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United States Code. 3. Subsequent to filing his Motion for Stay on July 1, 2008, Defendant Epstein filed a Notice advising this Court that the State Court criminal action against the Defendant was resolved, but that the federal criminal proceeding remained pending. It is Plaintiff’s counsel’s understa
United States District Court, Southern District of Florida Jack Alan Goldberger [email protected] Michael R. Tein [email protected] /s/ Adam D. Horowitz Case 9:08-cv-80119-KAM Document 18 Entered on FLSD Docket 07/1
ein was taking I consistent position with the State Attorney's Office, Judge McSorley, and the USAO, so I asked for I copy of what was filed in the State Court. This led to multiple letters with counsel for Epstein before I could finalize the victim notification letters (Exhibits B-57 through B-65). On July
5). I believe there was one other meeting soon after Epstein entered his guilty plea, when I went to Jack Goldberger's office and met with him and Mike Tein (Guy Lewis' law partner) about the victim list. Other than that, I do not recall any in-person meetings. I had I couple of telephone conversations
only the instant claim, but for six (6) other claims filed against Defendant EPSTEIN, including but not limited to the Florida RICO claims filed in State Court. WHEREFORE, Plaintiff respectfully request the Court grant her Motion to Preserve of all of the seized Evidence identified in Ex. A, to Exhibit 1 o
, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 202-6360 Fax: (561) 828-0983 Counsel for Sarah Kellen Served via U.S. Mail, postage prepaid Michael R. Tein, Esq. Email: [email protected] Lewis Tein 3059 Grand Avenue, Suite 340 Coconut Grove, FL 33133 Phone: (305)442-1101 Fax: (305) 442-6744 Couns
Epstein Well, our friend Jack Goldberger (probably really Mike Tein) is trying to be very smart. They have filed a Motion for Return of Property in State Court. The State Attorney will, no doubt, file a response saying, "we don't have it, the FBI took it pursuant to a federal grand jury subpoena." Then, Eps
LS); Lee, Dexter (USAFLS) Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Epstein Well, our friend Jack Goldberger (probably really Mike Tein) is trying to be very smart. They have filed a Motion for Return of Property in State Court. The State Attorney will, no doubt, file a response say
pstein Well, our friend Jack Goldberger (probably really Mike Tein) is trying to be very smart. They have filed a Motion for Return of Property in State Court. The State Attorney will, no doubt, file a response saying, "we don't have it, the FBI took it pursuant to a federal grand jury subpoena." Then, Ep
AFLS) Cc: Kuyrkendall, E N.; Richards, Jason R. Sent: Mon Jul 21 15:46:54 2008 Subject: Epstein Well, our friend Jack Goldberger (probably really Mike Tein) is trying to be very smart. They have filed a Motion for Return of Property in State Court. The State Attorney will, no doubt, file a response sa
Epstein Well, our friend Jack Goldberger (probably really Mike Tein) is trying to be very smart. They have filed a Motion for Return of Property in State Court. The State Attorney will, no doubt, file a response saying, "we don't have it, the FBI took it pursuant to a federal grand jury subpoena." Then, Eps
LS); Lee, Dexter (USAFLS) Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Epstein Well, our friend Jack Goldberger (probably really Mike Tein) is trying to be very smart. They have filed a Motion for Return of Property in State Court. The State Attorney will, no doubt, file a response say
Epstein Well, our friend Jack Goldberger (probably really Mike Tein) is trying to be very smart. They have filed a Motion for Return of Property in State Court. The State Attorney will, no doubt, file a response saying, "we don't have it, the FBI took it pursuant to a federal grand jury subpoena." Then, Eps
LS); Lee, Dexter (USAFLS) Cc: Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Epstein Well, our friend Jack Goldberger (probably really Mike Tein) is trying to be very smart. They have filed a Motion for Return of Property in State Court. The State Attorney will, no doubt, file a response say
papers have been filed. In accordance with 28 U.S.C. § 1446(d), defendants have served this Notice of Removal on July 18, 2008. All papers filed in State Court are attached to this Removal Petition. 3. There is unanimity among the defendants. In accordance with 28 U.S.C. § 1446(6) the undersigned are auth
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
30, #32, and #38 7/21/2008 Villafaiia; cc: Senior Sloman Email response to Vilkfaiia's 7/21/08 email regarding Motion for Return of Property in State Court 7/22/2008 Villafaiia K tz% rkcndall Email chain regarding victim addresses 7/22/2008 Emails between A. M. Vitiate's, A. Acosta, J. Sloman, R. S
5). I believe there was one other meeting soon after Epstein entered his guilty plea, when I went to Jack Goldberger's office and met with him and Mike Tein (Guy Lewis' law partner) about the victim list. Other than that, I do not recall any in-person meetings. I had a couple of telephone conversations
Entities connected to both State Court and Michael R. Tein

Jeffrey Epstein
PERSONJack Goldberger
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
A. Marie Villafana
PERSON
Alexander Acosta
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
United States
LOCATIONCoconut Grove
LOCATION
Department of Justice
ORGANIZATION
Lewis Tein
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Jeffrey Marc Herman
PERSON
Jeffrey Sloman
PERSON
George W. Bush
PERSON
Scarlett Johansson
PERSONRobert D. Critton
PERSON
Dexter Lee
PERSON