Epstein Secrets

and the record and is otherwise fully advised in the premises. As stated in the Local Rules for the Southern District of Florida, "proceedings in the United States District Court are public and Court filings are matters of public record." S.D. Fla. L.R. 5.4(A). It is well settled that the media and the public in general posse

JURY DEMAND: O NO VIII. RELATED CASE(S) IF ANY (See Instructicos): (SEE ATTACHED) JUDGE DATE pi . -1,0 46t SIGNATURE OF ATTORNEY OF RECORD UNITED STATES DISTRICT COURT S/F 1.2 REV. 9194 DOCKET NUMBER FOR OFFICE USE ONLY: Receipt No. Amount Date Paid: Wfp: EFTA00222675 Case 9:08-cv-80119-KAM Document 12

ng criminal action derived from the same underlying allegations. See 18 U.S.C. § 3509(k). Discussion The parallel state criminal action pending in Palm Beach Circuit Court is still in the discovery phase. State of Florida v. Jeffi-ey Epstein, Case No. 2006 CF 09454 AXX (Fifteenth Judicial Circuit, Palm Beach County).

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

ION Defendant Jeffrey Epstein's Motion to Stay this action is based on the incorrect premise that there are criminal actions pending against him in Palm Beach Circuit Court, State of Florida. Jeffrey Epstein, Case No. 2006 CF 09454 AXXMB (Fifteenth Judicial Circuit, Palm Beach County), and in the Southern District of F

28 U.S.C. §§ 1441, 1446, and 1332(a)(1), the defendants, Jeffrey Epstein and 1 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: 1. This case is within the original jurisdiction of this Court. This cas

s original jurisdiction over this action pursuant to 28 U.S.C. § 1332(a)(1). WHEREFORE, the defendants, Jeffrey Epstein and remove this case from Palm Beach Circuit Court to the United States District Court for the Southern District of Florida. Respectfully submitted, LEWIS TEIN, P.L. 3059 Grand Avenue, Suite 340

ith 28 U.S.C. §§ 1441, 1446, and 1332(aX1), 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: 1. This case is within the original jurisdiction of this Court. This cas

s original jurisdiction over this action pursuant to 28 U.S.C. § 1332(a)(1). WHEREFORE, the defendants, Jeffrey Epstein and remove this case from Palm Beach Circuit Court to the United States District Court for the Southern District of Florida. Respectfully submitted, LEWIS TEIN, P.L. 3059 Grand Avenue, Suite 340

mmarize any CDM or portions thereof, absent leave of the Court to file the document or portion thereof under seal in accordance with Local Rules of the United States District Court for the Southern District of Florida. See Exhibit 1, Proposed Protective Confidentiality Order. EFTA00191290 Case 9:08-cv-80736-KAM Document 247

2005. Plea bargain The appellate case stems from a decision by federal prosecutors not to charge Epstein if he pleaded guilty to state charges in Palm Beach Circuit Court for soliciting an underage girl for prostitution. He was sentenced to 18 months in jail and house arrest. Epstein moved back to New York City from

and the record and is otherwise fully advised in the premises. As stated in the Local Rules for the Southern District of Florida, "proceedings in the United States District Court are public and Court filings are matters of public record." S.D. Fla. L.R. 5.4(A). It is well settled that the media and the public in general posse

ing criminal action derived from the same underlying allegations. See 18 U.S.. § 3509(k). Discussion The parallel state criminal action pending in Palm Beach Circuit Court is still in the discovery phase. State of Florida'. Jeffrey Epstein, Case No. 2006 CF 09454 AXX (Fifteenth Judicial Circuit, Palm Beach County). Me