Case 9:08-cv-80736-KAM Document 312-1 Entered on FLSD Docket 02/23/2015 Page 1 of 25 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. THE CAREFUL BALANCE THAT CONGRESS STRUCK WITH THE CVRA COUNSELS AGAINST THE EXPANSION OF THESE CVRA PROCEEDINGS TO INCLUDE ADDITIONAL CLAIMS OR PARTIES. 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) (discussing rule's implementation of CVRA provisions for federal judicial proceedings), and the Rules of Criminal Procedure do not contemplate or permit any addition of parties such as petitioners seek. Thus, in determining whether to expand the CVRA proceedings initiated by Jane Doe No. 1 and Government Exhibit A Case No. 08-80736-CIV-MARRA EFTA01081459