Case 9:08-cv-80736-KAM Document 414 Entered on FLSD Docket 08/11/2017 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-cv-80736-KAM JANE DOE 1 AND JANE DOE 2, Petitioners, v. UNITED STATES, Respondent. JANE DOE 1 AND JANE DOE 2'S MOTION FOR FINDING OF WAIVER OF WORK PRODUCT AND SIMILAR PROTECTIONS BY GOVERNMENT AND FOR PRODUCTION OF DOCUMENTS Jane Doe 1 and Jane Doe 2 (also referred to as "the victims"), by and through undersigned counsel, file this motion for a finding that the Government has waived work production protections, as well as attorney-client and similar privileges, regarding documents that the Government has previously withheld based on these protections, and an order directing the Government to produce all such documents. As the Court will recall, it previously reviewed emails and other internal materials submitted to it in camera by the Government about its internal deliberations. See DE 330 at 12. The Court ultimately concluded that many of these documents were protected by work-product protection. DE 330 at 12-17. And yet, in recently-filed pleadings, the Government has now made many representations about these same internal deliberations — representations that it now argues should lead the Court to grant summary judgment in this case. See. e.g., DE 403-19 (Villafafia affidavit — filed June 2, 2017). The Government cannot simultaneously assert work product protection over relevant documents concerning its internal deliberations while making representations regarding those deliberations to obtain summary judgment. Because the 1 EFTA02757787