Case 9:08-cv-80736-KAM Document 169 Entered on FLSD Docket 04/23/2012 Page 1 of 20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. REPLY IN SUPPORT OF SUPPLEMENTAL BRIEFING BY LIMITED INTERVENORS BLACK, WEINBERG, LEFKOWITZ, AND EPSTEIN The limited intervenors Black, Weinberg, Lefkowtiz, and Epstein re-file this reply, which is identical to the reply that was previously filed during the litigation on intervention. We only add that, in Lafler v. 132 S. Ct. 1376 (2012) and Missouri v. Frye, 132 S. Ct. 1399 (2012), the United States Supreme Court flatly rejected the arguments by Jane Doe 1 and Jane Doe 2 that there are no "constitutional considerations that undergird plea bargaining" and that plea negotiations are "merely" a process that -serve[s] the administrative convenience of the parties." [DE 167 at 3]. As we set out in our Notice of Supplemental Authority filed last week [DE 163], the Supreme Court in Lafler and Frye constitutionalized the right to effective assistance of competent counsel in plea negotiations and specifically recognized that "plea bargains are . .. central to the administration of the criminal justice system" because ours is "a system of pleas, not a system of trials." Loiter, 132 S. Ct. at 1388; Frye, 132 S. Ct. at 1407. The rest of our reply, as previously filed, provided as follows: EFTA02753858