EFTA01081934.pdf

Case 9:08-cv-80736-KAM Document 205-3 Entered on FLSD Docket 07/05/2013 Page 1 of 4 Appendix C EFTA01081934 Case 9:08-cv-80736-KAM Document 205-3 Entered on FLSD Docket 07/05/2013 Page 2 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. MOTION TO SEAL The United States of America, by and through the undersigned Assistant United States Attorney, hereby moves to seal its Motion to Stay Discovery Pending Ruling upon Respondent's Motion to Dismiss for the following reasons: 1. The Motion contains information regarding proceedings before West Palm Beach Federal Grand Jury 05-02 and West Palm Beach Federal Grand Jury 07-103, which is subject to the secrecy protections of Fed. R. Crim. P. 6. 2. Pursuant to Rule 6(e)(6), "Necords, orders, and subpoenas relating to grand-jury proceedings must be kept under seal to the extent and as long as necessary to prevent the unauthorized disclosure of a matter occurring before a grand jury." 3. On November 7, 2011, the United States moved for permission to disclose limited information from those grand jury proceedings relevant to this litigation. The Court issued an Order allowing such limited disclosure, but required that all pleadings containing such information be filed under seal. EFTA01081935 Case 9:08-cv-80736-KAM Document 205-3 Entered on FLSD Docket 07/05/2013 Page 3 of 4 WHEREFORE, the United States respectfully requests that the Motion to Stay Discovery Pending Ruling upon Respondent's Motion to Dismiss be sealed. DATED: November 7, 2011 Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. A. MARIE VILLAFARA Attorney for Respondent CERTIFICATE OF SERVICE The undersigned hereby certifies and affirms that a copy of the foregoing was served via United States Mail this 7th day of November, 2011, upon Counsel for Petitioners Jane Doe #1 and Jane Doe #2. DEXTER A. LEE ASSISTANT U.S. ATTORNEY EFTA01081936 Case 9:08-cv-80736-KAM Document 205-3 Entered on FLSD Docket 07/05/2013 Page 4 of 4 SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., Paul G. Cassell The Law Offices of Brad Edwards & S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe # I and Jane Doe # 2 EFTA01081937