Epstein Secrets

se cases involving Epstein); b. Reached agreements to share attorneys fees with non-lawyers; c. Used investor money to pay plaintiffs (i.e., L.M., E.W. and Jane Doe) "up front" money such that plaintiffs would refuse to settle the Civil Actions; d. Conducted searches, wiretaps or intercepted conver

ed she worked at eleven (11) separate strip clubs, including Cheetah which RRA represented and in which ROTHSTEIN may have owned an interest; and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescriptio

plicable through Title 28, United States Code, Section 2461; and the procedures outlined at Title 21, United States Code, Section 853. " 1. 0#0.10 JEFFREY H. SLOMAN ACTING UNITED STATES ATTORNEY PAUL F. SCHWARTZ ASSISTANT UNITED STATES ATTORNEY FERE N. KAPLAN ASSIS ANT UNITED STATES ATTORNEY A CE D. eaV -CO

order compelling disclosure of a confidential federal non-prosecution agreement and addendum, pursuant to motions to unseal, filed by non-parties, E.W., B.B. and Palm Beach Newspapers d/b/a The Palm Beach Post ("the Post"),I The confidential federal non-prosecution agreement and addendum between th

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

00204381 EFTA02729367 I HEREBY CERTIFY that a copy of the foregoing has been sent by E-Mail and Federal Express this 3o.t.day of June, 2009, to: JEFFREY H. SLOMAN U.S. Attorney's Office-Southern District 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 WILLIAM J. BERGER ROTHSTEIN ROSENFELDT

'S MOTION TO DISIMISS PETITION FOR LACK OF JURISDICTION Petitioner, JEFFREY EPSTEIN, replies to the three separate responses filed by respondents, E.W., B.B., and the Post, and responds to E.W.'s Request to Dismiss Petition for Lack of Jurisdiction as follows: The non-prosecution agreement and adde

agreement and addendum is confidential by its terms. Mr. Epstein directs this Court to review paragraph 13 of the sealed non-prosecution agreement. E.W.'s argument is also disingenuous. EW has had the non-prosecution agreement for months, yet never advanced this position in federal or state court un

imes New Roman font. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been sent by mail this Z314-day of July, 2009, to: JEFFREY H. SLOMAN U.S. Attorney's Office-Southern District 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 WILLIAM J. BERGER ROTHSTEIN ROSENFELDT

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

S, P.A. , ES P0S/4 Zwee= awn ar Sam a r • S PITNEY DOWER, 02 1P 0004162054 JUL 08 2009 MAILED FROM ZIP CODE 33401 $ 000.61° 11111111 JEFFREY H. SLOMAN U.S. Attorney's Office-Southern District 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 S.S-14-45:623S '0023 11111111111111,11

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-~

VARGAS, P.A. Counsel for Petitioner By: 4 USLER-WALSH EFTA00233662 KREUSLER-WALSH, COMPIANI BC VARGAS, P.A. 11111111111,11,111 111,11,1 JEFFREY H. SLOMAN U.S. Attorney's Office-Southern District 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 334O:LS623S OO23 IA111111111111 Pt P

LLATE ATTORNEY'S FEES AND COSTS Petitioner, JEFFREY EPSTEIN, responds to the Motions for Appellate Attorneys' Fees and Costs filed by respondents, E.W., B.B., and Palm Beach Newspapers d/b/a The Palm Beach Post ("the Post"). This Court should deny the motions for appellate fees and costs for the fo

Costs filed by E.W., B.B., and the Post. I HEREBY CERTIFY that a copy of the foregoing has been sent by mail this 31-4-4 day of July, 2009, to: JEFFREY H. SLOMAN U.S. Attorney's Office-Southern District 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 WILLIAM J. BERGER ROTHSTEIN ROSENFELDT

ments will be disclosed and there will be no adequate remedy. I 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

le harm will result. I HEREBY CERTIFY that a copy of the foregoing has been sent by E-Mail and Federal Express this 3ccr.4- day of June, 2009, to: JEFFREY H. SLOMAN U.S. Attorney's Office-Southern District 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 WILLIAM J. BERGER ROTHSTEIN ROSENFELDT

ida Bar No. 197701 ROTHSTEIN ROSENFELDT ADLER 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale, FL 33394 Counsel for non-party intervener, E.W. DEANNA K. SHULLMAN Florida Bar No. 0514462 THOMAS, LOCICERO & BRALOW, P.L. 400 North Ashley Drive, Suite 1100 P. O. Box 2602 (33601) Tampa, FL

ar No. 455131 STATE ATTORNEY'S OFFICE-WEST PALM BEACH 401 North Dixie Highway West Palm Beach, FL 33401 Counsel for respondent, State of Florida JEFFREY H. SLOMAN Florida Bar No. 378879 U.S. Attorney's Office—Southern District 500 South Australian Avenue, Suite 400 09/12/2019 Page CONFIDENTIAL Agency to A

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 09/12/2019 CONFIDE

498 EFTA02729483 -enus.......II a.._1-1 I HEREBY CERTIFY that a copy of the foregoing has been sent byAmail this /41zi. day of July, 2009, to: JEFFREY H. SLOMAN U.S. Attorney's Office-Southern District 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 WILLIAM J. BERGER ROTHSTEIN ROSENFELDT