Epstein Secrets

w York, New York 10013 [212] 335.9000 Attorneys for Respondent /s/ Ramiro A. Honeywell Sworn to me this September 16, 2011 RAMIRO A. HONEYWELL Notary Public State of New York No Qualified in Kings County Commission Expires November 15. 2012 /s/ Howard Daniels Case Name: People v. Epstein EFTA00792607

Uncharged Allegations. 16 C. By Their Improper Attempt to Introduce New Arguments and "Evidence" on Appeal, the People Tacitly Acknowledge That the Lower Court's Order Is Not Supported By the Record 22 III. THE COURT BASED ITS LEVEL 3 DETERMINATION UPON IMPROPER CONSIDERATIONS AND IN VIOLATION OF THE MAND

sound and factual legal basis. CK A. GOLDBERGER, ESQ. WITNESS my hand and seal in the County and State last aforesaid this 11 day of June, 2009. Notary Public State of Fl My Commission Expires EFTA00233585 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnis

tify a Rule 2.420(cX9) Interest that Warrants Closure. 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

aforesaid this 11 day of June, 2009. AI% CHARLENE A. GRIFFITH. N Commission* DO 8130359 1 , Expires may 15, 2013 Aft no, Nor orgrit0 0:40401 Notary Public State of Fl My Commission Expires EFTA00183938 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnis

ify a Rule 2.420(cX9) Interest that Warrants Closure. 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