Case 9:08-cv-80736-KAM Document 83 Entered on FLSD Docket 05/23/2011 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-Civ-Mara JANE DOE #1 AND JANE DOE #2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. REPLY TO JANE DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION TO INTERVENE OR IN THE ALTERNATIVE FOR A SUA SPONTE RULE II ORDER Comes now, Movant Bruce E. Reinhart, and replies to Plaintiffs' Response to his Motion To Intervene Or In The Alternative For A Sua Spank. Rule II Order. Plaintiffs wrongly assert that there is no common question of law or fact sufficient to support permissive intervention. Plaintiffs do not address, nor oppose, Movant's request that the Court on its own initiative require Plaintiffs and their counsel to show their compliance with Federal Rule of Civil Procedure 11. The Court should hold a sanctions hearing, either through Movant's intervention or sum sporue. Plaintiffs also prematurely ask that, if the Court permits intervention, they should be allowed to take Movant's deposition. Issues of discovery are not ripe at this time. On March 21, 2011, Plaintiffs filed a Motion for Finding of Violations of the Crime Victims' Rights Act (the "CVRA Motion") [DE 48]. Paragraphs 52 and 53 of the CVRA Motion falsely alleged that Movant, a non-party to this matter, violated Florida Bar rules and Department of Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation EFTA02753378