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ounty Courhouse 205 North Dixie Highway West Palm Beach, Florida 33401 RE: State of Florida 1 Jeffrey Epstein Case No. 2008 CF009381A Dear Judge Colbath, JOSEPH R.ATTERBURY JACK A. GOLDBERGER JASON S.WEISS Board Certified Oiminallrial Attorney Member of New Jersey & Fonda Bars Enclosed please fi
attorney, Jack Goldberger, an op- portunity to argue that the document was properly sealed and asked lawyers to submit briefs to him by Friday. Colbath also set a full hearing for June 25. Attorneys for young women now suing Epstein are asking Colbath to un- seal the deal that Epstein brokered
pp. 2d 136,140-42 (D.D.C. 2008) (government not prohibited by 23 EFTA00183988 Rule 6 from disclosing plea agreement and other materials); Doe f . Hammond, 502 F. Supp. 2d 94, 99-101(D.D.C. 2007) (same). Moreover, "when the fact or document is sought for itself, independently, rather than because it w
County Courhouse 205 North Dixie Highway West Palm Beach, Florida 33401 RE: State of Florida Jeffrey Epstein Case No. 2008 CF009381A Dear Judge Colbath, JOSEPH R.ATTERBURY JACK A. GOLDBERGER JASON S.WEISS Board Certified Criminal Trial Attorney Member of New Jersey & Florida Bars Enclosed pleas
attorney, Jack Goldberger, an op- portunity to argue that the document was properly sealed and asked lawyers to submit briefs to him by Friday. Colbath also set a full hearing for June 25. Attorneys for young Epstein women now suing Epstein are asking Colbath to un- seal the deal that Epstein b
A 21 CONCLUSION 25 CERTIFICATE OF SERVICE 26 EFTA00233610 TABLE OF AUTHORITIES Federal Cases Craig I Harney, 331 U.S. 367 (1947) 8 Doe,. Hammond 502 F. Supp. 2d 94 (D.D.C. 2007) 24 In re Grand Jury Investigation of Ven-Fuel, 441 F. Supp. 1299 (M.D. Fla. 1977) 23, 24 Lockhead Martin Corp.
ion agreement and addendum is confidential and not a public record. It should remain sealed. Principles of supremacy and comity required that Judge Colbath defer to the federal court, which has twice denied disclosure of the confidential non- prosecution between the U.S. government and Mr. Epstein to th
disclosure of plea agreements that did not reveal the subject of a grand jury investigation. See In re Interested Party I, 530 F. Supp. 2d at 140; Hammond, 502 F. Supp. 2d at 100-01 & n.2. That is not the case here. 13 09112/2019 P CONFIDE CONFIDENTIAL Agency to Agency Requet: 19-411 SDNY_GM_003317
Entities connected to both Colbath and Hammond

Jeffrey Epstein
PERSONJack Goldberger
PERSON
George W. Bush
PERSONJane Doe
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Kenneth Marra
PERSONScott Rothstein
PERSON
Ghislaine Maxwell
PERSON
Marc Rich
PERSONLeon Black
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSONSpencer Kuvin
PERSONRobert D. Critton
PERSON
Alexander Acosta
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSON
Palm Beach County
LOCATION