Epstein Secrets

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

Inc. d/b/a The Palm Beach Post ("the Post") its attorneys' fees and costs in responding to this petition. JURISDICTION The Post adopts Respondent E.W.'s statement concerning jurisdiction. Insofar as this Court finds jurisdiction, the Post requests that this Court expedite its consideration of this

. 16 2. The Federal Court's Decisions in Case No. 08-80736 (S.D. Fla. 2008) Did Not Preclude the Lower Court's Orders Unsealing the NPA. 19 3. Federal Rule of Criminal Procedure 6 Did Not Preclude the Lower Court's Orders Unsealing the NPA 21 CONCLUSION 25 CERTIFICATE OF SERVICE 26 Page 3188 CONFIDENTIAL 09/12/2019 Ag

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

re. 16 2. The Federal Court's Decisions in Case No. 08-80736 (S.D. Fla. 2008) Did Not Preclude the Lower Court's Orders Unsealing the NPA. 19 3. Federal Rule of Criminal Procedure 6 Did Not Preclude the Lower Court's Orders Unsealing the NPA 21 CONCLUSION 25 CERTIFICATE OF SERVICE 26 EFTA00233610 TABLE OF AUTHORITIES Fe

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-~

— expressly noting lack of conflict with Judge Marra's orders) and did not depart from the essential requirements of law in unsealing the NPA. 3. Federal Rule of Criminal Procedure 6 Did Not Preclude the Lower Court's Orders Unsealing the NPA.t3 Finally, unsealing the NPA did not conflict with federal law. Records available unde