EFTA00027809.pdf

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Source set: data-set-8
Extracted text

Case 9:08-cv-80736-KAM Document 451 Entered on FLSD Docket 05/10/2019 Page 1 of 14 
IN THE UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF FLORIDA 
JANE DOE 1 AND JANE DOE 2, 
Civil Action No. 
Petitioners, 
v. 
UNITED STATES OF AMERICA, 
Respondent. 
08-80736-CIV-MARRA 
Government's Notice of Proposed Procedures for the 
Determination of a Remedy 
The United States of America, by Byung J. Pak, United States Attorney for the 
Northern District of Georgia, and 
Special Attorneys for the Southern District of Florida, files this notice outlining 
the Government's proposed schedule for determining the issue of what remedy, 
if any, should be applied based on the Court's Opinion and Order of February 
21, 2019. [Doc. 435]. 
Pursuant to the Court's order, the parties have conferred extensively over the 
past several weeks regarding the steps that may be necessary to aid the Court's 
determination of a remedy. While the parties agree on certain components, 
including cross-briefing and art opportunity for all parties to be heard, we have 
been unable to reach an agreement on a briefing schedule primarily based on 
two substantive disagreements. 
EFTA00027809


Case 9:08-cv-80736-KAM Document 451 Entered on FLSD Docket 05/10/2019 Page 2 of 14 
First, the government has requested a sixty-day period to speak directly with 
victims who may be affected by any remedy in this matter prior to submitting its 
recommendation. For the reasons discussed below, Petitioners counsel oppose 
this request. Based on discussions with Petitioners, the government anticipates 
that Petitioners are likely to propose remedies that could impact victims in 
significant—and perhaps unintended —ways. At this time, neither the 
government nor the Petitioners have spoken to the majority of victims. The 
victims views and concerns are critical to inform the government's 
recommendation of an appropriate remedy, particularly given the sensitive 
nature of the crime at issue. Accordingly, the g…
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