Case 9:08-cv-80736-KAM Document 222 Entered on FLSD Docket 08/09/2013 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRAJ JANE DOE I AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant REPLY TO JANE DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION In their Response, plaintiffs first contend that Mr. Epstein's limited motion to intervene is not timely because they first filed their discovery requests more than a year and a half ago. Response at 3-4. That date is wholly irrelevant for purposes of evaluating the timeliness of Mr. Epstein's motion, as there has been no prior litigation whatsoever on the specific question, raised by the request for limited intervention, of whether particularly identified documents are protected from disclosure to plaintiffs by the grand jury secrecy provision of Fed. R. Crim. P. 6(e). The applicability of the Rule 6(e) disclosure prohibition has not "been the subject of litigation for nearly two years." Response at 2. It has not been the subject of litigation ar alt Plaintiffs state that they did not object to Mr. Epstein's prospective motion to intervene at the remedy stage because "the issue had not yet been subject to any litigation." Response at 2. The same is true, however, with respect to this limited motion to intervene. EFTA02754429