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efta-efta00222327DOJ Data Set 9Other

Case 9:08-cv-80119-KAM

Date
Unknown
Source
DOJ Data Set 9
Reference
EFTA 00222327
Pages
4
Persons
4
Integrity
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Summary

Case 9:08-cv-80119-KAM Document 23 Entered on FLSD Docket 07,17'2008 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 I- I 0 fV DEFENDANT'S MOTION TO FILE EX PARTE AND UNDER SEAL EFTA00222327 Case 9:08-cv-80119-KAM Document 23 Entered on FLSD Docket 07/17/2008 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 pane 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 th

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Extracted Text (OCR)

EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
Case 9:08-cv-80119-KAM Document 23 Entered on FLSD Docket 07,17'2008 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 I- I 0 fV DEFENDANT'S MOTION TO FILE EX PARTE AND UNDER SEAL EFTA00222327 Case 9:08-cv-80119-KAM Document 23 Entered on FLSD Docket 07/17/2008 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 pane 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: 2 EFTA00222328 . Case 9:08-cv-80119-KAM Document 23 Entered on FLSD Docket 07)17.2008 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 Tel: 305 442 1101 Fax: 305 442 6744 By: GUY A. LEWIS Fla. Bar No. 623740 MICHAEL R. 1EIN Ha. Bar No. 993522 [email protected] 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 Attorneys for Defendant Jeffrey Epstein 3 EFTA00222329 Case 9:08-cv-80119-KAM Document 23 Entered on FLSD Docket 07/17/2008 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 I0, 2008. Michael R. Tein 4 EFTA00222330

Related Documents (6)

DOJ Data Set 9OtherUnknown

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DOJ Data Set 9OtherUnknown

0338E903Etek.888893941AAAA ODCIKNOM03712 En

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VIA FACSIMILE AND ELECTRONIC MAIL

VIA FACSIMILE AND ELECTRONIC MAIL Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. Roy Black, Esq. Black Srebnick Kornspan & Stumpf P.A. Re: Jeffrey Epstein U.S. Department of Justice United States Attorney Southern District of Florida June 27, 2008 Dear Messrs. Goldberger and Black: Thank you for providing me with the proposed plea agreement between Mr. Epstein and the State Attorney's Office. The U.S. Attorney's Office hereby provides Notice that the proposed sentencing provision does not comply with the terms of the Non-Prosecution Agreement. The second sentencing paragraph of the proposed plea agreement reads: On 08CF00938 1 AMB, the Defendant is sentenced to 18 months Community Control I (one). As a special condition of this Community Control the Defendant must serve the first 6 months in the Palm Beach County Detention Facility ... The Non-Prosecution Agreement specifically provides: Epstein shall be sentenced to consecutive terms of twelve (12) mo

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Case 9:08-cv-80893-KAM Document 214

Case 9:08-cv-80893-KAM Document 214 Entered on F LSD Docket 09/02/2010 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FT. LAUDERDALE DIVISION Case No. 08-CIV-80893-MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT, JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER AND OBJECTION TO DISCLOSURE OF CERTAIN DOCUMENTS WITH INTEGRATED MEMORANDUM OF LAW Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to a Joint Stipulation Regarding Certain Documentation files this his Motion for Protective Order and Objection to Disclosure of Certain Correspondence and Discovery for the reasons set forth below: I. PRELIMINARY STATEMENT During the underlying litigation, Epstein vigorously sought protection from the Court that these and other documents produced would be used for purposes other than those contemplated by the Federal Rules of Civil Procedure for discovery; i.e., dissemination in the

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Rol Slack lir „kite'

Rol Slack lir „kite' 2/949 Arcrwite a." 2434 7 Antai, Liu) 3 cut, , 4,/e EFTA00183732 KIRKLAND & ELLIS LLP AND AfilL/ArtO PART/H.3We; ' Cntercup Cantor 163 East 53'd Street New York, New York 10022-4611 WNW rwerA.COM September 2, 2008 VIA FACSIMILE (56D 820-8777 United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re:Jeffrey Bpstein Dear • Facsimile: In response to your letter dated August 26, 2008, I am confirming that Mr. Goldberger should continue to be listed as the contact pawn in the' mended victim notification letters and should receive the carbon copies of thoso letters as they are sent. • Also, we plan on speaking to Mr. Josofsberg this week to discuss a procedure for paying his fees. We intend to comply fully with the agreement and Mr. Epstein will pay Mr. Josfsberg's usual and customary hourly rates for his work pursuant to the agreement facilitating settlements unde

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Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 65 Entered on FLSD Docket 03/25/2009 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant, Jeffrey Epstein's Motion To Stay And Or Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby moves this Court for the entry of an order staying or continuing this action for a time certain (i.e., until late 2010 when the NPA expires), pursuant to the application of the Fifth Amendment of the U.S. Constitution and the fact that a parallel proceeding is ongoing and being investigated. In support of his motion, EPSTEIN states: I. Introduction At the outset, EPSTEIN notes this Court's prior Order, (DE 33), in which this Court denied a motion for stay brought by Def

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