EFTA00221960.pdf

Case 9:08-cv-80119-KAM Document 37 Entered on FLSD Docket 08,12 2008 Page 1 of 4 UNITED STATES DISTRIC OURT SOUTHERN DISTRICT 0 FLORIDA JANE DOE NO. 2, v CASE NO.: 08-80119-C1V- M-LRJ VS. JUL 2 JEFFREY EPSTEIN. I STEVEN 1.1 LARINORE CLERK U.S. DIST CT FLA MIAM JANE DOE NO. 3, vs. JEFFREY EPSTEIN. JANE DOE NO. 4, VS. JEFFREY EPSTEIN. JANE DOE NO. 5, vs. JEFFREY EPSTEIN. 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 3059GRA.Avt.sus. Suit 340.Cocom TGtovL FLOW. 33133 EFTA00221960 Case 9:08-cv-80119-KAM Document 37 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, LEWIS TEIN, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, Florida 33133 Tel: 305 442 1101 Fax: 305 442 6744 2 Lewis 'Minn. 3059 GRAND AVENUE. SURE 340. COCONL I GROVE, FLORIDA 33133 EFTA00221961 Case 9:08-cv-80119-KAM Document 37 Entered on FLSD Docket 08)12 2008 Page 3 of 4 By: GUY A. LEWIS Fla. Bar No. 623740 ~i~~~ MICHAEL R. TEIN Fla. Bar No. 993522 tein@lewistein.com 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 ailaileam~ 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 n the service list by U.S. Mail. ichael R. Tein 3 Lewis 'reinPl. 3059 GRAND MIND!. SIAM 340. COCOW I GROW. FLORIDA »131 EFTA00221962 Case 9:08-cv-80119-KAM Document 37 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: 305 931 0877 4 Lewis Tin en. 3059 GMMD Aloe 90C. SUITE 390. COCOM GRO9E. FLORIDA 33133 EFTA00221963