Case 9:08-cv-80736-KAM Document 266 Entered on FLSD Docket 10/20/2014 Page 1 of 17 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 Relevance Objections to Victims' First Request for Production to the Government (DE 260). The Government's objection is meritless for four reasons. First, the Government cannot object to discovery on "relevance" grounds, but only on the far narrower ground that the victims' requests that are not reasonably calculated to lead to the discovery of admissible evidence. All of the victims' requests are likely to lead to such evidence. Second, the Government has not identified, on a document-by-document basis, which ones it believes are actually "irrelevant." And the Government has filed an inadequate privilege log, which makes it impossible for the Court (and the victims) to identify which documents the Government thinks should not be released. Third, to the extent that the victims can determine which documents the Government deems "irrelevant," the Government's arguments are meritless. The requested documents go to the central issues in this case, such as whether the 1 EFTA01202952