Case 9:08-cv-80736-KAM Document 227 Entered on FLSD Docket 08/16/2013 Page 1 of 4 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 PROTECTIVE PETITION FOR DISCLOSURE OF GRAND JURY MATERIALS RELEVANT TO THEIR PETITION FOR ENFORCEMENT OF THEIR CVRA RIGHTS COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to file this protective petition for release of relevant grand jury materials, pursuant to Fed. R. Crim. P. 6(e)(3)(F). The protective filing is made to obviate any claim that they have not properly petitioned for release of grand jury information under the rule. As the Court is well aware, a discovery dispute is on-going about whether certain grand jury materials can be released to the victims in this case. In its privilege log, the Government has argued at a number of points that "Rule 6(e)" of the Federal Rules of Criminal Procedure forbids release of materials to the victims in discovery. See DE 212-1. The victims have raised other responses to that argument. See Jane Doe #1 and Jane Doe #2's Motion to Compel Production of Documents That Are Not Privileged (filed contemporaneously with this petition). But in addition, the victims wish to have in the record a formal petition for release of information, as specifically provided in Rule 6(e)(3)(F) (providing authority for a petition for release of grand jury information). 1 EFTA01081204