Case Document Entered on FLSD Docket Page of UNITED ST A TES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CV-80232-MARRA-JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant I FILED EX PARTE UNDER SEAL DEFENDANTS MOTION TO FILE EX PARTE AND UNDER SEAL Case Document Entered on FLSD Docket Page of Pursuant to S.D Fla L.R defendant Jeffrey Epstein hereby moves to file his Notice of Continued Pendency of Federal Criminal Action as well as this motion ex parte and under seal stating as follows In support of his motion to stay DE defendant has herewith filed a Notice of Continued Pendency of Federal Criminal Action The Notice relates to a confidential agreement between the United States Attorneys Office for the Southern District of Florida and the defendant The information contained in the Notice is material to this Courts consideration of Epsteins motion to stay To avoid disclosure of confidential material Epstein requests leave to file the Notice and this motion ex parte and under seal Pending a ruling from this Court Epstein has not served this motion or the Notice on counsel for plaintiff Case Document Entered on FLSD Docket Page of 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 Grand Avenue Suite Coconut Grove Florida Tel Fax By GUY A LEWIS Fla Bar No lewis lewistein.com MICHAEL TEIN Fla Bar No tein lewistein.com ATTERBURY GOLDBERGER WEISS P.A Australian A venue South Suite West Palm Beach Florida Tel Fax By JACK A GOLDBERGER Fla Bar No jgoldberger agwpa.com Attorneys for Defendant Jeffrey Epstein Case Document Entered on FLSD Docket Page of CERTIFICATE OF SERVICE I HEREBY CERTIFY that this motion in accordance with S.D Fla L.R has not been served on opposing counsel and was filed under seal on July Tein
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