Case 9:08-cv-80736-KAM Document 300 Entered on FLSD Docket 01/28/2015 Page 1 of 4

Case 9:08-cv-80736-KAM Document 300 Entered on FLSD Docket 01/28/2015 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, 1. Plaintiffs, UNITED STATES OF AMERICA, : Defendant. EPSTEIN'S REPLY IN SUPPORT OF SUPPLEMENTAL PROTECTIVE ORDER There is no doubt that the Eleventh Circuit has held that Epstein's plea negotiation and settlement communications are not privileged. We acknowledged this throughout our initial filing. However, there also can be no doubt that despite these negotiations not being privileged, they are still confidential by longstanding tradition. And confidential material can be filed under seal, even if it is relevant, as the plaintiffs say, to an issue in the case. The question is not whether the material is relevant, but whether good cause exists to temporarily seal this confidential information pending a determination by the court as to whether all or part or none of the