EFTA00598957.pdf

Case 9:08-cv-80736-KAM Document 423 Entered on FLSD Docket 09/15/2017 Page 1 of 4 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 ENLARGEMENT OF TIME TO FILE REPLY TO PETITIONERS' RESPONSE TO RESPONDENT'S CROSS-MOTION FOR SUMMARY JUDGMENT Respondent, United States of America, by and through its undersigned counsel, files its Unopposed Motion for Enlargement of Time to File Reply to Petitioners' Response to Respondent's Cross-Motion for Summary Judgment, and states: I. Respondent's reply to petitioners' response to respondent's cross-motion for summary judgment is due on Friday, September 15, 2017. 2. The U.S. Attorney's Office closed on September 7-8, 2017, to prepare for the approach of Hurricane Irma. The Office was closed on September 11-13, 2017, due to the impact of the storm. The Office reopened on September 14, 2017, with many employees still absent due to the effects of the storm. 3. Due to the disruption caused by the storm, respondent respectfully requests an enlargement of time of three weeks, up to and including October 6, 2017, to file its reply to petitioners' response to respondent's cross-motion for summary judgment. On September 14, 2017, the undersigned counsel contacted petitioners' counsel, Brad Edwards, Esq., regarding 1 EFTA00598957 Case 9:08-cv-80736-KAM Document 423 Entered on FLSD Docket 09/15/2017 Page 2 of 4 petitioners' position on the instant motion. Mr. Edwards graciously did not oppose respondent's motion. WHEREFORE, respondent respectfully requests an enlargement of time, up to and including October 6, 2017, to file its reply to petitioners' response to respondent's cross-motion for summary judgment. DATED: September 15, 2017 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: Assistant Ha. Bar No Miami. Florida 33132 E-mail: ATTORNEY FOR RESPONDENT CERTIFICATE OF SERVICE I HEREBY CERTIFY that on September 15, 2017, the foregoing was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. Assistant United States Attorney 2 EFTA00598958 Case 9:08-cv-80736-KAM Document 423 Entered on FLSD Docket 09/15/2017 Page 3 of 4 SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, ENISSISS . Fort Lauderdale Florida E-mail: Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the MOM Salt Lake City. Utah 84112 Tel: E-mail: Attorneys for Jane Doe 1 and Jane Doe 2 Jacqueline Perczek PF Mi ' Tel: Email: Roy E. Black BLACK SREBNICK KORNSPAN & STUMPF Miami FL 33131 Tel: Email: Attorneys for Intervenor Jeffrey Epstein 3 EFTA00598959 Case 9:08-cv-80736-KAM Document 423 Entered on FLSD Docket 09/15/2017 Page 4 of 4 Dexter A. Lee Assistant United States Attorney Mi Tel: E-mail: Assistant United States Attorney West Palm Beach, Florida 33401 Tel: E- Assistant United States Attorney Miami, Florida 33132 Tel: Em. Attorneys for the United States 4 EFTA00598960