¶
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA¶
JANE DOE NO. 2,¶
CASE NO.: 08-80119-CIV-KAM-LRJ¶
vs.¶
JEFFREY EPSTEIN.¶
JANE DOE NO. 3,¶
CASE NO.: 08-80232-CIV-KAM-LRJ¶
vs.¶
JEFFREY EPSTEIN.¶
JANE DOE NO. 4,¶
CASE NO.: 08-80380-CIV-KAM-LRJ¶
vs.¶
JEFFREY EPSTEIN.¶
JANE DOE NO. 5,¶
CASE NO.: 08-80381-CIV-KAM-LRJ¶
vs.¶
JEFFREY EPSTEIN.¶
FILED UNDER SEAL¶
DEFENDANT'S MOTION TO FILE UNDER SEAL¶
¶
3059 GRAND AVENUE, SUITE 340, COCONUT GROVE, FLORIDA 33133¶
3/15¶
Pursuant to Rule 5.4 of the Local Rules of the United States District Court for the Southern District of Florida, defendant Jeffrey Epstein hereby moves to file his reply to plaintiffs' responses to his motions for stay, as well as this motion, under seal, stating as follows:¶
- I. In his reply to plaintiffs' responses to his motions for stay, defendant Jeffrey Epstein refers to a confidential agreement between the United States Attorney's Office for the Southern District of Florida and Jeffrey Epstein.
-
- The information contained in the confidential agreement is material to this C'ourt's consideration of defendant's reply to plaintiffs' responses to his motions for stay.
-
- To avoid disclosure of confidential material, defendant requests leave to file his reply to plaintiffs' responses to his motions for stay, and this motion, under seal.
-
- 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.
WHEREFORE, defendant Jeffrey Epstein respectfully requests leave to file this motion and his reply to plaintiffs' responses to his motions for stay, under seal.¶
Respectfully submitted,¶
TEIN, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, Florida 33133 Tel: 305 442 1101 Fax: 305 442 6744¶
f3¶
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¶
IHEREBY CERTIFY that the foregoing document is being served this day, July 28, 2008, on counsel of record identified on the service list by U.S. Mail.¶
114Aib¶
Michael R. Tein¶
Service List¶
Jeffrey M. Herman, Esq. Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Herman & Mermelstein, P.A. 18205 Biscayne Blvd, Suite 2218 Miami, Florida 33160 Fax: 305 931 0877¶
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