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Court filing · June 26, 2009

Proposed order unsealing Epstein's non-prosecution agreement, June 2009

Fax from the Palm Beach Post's counsel transmitting a proposed order unsealing Epstein's non-prosecution agreement and denying a stay.Machine-written summary

EFTA00180671

06-26-‘09 13:39 FROM-THOMAS & LOCICERO

8139843070

T-059 P001/005 F-889

THOMASLOCICERO
&BRALOW

400 N. Ashley Drive • Suite 1100 • Tampa, FL 33602 813-984-3060 (Phone) • 813-984-3070 (Fax) Toll Free: 866-395-7100

facsimile transmittal

To: Marilyn, Judicial Assistant to Judge Colbath

R. Alexander Acosta, Esq., USAO

FAX

Barbara Burns, Esq., ASAO

Jack Alan Goldberger, Esq.

Bradley J. Edwards, Esq.

William J. Berger, Esq.

Robert D. Critton, Esq.

Spencer T. Kuvin, Esq.

From: Deanna K. Shullman, Esq.

Date: 06/04/2009

Re: State . J. Epstein

Pages: 5

UrgentFor reviewPlease commentPlease replyPlease recycle

Please see attached proposed Order.

This electronic message transmission contains information from the law firm of Thomas, LoCicero & Bralow PL and is confidential or privileged. The information is intended to be for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you have received this electronic transmission in error, please notify us by telephone (813) 984-3060 immediately. Thank you for your cooperation.

IRS Circular 230 Disclosure. To the extent this correspondence contains federal tax advice, such advice was not intended to be used, and cannot be used by any taxpayer, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein. If you would like us to prepare written tax advice designed to provide penalty protection, please contact us and we will be happy to discuss the matter with you in more detail.

confidential

EFTA00180672

06-26-‘09 13:39 FROM-THOMAS & LOCICERO

8139843070

T-059 P002/005 F-889

THOMASLOCICERO
&BRALOW

Tampa

400 N. Ashley Dr., Ste. 1100, Tampa, FL 33602

P.O. Box 2602, Tampa, FL 33601-2602

ph. 813-984-3060 fax 813-984-3070 toll free 886-395-7100

| Ft. Lauderdale |

|----------------|

| 101 N.E. Third Ave., Ste. 1500 |

| Ft. Lauderdale, FL 33301 |

| ph 954-332-3619 fax 877-987-2244 toll free 866-967-2009 |

New York City

220 E. 42nd St., 10th Floor

New York, NY 10017

ph 6 fax 8

www.tlolawfirm.com

Deanna K. Shullman

June 26, 2009

Reply To Tampa

VIA FASCIMILE

The Honorable Jeffrey Colbath

Fifteenth Judicial Circuit-Palm Beach

Palm Beach County Courthouse

Main Judicial Complex

205 N. Dixie Highway, Room 11F

West Palm Beach, FL 33401

Re: State of Florida v. Jeffrey Epstein

Dear Judge Colbath:

This law firm represents the Palm Beach Post in the above matter. I have prepared a proposed Order, which I believe accurately reflects your ruling at the hearing on June 26, 2009 on Defendant Jeffrey Epstein’s Motion to Stay Disclosure of the Non-Prosecution Agreement and Addendum Pending Review.

By copy of this letter, I am providing all counsel of record a copy of the proposed Order. If the attached Order meets with Your Honor’s approval, please enter the same. If you would like to have an electronic copy of this proposed order, please have your Judicial Assistant call my office to make arrangements for us to send you the order via email.

Sincerely,

THOMAS, LOCICERO & BRALOW PL

Deanna K Shullman

Deanna K. Shullman

EFTA00180673

06-26-‘09 13:40 FROM-THOMAS & LOCICERO 8139843070

T-059 P003/005 F-889

Hon. J: Colbath

06/26/09

Page 2 of 2

Enclosures

cc: U.S. Attorney’s Office (via facsimile)

State Attorney’s Office (via facsimile)

Jack Alan Goldberger, Esq. (via facsimile)

Bradley J. Edwards, Esq. (via facsimile)

Deanna K. Shullman, Esq. (via facsimile)

Spencer T. Kuvin, Esq. (via facsimile)

EFTA00180674

06-26-‘09 13:41 FROM-THOMAS & LOCICERO

8139843070

T-059 P004/005 F-889

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

STATE OF FLORIDA

Case Nos.: 2006-CF9454-AXX &

2008-9381CF-AXX

JEFFREY EPSTEIN

ORDER

This matter came before the Court on Defendant Jeffrey Epstein’s Motion to Stay Disclosure of the Non-Prosecution Agreement and Addendum Pending Review and upon further consideration of this Court’s June 26, 2009 Order unsealing certain records in this case. A hearing was conducted on these matters on June 26, 2009.

On June 26, 2009, this Court entered an order unsealing the non-prosecution agreement and an addendum on file in this case. Having inspected the documents, this Court finds that they do not name any victims and do not contain any material subject to confidentiality pursuant to Federal Rule of Criminal Procedure 6. Thus, the Court declines to make any redactions to the records before releasing them to the public.

The Court further finds that Defendant has not demonstrated that a stay pending appeal is warranted. Defendant has not shown any irreparable harm or likelihood of success on the merits on appeal. These documents were not properly closed in the first instance, no present basis for closure exists, and good cause supports disclosure given the public interest in these proceedings and the lack of compelling interest in closure.

Accordingly, it is ordered and adjudged as follows:

  1. Effective at noon on July 2, 2009, the non-prosecution agreement (docketed July

  2. Effective at noon on July 2, 2009, the non-prosecution agreement (docketed July 2, 2008) and addendum (docketed August 25, 2008) are unsealed;

EFTA00180675

06-26-‘09 13:42 FROM-THOMAS & LOCICERO

8139843070

T-059 P005/005 F-889

  1. Defendant’s Motion for Stay pending appellate review is DENIED;

  2. The Clerk of Court is directed to release the documents to the public at noon on Thursday, July 2, 2009.

Done and ordered this ___ day of June, 2009 in Palm Beach County, West Palm Beach, Florida.

Hon. Jeffrey Colbath

CIRCUIT JUDGE

cc: U.S. Attorney’s Office State Attorney’s Office Jack Alan Goldberger, Esq. Bradley J. Edwards, Esq. Deanna K. Shullman, Esq. Spencer T. Kuvin, Esq.

2

Proposed order unsealing Epstein's non-prosecution agreement, June 2009

Court filings

Fax from the Palm Beach Post's counsel transmitting a proposed order unsealing Epstein's non-prosecution agreement and denying a stay.

DOJ Epstein Files, Data Set 9 · June 26, 2009

EFTA00180671 06-26-'09 13:39 FROM-THOMAS & LOCICERO 8139843070 T-059 P001/005 F-889 <table border="1" <tr <td THOMAS</td <td LOCICERO</td </tr <tr <td &amp;</td <td BRALOW</td </tr </table 400 N. Ashley Drive • Suite 1100 • Tampa, FL 33602 813-984-3060 (Phone) • 813-984-3070 (Fax) Toll Free: 866-395-7100 facsimile transmittal To: Marilyn, Judicial Assistant to Judge Colbath R. Alexander Acosta, Esq., USAO FAX Barbara Burns, Esq., ASAO Jack Alan Goldberger, Esq. Bradley J. Edwards, Esq. William J. Berger, Esq. Robert D. Critton, Esq. Spencer T. Kuvin, Esq. From: Deanna K. Shullman, Esq. Date: 0…