UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA¶
CASE NO.: 08-80804-CIV-MARRA/ [REDACTED]¶
JANE DOE, a/k/a
JANE DOE NO. 1,¶
Sealed¶
Plaintiff,¶
vs.¶
JEFFREY EPSTEIN, [REDACTED]
[REDACTED] and [REDACTED]¶
Defendants.¶
_____ /¶
¶
FILED UNDER SEAL¶
DEFENDANTS JEFFREY EPSTEIN AND [REDACTED]
MOTION TO FILE UNDER SEAL¶
[REDACTED] is Tein PL
CONSUMER SERVICE¶
3059 GRAND AVENUE, SUITE 340, COCONUT GROVE, FLORIDA 33133¶
ig¶
Pursuant to Rule 5.4 of the Local Rules of the United States District Court for the Southern District of Florida, defendants Jeffrey Epstein and hereby move to file their motion for stay, as well as this motion, under seal, stating as follows:¶
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In their motion for stay, defendants Jeffrey Epstein and refer to a confidential agreement between the United States Attorney's Office for the Southern District of Florida and Jeffrey Epstein.
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The information contained in the confidential agreement is material to this Court's consideration of the defendants' motion for stay.
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To avoid disclosure of confidential material, the defendants request leave to file their motion for stay, and this motion, under seal.
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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.
The undersigned are authorized to represent that defendant joins in this motion.¶
WHEREFORE, defendants Jeffrey Epstein and [REDACTED] respectfully request leave to file this motion and their motion for stay, under seal.¶
Respectfully submitted,¶
[REDACTED] TEIN, P.L.
3059 Grand Avenue, Suite 340
Coconut Grove, Florida 33133
Tel: 305 442 1101
Fax: 305 442 6744¶
By:¶
GUY A. [REDACTED]
Fla. Bar No. 623740¶
[REDACTED]¶
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
jgoldberger@agwpa.com¶
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 25, 2008, on counsel of record identified on the service list by U.S. Mail.¶
Michael R. Tein¶
Service List¶
Theodore J. Leopold, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Fax: 561 697 2383 Counsel for Plaintiff Jane Doe¶
Douglas M. McIntosh, Esq. Jason A. , Esq. McIntosh, Sawran, Peltz & Cartaya, P.A. Centurion Tower 1601 Forum Place, Suite 1110 West Palm Beach, Florida 33401 Fax. 561 682-3206 Counsel for Defendant¶
Bruce E. Reinhart, Esq. Bruce E. Reinhart, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401 Fax. 561 828 0983 Counsel for Defendant¶
Robert D. Critton, Esq. Michael J. Pike, Esq. Burman, Critton, Luther & Coleman, LLP 515 N. Flagler Drive, Suite 400 West Palm Beach, Florida 33401 Fax. 561 515 3148 Co-Counsel for Jeffrey Epstein¶