Case 9:08-cv-80736-KAM Document 130 Entered on FLSD Docket 12/05/2011 Page 1 of 3

Case 9:08-cv-80736-KAM Document 130 Entered on FLSD Docket 12/05/2011 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S PROTECTIVE MOTION TO COMPEL COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to file this protective motion to compel. For the reasons explain in the victims' Response to the Government's Motion to Stay Discovery, the victims move this Court to order the Government to comply with their discovery requests. In particular, after the Court denies the Government's motion to dismiss, the Court should then order the Government to produce within 14 days: (1) The Government's initial disclosures pursuant to Fed. R. Civ. P. 26(a)(1); I (2) Answers to all of the victims' requests for admission; (3) All documents, correspondence, and other information that the Government d