Epstein Secrets

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 Epstein's motion to stay. 4. To avoid

that this motion, in accordance with S.D. Fla. L.R. 5.4, has not been served on opposing counsel and was filed under seal on July 10, 2008. Wi cs Michael R. Thin 4 EFTA00222631 Case 9:08-cv-80232-KAM Document 19 Entered on FLSD Docket 07,17.2008 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRI

irEELSEXDO:0810=071301:6agPagef716f 17 Following the signing of the Non-Prosecution Agreement and the modifications thereto by the U.S. Attorney's Office for the Southern District of Florida, Epstein received an unusual benefit that the Government does not ordinarily provide to other criminal defendants: his performance was delayed whit

tate to call me if you wish farther clarification of our position or to discuss this matter in any way. Until then, I remain, • Very truly yours, Michael R. Thin cc; Jack Goldberger, Esq. 08-80736-CV-MARRA RFP WPB 000547 ••• • •I•MPISIM EFTA00185097 Case 9:08-cv-80736-KAM Document 362-52 Entered on F

e No. 2006 CF 09454, Fifteenth Judicial Circuit, Palm Beach County) (the "Florida Criminal Actiont Shortly thereafter, the United States Attorney's Office for the Southern District of Florida (the "USAO") began a federal grand-jury investigation into allegations arising out of the same incidents alleged in the instant actions (Grand Jury

8-80119-CIV-MARRA/JOHNSON Respectfully submitted, LEWIS TEIN, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, Florida 33133 Tel: Fax: By: /s/ Michael R. Thin GUY A. LEWIS MICHAEL R. TEIN ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Palm Florida 33401 Tel.