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EFTA00210597

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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 OPPOSITION TO JANE DOE NO. 1 AND JANE DOE NO. 2's PROTECTIVE MOTION PURSUANT TO RULE 15 TO AMEND THEIR PETITION TO CONFORM TO EXISTING EVIDENCE AND TO ADD JANE DOE NO. 3 AND JANE DOE NO. 4 AS PETITIONERS Respondent United States, by and through its undersigned counsel, files its Opposition to Jane Doe No. 1 and Jane Doe No. 2's Motion pursuant to Rule 15 to Amend their Petition to Conform to Existing Evidence and to Add Jane Doe No. 3 and Jane Doe No. 4 as Petitioners, and states: I. UNDER THE FEDERAL RULES OF CIVIL PROCEDURE, FED.R.CIV.P. 15 GOVERNS ATTEMPTS TO AMEND A PETITION TO ADD NEW PETITIONERS Petitioners have filed their "protective" motion to amend their petition and to add two new petitioners, Jane Doe No. 3 and Jane Doe No. 4. As the Government has previously explained (see, e.g., D.E. 290 at 1-2), these CVRA proceedings are ancillary criminal proceedings, see Fed.R.Crim.P. 60, Advisory Committee Note (2008 Adoption) ("This rule implements several provisions of the Crime Victims' Rights Act, codified at 18 U.S.C. § 3771, in judicial proceedings in the federal courts."), and the Rules of Criminal Procedure do not contemplate or permit any addition of parties such as petitioners seek. To the extent that this EFTA00210597

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