Case 9:08-cv-80736-KAM Document 129 Entered on FLSD Docket 12/05/2011 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S RESPONSE TO GOVERNMENT'S SEALED MOTION TO STAY COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to respond to the Government's Motion to Stay Discovery. The Government's belated motion alleging a lack of jurisdiction appears to be nothing but a delaying tactic, designed to prevent the victims from establishing the facts surrounding the Government's violation of their CVRA rights. The Court should accordingly simply deny the motion, thereby mooting any further request for a stay of discovery until the motion can be resolved. The Court should also order the Government to respond to the victims' discovery requests within 14 days of the Court's denial of the motion to dismiss. As the Court is well aware, the victims filed this case alleging Government violations of the CVRA in July 2008. More than three years later, the Government suddenly decided to file a motion alleging that this Court does not possess subject matter jurisdiction over the case. The date on which the Government filed its motion is, coincidentally, exactly the same date on which the Government's responses to the victims' document requests were due! EFTA02753698