Case 9:08-cv-80736-KAM Document 160 Entered on FLSD Docket 04/17/2012 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. INTERVENORS' MOTION FOR A PROTECTIVE ORDER AND OPPOSITION TO MOTIONS OF JANE DOE 1 AND JANE DOE 2 FOR PRODUCTION, USE, AND DISCLOSURE OF SETTLEMENT NEGOTIATIONS Jane Doe 1 and Jane Doe 2 complain that the government treated them unfairly by not keeping them involved in the government's settlement negotiations with Jeffrey Epstein. They seek to invalidate the Non-Prosecution Agreement between Mr. Epstein and the government, claiming that the agreement violates the Crime Victims's Rights Act. Jane Doe I and Jane Doe 2 seek disclosure of all the letters between the lawyers defending Mr. Epstein and federal prosecutors during the criminal investigation. They claim that the letters are relevant and admissible to show that the government did not live up to its obligations under the Crime Victims' Rights Act. Jane Doe I and Jane Doe 2 have copies of the letters and emails the government wrote to the defense team, and now seek copies of the letters the defense wrote to the prosecutors. [DE 50 at 5]. The letters and emails prepared by the government are subject to a protective order prohibiting their disclosure. In the related case 9:08-CV-80893 (the case where Jane Doe 1 and Jane Doe 2 sued Mr. Epstein for money), the Magistrate Judge prohibited Jane Doe I and Jane Doe 2 EFTA00205542