Case 9:08-cv-80736-KAM Document 219 Entered on FLSD Docket 08/02/2013 Page 1 of 3 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 OF AMERICA, Respondent. RESPONDENT'S MOTION FOR LEAVE OF COURT TO FILE RELEVANCE OBJECTIONS TO PETITIONERS' FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT Respondent, by and through its undersigned counsel, files its Motion for Leave of Court to File Relevance Objections to Petitioners' First Request for Production to The Government, and state: I. On June 18, 2013, this Court entered its Omnibus Order, where it directed the respondent, within thirty (30) days of the entry date to (a) file answers to all outstanding requests for admissions in the open court file; (b) produce responsive documents in response to all outstanding requests for production of documents encompassing any documentary material exchanged by or between the federal government and persons or entities outside the federal government (including without limitation all correspondence generated by or between the federal government and Epstein's attorneys); and (c) produce all other responsive documents in response to all outstanding requests for production of documents. D.E. 190 at 2. 2. With regard to any claims of privilege asserted in connection with the production of materials other than communications generated between the federal government and outside persons and entities. the Court directed the government to file and serve, in the public portion of EFTA02754412