UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, : Defendant. INTERVENOR'S MOTION FOR THE COURT TO PROTECT FROM DISCLOSURE GRAND JURY MATERIALS IDENTIFIED IN GOVERNMENT'S PRIVILEGE LOGS AT DE 212-1 AND DE 216-1 Intervenor Jeffrey Epstein moves that this Honorable Court, pursuant to Federal Rule of Criminal Procedure 6(e), prevent the disclosure of matters that occurred before the two grand juries that investigated Mr. Epstein in 2005-2007. Mr. Epstein joins the Government in its assertion of Rule 6(e) objections to the various requests by plaintiffs for broad discovery, discovery that is either irrelevant or at bemmost -marginally relevant to the issues regarding the application and possible violation of the Crime Victims' Rights Act, and, if allowed, would be adverse to be deeply injurious to the privacy and reputational interests of the intervenor. Although Mr. Epstein was convicted of state offenses and was -sentenced to jail_r and—has otherwise suffered reputational injury from his past offenses, he nevertheless has a right to the safeguards and requirements of Rule 6(e) including its imperative that absent particularized need, the secrecy of grand jury proceedings remains intact both to protect the confidentiality of past proceedings including the identity of witnesses, subjects, and targets and the nature of considered charges, but also to protect the rights of all citizen who vms-set-are not charged to -from the disclosure of 6(e) information, documents, and testimony. ilet-have-his-Feputiitfien-newly-injtir-ed —here-ever--7-years-after-the-r-eselatien-ef--the-fedefal-investigatien. EFTA01199841