EFTA01081942.pdf

Case 9:08-cv-80736-KAM Document 312 Entered on FLSD Docket 02/23/2015 Page 1 of 3 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 OF AMERICA, Respondent. RESPONDENT'S UNOPPOSED MOTION FOR LEAVE OF COURT TO FILE OPPOSITION TO JANE DOE NO. 1 AND JANE DOE NO. 2's PROTECTIVE MOTION TO AMEND PETITION AND ADD JANE DOE NO. 3 AND JANE DOE NO. 4, IN EXCESS OF TWENTY PAGES Respondent, by and through its undersigned counsel, files its Unopposed Motion for Leave of Court to File Opposition to Jane Doe No. 1 and Jane Doe No. 2's Protective Motion Pursuant to Rule 15 to Amend Their Petition to Conform to Existing Evidence, and to Add Jane Doe No. 3 and Jane Doe No. 4 as Petitioners, In Excess of Twenty Pages, and state: I. Respondent United States of America has prepared its Opposition to Jane Doe No.1 and Jane Doe No. 2's Protective Motion Pursuant to Rule 15 to Amend Their Petition to Conform to Existing Evidence and to Add Jane Doe No. 3 and Jane Doe No. 4 as Petitioners (D.E. 311). Respondent's opposition number twenty-four (24) pages, and is attached as Exhibit A. 2. Under S.D.Fla.L.R. 7.1(c)(2), "[a]bsent prior permission of the Court, neither a motion and its incorporated memorandum of law nor the opposing memorandum of law shall exceed twenty (20) pages." Respondent respectfully requests leave of the Court to file its opposition to petitioners' motion, which numbers 24 pages in length. EFTA01081942 Case 9:08-cv-80736-KAM Document 312 Entered on FLSD Docket 02/23/2015 Page 2 of 3 3. On February 23, 2015, respondent's undersigned counsel contacted petitioners' counsel regarding their position on this motion. Petitioners graciously did not oppose this motion. WHEREFORE, respondent respectfully requests leave of this Court to file their Opposition to Jane Doe No. 1 and Jane Doe No. 2's Protective Motion Pursuant to Rule 15 to Amend Their Petition to Conform to Existing Evidence and to Add Jane Doe No. 3 and Jane Doe No. 4 as Petitioners, which numbers twenty-four (24) pages. DATED: February 23, 2015 Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney ATTORNEY FOR RESPONDENT CERTIFICATE OF SERVICE I HEREBY CERTIFY that on February 23, 2015, 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 2 EFTA01081943 Case 9:08-cv-80736-KAM Document 312 Entered on FLSD Docket 02/23/2015 Page 3 of 3 United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer Jaffe Weissin Edwards Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe # I and Jane Doe # 2 Roy Black Jackie Perczek Black. Srebnick. Korns an & Stumpf, P.A. Attorneys for Intervenors 3 EFTA01081944