Case 9:08-cv-80736-KAM Document 193 Entered on FLSD Docket 06/26/2013 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Petitioners v. UNITED STATES OF AMERICA, Respondent INTERVENORS' MOTION FOR STAY PENDING APPEAL Intervenors Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein request that the Court stay pending appeal its order of June 18, 2013 (Doc. 188), denying their Motion for a Protective Order and ordering disclosure of the intervenor attorneys' written communications with federal prosecutors in the Southern District of Florida made with the specific purpose of obtaining a favorable resolution of the criminal investigation of Mr. Epstein through attorney-to- attorney settlement negotiations. Intervenors also seek to stay those portions of the Court's orders at DE 189 and DE 190 that would require disclosure of these materials. Undersigned spoke with counsel for the government, who stated that the government does not object to a stay pending appeal. Undersigned also spoke with Paul Cassell, counsel for the petitioners, who stated that he objects to a stay pending appeal. In determining whether to grant a stay pending appeal, the Court considers four factors: "(1) the likelihood that the moving party will ultimately prevail on the merits of the appeal; (2) EFTA01098125