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FLSD Docket 08/16/2013 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS THAT ARE NOT PRIVILEGED EFTA00208672 Case 9:08-cv-8
grand jury materials here, and the Government has no independent "privilege" to interpose against court-ordered disclosure of grand jury materials. The Court Has Inherent Power to Release Grand Jury Materials — The Court has "inherent power beyond the literal wording of Rule 6(e)(3) to disclose grand jury material" and has
A-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-008809 Thru P-008847 File folder entitled "[Victim namej/Jane Doe #6" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product
Production Privilege Does No Apply When the Attorney's Conduct is at Issue Rule 6(e) Court-Authorized Disclosure Not Covered Under Rule 6(e)(3)(E) The Court Has Inherent Power to Release Grand Jury Materials Victims Have Properly Petitioned for the Release of Grand Jury The CVRA Gives the Court Authority to Release Grand
FLSD Docket 08/16/2013 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 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S NOTICE OF FILING OF OBJECTIONS TO PRIVLEGE LOG COME NOW Jane Doe #1 and Jane Doe #2 (also refe
Production Privilege Does No Apply When the Attorney's Conduct is at Issue Rule 6(e) Court-Authorized Disclosure Not Covered Under Rule 6(eX3)(E) The Court Has Inherent Power to Release Grand Jury Materials Victims Have Properly Petitioned for the Release of Grand Jury The CVRA Gives the Court Authority to Release Grand
Entities connected to both Jane Doe and The Court Has Inherent Power

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONMaria Farmer
PERSONLeon Black
PERSON
Alexander Acosta
PERSON
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSONRoy Black
PERSON
Jay Lefkowitz
PERSON
Sarah Kellen
PERSONMartin Weinberg
PERSON
the University of Utah
ORGANIZATION
Dexter Lee
PERSON
S.J. Quinney College of Law
ORGANIZATION