Case 9:08-cv-80736-KAM Document 74 Entered on FLSD Docket 05/02/2011 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S REPLY TO GOVERNMENT'S RESPONSE TO THEIR MOTION TO USE CORRESPONDENCE TO PROVE VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT AND TO HAVE THEIR UNREDACTED PLEADINGS UNSEALED COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, reply to the Government's response (DE #60) to their motion to use correspondence to prove violations of the Crime Victims' Right Act and to Have Their Unredacted Pleadings Unsealed (DE #51). The Government does not contest the first part of the victims' motion — that they should be allowed to use the correspondence to prove CVRA violations — and that part of the victims' motion should therefore be granted. The Government does argue that some parts of the correspondence cannot be disclosed because of grand jury secrecy or constitutional requirements. The Court should reject these frivolous arguments. None of the materials disclose matters occurring before a grand jury; nor do any of them constitute a "public smear" of an "innocent" person that would violate the Constitution. Accordingly, the Court should grant the victims' motion.' There are occasional references in the correspondence to internal phone numbers of the prosecutors and similar information. The victims have no objection to such information I EFTA00207967