersigned counsel, files its Second Unopposed Motion for Enlargement of Time to File Response to Petitioners' Motion for Depositions of Government Witnesses, and states: I. On January 5, 2016, this Court granted respondents' unopposed motion for enlargement of time to respond to petitioners' motion for depositions of government witnesses. D.E. 350. A response is due on January 11, 2016. 2. The Government's proposed response contains arguments which are being reviewed at various sections within the Department of Justice. That process was commenced prior to the week of January 4, 2016, but has not been completed. The Government expects it may take several more weeks for this process to conclude Accordingly, the Government requests an enlargement of time of three weeks, up to and including February 1, 2016, to file its response to petitioners' motion for depositions of government witnesses. 3. On January 11, 2016, respondent requested petitioners' position on the instant EFTA00622813 Case 9:08-cv-80736-KAM Document 351 Entered on FLSD Docket 01/11/2016 Page 2 of 3 motion. Petitioners' counsel graciously did not oppose the instant motion. WHEREFORE, respondent respectfully requests an enlargement of time of three weeks, up to and including February 1, 2016, to file their response to the petitioners' motion for depositions of government witnesses. DATED: January 11, 2016 Respectfully submitted, WILFREDO A. FERRER UNITED STATES ATTORNEY By: s/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. 4th Street, Suite 300 Miami Florida 33132 may : ATTORNEY FOR RESPONDENT CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 11, 2016, 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 States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 2 EFTA00622814 Case 9:08-cv-80736-KAM Document 351 Entered on FLSD Docket 01/11/2016 Page 3 of 3 E-mail: Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 E-mail: Attorneys for Jane Doe # I and Jane Doe # 2 3 EFTA00622815