Court Records
Case 9:08-cv-80380-KAM Document 43 Entered on FLSD Docket 08/12/2008 Page 1 of 4 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 CASE NO.: 08-80119 -CI Salo D.c7 JUL 2 8 2008 STEVEN M. LARIMORE Craltlit Cl 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 Fein W. 3159 GRAND AVENtE, SUITE 3.10. COCOM T GROVE. FLOKIDA 33133 EFTA02740512 Case 9:08-cv-80380-KAM Document 43 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, TEIN, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, Florida 33133 Tel: [Phone Redacted] Fax: [Phone Redacted] 2 Minn 3039 G4.40,0 Mimic SinTE 340. C0coNtrr GROVE, FLORIDA 33131 EFTA02740513 Case 9:08-cv-80380-KAM Document 43 Entered on FLSD Docket 08/12/2008 Page 3 of 4 By: GUY A. Fla. Bar No. 623740 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 [Email Redacted] 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 the service list by U.S. Mail. 444wris• Michael R. Tein 3 'rein re. 3059 GRAND AVANLE. Suitt 340.COCOWT GROW. FLORIDA 33133 EFTA02740514 Case 9:08-cv-80380-KAM Document 43 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. Heenan & Mermelstein, P.A. 18205 Biscayne Blvd. Suite 2218 Miami. Florida 33160 Fax: [Phone Redacted] 4 ‘.. .E111 rt. 3039 GRAND AVENUE, SUM, 340. C000,40 GROVE. FLORIDA 33133 EFTA02740515