Epstein Secrets

11 BEFORE THE HONORABLE KENNETH A. MARRA, UNITED STATES DISTRICT JUDGE 12 APPEARANCES: 13 FOR THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. 14 Mermelstein & Horowitz 18205 Biscayne Boulevard 15 Miami, FL 3

GOLDBERGER: Good morning, Your Honor. Jack 6 Goldberger on behalf of Mr. Epstein. 7 THE COURT: I see we have some representatives from 8 the United States Attorney's Office here. 9 MS. VILLAFANA: Good morning, Your Honor. Ann Marie 10 Villafana for the U.S. Attorney's office. 11 THE COURT: Good morni

knew it. 2 He appears to be having second thoughts now about he 3 could have negotiated this way or he could have negotiated that 4 way with the U.S. Attorney's Office. And they want to impose 5 their second thoughts on the innocent plaintiffs. We don't 6 think that's fair. We think it's in the nature of invited

33133 Case 9:08-cv-80119-KAM Document 37 Entered on FLSD Docket 08/12/2008 Page 4 of 4 Jeffrey M. Herman, Esq. Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Herman & Mermelstein, P.A. 18205 Biscayne Blvd, Suite 2218 Miami. Florida 33160 Fax: 305 931 0877 Service List 4 Lewis Tein 1'1. " 305

as follows: 1. In his reply to plaintiffs' responses to his motions for stay, defendant Jeffrey Epstein refers to a confidential agreement between the United States Attorney's Office for the Southern District of Florida and Jeffrey Epstein. 2. The information contained in the confidential agreement is material to this Court's

foregoing was served on July 28, 2008 by U.S. mail on all counsel named on the service list. Jeffrey M. Herman, Esq. Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Herman & Mermelstein, P.A. 18205 Biscayne Boul,~vard, Suite 2218 Miami, Florida 33160 Michael R. Tein SERVICE LIST 12

1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein, if any

is Jd_ day of ¥ , 2009. Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 [email protected]

s Constitution. Moreover, the court recognized that the threat of criminal prosecution is real and present as Epstein remains under the scrutiny of the United States Attorney's Office ("USAO"), which is explained and acknowledged in the Court's Order (DE 242). Recognizing the foregoing, the court has rightfully acknowledged Epst

pecified by CM/ECF on this J_L day of May, 2009: Adam D. Horowitz, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayn

the terms of his Non-Prosecution Agreement with the U.S. Attorney's Office. Defendant relies upon an amorphous - 2 -

80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscay

way or he could have negotiated that 4' way with the U.S. Attorney's Office. And they want to impose 5 their second though

1 TRANSCRIPT OF MOTION HEARING BEFORE THE HONORABLE KENNETH A. MARRA, 12 UNITED STATES DISTRICT JUDGE APPEARANCES: 13 14 FOR THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 15 18205 Biscayne Boulevard Miami, FL 33160 305.931.2200 16 For Jane Doe 17 BRADLEY J. EDWARDS, ESQ. Rothstein

Epstein, or his legal representatives, making statements to the press. And we didn't hear any of those things. So that's what I was expecting that the U.S. Attorney's Office was going to expound on and say, yes, we've made some communications to Epstein. He's violating. What we're hearing right now, today, just so that

stay, which we're all battling here. So I just wanted to indicate to the Court or remind the Court that there have been specific allegations made, the United States Attorney's Office is making these allegations of breach, which we haven't heard any of the evidence of. Thank you. THE COURT: All right. Ms. , did you want to res