EFTA00013564.pdf

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Source set: data-set-8
Extracted text

Case 9:08-cv-80119-KAM 
Document 23 
Entered on FLSD Docket 07/17/2008 
Page 1 of 4 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA-JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
I 
FILED EX PARTE 
UNDER SEAL 
DEFENDANT'S MOTION TO FILE EX PARTE AND UNDER SEAL 
EFTA00013564


• 
Case 9:08-cv-80119-KAM 
Document 23 
Entered on FLSD Docket 07/17/2008 
Page 2 of 4 
Pursuant to S.D. Fla. L.R. 5.4, defendant Jeffrey Epstein hereby moves to 
file his Notice of Continued Pendency of Federal Criminal Action, as well as this 
motion, ex pane and under seal, stating as follows: 
1. 
In support of his motion to stay [DE 12], defendant has herewith filed 
a Notice of Continued Pendency of Federal Criminal Action. 
2. 
The Notice relates to a confidential agreement between the United 
States Attorney's Office for the Southern District of Florida and the defendant. 
3. 
The information contained in the Notice is material to this Court's 
consideration of Epstein's motion to stay. 
4. 
To avoid disclosure of confidential material, Epstein requests leave to 
file the Notice, and this motion, ex parte and under seal. 
5. 
Pending a ruling from this Court, Epstein has not served this motion 
or the Notice on counsel for plaintiff. 
2 
EFTA00013565


Case 9:08-cv-80119-KAM 
Document 23 
Entered on FLSD Docket 07:17/2008 
Page 3 of 4 
WHEREFORE, defendant Jeffrey Epstein respectfully requests leave to file 
this motion and his Notice of Continued Pendency of Federal Criminal Action, ex 
parte and under seal. 
Respectfully submitted, 
LEWIS TEIN, P.L. 
3059 Grand Avenue, Suite 340 
Coconut Grove, Florida 33133 
Tel: 305 442 1101 Fax: 305 442 6744 
By: 
GUY A. LEWIS 
Fla. Bar No. 623740 
MICHAEL R. TEIN 
Ha. Bar No. 993522 
ATTERBURY, GOLDBERGER & WEISS, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, Florida 33401 
Tel. 561 659 8300 Fax. 561 835 8691 
By: 
JACK A. GOLDBERGER 
Fla. Bar No. 262013 
Attorney…
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