Epstein Secrets

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

granted, and the remedial quality of any such harm. See Perez v. Perez, 769 So. 2d 389, 391 n.4 (Fla. 3d DCA 1999); see also State ex rel. Price v. McCord, 380 So. 2d 1037, 1038 n.3 (Fla. 1980). The trial court agreed that Mr. Epstein had established irreparable harm (A-17:16), denied a 7 EFTA0018064

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

granted, and the remedial quality of any such harm. See Perez v. Perez, 769 M. 2d 389, 391 n.4 (Fla. 3d DCA 1999); see also State ex rel. Price v. McCord, 380 E. 2d 1037, 1038 n.3 (Fla. 1980). The trial court agreed that Mr. Epstein had established irreparable harm (A-17:16), denied a 7 EFTA00231139

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

clude the moving party's likelihood of success on the merits, and the likelihood of harm should a stay not be granted. See State ex rel. Price v. McCord, 380 1.2d 1037 (Fla.1980). During the course of the trial court pro- ceedings, the children had been spending the summer with the Former Husband p

NEY. LAW SUITE 400 250 AUSTRALIAN AVENUE SOUTH WEST PALM BEACH FLO 01-5066 TELEPHONE FAX- 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 of Florida v. Epstein

granted, and the remedial quality of any such harm. See Perez v. Perez, 769 So. 2d 389, 391 n.4 (Fla. 3d DCA 1999); see also State ex rel. Price v. McCord, 380 So. 2d 1037, 1038 n.3 (Fla. 1980). The trial court agreed that Mr. Epstein had established irreparable harm (A-17:16), denied a 7 EFTA0023225

Beach Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of M., Mr. Kuvin, Esq. was present on behalf of 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

clude the moving party's likelihood of success on the merits, and the likelihood of harm should a stay not be granted. See State ex rel. Price v. McCord, 380 So.2d 1037 (Fla.1980). During the course of the trial court pro- ceedings, the children had been spending the summer with the Former Husband