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.
I
FILED EX PARTE
UNDER SEAL
DEFENDANT'S MOTION TO FILE EX PARTE AND UNDER SEAL
EFTA00013564
• 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
EFTA00013565
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. TEIN
Ha. Bar No. 993522
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
Attorneysfor Defendant Jeffrey Epstein
3
EFTA00013566
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. I,.R.
5.4, has not been served on opposing counsel and was filed under seal on July I0,
2008.
Michael R. Tein
4
EFTA00013567