Epstein Secrets

3401 oytt. .;:ercA; Alexander Acosta United States Attorne ::1::1:::: 04.5.-IBSCfa513&2 $0.442 C 06/11/2009 Filailtd From334( EFTA00183941 NE PALM BEACH POST THURSDAY, JUNE 11.2009 Judge delays ruling on request to unseal plea deal in sex case By SUSAN SPENCER -WENDEL Palm Beach Post Staff Witter WES

have called it "unprec- edented" and "highly unusual." Goldberger said his cli- ent has not received any special treatment. sm. EFTA00183942 THE PALM BEACH POST • WEDNESDAY, JUNE 10, 2009 Women want sex plea deal unsealed Their attorneys will ask a judge to open Jeffrey Epsteffi's records. By SUSAN SPENCE

the Fifteenth Judicial Circuit in and for Palm Beach County, Florida, Case Nos. 2006 CF 9454AMB, 2008 CF 9381 AMB PALM BEACH NEWSPAPERS, INC. d/b/a THE PALM BEACH Paws RESPONSE TO EMERGENCY PETITION FOR WRIT OF CERTIORARI THOMAS, LoCICERO & BRALOW PL Deanna K. Shullman James B. Lake 101 N.E. 3rd Avenue, Suite 1

pp. 2d 136,140-42 (D.D.C. 2008) (government not prohibited by 23 EFTA00183988 Rule 6 from disclosing plea agreement and other materials); Doe f . Hammond, 502 F. Supp. 2d 94, 99-101(D.D.C. 2007) (same). Moreover, "when the fact or document is sought for itself, independently, rather than because it w

RDS FILED BY BRADLEY EDWARDS, ESQ 64 MOT - MOTION Filing Date: 03-JUN-2009 Filing Party: EPSTEIN, JEFFREY E Disposition Amount: Docket Text: PALM BEACH POST'S MOTION TO INTERVENE AND PETITION FOR ACESS FILED BY DEANNA SHULLMAN, ESQ. EVRST EVENT RESET Filing Date: 10-JUN-2009 Filing Party: EPSTEIN, JEF

ates Attorney's Office Southern District 500 S. Australian Ave. Suite 400 West Palm Beach, Florida 33401 33623+6237" "" "" lid EFTA00233588 THE PALM BEACH POST • THURSDAY, JUNE 11.2009 Judge delays ruling on request to unseal plea deal in sex case By SUSAN SPENCER-WENDEL Palm Beach Post Saill Writer WEST P

A 21 CONCLUSION 25 CERTIFICATE OF SERVICE 26 EFTA00233610 TABLE OF AUTHORITIES Federal Cases Craig I Harney, 331 U.S. 367 (1947) 8 Doe,. Hammond 502 F. Supp. 2d 94 (D.D.C. 2007) 24 In re Grand Jury Investigation of Ven-Fuel, 441 F. Supp. 1299 (M.D. Fla. 1977) 23, 24 Lockhead Martin Corp.

DANIELS,LESLIE B KOCH,DAVID H PALM BEACH RESORT JACOBS,ANTHONY SAY HEY LLC K

2100 CONDO ASSOC INC CLARK,JAMES H HAMMOND,DANA TIGANI JR,JAMES V NEDERLANDER,

criminal activity came to light when stepmother learned of a fight between and a friend at school over $300 cash found in purse. cooperated with the Palm Beach Police and made recorded telephone calls with to set up a second "massage" with Epstein. Handwritten notes were found in Epstein's trash confirming this

as potential loss of their c property. See generally United tates I Noriega-Sarabia, 116 F.3d 417, 420-21 (9th Cir. 1997). See also United States Hammond, 204 F.Supp.2d 1157, 1166-67 (E.D.Wis. 2002) (sufficiency of the secure y offered). 26.10 Resources The main treatise on federal detention and bai