EFTA01091399.pdf

Case 9:08-cv-80736-KAM Document 357 Entered on FLSD Docket 01/29/2016 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 REPLY IN SUPPORT OF MOTION TO COMPEL ANSWERS TO SUPPLEMENTAL REQUESTS FOR ADMISSION AND REQUESTS FOR PRODUCTION COME NOW Jane Doe No. 1 and Jane Doe No. 2 (the "victims"), by and through undersigned counsel, to file this motion to temporarily seal their reply in support of their motion to compel the Government either to provide answers to certain requests for admission and requests for production involving Epstein lawyer Alan Dershowitz or, in the alternative, to properly assert privilege over these discovery requests. 1. On December 28, 2015, Jane Doe 1 and Jane Doe No. 2 filed their motion to temporarily seal their motion to compel answers to supplemental requests for admissions and requests for production. D.E. 347. Petitioners then filed, under seal, their motion to compel answers. 2. On January 14, 2015, respondent filed its opposition to petitioners' motion to compel answers to supplemental requests for admission and requests for production under seal. 3. Since the motion involves a non-party, respondent requests that it be allowed to file it under seal, pending this Court's resolution of the petitioners' motion to temporarily seal. 1 EFTA01091399 Case 9:08-cv-80736-KAM Document 357 Entered on FLSD Docket 01/29/2016 Page 2 of 4 WHEREFORE, the victims request that their Reply in Support of 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: January 29, 2016 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 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` 332 S. 1400 E. Salt Lake City, UT 84112 Attorneysfor Jane Does No. 1, Z 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 EFTA01091400 Case 9:08-cv-80736-KAM Document 357 Entered on FLSD Docket 01/29/2016 Page 3 of 4 CERTIFICATE OF SERVICE I certify that the foregoing document was served on January 29, 2016, on the following using the Court's CM/ECF system or, for non-parties, by separate email service: Dexter Lee A. Marie Villafafia Attorneys for the Government Roy Eric Black Jacqueline Perczek Black Srebnick Kornspan & Stumpf 201 S Biscayne Boulevard Suite 1300 Miami, FL 33131 Attorneys for Jeffrey Epstein Kendall Coffey, Fla. Bar No. 259681 Gabriel Groisman, Fla. Bar No. 25644 Ben.amin H. Brodsky. Fla. Bar No. 73748 COFFEY BURLINGTON, 2601 South Bayshore Drive, PHI Miami, Fl • Telephon Facsimile: Thomas E. co , r. Cole Scott & Kissane 3 EFTA01091401 Case 9:08-cv-80736-KAM Document 357 Entered on FLSD Docket 01/29/2016 Page 4 of 4 Dadeland Centre II Suite 1400 9150 S Dadeland Boulevard Miami, FL 33156 Email: Attorneys for Alan Dershowitz Is/ Bradley J. Edwards 4 EFTA01091402