S-5T1AT-4ES DI-7STRICT COURT 10655SOUTHERN DIST-4RI-6CT OF FL-4ORIDA No 08-80736-Civ-Marra/Joh6nson JANE DOE and JANE DOE UNITE-5D S-6TAT-5ES JANE DOE-4 AND J-6ANE DOE 2S PRO TECTIVE M-7O-3TION FOR REME-4DI-7ES 2650COME NOW Jane Doe and Jane Doe als referred to as 223the victim8s by and through undersigned counsel to file this protective m8o1tion for re-6m8e-1dies for violations of their rights under the Crim9e Victim9s Rights Act their concurrently-filed response to the Governm8e-1nt 2s motion to dism8iss and sealed response to the Governm9ent 2s m9o1tion to dism9i-6ss the victim9s outline num9erous rem9edies that-6 would be proper once they prove the Governm8e-1nt vi o5l-2ated th5e CVRA At variou6s p6o1ints in its5 earlier p6l-1ead6ings however the Governm9ent seem9s to contend that the fact that the victim9s have not form9ally filed a m9o1tion assertin6g each and6 ev ery one o6f4 these specific rem8e-1dies m8a-1y have som8e-1 significance in this case.6 The Governm8e-1nt also inaccurately desc ribes6 the5 re5m9edies th6e5 victim9s are seeking the Court is aware,6 this case presents various issues of first im8pression and the procedures that the crime victim8s should follow to protect their CVRA rights are not clearly established Accordingly to prot ect their right to seek all of th rem8e-1dies they are seeking the victim9s protectiv6ely f4ile5 this m8o1tion asking the Court to award all these rem9edies that they Case Document Entered on FLSD Docket Page of outlin6e in th6eir responses to the m9o1tion to dism9iss The Court should award all of thes5e rem9edies5 to the victim9s for the reasons explain6ed in their pleadings and because th6es5e rem9edies address the Governm8e-1nt-7 2s violati ons of their rights DATED Decem8ber Respectf4u1lly6 Subm9itted Bradley Edwards Bradley E6d1wards FARMER J-7A1FFE WEI-8SSING EDWARDS FISTOS LEHRMAN P.L North Andrews Avenue Suite Fort Lauderdale Florida Telephone Facsim8ile Florida Bar No E-m9ail brad6 pathtoju6stice.com9 and Pro Hac Vice S.J 2750Quinney 2750College 2750University 2750Utah Salt 2750Lake 2750City Telephone Facsim8ile cassellp law.utah.edu 1251Attorneys for Jane Doe and Jane Doe Case Document Entered on FLSD Docket Page of CERTIFICATE OF S-5E1RVI-7CE 200The foregoing docum8ent was served on Decem8ber on the followin6g1 using th11e Court 2s CM/ECF system Dexter Lee A Marie Villafa Assistan5t U.S Attorneys Australian Ave Suite West Palm8 Beach FL Fax E-m9ail Dexter.Lee usd6o1j.gov E-m10a1il ann.m8arie.c.villafana usdoj.gov Attorneys fo6r the Govern6m8e-1nt Roy Black Esq Jackie Perczek Esq Black Srebnick Kornspan Stumpf P.A South Biscayne Boulevard Suite Miam9i FL Martin Weinberg P.C Park Plaza Suite Boston MA Case Document Entered on FLSD Docket Page of
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