Case 9:08-cv-80736-KAM Document 219-1 Entered on FLSD Docket 08/02/2013 Page 1 of 6 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 RELEVANCE OBJECTIONS TO PETITIONERS' FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT Respondent United States of America, by and through its undersigned counsel, files its Relevance Objections to Petitioners' First Request for Production, and state: I. INTRODUCTION On September 26, 2011, this Court found that the Crime Victims Rights Act (CVRA), 18 U.S.C. § 3771 et. seq., can apply before formal charges are filed. D.E. 99 at 5-10. The Court found that "some factual development is necessary to resolve the remaining issues in this case," and it would "permit Plaintiffs the opportunity to conduct limited discovery in the form of document requests and requests for admissions from the U.S. Attorney's Office." D.E. 99 at 11. The Court also stated that, "[b]ecause the Court will allow this limited factual development, it is unnecessary to decide here whether the CVRA or the Federal Rules of Civil Procedure provide discovery rights in this context." Id. Petitioners' first request for production goes well beyond the "limited factual development" permitted by the Court it its September 26, 2011 Order. Respondent has submitted a Privilege Log which describes each document withheld, and the privilege invoked Respondent's Exhibit A Case No. 08-80736-CIV-MARRA EFTA00594003