Epstein Secrets

urratarr-Illq.COO1 Re: State v. Epstein Case Nos. 2008CF00938IAXX and 2008CF009454AXX - Division W Dear Judge Colbath, The undersigned represents E.W., a nonparty in these cases. Enclosed is a copy of E.W.'s motion to vacate order sealing records and unseal records. This motion is made pursuant to

8CF00938IAXX and 2008CF009454AXX - Division W Dear Judge Colbath, The undersigned represents E.W., a nonparty in these cases. Enclosed is a copy of E.W.'s motion to vacate order sealing records and unseal records. This motion is made pursuant to the procedure for nonparties set forth in Rule of Judi

ifitWorki Requet: 19-411 09/12/2079 NlVW .iP I -LI W.C.'111 SDNY_GM_00331910 EFTA_00204636 EFTA02729621 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA, CRIMINAL DIVISION STATE OF FLORIDA, vs. JEFFREY EPSTEIN, Defendant. Case Nos.2006-CF9454 AXX 2008-9381C

quy, they were an inducement for defendant to enter into his guilty pleas. They are proper objects of discovery. However, unless they are unsealed, E.W. is unable to obtain them or utilize them in her case. 7. Pursuant to Rule 2.420(dX5), the Court must hold a hearing on this motion in open court.

(Exhibit "C".) 6. It is against public policy for these documents to have been sealed and hidden from public scrutiny. As a member of the public, E.W. has a right to have these documents unsealed. Furthermore, these documents are relevant and material to E.W 's civil action against defendant. As s

IN THE CIRCUIT COURT OF THE F l'EENTH JUDICAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA, CRIMINAL DIVISI01% ca STATE OF FLORIDA, vs. JEFFREY EPSTEIN, Defendant. Case Nos.2006.CF9454 AXX NONPART

33401; Jack Goldberger, attorney for defendant — 250 Australia Ave. So. Suite 1400, West Palm Beach, FL 33401; and William J. Berger, attorney for E.W. — 401 E. Las Olas Blvd., Suite 1650, Ft. Lauderdale, FL 33301 ft'swrdoes'09-22784 cw y. Epsion'EPSTEN O•SEITENG HRG-UNSEAL doc 09/12/2019 Page 81

Agency Reguet: 19-411 A736950 PassPeONFIDENTAt gOV Par.= SDNY_GM_00331864 EFTA 00204590 EFTA02729575 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA, CRIMINAL DIVISION STATE OF FLORIDA, vs. JEFFREY EPSTEIN, Defendant. Case Nos.2006-CF9454 AMC 2008-9381C

s: 1. EW is filed a motion to vacate the agreed order sealing records and to unseal the nonprosecutuion agreement and addendum in this file. Also, E.W. opposed defendant's motion to unseal said records. E.W.'s motion was granted and defendant's was denied at hearing on June 26, 2009. 2. E.W. is en

02 09/12/2019 CONFIDENTIAL Agency to Agency Requet: 19-411 SDNY_GM_00331947 EFTA_00204673 EFTA02729657 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA, CRIMINAL DIVISION STATE OF FLORIDA, vs. JEFFREY EPSTEIN, Defendant. Case Nos.2006-CF9454 AMC 2008-9381C