Case 9:08-cv-80736-KAM Document 244 Entered on FLSD Docket 10/28/2013 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 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S REPLY IN SUPPORT OF RENEWED MOTION FOR AN ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to file this reply in support of their Motion for an Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50, renewed in DE 226), in light of the Government's response (DE 230). The Government's response confirms each of the victims' arguments in support of their motion, specifically (1) that the Government's privilege log is grossly inadequate; (2) the CVRA's requirement that the Government exercise its "best efforts" to protect crime victims' rights requires the production of the withheld documents; and (3) the CVRA creates a right to access to documents that support their position, just as criminal defendants have a right to access such documents. For each of these reasons, the Court should grant the victims' motion and provide the materials that it has received in camera to the victims. I. THE GOVERNMENT'S PRIVILEGE LOG IS GROSSLY INADEQUATE. In their motion, the victims explained that the Government has substantially violated the Court's order to provide an appropriate privilege log in connection with the disputed documents. 1 EFTA01081219