Epstein Secrets

GROUNDS FOR RELIEF IN LIGHT OF CHANGED CIRCUMSTANCES Defendant's Motion should be denied in that Defendant failed to comply with the Local Rules of the United States District Court for the Southern District of Florida in that Defendant's counsel neither conferred nor attempted to confer with counsel for the Plaintiff as to the

EPSTEIN CASE NO.: 08-CV-80119-MARRA/JOHNSON United States District Court, Southern District of Florida Jack Alan Goldberger [email protected] Michael R. Tein [email protected] /s/ Jeffrey M. Herman HERMAN & MERMELSTEIN. P. A. www.hermanlaw.com - 9 - EFTA00222339

the individuals referred to in paragraph (7), supra, elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Epstein waives his right to contest liability and also waives h

his guilty plea. On June 30th, a couple of hours after the change of plea, the agents and I went to Jack Goldberger's office and met with Jack and Mike Tein. We provided them with the proposed Notification of Identified Victims. On the first page of that notice, we wrote the following: In light of the e

the individuals referred to in paragraph (7), supra, elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Epstein waives his right to contest liability and also waives h

tate to call me if you wish further clarification of our position or to discuss this matter in any way. Until then, I remain, Very truly yours, • Michael R. Tein • cc: Jack Goldberger, Esq. • Roy Black, Esq. Alex Acosta, Esq. 3059 GRAND AVENUE • SUITE 340 • COCONUT GROVE, FLORIDA 33133 TELEPHONE (305)

8 U.S.C. §§ 1441, 1446, and 1332(a)(1), the defendants, Jeffrey Epstein, , and hereby remove this action) from Palm Beach County Circuit Court to the United States District Court for the Southern District of Florida, and respectfully state as follows: Introduction Six months ago, this plaintiff filed virtually the identical

the foregoing document is being served this day, July 18, 2008, on counsel of record identified on the service list by U.S. Mail. ir • 14 lista Michael R. Tein 24 Lentyk.1:17fin ri. 3059 Guido Avow', Sum 340, CocomviGeovt, flew 33333 34 el 3111 EFTA00180430 Case 9:08-cv-80804-KAM Document 1 Entered

RECEIVE NOTICES OF ELECTRONIC FILING In accordance with Local Rules 4.6 of the Special Rules Governing the Admission and Practice of Attorneys of the United States District Court for the Southern District of Florida, the undersigned respectfully moves for the admission of Jay C. Howell for purposes of limited appearance as c

berger, Esquire Atterburty, Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401 [email protected] Michael R. Tein, Esquire Lewis Tein, P.L. 3059 Grand Avenue Suite 340 Coconut Grove, Florida 33133 [email protected] Robert D. Critton, Jr., Esquire Michael