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efta-efta00211157DOJ Data Set 9Other

UNITED STATES DISTRICT COURT

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. THE PARTIES' JOINT STATUS REPORT AND MOTION FOR REVISED BRIEFING AND DISCOVERY SCHEDULE The parties, by and through their undersigned counsel, hereby file this Joint Status Report and Motion for Revised Briefing and Discovery Schedule. In support thereof, the parties state: 1. Briefing and responses to discovery in this matter were stayed while the parties pursued settlement negotiations with the assistance of U.S. Magistrate Judge Dave Lee Brannon. After Judge Brannon declared an impasse, the parties continued to pursue settlement. While those efforts will continue, at this time the parties believe that the Court should re-institute a briefing schedule on the petitioners' pending summary judgment motion and re-set the deadline for the government to respond to the petitioners' amended disco

Date
Unknown
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DOJ Data Set 9
Reference
EFTA 00211157
Pages
3
Persons
4
Integrity

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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. THE PARTIES' JOINT STATUS REPORT AND MOTION FOR REVISED BRIEFING AND DISCOVERY SCHEDULE The parties, by and through their undersigned counsel, hereby file this Joint Status Report and Motion for Revised Briefing and Discovery Schedule. In support thereof, the parties state: 1. Briefing and responses to discovery in this matter were stayed while the parties pursued settlement negotiations with the assistance of U.S. Magistrate Judge Dave Lee Brannon. After Judge Brannon declared an impasse, the parties continued to pursue settlement. While those efforts will continue, at this time the parties believe that the Court should re-institute a briefing schedule on the petitioners' pending summary judgment motion and re-set the deadline for the government to respond to the petitioners' amended disco

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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. THE PARTIES' JOINT STATUS REPORT AND MOTION FOR REVISED BRIEFING AND DISCOVERY SCHEDULE The parties, by and through their undersigned counsel, hereby file this Joint Status Report and Motion for Revised Briefing and Discovery Schedule. In support thereof, the parties state: 1. Briefing and responses to discovery in this matter were stayed while the parties pursued settlement negotiations with the assistance of U.S. Magistrate Judge Dave Lee Brannon. After Judge Brannon declared an impasse, the parties continued to pursue settlement. While those efforts will continue, at this time the parties believe that the Court should re-institute a briefing schedule on the petitioners' pending summary judgment motion and re-set the deadline for the government to respond to the petitioners' amended discovery requests. 2. The parties have conferred and jointly request that the Court extend these deadlines as set below to allow the parties time to continue exploring resolution of the matter while also moving towards resolution if settlement cannot be reached. 3. 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: October 17, 2016 Government's Responses to Outstanding Discovery Requests Due EFTA00211157 October 17, 2016 Government's Response to Petitioners' Motion for Summary Judgment and Cross-Motion for Summary Judgment Due November 21, 2016 Petitioners' Reply to Government's Response and Response to Government's Cross-Motion Due December 12, 2016 Government's Reply to Petitioners' Response Due. CONCLUSION For the foregoing reasons, the parties respectfully request that the Court impose the proposed briefing/discovery schedule. A proposed Amended Scheduling Order is attached. Respectfully submitted, Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY slPaul G. Cassell Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit Utah 84112 COUNSEL FOR PETITIONERS By: COUNSEL FOR RESPONDENTS CERTIFICATE OF SERVICE I HEREBY CERTIFY that on August 22, 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. 2 EFTA00211158 SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit Utah 84112 Attorneys for Jane Doe # 1 and Jane Doe # 2 EFTA00211159

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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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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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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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UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I UNITED STATES DECLARATION OF BRADLEY J. EDWARDS, ESQ. I. I, Bradley J. Edwards, Esq., do hereby declare that I am a member in good standing of the Bar of the State of Florida. Along with co-counsel, I have represented Jane Doe #1 and Jane Doe #2 in civil suits against Jeffrey Epstein for sexually abusing them. I have also represented other girls who were sexually abused by Epstein. As a result of that representation, I have become familiar with many aspects of the criminal investigation against Epstein and have reviewed discovery and correspondence connected with the criminal investigation. I have also spoken to Jane Doe #1 and Jane Doe #2 at length about the criminal investigation and their involvement in it, as well enforcement (or lack their of) of their rights as crime victims in the investigation. I also represent Jane Doe #1 and Jane Doe #2 in the pen

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