Case 9:08-cv-80736-KAM Document 140 Entered on FLSD Docket 01/24/2012 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. RESPONDENT'S REPLY TO PETITIONERS' RESPONSE TO RESPONDENT'S SEALED MOTION TO STAY DISCOVERY PENDING RULING UPON RESPONDENT'S MOTION TO DISMISS [DE 129] AND RESPONDENT'S RESPONSE IN OPPOSITION TO PETITIONERS' PROTECTIVE MOTION TO COMPEL [DE 130] Respondent, by and through its undersigned counsel, hereby files this Reply to Petitioner Jane Doe #1 and Jane Doe #2's Response to the Respondent's Sealed Motion to Stay Discovery Pending Ruling upon Respondent's Motion to Dismiss [DE129] and Response in Opposition to Petitioners' Protective Motion to Compel [DE 130]. For the following reasons and the reasons set forth in Respondent's Motion to Stay Discovery, the Court should grant the United States' Motion to Stay Discovery pending the Court's decision on the United States' Motion to Dismiss for Lack of Subject Matter Jurisdiction and, similarly, deny the Petitioners' Protective Motion to Compel. In both their Response to the Motion to Stay Discovery and their Motion to Compel, Petitioners fail to cite any statute or case law that supports their position that the Court should order the United States to produce discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has clearly and repeatedly stated that dispositive motions should be decided before discovery begins: EFTA02753725