EFTA01139288.pdf

Case 9:08-cv-80736-KAM Document 275 Entered on FLSD Docket 11/07/2014 Page 1 of 4 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, Respondent. RESPONDENT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE RESPONSE TO PETITIONERS' REASSERTION OF OBJECTIONS TO GOVERNMENT'S ASSERTIONS OF PRIVILEGES Respondent, by and through its undersigned counsel, files its Unopposed Motion for Enlargement of Time to File Response to Petitioners' Reassertion of Objections to Government's Assertions of Privileges, and states: I. On September 22, 2014, this Court granted Petitioners' Motion for Ordinary Briefing Schedule and Ordinary Page Limits to Respond to the Government's Privilege Assertions. ■. 257 at 3. 2. On October 20, 2014, petitioners filed their Reassertion of Objections to Government's Assertions of Privileges. M. 265. 3. In previous filings, the Government has responded to many of petitioners' objections to the adequacy of the privilege log, the validity of the privileges asserted, including attorney- client; attorney work-product; law enforcement investigative privilege; and the deliberative process privilege. See Respondent's Opposition to Petitioners' Renewed Motion for an Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (E. 230), and EFTA01139288 Case 9:08-cv-80736-KAM Document 275 Entered on FLSD Docket 11/07/2014 Page 2 of 4 Respondent's Opposition to Petitioners' Motion to Compel Production of Document That Are Not Privileged (E. 229). 4. In order to maintain the proper sequence of filed documents, respondent wishes to reassert its responses to petitioners' objections in a single document, so the Court and parties can more easily find the government's response to a particular objection noted by petitioners. 5. Respondent's counsel has been engaged in depositions and discovery in another case, and has not been able to devote full attention to preparing the response to petitioners' Reassertion of Objections to Government's Assertions of Privileges (E. 265). Respondent respectfully requests an enlargement of time, up to and including November 14, 2014, to file its response to petitioners' Reassertion of Objections to Government's Assertions of Privileges. 6. On November 6, 2014, the undersigned conferred by e-mail with petitioners' counsel, to determine their position on this motion. Petitioners' counsel graciously did not oppose this motion. WHEREFORE, respondent respectfully requests an enlargement of time, up to and including November 14, 2014, to file its response to petitioners' Reassertion of Objections to Government's Assertions of Privileges. DATED: November 7, 2014 Respectfully submitted, WILFREDO A. FERRER UNITED STATES ATTORNEY By: s/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney Flas kar No. 0936693 99 M. 4th Street, Suite 300 Miami, Florida 33132 (305) 961-9320 2 EFTA01139289 Case 9:08-cv-80736-KAM Document 275 Entered on FLSD Docket 11/07/2014 Page 3 of 4 Fax: (305) 530-7139 E-mail: [email protected] ATTORNEY FOR RESPONDENT CERTIFICATE OF SERVICE I HEREBY CERTIFY that on November 7, 2014, 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 I and 2 v. United States, Case No. 08-80736-CIV-MARRA United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, ■. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 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 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # I and Jane Doe # 2 Roy Black Jackie Perczek Black, Srebnick, Komspan & Stumpf, ■. 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 3 EFTA01139290 Case 9:08-cv-80736-KAM Document 275 Entered on FLSD Docket 11/07/2014 Page 4 of 4 (305) 371-6421 Fax: (305 35 -2006 E-mail: Attorneys for Intervenors 4 EFTA01139291