EFTA00208814.pdf

Appendix C EFTA00208814  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. EFTA00208815  the Motion to Stay Discovery WHEREFORE, the United States respectfully requests that be sealed. Pending Ruling upon Respondent's Motion to Dismiss DATED: November 7, 2011 Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: reet • * • idF 33132 Fax: E-mail: Attorney for Respondent CERTIFICATE OF SERVICE the foregoing was served via The undersigned hereby certifies and affirms that a copy of sel for Petitioners Jane Doe #1 and United States Mail this 7th day of November, 2011, upon Coun Jane Doe #2. ASSISTANT U.S. ATTORNEY EFTA00208816  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 Quinney College of Law at the Associates, LLC University of Utah 2028 Harrison Street, Suite 202 332 S. 1400 E. Ho11 wood, Florida 33020 Salt Lake Cit , Utah 84112 ttorneys or ane oe an Jane Doe #2 EFTA00208817