Case 9:08-cv-80736-KAM Document 305 Entered on FLSD Docket 02/02/2015 Page 1 of 12 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. NON-PARTIES THE PALM BEACH POST AND PALM BEACH DAILY NEWS' MOTION TO INTERVENE TO OPPOSE INTERVENOR EPSTEIN'S MOTION FOR ENTRY OF A SUPPLEMENTAL PROTECTIVE ORDER (DOC. 261) The Palm Beach Post and Palm Beach Daily News ("Media Intervenors")' respectfully move this Court to intervene for the limited purpose of responding to Intervenor Jeffrey Epstein's Motion for a Supplemental Protective Order (Doc. 261). In connection therewith, Media Intervenors respectfully submit this incorporated Memorandum of Law in support of their Motion to Intervene, in opposition to Epstein's Motion for a Supplemental Protective Order (Doc. 261), and in response to the Court's Order inquiring whether there is justification for the request in Epstein's motion that an entire category of documents be filed under seal. (Doc. 286.) INTRODUCTION This matter involves claims by two Jane Doe Plaintiffs against the United States, alleging that the Government violated the Crime Victims' Rights Act in connection with entering into a non-prosecution agreement with Intervenor Jeffrey Epstein in exchange for his offer to plead guilty to certain Florida state offenses. As the Media Intervenors ' The Palm Beach Post and Palm Beach Daily News are both owned by Cox Media Group, LLC, which is itself owned by Cox Enterprises, Inc., a privately held corporation. EFTA01132524