EFTA01149660.pdf

Case 9:08-cv-80736-KAM Document 292 Entered on FLSD Docket 01/22/2015 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. r- UNITED STATES, r ,1 Respondent. SEALED DOCUMENT MOTION TO SEAL Petitioners Jane Doe No. 1 and Jane Doe No. 2, joined by movants Jane Doe No. 3 and Jane Doe No. 4, move to file the attached pleading and supporting exhibit 30 under seal. A public pleading has been filed that has one sentenced redacted. That sentence comes from exhibit 30, which is correspondence sent by Alan Dershowitz and Gerald Lefcourt, attorneys for Jeffrey Epstein. As the Court is aware, the parties are currently briefing issues surrounding whether such correspondence should be kept under seal or filed in the public court file. See DE 286 (requesting justification for a motion for a supplemental protective order). To give the Court the opportunity to rule on that issue before this correspondence is released, the victims are filing this under seal. It is the victims' view that these materials should be included in the public court file, for reasons articulated in the Opposition to Epstein's Motion for a Protective Confidentiality Order (DE 251). The victims intend to elaborate on their position in a filing they will make shortly. 1 EFTA01149660 Case 9:08-cv-80736-KAM Document 292 Entered on FLSD Docket 01/22/2015 Page 2 of 3 WHEREFORE, Petitioners respectfully request that attached pleading and supporting exhibit 30 be sealed until further order of the Court. Alternatively, if the Court denies the instant motion to seal, then Petitioners respectfully request that their attached pleading and supporting exhibit 30 be filed in the public file and docketed as of today's date, as timely filed. DATED: January 21, 2015. Respectfully Submitted, 'Wradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, M. Fort Lauderdale, Florida 33301 And Paul G. Cassell Pro Hac Vice Quinney College of Law at the University of Utah. Salt Lake City, UT 84112 Attorneysfor Jane Doe #1 and Jane Doe #2 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 EFTA01149661 Case 9:08-cv-80736-KAM Document 292 Entered on FLSD Docket 01/22/2015 Page 3 of 3 CERTIFICATE OF SERVICE I certify that the foregoing document was served on January 21, 2015, on the following via US Mail: Dexter Lee A. Marie Villafaiia West Palm Beach, FL 33401 Attorneysfor the Government Thomas Scott COLE, SCOTT & KISSANE, MEMIMMI Miami, Florida 33156 -and- Kendall Coffey Gabriel Groisman Benjamin H. Brodsky Attorneysfor Alan Dershowitz /s/ Bradley J. Edwards 3 EFTA01149662