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Case 9:08-cv-80736-KAM Document 368 Entered on FLSD Docket 02/19/2016 Page 1 of 3

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Case 9:08-cv-80736-KAM Document 368 Entered on FLSD Docket 02/19/2016 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, v. UNITED STATES OF AMERICA, Respondent, UNITED STATES' UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEFING AND TO RESPOND TO DISCOVERY REQUESTS The Respondent, United States of America, by and through the undersigned Assistant United States of America, hereby files this unopposed motion for a 21-day extension of time to file briefing and to respond to outstanding discovery requests. In support thereof, the undersigned states: 1. Pursuant to the Court's Amended Scheduling Order (DE 356), the Respondent must file its response to Petitioners' motion for summary judgment and its own cross-motion for summary judgment, by March 24, 2016. 2. Petitioners also have served the government with amended discovery requests, and responses to those requests are currently due on February 22, 2016. 3. Counsel for the parties have conferred and jointly request that the Court extend these deadlines by twenty-one days to allow the parties time to explore resolution of the matter. 4. Should the parties be unable to resolve the matter, the parties have agreed to ask that the Court enter an amended briefing and response schedule as follows: March 14, 2016 Government's Responses to Outstanding Discovery Requests Due EFTA00610780 Case 9:08-cv-80736-KAM Document 368 Entered on FLSD Docket 02/19/2016 Page 2 of 3 April 14, 2016 Government's Response to Petitioners' Motion for Summary Judgment and Cross-Motion for Summary Judgment Due May 3, 2016 Petitioners' Reply to Government's Response and Response to Government's Cross-Motion Due May 17, 2016 Government's Reply to Petitioners' Response Due. 5. This request is not interposed for purposes of delay, but rather to allow the parties sufficient time to meet and discuss outstanding issues. CONCLUSION For the foregoing reasons, Respondent respectfully requests that the Court grant a 21-day extension of time to file briefing and to respond to outstanding discovery requests. A proposed Amended Scheduling Order is attached. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: 2 EFTA00610781 Case 9:08-cv-80736-KAM Document 368 Entered on FLSD Docket 02/19/2016 Page 3 of 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on February 19, 2016, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. According to the Court's website, counsel for all parties are able to receive notice via the CM/ECF system. SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/MAITHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman Paul G. Cassell S.J. Quinney College of Law at the University of Utah Fax: E-mail: Attorneys for Jane Doe # 1 and Jane Doe # 2 3 EFTA00610782

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Case #9:08-CV-80736-KAM

Related Documents (6)

DOJ Data Set 9OtherUnknown

Case 9:08-cv-80893-KAM Document 217 Entered on FLSD Docket 09/13/2010 Page 1 of 7

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DOJ Data Set 9OtherUnknown

Subjec

Fr • < > Subjec :Deliberative t Process ec aratton rom am Justice - equest or wo ee xtension Date: Fri, 20 Sep 2013 17:59:47 +0000 Importance: Normal We have no objection, provided we get the following accommodation, which you already anticipated. We would request that your motion for extension of time give us an extension on our reply document, such that our reply would be due 10 days after the main Justice Department declaration that will be coming in two weeks. If you would include such language as well in any proposed order, saving us (and the court) drafting time, that would be very much appreciated. Paul Cassell and Brad Edwards for Jane Doe #1 and Jane Doe #2 Paul G Cassell CONFIDENTIAL: This electronic message along with any/all attachments is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message

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DOJ Data Set 9OtherUnknown

Case 9:08-cv-80736-KAM Document 50

Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 0372172011 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for an order from this Court directing the U.S. Attorney's Office not to suppress material evidence relevant to this case. The Court should enter an order, as it would in other criminal or civil cases, requiring the Government to make appropriate production of such evidence to the victims. BACKGROUND In discussions with the U.S. Attorney's Office about this case, counsel for Jane Doe #1 and Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims information in its possession that was mater

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Case 9:08-cv-80736-KAM Document 50

Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 0372112011 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for an order from this Court directing the U.S. Attorney's Office not to suppress material evidence relevant to this case. The Court should enter an order, as it would in other criminal or civil cases, requiring the Government to make appropriate production of such evidence to the victims. BACKGROUND In discussions with the U.S. Attorney's Office about this case, counsel for Jane Doe #1 and Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims information in its possession that was mater

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DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 013-80736-Civ-Marra/Nlatthewman JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES, Respondent. DECLARATION OF IN SUPPORT OF GOVERNMENT'S RESPONSE AND OPPOSITION TO PETITIONERS' MOTION FOR PARTIAL SUMMARY JUDGMENT AND CROSS-MOTION FOR SUMMARY JUDGMENT do hereby declare that I am a member in good standing of the Bar of the State of Florida. I also am admitted to practice in all courts of the states of Minnesota and Florida, the Eighth, Eleventh, and Federal Circuit Courts of Appeals, and the U.S. District Courts for the Southern District of Florida, the District of Minnesota, and the Northern District of California. My bar admission status in California and Minnesota is currently inactive. I am currently employed as an Assistant United States Attorney in the Southern District of Florida and was so employed during all of the events described herein. 2. I am the Assistant United States Attorne

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DOJ Data Set 9OtherUnknown

STATEMENT BY ALAN DERSHOWITZ

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