Case 9:08-cv-80736-KAM Document 150 Entered on FLSD Docket 02/07/2012 Page 1 of 6 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 MOTION REQUESTING AN ORDER DIRECTING THE GOVERNMENT TO FILE REDACTED PLEADINGS IN THE PUBLIC COURT FILE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to file this motion for an order directing the Government to file in the public court file redacted versions of its (I) Sealed Memorandum in Support of Motion to Dismiss for Lack of Subject Matter Jurisdiction, (2) Sealed Motion to Stay Discovery, and (3) Sealed Reply in Support of Motion to Dismiss for Lack of Subject Matter Jurisdiction. There is not even an arguable basis for keeping the vast majority of these pleadings under seal. Sealing all of these pleadings interferes with counsel's ability to prepare a response, in addition to denying the public the right to know how the Government is interpreting the CVRA in this case. The Government cannot carry its burden of showing a need to seal all of these pleadings. Accordingly, the Government should file a redacted pleading in the public court file that redacts only information for which there is a basis for confidentiality — i.e., information that specifically discloses grand jury material. FACTUAL BACKGROUND 1 EFTA02753747