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. RESPONDENT'S MOTION TO STAY DISCOVERY PENDING RULING UPON RESPONDENT'S MOTION TO DISMISS Respondents, by and through their undersigned counsel, file their Motion to Stay Discovery Pending Ruling upon Respondent's Motion to Dismiss, and state: I. FACTUAL BACKGROUND On October 3, 2011, petitioners served on respondent their First Request for Production to the Government Regarding Information Relevant to Their Pending Action Concern (sic) The Crime Victims Rights Act. The request for production contains twenty-five lengthy requests for documents, each containing petitioners' editorial narrative as a preface to stating what documents are being sought. This Court has ruled that the rights in 18 U.S.C. § 3771(a) apply prior to the filing of a formal charge. DE 99. The issues that remain to be resolved by this Court are: (1) whether the government used its best efforts to comply with the Crime Victims Rights Act (CVRA); and (2) if the Court finds the government did not use its best efforts, the remedy for a violation of the CVRA. Many of petitioners' requests for documents go well beyond the issues pending in this litigation. Petitioners seek many documents pertaining to the criminal investigation of Jeffrey Epstein, including the prosecution memo prepared in the case. Request for Production No. 1. Petitioners rely upon a comment made by the Court, in its September 26, 2011 Order, where this Court referenced petitioners' assertion that the FBI and U.S. Attorney's Office had developed a strong case for prosecuting Epstein, based on "overwhelming" evidence. Request for Production at 2. The Court, according to petitioners, stated that this was an allegation that needed "further factual development." Id. at 2, citing DE 99 at 2 n.2. Presumably, the obligation to confer with the attorney for