Epstein Secrets

risdiction of this Court. This case is properly removable because it falls within the original jurisdiction of the United States District Court for the Southern District of Florida. See 28 U.S.C. § 1332(a)(1) (establishing that federal district courts have original I C.M.A. v. Epstein et aL, Case No. 50 2008 CA 005

I C.M.A. v. Epstein et aL, Case No. 50 2008 CA 005240 XXXX MB (Fla. 15th Cir. Ct. filed Feb. 21, 2008). Lewis.tein n. 3059 Gray MINUE, Sum 340, COCONUT GROVE, FLORIDA 33133 14440 EFTA00234068 • Case 9:08-cv-80811-WJZ Document 1 Entered on FLSD Docket 07/21/2008 Page 2 of 40 jurisdiction over cases

ess is .... Ga.," and stating that - S.D.G. is also the unnamed party in a lawsuit filed by her father on her behalf in the U.S. District Court for the Southern District of Florida, Case No. 08-80069, which was filed without the consent of the mother"), In re Sandberg v. Gonzalez, Case No. 50 2008 DR 001141 (Palm Be

gested the unlawful conduct to begin with). See also Turner v. Anderson, 704 So. 2d 748, 751 (Fla. 4th 17 Lewis 'Minn. 3059 G4Atto Amax. Sum 340, COCONUT GROVE, hasp 33133 17 01316 EFTA00234240 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 0721:2008 Page 18 of 100 DCA 1998) (approving reas

mi Field Office ort t iami eac t, 9 Re: Freedoth of Information Act/Privacy Act Request ..Seeking:Documents from a USA° / FBI Investigation in the Southern District of Florida. ! • To Whom it Miy Concern: We write on behalf of our client,ltfaSt, to request certain records under the Freedom of Information Ac

r your courtesy. • • Very truly yours, (DOB (ii (DOB (iv) • ME), (vi (DOB We believe t cse interviews would Un l TCLCOHON; • FACSIMILE COCONUT GROVE, r_OR IDA 33133 • WWW.LEWISTE1N .00 M EFTA01718410 Old 14 - 4VVV VO . 14 Wi n 1/4 4.11;c0 I LS% Oa • I I US. Department of Justice I •

in all courts of the states of Minnesota and Florida, the Eighth, Eleventh, and Federal Circuit Courts of Appeals, and the U.S. District Courts for the Southern District of Florida, the District of Minnesota, and the Northern District of California. My bar admission status in California and Minnesota is currently in

5 561.355.7100 6 On behalf of the Defendant: MICHAEL R. TEIN, ESQ. 7 KATHRYN A. MEYERS, ESQ. LEWIS TEIN, PL 8 3059 GRAND AVENUE, SUITE 340 COCONUT GROVE, FL 33133 9 10 11 12 13 14 On behalf of the Defendant: JACK A. GOLDBERGER, ESQ. ATTERBURY, GOLDBERGER & WEISS 250 AUSTRALIAN AVENUE SOUTH

ress is .... Ga.," and stating that "S.D.G. is also t e unnamed party in a lawsuit filed by her father on her behalf in the U.S. District Court for the Southern District of Florida, Case No. 08-80069, which was filed without the consent of the mother"), In re Sandberg v. Gonzalez Case No. 50 2008 DR 001141 (Palm Bea

5 561.355.7100 6 On behalf of the Defendant: MICHAEL R. TEIN, ESQ. 7 KATHRYN A. MEYERS, ESQ. LEWIS TEIN, PL 8 3059 GRAND AVENUE, SUITE 340 COCONUT GROVE, FL 33133 9 On behalf of the Defendant: 10 JACK A. GOLDBERGER, ESQ. ATTERBURY, GOLDBERGER & WEISS 11 250 AUSTRALIAN AVENUE SOUTH SUITE 1400

l investigation, he has not been charged in EFTA00183654 Case 9:08-cv-80736-KAM Document 13 Entered on FLSD Docket 07/15/2008 Page 2 of 8 *el the Southern District of Florida. Title 18, U.S.C., Section 3771(b)(1) provides in pertinent part that, "[i]n any court proceeding involving an offense against a crime v

Florida prosecution in this District, for these offenses shall be deferred in favor of prosecution by 2 Levftvitin". 3059 GlIANO AVM/E.SUITE 340. COCONUT GROVE. FLOIUDA 33133 EFTA00183687 Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 4 of 41 the State of Florida, provided t

ress is .... Ga.," and stating that "S.D.G. is also the unnamed party in a lawsuit filed by her father on her behalf in the U.S. District Court for the Southern District of Florida, Case No. 08-80069, which was filed without the consent of the mother"), In re (Palm Beach Co. Family Ct.) . If this turns out to be th

Florida 33401 5 6 On behalf of the Defendant: MICHAEL R. TEIN, ESQ. 7 KATHRYN A. MEYERS, ESQ. LEWIS TEIN, PL 8 3059 GRAND AVENUE, SUITE 340 COCONUT GROVE, FL 33133 9 On behalf of the Defendant: 10 JACK A. GOLDBERGER, ESQ. ATTERBURY, GOLDBERGER & WEISS 11 250 AUSTRALIAN AVENUE SOUTH SUITE 1400

ess is .... Ga.," and stating that "S.D.G. is also the unnamed party in a lawsuit filed by her father on her behalf in the 11.5. District Court for the Southern District of Florida, Case No. 08-80069, which was filed without the consent of the mother"), In re v. Case No. 50 2008 DR 001141 (Palm Beach Co. Family Ct

5 561.355.7100 6 On behalf of the Defendant: MICHAEL R. TEIN, ESQ. 7 KATHRYN A. MEYERS, ESQ. LEWIS TEIN, PL 8 3059 GRAND AVENUE, SUITE 340 COCONUT GROVE, FL 33133 9 On behalf of the Defendant: 10 JACK A. GOLDBERGER, ESQ. ATTERBURY, GOLDBERGER & WEISS 11 250 AUSTRALIAN AVENUE SOUTH SUITE 1400

ion into allegations arising out of the same incidents alleged in the instant action (Grand Jury No. 07-103 (WPB), United States District Court for the Southern District of Florida) ("the Federal Criminal Action"). In September 2007, the USAO and Mr. Epstein entered into a highly unusual and unprecedented deferred-

d States I Brown, 526 F.3d 691, 705 (11th Cir. 2008) (definition of "knowingly" in criminal statute). 10 LesyrA rtsin n. 3039 GU MP AMAXSIMI 340, COCONUT GROVE. RONDA 33133 EFTA00233841 Case 9:08-cv-80811-KAM Document 33 Entered on FLSD Docket 01/07/2009 Page 12 of 41 III. Section 3509(k) Applies Eve