Case 9:08-cv-80736-KAM Document 263 Entered on FLSD Docket 10/09/2014 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE I and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, : Defendant. INTERVENOR'S MOTION FOR THE COURT TO PROTECT FROM DISCLOSURE GRAND JURY MATERIALS IDENTIFIED IN GOVERNMENT'S PRIVILEGE LOGS AT D.E. 212-1 AND D.E. 216-1 Intervenor Jeffrey Epstein moves that this Honorable Court, pursuant to Federal Rule of Criminal Procedure 6(e), prevent the disclosure of matters that occurred before the two grand juries that investigated Mr. Epstein in 2005-2007. Mr. Epstein joins the Government in its assertion of Rule 6(e) objections to the various requests by plaintiffs for broad discovery, discovery that is either irrelevant or at most marginally relevant to the issues regarding the application and allegations of possible violation of the Crime Victims' Rights Act, and, if allowed, would be adverse to the privacy and reputational interests of the Intervenor. Although Mr. Epstein was convicted of state offenses and was sentenced to jail, he nevertheless has a right to the safeguards and requirements of Rule 6(e). Those protections include Rule 6(e)'s imperative that absent particularized need, the secrecy of grand jury proceedings must remain intact not only to protect the confidentiality of past proceedings, including the identity of witnesses, subjects, targets, and the nature of considered charges, but also to protect all citizens who are not charged from the disclosure of 6(e) information, documents, and testimony. This Court granted plaintiffs limited discovery, finding that "some factual development is necessary to resolve the remaining issues in this case[.]" Order on Plaintiffs' Motion for Finding EFTA02754898