OPERATION LEAP YEAR
OPERATION LEAP YEAR REVISED INDICTMENT SUMMARY CHART (by victim) New Jane Doe # Old Jane Doe # Name DOB Range of activity dates Overt Acts Substantive Counts GJ Transcript Pages 1 n/a 8/9/83 1988 - 2001 2 n/a 2 n/a 1/2/87 2001 to 2003 1-15 23 3 n/a 7/26/88 2003 42 n/a 4 n/a 10/23/87 2003 16-22, 138, 5 165 5 1 4/9/86 March 2004 27-29, 80-81, 6 91, 153-154, 159, 175, 177, 179, 182, 185-186 ( 4 6/30/87 4/04 - 6/29/05 23-24, 32-35, 7, 20, 24 37-38, 57, 59, 124, 174, 176 12 4/29/88 7/04 41-47, 51, 53 8, 19, 25 N 6 12/30/86 7/04 - 12/04 25, 48-50, 9, 19, 26 52, 56, 58, 60,63-65, 102, 111-112, 144 7 2/1/87 7/04 - 11/05 55, 61, 66- 10, 19, 27 67, 102, 107- 108, 140, 142-143, 150 10 14 4/23/87 8/04 - 2/05 68-71, 145 11, 28 I I 13 5/28/87 8/04 -5/05 78, 145-148, 12, 29 168 12 10 3/5/88 9/04 - 12/04 80-84, 94, n/a 106 13 5 6/18/87 11/04 - 3/05 72-76, 109- 13, 20, 30 110, 114-117, 136-137,
Summary
OPERATION LEAP YEAR REVISED INDICTMENT SUMMARY CHART (by victim) New Jane Doe # Old Jane Doe # Name DOB Range of activity dates Overt Acts Substantive Counts GJ Transcript Pages 1 n/a 8/9/83 1988 - 2001 2 n/a 2 n/a 1/2/87 2001 to 2003 1-15 23 3 n/a 7/26/88 2003 42 n/a 4 n/a 10/23/87 2003 16-22, 138, 5 165 5 1 4/9/86 March 2004 27-29, 80-81, 6 91, 153-154, 159, 175, 177, 179, 182, 185-186 ( 4 6/30/87 4/04 - 6/29/05 23-24, 32-35, 7, 20, 24 37-38, 57, 59, 124, 174, 176 12 4/29/88 7/04 41-47, 51, 53 8, 19, 25 N 6 12/30/86 7/04 - 12/04 25, 48-50, 9, 19, 26 52, 56, 58, 60,63-65, 102, 111-112, 144 7 2/1/87 7/04 - 11/05 55, 61, 66- 10, 19, 27 67, 102, 107- 108, 140, 142-143, 150 10 14 4/23/87 8/04 - 2/05 68-71, 145 11, 28 I I 13 5/28/87 8/04 -5/05 78, 145-148, 12, 29 168 12 10 3/5/88 9/04 - 12/04 80-84, 94, n/a 106 13 5 6/18/87 11/04 - 3/05 72-76, 109- 13, 20, 30 110, 114-117, 136-137,
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Case 9:08-cv-80119-KAM
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
Case 9:08-cv-80119-KAM
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
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
Case 9:08-cv-80119-KAM Du..ument 511 Entered on FLSD Docku, J3/29/2010 Page 1 of 11
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