Epstein Secrets

BRALOW 400 N. Ashley Drive,Suite I100.Tampa, FL 33602 813.984.3060 (Phone)e813.984-3070 (Fax) Toll Free: 866-395-7100 facsimile transmittal To: Marilyn, Judicial Assistant to Judge FAX Colbath R. Alexander Acosta, Esq., USAO Barbara Burns, Esq., ASAO Jack Alan Goldberger, Esq. Bradley J. Edward

cuments will be disclosed and there will be no adequate remedy. 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

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

8 USAO WEB CONFRM 07-20-'09 14:21 FROM-THOMAS 8. LOCICERO 8139843070 T- 113 FIJW1/10t9246/ THOMAS LOCI CERO BRALOW facsimile transmittal To: Marilyn, -Judicial Assistant to Judge Colbath _R. Alexander Acosta, Esq., USAO PAX 561-355-1616 (561) 820-8777 Barbara Burns, Esq., ASAO (561) 355-735

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-~

Edwards, Esq. (954) 527.8663 William J. Berger, Esq. From: Deanna K. Shullman, Esq. Date: 06/04/2009 Re: State v. J. Epstein Pages: 6 Cc: Marilyn Judicial Assistant to Judge 561.355-1616 Colbath T-995 F001/023 F-849 Urgent O For review n Please comment-O Please see attached Motion to Int

s: 1. EW is filed a motion to vacate the agreed order sealing records and to unseal the nonprosecutuion agreement and addendum in this file. Also, E.W. opposed defendant's motion to unseal said records. E.W.'s motion was granted and defendant's was denied at hearing on June 26, 2009. 2. E.W. is en

/005 F-889 THOMAS LOCICERO BRALOW 400 N. DriveeSuite 1100•Tam a FL 33602 (Phone) (Fax) Toll Free: 866.395-7100 L facsimile transmittal To: Marilyn, Judicial Assistant to Judge FAX 561-355-1616 Colbath R. Alexander Acosta, Esq., USAO Barbara Burns, Esq., ASAO Jack Alan Goldberger, Esq. Bra

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