Epstein Secrets

8 CF 9381 JEFFREY EPSTEIN, Petitioner, STATE OF FLORIDA, et. al, Respondents. E.W.'S MOTION TO FILE PORTION OF RESPONSE UNDER SEAL Respondent, E.W., moves to file under seal a portion of her response (dealing with this Court's lack of jurisdiction) to the petition for writ of certiorari, on the

hereto in the sealed envelope, E.W. discusses page-by-page the sealed document, the Non-Prosecution Agreement. Public disclosure of this portion of E.W.'s response would violate this Court's order staying disclosure of the NPA. For this reason, E.W. moves to file the attached under seal. Copies of

y of the foregoing has been served by mail on the parties listed below this lay of July, 2009. I HEREBY CERTIFY that the foregoing is submitted in Times New Roman 14-point font and complies with the font requirement of Rule 9.100. ROTHSTEIN ROSENFELDT ADLER Attorneys for E.W. 401 East Las Olas Blvd.,

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-~

py of the foregoing has been served by mail on the parties listed below this ay of July, 2009. I HEREBY CERTIFY that the foregoing is submitted in Times New Roman 14-point font and complies with the font requirement of Rule 9.100. ROTHSTEIN ROSENFELDT ADLER Attorneys for E.W. By: W. iam / J. Berge

ATE OF FLORIDA, E.W., THE PALM BEACH POST, B.B, Respondents. E.W.'S SEALED REQUEST TO DISMISS THE PETITION FOR LACK OF JURISDICTION Respondent, E.W., would show the Court as follows: 1. This Court lacks jurisdiction to hear this petition. The order under review is a non-final order for which no

of the foregoing has been served by mail on the parties listed below this 1 day of July, 2009. I HEREBY CERTIFY that the foregoing is submitted in Times New Roman 14-point font and complies with the font requirement of Rule 9.100. ROTHSTEIN ROSENFELDT ADLER Attorneys for E.W. 50 Willia; J. verger SE