ease 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 1 of 20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-cv-80736-Civ-KAM 0_cn4 CAW rn CD en b ,r x <, 1 JANE DOE I and JANE DOE 2 c:, v. z -ri c.o:-r - r Dal.N'' -n_4---r• X rsol=, UNITED STATES / ri rn 73 JANE DOE I AND JANE DOE 2'S RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER fh COME NOW Jane Doe 1 and Jane Doe 2 (also referred to as "the victims"), by and through undersigned counsel, to file this response in opposition to Epstein's Motion for a Protective Confidentiality Order (DE 247). Epstein's motion is a thinly-disguised attempt to relitigate issues already covered by the court's earlier ruling eleven months ago (DE 188), which allowed the victims to file correspondence relating to Epstein's non-prosecution agreement in the public court file. Rather than reverse its previous ruling, this Court should reaffirm it — and allow the important issues presented by this case to be litigated in the light of day. BACKGROUND Because of Epstein's penchant for relitigating issues that have already been decided, it is necessary to recount the litigation that has already gone on in this case regarding confidentiality, including the Court's directive in DE 188 allowing filing of materials in the public court file. On March 21, 2011, the victims tiled what was essentially a Motion For Summary Judgment in this case, explaining why (in their view) the Government had violated its obligations under the Crime Victims' Rights Act (CVRA) to notify them of court hearings, to EFTA02754789