Court Records
Case 9:08-cv-80232-KAM Document 32 Entered on FLSD Docket Q8/12/2008 Page 1 of 4 bealeci JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, vs. JEFFREY EPSTEIN. JANE DOE NO. 4, Vs. JEFFREY EPSTEIN. JANE DOE NO. 5, Vs. JEFFREY EPSTEIN. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Y.AIM STEVEN M LARIMORE ME AMTCASE NO.: 08-80119- JUL CASE NO.: 08-80232-CIV-KAM-LRJ CASE NO.: 08-80380-CIV-KAM-LRJ CASE NO.: 08-80381-CIV-KAM-LRJ FILED UNDER SEAL DEFENDANT'S MOTION TO FILE UNDER SEAL 3059 Gun* Avenk. Sum 300, Ca owl GROVE, FLORMA 3313) EFTA02739369 Case 9:08-cv-80232-KAM Document 32 Entered on FLSD Docket 08/12/2008 Page 2 of 4 Pursuant to Rule 5.4 of the Local Rules of the United States District Court for the Southern District of Florida, defendant Jeffrey Epstein hereby moves to file his reply to plaintiffs' responses to his motions for stay, as well as this motion, under seal, stating as follows: I. In his reply to plaintiffs' responses to his motions for stay, defendant Jeffrey Epstein refers to a confidential agreement between the United States Attorney's Office for the Southern District of Florida and Jeffrey Epstein. 2. The information contained in the confidential agreement is material to this Court's consideration of defendant's reply to plaintiffs' responses to his motions for stay. 3. To avoid disclosure of confidential material, defendant requests leave to file his reply to plaintiffs' responses to his motions for stay, and this motion, under seal. 4. We recognize that this Court has previously unsealed documents referring to this same agreement. We mean in no way to disregard that order, but seek merely to comply with the confidentiality clause in that agreement for this new and independent filing, in an abundance of caution, until directed otherwise by the Court. WHEREFORE, defendant Jeffrey Epstein respectfully requests leave to file this motion and his reply to plaintiffs' responses to his motions for stay, under seal. Respectfully submitted, TEM, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, Florida 33133 Tel: [Phone Redacted] Fax: [Phone Redacted] 2 Teinn. 3059 GIAND AVDAIE. SURE 340. COCONUT GROVE, FLO/00A 33133 EFTA02739370 Case 9:08-cv-80232-KAM Document 32 Entered on FLSD Docket 08/12/2008 Page 3 of 4 By: MICHAEL R. TEIN Fla. Bar No. 993522 [Email Redacted] ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, Florida 33401 Tel. [Phone Redacted] Fax. [Phone Redacted] By: Jack A. Goldberger Fla. Bar No. 262013 jgoldberger®agwpa.com CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1 Undersigned counsel has conferred in good faith with counsel for the plaintiff. who opposes the relief requested in this motion. Michael R. Tein CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing document is being served this day, July 28, 2008, on counsel of record identified on 3c service list by U.S. Mail. • Mic ael . 3 3059 GitAno Avims. Sure 340. Cccomn Gaon. FLOItilm 33133 EFTA02739371 Case 9:08-cv-80232-KAM Document 32 Entered on FLSD Docket 08/12/2008 Page 4 of 4 Service List Jeffrey M. Herman, Esq. Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Herman & Mermelstein, P.A. 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Fax: [Phone Redacted] 4 IIIMIT:40 /1 n 3059 GRAND M MA. Sunt 340. COCONUT GROVE, FLORIDA 33133 EFTA02739372