Case 9:08-cv-80736-KAM Document 271 Entered on FLSD Docket 10/24/2014 Page 1 of 11 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 EPSTEIN'S MOTION TO PROTECT FROM DISCLOSURE GRAND JURY MATERIALS COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to respond to Epstein's motion to protect from disclosure certain grand jury materials (DE 263). Epstein's objections are meritless for three reasons. First, Epstein misstates the legal standard regarding release of grand jury materials. The Court clearly has discretion to release the materials and should do so if an appropriate reason is shown for release. Any alleged "reputational harm" to Epstein can be resolved by simply keeping the materials under seal. Second, Epstein misunderstands the compelling need that the victims have for those materials. The materials all relate directly to important and disputed issues in this case. Third, at a minimum, Epstein's motion should not be granted at this time, because the Government has failed to provide a specific privilege log about the grand jury materials at issue. Until the Government has properly itemizes the materials at issue, it is impossible for the victims to properly respond to Epstein's (and the Government's) objections to release of the materials. 1 EFTA01139610