Epstein Secrets

2002) (relying on Black's Law Die tionary, in the contexi: of a criminal case, for the definition of ''pending" as ··awaiting decision"); Swartz v. Meyers, 204 F.3d 417, 421 (3d Cir. 2000) (relying on Black's Law Dictionary for the definition of "pending,'' expressly because '"pendi :1g' is not defined

ction is no longer pending. Case 9:08-cv-80119-KAM Document 38 Entered on FLSD Docket 08/12/2008 Page 12 of 13 By: Respectfully submitted, LEWIS TEIN, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, Florida 33133 Tel: 305 442 1101 Fax: 305 442 6744 GU'l'd.~ Fla. Bar No. 623740 lewis@lewistei

Cir. 2002) (relying on Black's Law Dictionary, in the context of a criminal case, for the definition of "pending" as "awaiting decision"); Swam v. Meyers, 204 F.3d 417, 421 (3d Cir. 2000) (relying on Black's Law Dictionary for the definition of "pending," expressly because "'pendi,g' is not defined in

uth Suite 1400 West Palm Beach, FL 33401-5012 561-659—8300 Fax: 835-8691 Email: [email protected] ATTORNEY TO BE NOTICED Michael Ross Tein Lewis Tein 3059 Grand Avenue Suite 340 EFTA00222692 Case 9:08-cv-80-OSsKA108-Eraelrleit 2Ae2of: CatliadethollIDIEIMEN07/11156138 Page 2 of 3 Coconut Grov

n August 21, 2008, counsel for the plaintiff called Kathryn Meyers, Esq. of the Lewis Tein law firm to elicit Epstein's position on this motion. Ms. Meyers responded that she would confer with Mr. Tein and call them back. Less than thirty minutes later, however, plaintiff's counsel - - without waiting

E 12 at 2 (emphasis added). That certification is inaccurate. 2. On August 21, 2008, counsel for the plaintiff called Kathryn Meyers, Esq. of the Lewis Tein law firm to elicit Epstein's position on this motion. Ms. Meyers responded that she would confer with Mr. Tein and call them back. Less than thirty