Epstein Secrets

s and Elton John to President Clinton, Princess Diana and Martha Stewart. 'He was our hero: the man

er filled the ritzy Manhattan restau- rant's kitchen for 36 years. He served guests from Jacqueline Onassis and Elton John to President Clinton, Princess Diana and Martha Stewart. 'He was our hero: the man we always turned to when we knew we had to achieve the impossible," Mr. Albin said a statement r

th to do so today. "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 the right to have these documents unsealed," wrote former Circuit Judge Bill Berger, now in private practice and representing one of the women.

EFTA_00204530 EFTA02729515 SPENCER T. KUVIN DIANA L. MARTIN LEOPOLD-KUVIN, P.A. 2925 PGA Boulevar

'S MOTION TO DISIMISS PETITION FOR LACK OF JURISDICTION Petitioner, JEFFREY EPSTEIN, replies to the three separate responses filed by respondents, E.W., B.B., and the Post, and responds to E.W.'s Request to Dismiss Petition for Lack of Jurisdiction as follows: The non-prosecution agreement and adde

agreement and addendum is confidential by its terms. Mr. Epstein directs this Court to review paragraph 13 of the sealed non-prosecution agreement. E.W.'s argument is also disingenuous. EW has had the non-prosecution agreement for months, yet never advanced this position in federal or state court un

t. NOTICE OF APPEARANCE PLEASE TAKE NOTICE that Diana L. Martin of the law firm of LEOPOLD—KUVIN, P.A.

was entitled to see the nonprosecution agreement in cases other than the one immediately before it. Back in state court, one of Epstein's victims, E.W., intervened in the criminal case and moved to vacate the order sealing the nonprosecution agreement. (A-10). E.W. argued that the agreement was imp

that it is pointless to keep the document sealed in state court. (A-11, p. 4). The trial court held a hearing on the motions to intervene filed by E.W. and the Post. (Respondent B.B.'s Appendix ("RA")). The judge advised the parties that it did not appear the proper procedures were followed with re

sel for respondents (William J. Berger for E.W.; Diana L. Martin for B.B.; and Deanna K. Shullman for th

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-~

le, FL 33301 Counsel for E.W. SPENCER T. KUVIN DIANA L. MARTIN LEOPOLD-KUVIN, P.A. 2925 PGA Boulevar

LLATE ATTORNEY'S FEES AND COSTS Petitioner, JEFFREY EPSTEIN, responds to the Motions for Appellate Attorneys' Fees and Costs filed by respondents, E.W., B.B., and Palm Beach Newspapers d/b/a The Palm Beach Post ("the Post"). This Court should deny the motions for appellate fees and costs for the fo

sel for respondents (William J. Berger for E.W.; Diana L. Martin for B.B.; and Deanna K. Shullman for 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 09/12/2019 CONFIDE