Epstein Secrets

h, FL 33401; R. Alexander Acosta, United States Attorney's Office - Southern District, 500 S. Australian Ave., Ste. 400, West Palm Beach, FL 33401; Barbara Burns, Esq., State Attorney's Office - West Palm Beach, 401 North Dixie Highway, West Palm Beach, FL 33401; Jack Alan Goldberger, Esq., Atterbury Goldber

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

a Wenzel Sent: Friday, June 19, 2009 10:28 AM To: Linda Moberg Cc: Judith Arco Subject: RE: Jeffrey EPSTEIN case nos. 06c1009454 & 08c1009381 Barbara Burns will be handling hearing From: Linda Moberg Sent: Friday, June 19, 2009 7:59 AM To: Barbara Wenzel Cc: Judith Arco Subject: def: Jeffrey EPSTEIN

quy, they were an inducement for defendant to enter into his guilty pleas. They are proper objects of discovery. However, unless they are unsealed, E.W. is unable to obtain them or utilize them in her case. 7. Pursuant to Rule 2.420(dX5), the Court must hold a hearing on this motion in open court.

(Exhibit "C".) 6. It is against public policy for these documents to have been sealed and hidden from public scrutiny. As a member of the public, E.W. has a right to have these documents unsealed. Furthermore, these documents are relevant and material to E.W 's civil action against defendant. As s

50 AUSTRALIAN AVENUE SOUTH WEST PALM BEACH, FLORIDA 33401-5086 TELEPHONE FAX (561) 835-8691 FAX COVER SHEET To: R. Alexander Acosta, Esq. USAO Barbara Burns, Esq. ASAO Bradley J. Edwards, Esq. William J. Berger, Esq. Robert D. Critton, Esq. Spencer T. Kuvin, Esq. Subject: State ofFlorida v. Epstein

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

NG SCRIVENER'S ERROR? 49 :NM CA ) THIS MATTER came before the Court upon the agreement of J c A.Goldberger, Esq., attorney for the Defendant, and Barbara Burns, Esq., Assistant State Attorney, and the Court being otherwise fully apprised of the facts and circumstances therein, it is hereby ORDERED AND ADJU

for respondent, State of Florida) B.B. (non-party intervener) William J. Berger of Rothstein Rosenfeldt Adler (counsel for non-party intervener, E.W.) Honorable Jeffrey J. Colbath (circuit court judge) Barbara J. Compiani of Kreusler-Walsh, Compiani & Vargas, P.A. (appellate counsel for petiti

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

h, FL 33401; R. Alexander Acosta, United States Attorney's Office - Southern District, 500 S. Australian Ave., Ste. 400, West Palm Beach, FL 33401; Barbara Burns, Esq., State Attorney's Office - West Palm Beach, 401 North Dixie Highway, West Palm Beach, FL 33401; Jack Alan Goldberger, Esq., Atterbury Goldber

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-~

ost, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of E.W., Mr. Kuvin, Esq. was present on behalf of B.B., Assistant State Attorney Barbara Bums was present on behalf of the State of Florida. No appearance was filed on behalf of the United States. After giving an opportunity for all parties

Jeffrey Epstein. Ms. Shullman, Esq. was present on behalf of the Palm Beach Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of E.W., Mr. Kuvin, Esq. was present on behalf of B.B., Assistant State Attorney Barbara Bums was present on behalf of the State of Florida. No appearance

opies furnished: R. Alexander Acosta, U.S. Attorney's Office - Southern District 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 Barbara Burns, Esq., State Attorney's Office 401 North Dixie Highway West Palm Beach, FL 33401 William J. Berger, Esq. Bradley .). Edwards, Esq. Rothstein Ros

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

ost, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of E.W., Mr. Kuvin, Esq. was present on behalf of B.B., Assistant State Attorney Barbara Burns was present on behalf of the State of Florida. No appearance was filed on behalf of the United States. After giving an opportunity for all parties

Jeffrey Epstein. Ms. Shullman, Esq. was present on behalf of the Palm Beach Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of E.W., Mr. Kuvin, Esq. was present on behalf of B.B., Assistant State Attorney Barbara Burns was present on behalf of the State of Florida. No appearance

SUITE 1400 250 AUSTRALIAN AVENUE SOUTH WEST PALM BEACH, FLORIDA 33401-5086 TELEPHONE FAX FAX COVER SHEET To: R. Alexander Acosta, Esq. USAO Barbara Burns, Esq. ASAO Bradley J. Edwards, Fsq. William J. Berger, Esq. Robert D. Critton, Esq. Spencer T. Kuvin, Esq. Subject: State of Florida v. Epstein

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

ch Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of M., Mr. Kuvin, Esq. was present on behalf of M., Assistant State Attorney Barbara Burns was present-on behalf-of-the State of Florida; -No appearance was filed on behalf of the United States. After giving an opportunity for all parties

quy, they were an inducement for defendant to enter into his guilty pleas. They are proper objects of discovery. However, unless they are unsealed, E.W. is unable to obtain them or utilize them in her case. 7. Pursuant to Rule 2.420(dX5), the Court must hold a hearing on this motion in open court.