Case 9:08-cv-80736-KAM Document 220 Entered on FLSD Docket 08/05/2013 Page 1 of 8 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 RESPONSE TO GOVERNMENT'S MOTION FOR LEAVE TO FILE RELEVANCE OBJECTIONS TO PETITIONER'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to respond to the Government's Motion for Leave to File Relevance Objections to Petitioners' First Request for Production to the Government (DE 219). The victims object to the Government's proposed filing for three reasons: First, the Government's objection is untimely, as the Government has already produced all of the documents in question to the Court; "irrelevance" is not a valid reason for the Court not to turn the documents over to the victims. Second, the Government cannot object to discovery on "relevance" grounds but only more narrowly to requests that are not reasonably calculated to lead to the discovery of admissible evidence. Third, the Government has not identified, on a document-by-document basis, which documents it believes are "irrelevant". And the Government has filed an inadequate privilege log, which makes it effectively impossible to identify what documents the Government is objecting to producing. Accordingly, the Court should simply deny the motion. EFTA01098184