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as follows: 1. In his reply to plaintiffs' responses to his motions for stay, defendant Jeffrey Epstein refers to a confidential agreement between the United States Attorney's Office for the Southern District of Florida and Jeffrey Epstein. 2. The information contained in the confidential agreement is material to this Court's
espectfully requests leave to file this motion and his reply to plaintiffs' responses to his motions for stay, under seal. Respectfully submitted, LEWIS TEIN, P.L. 3059 Grand A venue, Suite 340 Coconut Grove, Florida 33133 Tel: 3054421101 Fax: 305 442 6744 2 Lewis Tein P1. 3059 GRAND AVENUE, SUITE 3
1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein, if any
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
defendant has herewith filed 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 Ep
Page: EFTA00013565 →uests leave to file this motion and his Notice of Continued Pendency of Federal Criminal Action, ex parte and under seal. Respectfully submitted, LEWIS TEIN, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, Florida 33133 Tel: 305 442 1101 Fax: 305 442 6744 By: GUY A. LEWIS Fla. Bar No. 623740 MICHA
Page: EFTA00013566 →Entities connected to both U.S. Attorney's Office and Lewis Tein

Jeffrey Epstein
PERSONJack Goldberger
PERSONJane Doe
PERSON
Ghislaine Maxwell
PERSONCoconut Grove
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSON
Alexander Acosta
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Bradley Edwards
PERSONMichael R. Tein
PERSONRobert D. Critton
PERSON
Paul Cassell
PERSONSouthern District of Florida
LOCATIONMartin Weinberg
PERSONFBI
ORGANIZATIONMichael J. Pike
PERSON
A. Marie Villafana
PERSON