Epstein motion seeking court approval to travel to New York in December 2009

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

CASE NO. 2008CF009381A¶

STATE OF FLORIDA¶

vS.¶

JEFFREY EPSTEIN,¶

Defendant.¶

MOTION FOR AUTHORIZATION TO TRAVE(.¶

COMESNOW the Defendant, JEFFREY EPSTEIN, by and through his undersigned attorney and moves this Honorable Court to enter an Or r authorizing the Defendant to travel to New York on December 3, 2009 and Dece. e 1 009. In support thereof the Defendant would state as follows:¶

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• 1. The Defendant has been on co let sto ontrol since July 22, 2009. 2 The Defendant has been in comp mpliance with his conditions of community control since being placed on supervision.

3 At a hearing on November 18, 2009 concerning the status of a No Contact Order, the Defendant, through counsel, requested this Honorable Court to allow the Defendant to travel for business purposes as long as he received the prior approval of his probation officer. The Court denied the motion at that time without prejudice and indicated that when there is a specific business trip planned for the Defendant to bring the matter back before the Court and it would be considered.¶

4 The Defendant desires to travel to New York on December 3, 2009 and to return to West Palm Beach on the same date. The purpose of the meeting is forthe Defendant to meet with his attorney, Stephen Susman at the Law Office of Polk and Wardwell, located at 450 Lexington Avenue, New York, New York 10017. The purpose of the meeting¶

is for Mr. Epstein and his attorney to review documents at the= Polk Law Offices. Attached hereto as Exhibit “A” is a letter from the Defendant’s civil counsel, Stephen Susman, confirming the need for the meeting to take place at the Polk Law Office in New York.¶

5 The Defendant would travel to New York on the morning of December 3, 2009 and would return to West Palm Beach on the evening of December 3, 2009. Th Aiiimmt fendant would confirm the specific times of his travel with his probation officer pri0Vo tflfvel.¶

6. The Defendant also needs to travel to New York on Decemtter 12, 2009 for a meeting with a governmental official from a foreign country ce again, the Defendant would travel to New York on the morning of December 12,009 and would return the evening of December 12, 2009. The Defendant would 9’ in confirm the specific travel times with his probation officer prior to travel.

WHEREFORE, the Defendant moves $ Honorable Court to enter an Order authorizing the Defendant to travel for the day on December 3, 2009 and December 12, {sup}2009)¶

I HEREBY CERTIFY that of the foregoing has been furnished by mail to Barbara Esquire State Attorney’s Office, 401 North Dixie Highway, West Palm Beach, Florida 33401 an o Carmen Sloane, Department of Corrections, 423 Fern Street, West Palm Beach, Florida 33401, this 24th day Nov ber, 2009.¶

JAC Av G•LDBERGER, ESQ. Atte ury, Goldberger & Weiss, P.A. 250 • ustralian Avenue South Suite 1400 West Palm Beach, Florida 33401 (561) 659-08300 Florida Bar No. 262013

¶

SUSMAN GODFREY L.L.P.¶

A REGISTERED LIMITED LIABILITY PARTNERSHIP¶

Suite 5100¶

1000 LOUISIANA¶

HOUSTON, TEXAS 77002-5096¶

(713) 651-9366¶

FAX (713) 654-6666¶

WWW.SUSMANGODFREY.COM¶

SUITE 5100 901 MAIN STREET DALLAS, TEXAS 75202-3775 (214) 754-1900¶

SUITE 950 1901 AVENUE OF THE STARS LOS ANGELES, CALIFORNIA 90067-6029 (310) 789-3100¶

SUITE 3800 1201 THIRD AVENUE SEATTLE, WASHINGTON 98101-3000 (206) 516-3680¶

STH FLOOR 654 MADISON AVENUE NEW YORK, NEW YORK 10005-6440 (212) 336-8330¶

STEPHEN D. SUSMAN DIRECT DIAL (713) 653-7601¶

DIRECT DIAL FAX (713) 654-6670 E-MAIL SSUSMAN@SUSMANGODFREY.COM¶

November 24, 2009¶

VIA EMAIL¶

Mr. Jeffrey Epstein 3901 East 66 Street, 10B New York, NY 10065¶

Re: Potential Claims against D.B. Zwirn¶

Dear Jeffrey:¶

I need you to come to New York City on December 3{sup}rd to meet with me and go to [REDACTED] Polk’s office to review some documents that they will only show us in their office. They claim they are subject to confidentiality agreements. This is necessary to help us evaluate the above claim.¶

Sincerely,¶

Stephen D. Susman¶

cc: Daryl Indyke Harry Susman¶