UNITED STATES DISTRICT COURT

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 OF AMERICA, Respondent. RESPONDENT'S MOTION FOR LEAVE OF COURT TO FILE RELEVANCE OBJECTIONS TO PETITIONERS' FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT Respondent, by and through its undersigned counsel, files its Motion for Leave of Court to File Relevance Objections to Petitioners' First Request for Production to The Government, and state: I. On June 18, 2013, this Court entered its Omnibus Order, where it directed the respondent, within thirty (30) days of the entry date to (a) file answers to all outstanding requests for admissions in the open court file; (b) produce responsive documents in response to all outstanding requests for production of documents encompassing any documentary material exchanged by or between the federal government and persons or entities outside the federal government (including without limitation all correspondence generated by or between the federal government and Epstein's attorneys); and (c) produce all other responsive documents in response to all outstanding requests for production of documents. D.E. 190 at 2. 2. With regard to any claims of privilege asserted in connection with the production of materials other than communications generated between the federal government and outside persons and entities, the Court directed the government to file and serve, in the public portion of EFTA00209334 the court file, a privilege log; and submit all responsive documents withheld on claim of privilege to the court for in camera inspection by submitting the same for filing with the court under seal. D.E. 190 at 2, ¶ 3(c)(i) and (ii). 3. The Court's Omnibus Order did not provide for the filing of any relevance objections by respondent. Since lack of relevance is not an evidentiary privilege, respondent has not included any relevance objections in its Privilege Logs. Respondent respectfully requests leave of the Court to allow it to file a five-page document entitled Respondent's Relevance Objections to Petitioners' First Request for Production to The Government, attached as Exhibit A to this motion. CERTIFICATE OF CONFERENCE On July 30, 2013, respondent's counsel sought petitioners' position on the instant motion. Petitioners stated that they oppose the motion. DATED: July 19, 2013 Respectfully submitted, WILFREDO A. FERRER UNITED STATES ATTORNEY By: ATTORNEY FOR RESPONDENT CERTIFICATE OF SERVICE 2 EFTA00209335 I HEREBY CERTIFY that on August 2, 2013, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. ___5/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney SERVICE LIST Jane Does 1 and 2 I. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ISM Paul G. Cassell Attorneys for Jane Doe # 1 and Jane Doe # 2 3 EFTA00209336