Epstein Secrets

340 EFTA02729326 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via U.S. Mail to: Hon. Jeffrey Colbath, Palm Beach County Courthouse, 205 N. Dixie Highway, Room 11F, West Palm Beach, FL 33401; R. Alexander Acosta, United States Attorney's Office - So

fact, the U.S. Attorney's Office has taken no position on this matter throughout the lower court proceedings and specifically informed counsel for E.W. that it had no position (A-18 at p. 7,11. 10-14.) At that hearing, the Court found that the proper procedures to initially seal the records were not

Inc. d/b/a The Palm Beach Post ("the Post") its attorneys' fees and costs in responding to this petition. JURISDICTION The Post adopts Respondent E.W.'s statement concerning jurisdiction. Insofar as this Court finds jurisdiction, the Post requests that this Court expedite its consideration of this

FLORIDA 33401.5913 JANE KREU5LER-wALSH BARBARA J. COMPIANi REBECCA MERCIER VARGAS BOARD CERTIFIED APPELLATE LAWYERS By Hand Delivery Honorable Jeffrey Colbath Palm Beach County Courthouse Fifteenth Judicial Circuit 205 North Dixie Highway, Room 11F West Palm Beach, FL 33401 June 30, 2009 Re: Epstein

order compelling disclosure of a confidential federal non-prosecution agreement and addendum, pursuant to motions to unseal, filed by non-parties, E.W., B.B. and Palm Beach Newspapers d/b/a The Palm Beach Post ("the Post"),I The confidential federal non-prosecution agreement and addendum between th

ith notice to the United States, the other party to the Agreement. (A-6). Rather than seeking relief from Judge Marra in federal court, non- party E.W., a victim of Mr. Epstein, filed a motion in the state criminal action on May 12, 2009, seeking to intervene and unseal the non-prosecution agreemen

Palm Beach, Fl 33401 Judith Stevenson Arco State Attorney's Office- West Palm Beach 40I North Dixie Highway West Palm Beach, Fl 33401 Honorable Jeffrey Colbath Palm Beach County Courthouse 205 North Dixie Highway Room 11F West Palm Beach. Fl 33401 09112/2019 Pal; 3497 CONFIDENTIAL Agency to Agency Req

8 CF 9381 JEFFREY EPSTEIN, Petitioner, STATE OF FLORIDA, et. al, Respondents. E.W.'S MOTION TO FILE PORTION OF RESPONSE UNDER SEAL Respondent, E.W., moves to file under seal a portion of her response (dealing with this Court's lack of jurisdiction) to the petition for writ of certiorari, on the

hereto in the sealed envelope, E.W. discusses page-by-page the sealed document, the Non-Prosecution Agreement. Public disclosure of this portion of E.W.'s response would violate this Court's order staying disclosure of the NPA. For this reason, E.W. moves to file the attached under seal. Copies of

(A-18:26). In a further attempt to avoid the comity issue, E.W. argues that "Judge Marra expressly authorized the lower court, the Honorable Judge Jeffrey Colbath, to resolve the issue of whether the state court records should be unsealed" at the June 12, 2009 hearing on Mr. Epstein's renewed motion to stay t

'S MOTION TO DISIMISS PETITION FOR LACK OF JURISDICTION Petitioner, JEFFREY EPSTEIN, replies to the three separate responses filed by respondents, E.W., B.B., and the Post, and responds to E.W.'s Request to Dismiss Petition for Lack of Jurisdiction as follows: The non-prosecution agreement and adde

agreement and addendum is confidential by its terms. Mr. Epstein directs this Court to review paragraph 13 of the sealed non-prosecution agreement. E.W.'s argument is also disingenuous. EW has had the non-prosecution agreement for months, yet never advanced this position in federal or state court un

Rothstein Rosenjeldt Adler At torneys at Law May 12, 2009 BY HAND DELIVERY Honorable Jeffrey Colbath Palm Beach County Courthouse Main Courthouse 205 N. Dixie Hwy, Room 11.2213 West Palm Reach, FL 33401 William J. Berger Attorney 91Hrlurratarr

urratarr-Illq.COO1 Re: State v. Epstein Case Nos. 2008CF00938IAXX and 2008CF009454AXX - Division W Dear Judge Colbath, The undersigned represents E.W., a nonparty in these cases. Enclosed is a copy of E.W.'s motion to vacate order sealing records and unseal records. This motion is made pursuant to

8CF00938IAXX and 2008CF009454AXX - Division W Dear Judge Colbath, The undersigned represents E.W., a nonparty in these cases. Enclosed is a copy of E.W.'s motion to vacate order sealing records and unseal records. This motion is made pursuant to the procedure for nonparties set forth in Rule of Judi

25 EFTA00233637 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via U.S. Mail to: Hon. Jeffrey Colbath, Palm Beach County Courthouse, 205 N. Dixie Highway, Room 11F, West Palm Beach, FL 33401; R. Alexander Acosta, United States Attorney's Office - So

not a record of the federal court. (A-6) ("First, as respondent points out, the Agreement was not filed in this 10 The Post adopts and incorporates E.W.'s arguments and analysis on this issue in addition to the arguments it sets forth herein. " The Post notes that A-3 through A-5 were not part of th

at the reply is due 10 days from service of the last-filed response. Opposing counsel has contacted counsel for respondents (William J. Berger for E.W.; Diana L. Martin for B.B.; and Deanna K. Shullman for the Post), who have all advised they have no objection to this motion. 2 EFTA00233660 -Q-~

followed and that "good cause exists for unsealing the documents because of their public significance." (A-11:3). Fifteenth Judicial Circuit Judge Jeffrey Colbath heard E.W.'s and The Post's motions in the state criminal action on June 10, 2009 (A-13). The court granted both motions to intervene, but deferred

ments will be disclosed and there will be no adequate remedy. I Petitioner, Jeffrey Epstein is referred to by proper name. Non-party interveners, E.W., B.B. and The Post are referred to as E.W., B.B. and The Post. All emphasis is supplied unless indicated otherwise. The following symbol is used: A

Palm Beach, Fl 33401 Judith Stevenson Arco State Attorney's Office- West Palm Beach 401 North Dixie Highway West Palm Beach, Fl 33401 Honorable Jeffrey Colbath Palm Beach County Courthouse 205 North Dixie Highway Room 11F West Palm Beach. Fl 33401 09/12/2019 3 age 3430 CONFIDENTIAL Agency to Agency

CF 9381 JEFFREY EPSTEIN, Petitioner, STATE OF FLORIDA, et. al, Respondents. E.W.'S MOTION FOR APPELLATE ATTORNEYS FEES AND COSTS Respondent, E.W., moves pursuant to Administrative Rule 2.303 of the Circuit Court for the Fifteenth Judicial Circuit (copy attached) for appellate attorneys fees a

with him and now are seeking damages. Attorneys for some ofthose women want his agreement with federal prosecutors unsealed and will ask CircuitJudge Jeffrey Colbath to do so today. "It.is against public policy for these documents to be have been sealed and hidden from public scrutiny. As a member of the public, E

h to do so today. "It.is against public policy for these documents to be have been sealed and hidden from public scrutiny. As a member of the public, E.W. has a right to have these documents unsealed," wrote former CircuitJudge Bill Berger, now in private practice-and representing one ofthe women. The P