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efta-efta00205709DOJ Data Set 9Other

Case 9:08-cv-80736-KAM Document 105 Entered on FLSD Docket 10/10/2011 Page 1 of 3

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DOJ Data Set 9
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EFTA 00205709
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3
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8
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Case 9:08-cv-80736-KAM Document 105 Entered on FLSD Docket 10/10/2011 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANDE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR FIVE EXTRA PAGES TO RESPOND TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO INTERVENE BY ROY BLACK ET AL. COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move this Court to allow them five extra pages beyond the twenty-page limit to respond to the Supplemental Briefing in Support of Motion to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz (DE 94) and the government response thereto (DE 100). The motion is unopposed. In support of the motion, the victims note that initial Supplemental Briefing from Epstein they are responding to (DE 94) is 23 pages long. The Government's response (DE 100) supports many of Epstein's arguments

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EFTA Disclosure
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Case 9:08-cv-80736-KAM Document 105 Entered on FLSD Docket 10/10/2011 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANDE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR FIVE EXTRA PAGES TO RESPOND TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO INTERVENE BY ROY BLACK ET AL. COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move this Court to allow them five extra pages beyond the twenty-page limit to respond to the Supplemental Briefing in Support of Motion to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz (DE 94) and the government response thereto (DE 100). The motion is unopposed. In support of the motion, the victims note that initial Supplemental Briefing from Epstein they are responding to (DE 94) is 23 pages long. The Government's response (DE 100) supports many of Epstein's arguments and is 11 pages long. As a result, the victims have a total of 33 pages that they need to respond to. The victims require 25 pages to set forth all of their arguments and authorities on the issues addressed in the briefs. The victims have discussed this motion with counsel for Epstein and the Government, and they do not oppose the motion. 1 EFTA00205709 Case 9:08-cv-80736-KAM Document 105 Entered on FLSD Docket 10/10/2011 Page 2 of 3 CONCLUSION For all the foregoing reasons, the Court should allow Jane Doe #1 and Jane Doe #2 an additional five pages (a total of 25 pages) to respond to the Supplemental Briefing in Support of Motion to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz (DE 94) and the government response thereto (DE 100). DATED: October 10. 2011 Respectfully Submitted, 5/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the Universit of Utah Salt Lake City, UT 84112 Attorneys for Jane Doe #1 and Jane Doe #2 2 EFTA00205710 Case 9:08-cv-80736-KAM Document 105 Entered on FLSD Docket 10/10/2011 Page 3 of 3 CERTIFICATE OF SERVICE The foregoing document was served on October 10, 2011, on the following using the Court's CM/ECF system: A. Marie Villafafia Assistant U.S. Attorney West Palm Beach, FL 33401 Attorney for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. Miami, FL 33131 Attorneys for Proposed Intervenors Roy Black et al. 3 EFTA00205711

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DOJ Data Set 9OtherUnknown

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Case 9:08-cv-80736-KAM Document 99

Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/2672011 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOES #1 AND #2, Plaintiffs, vs. UNITED STATES, Defendant. / ORDER THIS CAUSE is before the Court upon Plaintiffs' Motion for Finding of Violations of the Crime Victims' Rights Act (DEs 48, 52), Plaintiffs' Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49), Plaintiffs' Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50), and Bruce E. Reinhart's Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order (DE 79).1 All motions are fully briefed and ripe for review, and the Court has heard oral arguments on all motions. The Court has carefully considered the briefing and the parties' arguments and is otherwise fully advised in the premises. The Court is awaiting supplemental brie

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Case 9:08-cv-80736-KAM Document 99

Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09:2672011 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOES #1 AND #2, Plaintiffs, vs. UNITED STATES, Defendant. / ORDER THIS CAUSE is before the Court upon Plaintiffs' Motion for Finding of Violations of the Crime Victims' Rights Act (DEs 48, 52), Plaintiffs' Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49), Plaintiffs' Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50), and Bruce E. Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order (DE 79).1 All motions are fully briefed and ripe for review, and the Court has heard oral arguments on all motions. The Court has carefully considered the briefing and the parties' arguments and is otherwise fully advised in the premises. The Court is awaiting supplemental briefing on th

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DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Plaintiffs I UNITED STATES, Defendants JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT COME NOW Jane Doe #1 and Jane Doe #2 ("the victims"), by and through undersigned counsel, and request the defendant United States (hereinafter "the Government") to produce the original or best copy of the items listed herein below for inspection and/or copying, pursuant to the Court's Order (DE #99) directing discovery in this case. BACKGROUND As the Government will recall, the victims have asked the Government to stipulate to undisputed facts in this case. The Government has declined. Accordingly, the victims filed their Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a Hearing on Appropriate Remedies (DE 48

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DOJ Data Set 9OtherUnknown

Case 9:08-cv-80736-KAM Document 99

Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/2672011 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOES #1 AND #2, Plaintiffs, vs. UNITED STATES, Defendant. / ORDER THIS CAUSE is before the Court upon Plaintiffs' Motion for Finding of Violations of the Crime Victims' Rights Act (DEs 48, 52), Plaintiffs' Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49), Plaintiffs' Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50), and Bruce E. Reinhart's Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order (DE 79).1 All motions are fully briefed and ripe for review, and the Court has heard oral arguments on all motions. The Court has carefully considered the briefing and the parties' arguments and is otherwise fully advised in the premises. The Court is awaiting supplemental brie

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