Case 9:08-cv-80119-KAM Document 37 Entered on FLSD Docket 08/12/2008

Page 1 of 4 JANE DOE NO. 2, VS. JEFFREY EPSTEIN. I JANE DOE NO. 3, vs JEFFREY EPSTEIN. I JANE DOE NO. 4, vs. JEFFREY EPSTEIN. I JANE DOE NO. 5, vs. JEFFREY EPSTEIN. I UNITED STATES DISTRIC OURT SOUTHERN DISTRICT O FLORIDA 08-80119-CIV-~-LRJ rE;:: 2 2008°c I I STE_VEN M. LARll,IORE I I CLE~RK U.S. DIST CT ·-··--§J~.QE£.LA MIIIMI ........ -..__.. . .,. _ __, CASE NO.: 08-80232-CIV-KAM-LRJ CASE NO.: 08-80380-CIV-KAM-LRJ CASE NO.: 08-80381-CIV-KAM-LRJ FILED UNDER SEAL DEFENDANT'S MOTION TO FILE UNDER SEAL Lewis Tein PL 3059 GRAND AVENUE, SUITE 340, COCONL T GROVE, FLORIDA 33133 Case 9:08-cv-80119-KAM Document 37 Entered on FLSD Docket 08/12/2008

Page 2 of 4 Pursuant to Rule 5.4 of the Local Rules of the United States District Court for the Southern District of Florida, defendant Jeffrey Epstein hereby moves to file his reply to plaintiffs' responses to his motions for stay, as well as this motion, under seal, stating as follows: 1. In his reply to plaintiffs' responses to his motions for stay, defendant Jeffrey Epstein refers to a confidential agreement between the United States Attorney's Office for the Southern District of Florida and Jeffrey Epstein. 2. The information contained in the confidential agreement is material to this Court's consideration of defendant's reply to plaintiffs' responses to his motions for stay. 3. To avoid disclosure of confidential material, defendant requests leave to file his reply to plaintiffs' responses to his motions for stay, and this motion, under seal. 4. We recognize that this Court has previously unsealed documents referring to this same agreement. We mean in no way to disregard that order, but seek merely to comply with the confidentiality clause in that agreement for this new and independent filing, in an abundance of caution, until directed otherwise by the Court. WHEREFORE, defendant Jeffrey Epstein respectfully requests leave to file this motion and his reply to plaintiffs' responses to his motions for stay, under seal. Respectfully submitted, LEWIS TEIN, P.L. 3059 Grand A venue, Suite 340 Coconut Grove, Florida 33133 Tel: 3054421101 Fax: 305 442 6744 2 Lewis Tein P1. 3059 GRAND AVENUE, SUITE 340, COCONL T GROVE, FLORIDA 33133 Case 9:08-cv-80119-KAM Document 37 Entered on FLSD Docket 08/12/2008

Page 3 of 4 By: GUY A. LEWIS Fla. Bar No. 623740 [email protected] MICHAEL R. TEIN Fla. Bar No. 993522 [email protected] ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian A venue South, Suite 1400 West Palm Beach, Florida 33401 Tel. 561 659 8300 Fax. 561 835 8691 By: Jack A. Goldberger Fla. Bar No. 262013 [email protected] CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1 Undersigned counsel has conferred in good faith with counsel for the plaintiff, who opposes the relief requested in this motion. ~kM- Michael R. Tein CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing document is being served this day, July 28, 3 Lewis Tein PL 3059 GRAND A \'ENUE, SUITE 340, CO<-ONL I' GROVE, FLORIDA 33133 Case 9:08-cv-80119-KAM Document 37 Entered on FLSD Docket 08/12/2008