- Case 9:08-cv-80736-KAM Document 267 Entered on FLSD Docket 10/22/2014 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, V. UNITED STATES, Respondent. enr. • SEALED DOCUMENT MOTION TO SEAL !"..) rn F L7 a c C7 ‘.9 Petitioners Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), through counsel, hereby move to seal their SUPPLEMENT SUPPORTING RESPONSE TO GOVERNMENT'S MOTION FOR LEAVE TO FILE RELEVANCE OBJECTIONS TO PETITIONER'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS for the following reasons: 1. This Honorable Court's Order [DE 255] granted in part Epstein's Motion for protective Order related to the correspondence. 2. Petitioners seek leave to file this JANE DOE #1 AND JANE DOE #2'S SEALED SUPPLEMENT SUPPORTING RESPONSE TO GOVERNMENT'S MOTION FOR LEAVE TO FILE RELEVANCE OBJECTIONS TO PETITIONER'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS under seal, in an abundance of caution, because it discusses material that Epstein has Moved to prevent the disclosure of, and the Court has ordered the victims not to file other similar material in its previous Order [DE 255]. EFTA01199891 • Case 9:08-cv-80736-KAM Document 267 Entered on FLSD Docket 10/22/2014 Page 2 of 3 WHEREFORE, Petitioners respectfully request that be sealed until further order of the Court. Alternatively, if the Court denies the instant motion to seal, then Petitioners respectfully request that their JANE DOE #1 AND JANE DOE #2'S SEALED SUPPLEMENT SUPPORTING RESPONSE TO GOVERNMENT'S MOTION FOR LEAVE TO FILE RELEVANCE OBJECTIONS TO PETITIONER'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS be filed in the public file and docketed as of today's date, as timely filed. DATED: October 21, 2014 Respectfully Submitted, Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale. Florida 33301 Telephone Facsimil Florida Bar No.: 542075 E-mail: and Paul G. Cassell Pro Mac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit , UT 84112 Telephone: Facsimile E-Mail Attorneys for Jane Doe #1 and Jane Doe #2 EFTA01199892 • Case 9:08-cv-80736-KAM Document 267 Entered on FLSD Docket 10/22/2014 Page 3 of 3 CERTIFICATE OF SERVICE I certify that the foregoing document was served on October 20, 2014, on the following using the Court's CM/ECF system: Dexter Lee A. Marie Vitiate& 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 Fax: E-mail: E-mail: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard, Suite 1300 Miami, FL 33131 Email: Jay P. Lefkowitz Kirkland & Ellis, LLP 601 Lexington Avenue New York, NY 10022 Email Martin G. Weinberg, P.C. 20 Park Plaza, Suite 1000 Boston, MA 02116 Email Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards EFTA01199893