EFTA02725591.pdf

Case 9:08-cv-80736-KAM Document 199 Entered on FLSD Docket 06/28/2013 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/MATTHEWMAN JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. RESPONDENT'S UNOPPOSED MOTION FOR EXTENSION OF TIME To COMPLY WITH COURT'S ORDER TO FILE PLEADINGS IN PUBLIC PORTION OF COURT FILE Respondent United States of America, by and through the undersigned Assistant United States Attorney, hereby files this Motion for a one-week extension of time to Comply with the Court's Order to File Redacted Copies of the Government's Pleadings in the Public Portion of the Court File [DE 150]. In support thereof, Respondent states: I. On June 18, 2013, the Court entered an Order requiring the United States to file within 10 days redacted copies of its sealed pleadings in the public portion of the court file [DE 187]. 2. Some of those pleadings have attached to them a Sealed Order entered by the Hon. Donald M. Middlebrooks. To avoid contravening the Orders of this Court and Judge Middlebrooks' Order, Respondent has determined that it must seek permission from Judge Middlebrooks to unseal or partially unseal his Order. 3. An additional seven (7) days is requested to prepare and receive a ruling on that motion. This request is not being interposed for purposes of delay, but rather to avoid the possibility of being found in violation of an order entered by another judge of this Court. 1 EFTA_R1_02213114 EFTA02725591 Case 9:08-cv-80736-KAM Document 199 Entered on FLSD Docket 06/28/2013 Page 2 of 3 4. The undersigned has conferred with counsel for Petitioners, who have stated that they have no objection to the granting of this motion. Conclusion For the reasons set forth above, the United States respectfully requests that this Court grant an additional seven (7) days to comply with its Order requiring the filing of redacted pleadings in the public portion of the Court file. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/A. Marie Villafaiia A. Marie Villafalia Assistant United States Attorney Florida Bar No. 0018255 500 S. Australian Avenue, Suite 400 West Palm Beach, FL 33401 Tel: (561) 820-8711; Fax: (561) 820-8777 Email: ann.marie.c.villafana®usdoj.gov Dexter A. Lee Assistant United States Attorney Florida Bar No. 0936693 99 N.E. 4th Street Miami, Florida 33132 Tel: (305) 961-9320; Fax: (305) 530-7139 Email: [email protected] Eduardo I. Sanchez Assistant United States Attorney Florida Bar No. 877875 99 N.E. 4th Street Miami, Florida 33132 Tel: (305) 961-9057; Fax: (305) 536-4676 Email: eduardo.i.sanchez®usdoj.gov Attorneys for Respondent 2 EFTA_R1_02213115 EFTA02725592 Case 9:08-cv-80736-KAM Document 199 Entered on FLSD Docket 06/28/2013 Page 3 of 3 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served via CM/ECF this 28th day of June, 2013, upon Counsel for Petitioners Jane Doe #1 and Jane Doe #2. s/A. Marie Villafaiia A. Marie Villafalla Assistant United States 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 Brad Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: [email protected] 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 # 1 and Jane Doe # 2 3 EFTA_R1_02213116 EFTA02725593