EFTA00208818.pdf

Appendix E EFTA00208818  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 Reply in Support of Its Motion to Dismiss for Lack of Subject Matter Jurisdiction for the following reasons: I. 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. EFTA00208819  WHEREFORE, the United States respectfully requests that its Reply in Support of Its Motion to Dismiss for Lack of Subject Matter Jurisdiction be sealed. DATED: January 26, 2012 Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Fax: E-mail: 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 26th day of January, 2012, upon Counsel for Petitioners Jane Doe #1 and Jane Doe #2. ASSISTANT U.S. ATTORNEY EFTA00208820  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 Bradley Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale FL 33301-3268 Fax: [Service via U.S. Mail] Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. S_alt Lake_CitY Utah 84112 Fax: E-mail: [Service via U.S. Mail] Attorneys for Jane Doe # 1 and Jane Doe # 2 EFTA00208821