# IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICAL CIRCUIT No IN AND FOR PALM BEACH CotiNTS FLORIDA, CRIMINAL DIVISION, :',
STATE OF FLORIDA, on I

s.

vs. Case Nosalialern

JEFFREY EPSTEIN, 2008-938ICF AXX r.,

Defendant.

# NONPARTY MOTION FOR ATTORNEYS FEES AND COSTS
, a nonparty, moves pursuant to Administrative Rule 2.303 for attorneys fees and costs on the following grounds:

1. is filed a motion to vacate the agreed order sealing records and to unseal the nonprosecutuion agreement and add defendant's motion to unseal said rec was denied at hearing on June 2 this file. Also, opposed motion was granted and defendant's

2. is entitled t of reasonable attorneys fees and costs pursuant to said Administrative Rule. Defendant's motion to seal and his opposition to motion were not made in good faith and were not supported by a sound legal or factual basis.

3. adopts and incorporates by reference all arguments in the motion for fees filed by The Palm Beach Post.

I HEREBY CERTIFY that a true and correct copy of the foregoing has been served via U.S. Mail this attl day of July, 2009 to: Jack Alan Goldberger, Esq., Atterbury Goldberger et al., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401;

Michael McAuliffe, Esq. and Judith Stevenson Arco, Esq., State Attorney's Office-West Palm Beach, 401 North Dixie Highway, West Palm Beach, FL 33401; and Deanna K. Shullman, Esq. and James B. Lake, Esq., 101 N.E. Third Avenue, Suite 1500, Fort Lauderdale, FL 33301.

> ROTHSTEIN ROSENFELDT ADLE,R Attorneys for E.W. 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33394 Telephone (954) 522-3456 Telecopier (954) 527-8663

By: for William J. Berger Florida Bar No. 197701 wbergerarra-law.com

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