Case 9:08-cv-80736-KAM Document 354-2 Entered on FLSD Docket 01/14/2016 Page 1 of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Matthewman JANE DOE #1 and JANE DOE #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' SECOND REQUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "Respondent") hereby responds to Jane Doe I and Jane Doe 2's Second Request for Admissions to the Government Regarding Questions Relevant to Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Second Requestfor Admissions"), and states as follows: Objection to Requests' Overbroad and Unduly Burdensome Use of Petitioner-Defined "Government" The Respondent objects to the petitioners' use in ten of its numbered requests for admissions (i.e., Requests No. 9, 10, 13, 18, 19, 20, 23, 24, 25, and 26), half of which contain numerous subparts, of the capitalized word "Government," which petitioners have purported to define as follows: The Respondent's response is confined to Request No. 1 through Request No. 28 in the "Discovery Requested" section of the Second Request for Admissions and does not intend to respond to assertions in any other section of the Second Request for Admissions (including the "Background" section), none of which appear to separately state any matter calling for an admission. Nonetheless, the Respondent denies the assertion that the Respondent has declined the request of Jane Doe #1 and Jane Doe #2 to stipulate to undisputed facts in this case. Respondent's Exhibit B Case No. 08.80736-CIV-MARRA EFTA02756024