Case 9:08-cv-80736-KAM Document 78 Entered on FLSD Docket 05/02/2011 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marraa JANE DOE #1 and JANE DOE #2 v. UNITED STATES / JANE DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION TO INTERVENE OF ROY BLACK, WEINBERG, AND JAY LEFKOWITZ COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to oppose the motion of attorneys Roy Black, Weinberg, and Jay Lefkowitz (hereinafter referred to as "defense attorneys") to intervene in this case under Fed. R. Civ. P. 24(a) (DE #56). The motion to intervene should be denied for three separate reasons. First, the defense attorneys have not shown that they have an "interest" in the "transaction" at issue in this case, as required by Rule 24(a). This case involves crime victims' efforts to enforce their rights under the Crime Victims Rights Act — an issue of no concern to the defense attorneys. Second, the defense attorneys have no "confidential" material is at issue in this case. All of the correspondence involved has already been disclosed to the government — and to the victims. Third, the work product issues the defense attorneys seek to present to this Court were decided long ago. Their effort to relitigate these issues is simply untimely. The defense attorneys' motion to intervene should accordingly be denied. I EFTA02753313