EFTA00593003.pdf

Case 9:08-cv-80736-KAM Document 347 Entered on FLSD Docket 12/28/2015 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08.80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE NO. 1 AND JANE DOE NO. 2'S MOTION TO TEMPORARILY SEAL THEIR MOTION TO COMPEL ANSWERS TO SUPPLEMENTAL REQUESTS FOR ADMISSIONS AND REQUESTS FOR PRODUCTION COME NOW Jane Doe No. I and Jane Doe No. 2 (the "victims"), by and through undersigned counsel, to file this motion to temporarily seal their Motion to Compel Answers to Supplemental Requests for Admission and Requests for Production (hereinafter referred to as the "Motion to Compel"). As indicated in their Motion to Compel, see page 2 at n. 1, the victims have attempted to secure the documents in question through voluntary production, by requests to both the Government and an identified non-party. Those efforts have been unsuccessful, prompting the need for a motion to the court. The victims are aware that a non-party to this litigation may attempt to intervene and argue that their motion is not proper should not be a part of the public court file. The victims, of course, take the view that their Motion to Compel is proper and is the appropriate procedural method for obtaining this information that clearly meets the threshold of being reasonably calculated to lead to the discovery of admissible evidence. In light of local rule 5.4(a) which indicates that Court filings are generally a matter of public record, the victims understand that this motion would not typically be sealed. However, in order to give the identified non-party EFTA00593003 Case 9:08-cv-80736-KAM Document 347 Entered on FLSD Docket 12/28/2015 Page 2 of 4 an opportunity to try to raise any arguments he might wish to present to the Court on this issue, the victims request that their motion be placed under a temporary seal. WHEREFORE, the victims request that their Motion to Compel be placed under seal for ten days or until the Court has ruled on any motion by any non-party to seal the motion, whichever is longer. DATED: December 28, 2015 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Fort Lauderdale Florida 33301 Telephone Facsimile E-mail: And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah' Salt Lake Cit UT 84112 Telephone: Facsimile: E-Mai Attorneys for Jane Does No. 1, 2, 3 and 4 'This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah 2 EFTA00593004 Case 9:08-cv-80736-KAM Document 347 Entered on FLSD Docket 12/28/2015 Page 3 of 4 CERTIFICATE OF SERVICE I certify that the foregoing document was served on December 28, 2015, on the following using the Court's CM/ECF system or, for non-parties, by separate email service: West Palm Beach, FL 33401 Fax: E-mail: E-mail: Attorneysfor the Government Roy Eric Black Jacqueline Perczek Black Srebnick Kornspan & Stumpf Miami FL 33131 Fax: Email: Attorneysfor Jeffrey Epstein Kendall Coffe Fla. Bar No. Gabriel Groisman Fla. Bar No. Beniamin H. Brodsky, Fla. Bar No. COFFEY BURLINGTON, P.L. Miami, Florida 33133 Telephone; Facsimile: Thomas E. Scott , Jr. Cole Scott & Kissane 3 EFTA00593005 Case 9:08-cv-80736-KAM Document 347 Entered on FLSD Docket 12/28/2015 Page 4 of 4 Miami FL 33156 Fax: Email: Attorneys for Alan Dershowitz /s/ Bradley J. Edwards 4 EFTA00593006