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efta-efta00209459DOJ Data Set 9Other

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Plaintiffs I UNITED STATES, Defendants JANE DOE #1 AND JANE DOE #2'S SUPPLEMENTAL CLARIFICATION REGARDING REOUESTS FOR PRODUCTION TO MAKE CLEAR THAT IDENTIFYING INFORMATION IS NOT REQUESTED COME NOW Jane Doe #1 and Jane Doe #2, by and through undersigned counsel, to clarify that, to avoid any interference with any privacy rights of victims who are not parties to this litigation, Jane Doe #1 and Jane Doe #2 are not seeking any identifying information about other victims. In any of the documents that Jane Doe #1 and Jane Doe #2 have requested the Government produce, the Government should not produce the names of other victims or other identifying information (e.g., address or telephone number) but should instead redact that information. Of course, for documents identifying Jane Doe #1 and Jane Doe #2, those documents should be produced DATED: July

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Unknown
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DOJ Data Set 9
Reference
EFTA 00209459
Pages
2
Persons
2
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Summary

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Plaintiffs I UNITED STATES, Defendants JANE DOE #1 AND JANE DOE #2'S SUPPLEMENTAL CLARIFICATION REGARDING REOUESTS FOR PRODUCTION TO MAKE CLEAR THAT IDENTIFYING INFORMATION IS NOT REQUESTED COME NOW Jane Doe #1 and Jane Doe #2, by and through undersigned counsel, to clarify that, to avoid any interference with any privacy rights of victims who are not parties to this litigation, Jane Doe #1 and Jane Doe #2 are not seeking any identifying information about other victims. In any of the documents that Jane Doe #1 and Jane Doe #2 have requested the Government produce, the Government should not produce the names of other victims or other identifying information (e.g., address or telephone number) but should instead redact that information. Of course, for documents identifying Jane Doe #1 and Jane Doe #2, those documents should be produced DATED: July

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Plaintiffs I UNITED STATES, Defendants JANE DOE #1 AND JANE DOE #2'S SUPPLEMENTAL CLARIFICATION REGARDING REOUESTS FOR PRODUCTION TO MAKE CLEAR THAT IDENTIFYING INFORMATION IS NOT REQUESTED COME NOW Jane Doe #1 and Jane Doe #2, by and through undersigned counsel, to clarify that, to avoid any interference with any privacy rights of victims who are not parties to this litigation, Jane Doe #1 and Jane Doe #2 are not seeking any identifying information about other victims. In any of the documents that Jane Doe #1 and Jane Doe #2 have requested the Government produce, the Government should not produce the names of other victims or other identifying information (e.g., address or telephone number) but should instead redact that information. Of course, for documents identifying Jane Doe #1 and Jane Doe #2, those documents should be produced DATED: July 31, 2013 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. EFTA00209459 and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane Doe #2 EFTA00209460

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Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 0372112011 Page 1 of 15 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 MOTION FOR ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for an order from this Court directing the U.S. Attorney's Office not to suppress material evidence relevant to this case. The Court should enter an order, as it would in other criminal or civil cases, requiring the Government to make appropriate production of such evidence to the victims. BACKGROUND In discussions with the U.S. Attorney's Office about this case, counsel for Jane Doe #1 and Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims information in its possession that was mater

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UNITED STATES DISTRICT COURT

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