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Case 9:08-cv-80736-KAM Document 199 Entered on FLSD Docket 06/28/2013 Page 1 of 3

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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. EFTA01081820 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 Villafaila A. Marie Villafafia Assistant United States Attorney Florida Bar No. Dexter A. Lee Assistant United States Attorney Florida Bar No. Eduardo I. Sanchez Assistant United States Attorney Florida Bar No. 2 Attorneys for Respondent EFTA01081821 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 Villafatia 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 Paul G. Cassell S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe # I and Jane Doe # 2 3 EFTA01081822

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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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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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