EFTA00175683

Entered on FLSD Docket 07/11/2008

Page 1 of 4

# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 08-CV-80119-MARRA-JOHNSON

JANE DOE NO. 2,

Plaintiff,

VS.

JEFFREY EPSTEIN,

Defendant.





FILED EX PARTE

UNDER SEAL



DEFENDANT’S MOTION TO FILE EX PARTE AND UNDER SEAL

EFTA00175684

Case 9:08-cv-cv119-KAM



Docume... 23


Entered on FLSD Docket 07/1,,2008

Page 2 of 4

Pursuant to S.D. Fla. L.R. 5.4, defendant Jeffrey Epstein hereby moves to file his Notice of Continued Pendency of Federal Criminal Action, as well as this motion, ex parte and under seal, stating as follows:

1. In support of his motion to stay [DE 12], defendant has herewith filed a Notice of Continued Pendency of Federal Criminal Action.

2. The Notice relates to a confidential agreement between the United States Attorney’s Office for the Southern District of Florida and the defendant.

3. The information contained in the Notice is material to this Court's consideration of Epstein's motion to stay.

4. To avoid disclosure of confidential material, Epstein requests leave to file the Notice, and this motion, ex parte and under seal.

5. Pending a ruling from this Court, Epstein has not served this motion or the Notice on counsel for plaintiff.

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EFTA00175685

Entered on FLSD Docket 07/1,,2008

Page 3 of 4

WHEREFORE, defendant Jeffrey Epstein respectfully requests leave to file this motion and his Notice of Continued Pendency of Federal Criminal Action, ex parte and under seal.

Respectfully submitted,

LEWIS TEIN, P.L.

3059 Grand Avenue, Suite 340

Coconut Grove, Florida 33133







ATTERBURY, GOLDBERGER & WEISS, P.A.

250 Australian Avenue South, Suite 1400

West Palm Beach, Florida 33401

Tel. [blank] Fax.[blank]



By: JACK A. GOLDBERGER

Fla. Bar No. 262013

jgoldberger@agwpa.com

Attorneys for Defendant Jeffrey Epstein

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EFTA00175686

Case 9:08-cv-00119-KAM Document 23 Entered on FLSD Docket 07/...,2008

Page 4 of 4

## CERTIFICATE OF SERVICE

I HEREBY CERTIFY that this motion, in accordance with S.D. Fla. L.R.

5. 4, has not been served on opposing counsel and was filed under seal on July 10, 2008.



Michael R. Tein

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