Epstein Secrets

ERTIFY that this motion, in accordance with S.D. Fla. L.R. 5.4, has not been served on opposing counsel and was filed under seal on July I0, 2008. Michael R. Tein 4 EFTA00222330

a Notice of Continued Pendency of Federal Criminal Action. 2. The Notice relates to a confidential agreement between the United States Attorney's Office for the Southern District of Florida and the defendant. 3. The information contained in the Notice is material to this Court's consideration of Epstein's motion to stay. 4. To avoid

berger, Esquire Atterburty, Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401 [email protected] Michael R. Tein, Esquire Lewis Tein, P.L. 3059 Grand Avenue Suite 340 Coconut Grove, Florida 33133 [email protected] Robert D. Critton, Jr., Esquire Michael

d on FLSD Docket 08/C )8 Page 6 of 16 Following the signing of the Non-Prosecution Agreement and the modifications thereto by the U.S. Attorney's Office for the Southern District of Florida, Epstein received an unusual benefit that the Government does not ordinarily provide to other criminal defendants: his performance was delayed whil

5). I believe there was one other meeting soon after Epstein entered his guilty plea, when I went to Jack Goldberger's office and met with him and Mike Tein (Guy Lewis' law partner) about the victim list. Other than that, I do not recall any in-person meetings. I had a couple of telephone conversations

continued secrecy; and (5) the request is structured to cover only the needed materials. EFTA00225479 Accordingly, the United States Attorney's Office for the Southern District of Florida, including Assistant United States Attorney A. Marie Villafafia, and the Justice Department's Office of Professional Responsibility may disclose to