Case Document Entered on FLSD Docket Page of JANE DOE NO vs JEFFREY EPSTEIN I JANE DOE NO vs JEFFREY EPSTEIN I JANE DOE NO VS JEFFREY EPSTEIN I JANE DOE NO vs JEFFREY EPSTEIN I Sealed UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FILE I CASE NO STEVEN LARIMORE I CLEf1.K4-lhSti CT o/.MVlF t1A MIAMi CASE NO CASE NO CASE NO FILED UNDER SEAL DEFENDANTS MOTION TO FILE UNDER SEAL Lewis TeinP1 GRAND A VENUE SUITE COCONUT GROVE FLORIDA Case Document Entered on FLSD Docket Page of Pursuant to Rule 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 In his reply to plaintiffs responses to his motions for stay defendant Jeffrey Epstein refers to a confidential agreement between the United States Attorneys Office for the Southern District of Florida and Jeffrey Epstein The information contained in the confidential agreement is material to this Courts consideration of defendants 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 LEWIS TEIN P.L Grand Avenue Suite Coconut Grove Florida Tel Fax Lewis Tein GRAND AVENUE SUITE CDCDNUT GROVE FLORIDA Case Document Entered on FLSD Docket Page of 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 goldberger agwpa.com CERTIFICATE OF COMPLIANCE WITH LOCAL RULE Undersigned counsel has conferred in good faith with counsel for the plaintiff who opposes the relief requested in this motion Michael Tein CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing document is being served this day July on counsel of record identified on Lewis TeinP1 GRAND A ENUE SUITE COCONUl GROVE FLORIDA I Case Document Entered on FLSD Docket Page of Jeffrey Herman Esq Stuart Mermelstein Esq Adam Horowitz Esq Herman Mermelstein P.A Biscayne Blvd Suite Miami Florida Fax Service List Lewis Tein lL GRAND AVENUE SUITE COCONUT GROVE FLORIDA
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