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EFTA02726180

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Case 9:08-cv-80736-KAM Document 179 Entered on FLSD Docket 12/06/2012 Page 1 of 5 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 A PROMPT RULING DENYING GOVERNMENT'S MOTION TO STAY COME NOW Jane Doe #1 and Jane Doc #2 (also referred to as "the victims"), by and through undersigned counsel, to request an expedited ruling on the Government's Motion to Stay. The Government's motion was filed more than one year ago, yet (presumably because of a flurry of other motions) the Court has yet to rule on this particular motion. The practical effect of a lack of a ruling on that motion has been to effectively grant the stay — blocking discovery in this case. Court should rule quickly on that motion and deny that motion. Denying the stay would allow the limited discovery that the Court has previously authorized to move forward in this case, putting the case on a path toward final resolution. BACKGROUND As the Court is aware, the victims filed this case alleging Government violations of the CVRA in July 2008. Through more than four years of litigation, however, the Government has refused to reach a stipulated set of facts regarding how it treated the victims. Accordingly, more than eighteen months ago, on March 21, 2011 the victims filed a motion to have their detailed recitation of the facts accepted because of the Government's failure to contest their facts (DE EFTA_R1_02213857 EFTA02726180

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