Case 9:08-cv-80736-KAM Document 80 Entered on FLSD Docket 05/12/2011 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA JANE DOE I and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. REPLY IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK, WEINBERG, AND JAY LEFKOWITZ Jane Doe I and Jane Doe 2 oppose intervention because according to them, proposed intervenors Black, Weinberg and Lefkowitz do not have a claim of privilege or confidentiality. Jane Doe I and Jane Doe 2 contend that all the correspondence at issue was already turned over to them. They are mistaken. Undersigned counsel spoke with Paul Cassell, one of the lawyers representing Jane Doe 1 and Jane Doe 2, and he confirmed that he and his clients do not have any of the negotiation and settlement letters prepared by the defense attorneys. Additionally, while the settlement and negotiation letters prepared by the government have been turned over to Mr. Cassell and his clients pursuant to the Magistrate Judge's Order in the related case, that Order specifically maintains the confidentiality of those letters and prohibits Jane Doe 1 and Jane Doe 2 from filing them in the public record of any proceeding, disclosing them to the media, or otherwise disclosing them to the public. Finally, the Magistrate Judge's Order specifically does not rule on whether these settlement negotiations are admissible as evidence in any case, holding instead that the ultimate question of their admissibility must be put before the judge in each proceeding. [Doe v. Epstein, Case No. 9:08- EFTA02753356