N Defendant Jeffrey Epstein’s Motion to Stay this action is based on the incorrect premise that there are criminal actions pending against him in Palm Beach Circuit Court, State of Florida v. Jeffrey Epstein, Case No. 2006 CF 09454 AXXMB (Fifteenth Judicial Circuit, Palm Beach County), and in the Southern District of

ndant Epstein in their pending 3 Case 9:08-cv-80119-KAM Document 145 Entered on FLSD Docket 06/08/2009 Page 3 of 7 actions. In June 2008, Palm Beach Circuit Court Judge Pucillo ordered Defendant Epstein “not to have any contact, direct or indirect,” with any of his victims. Judge Pucillo clarified that forbi

ndirect contact with any victims. See Transcript of Plea Conference at 20. During the course of Defendant’s state plea conference of June 30, 2009, Palm Beach Circuit Court Judge Deborah Dale Pucillio explicitly instructed Defendant as follows: Court: Okay. D is, you shall not have any contact with the victim, are there

fendant's state plea conference of June 30, 2009, Palm Beach Circuit Court Judge Deborah Dale Pucillio explicitly instructe

icial Circuit in and for Palm Beach County, Florida. He was sentenced to 18 months in jail. 3. In the course of the plea/sentencing colloquy, Palm Beach Circuit Court Judge Deborah Dale Pucillio explicitly instructed Defendant as follows: Court: Okay. [Item] D is, you shall not have any contact with the victim,

. In the course of the plea/sentencing colloquy, Palm Beach Circuit Court Judge Deborah Dale Pucillio explicitly instructe

o “direct or indirect contact” with the Plaintiffs. (D.E. 238). 8. The July 31, 2009 Order mirrored the June 30, 2008 criminal sentence entered by Palm Beach Circuit Court Judge Deborah Dale Pucillio, wherein she instructed Jeffrey Epstein that he shall have “no direct or indirect contact” with the Plaintiffs. (D.E. 23

o “direct or indirect contact” with the Plaintiffs. (D.E. 238). The July 31, 2009 Order mirrored the June 30, 2008 criminal court order entered by Palm Beach Circuit Court Judge Deborah Dale Pucillio, wherein she ordered Epstein to have “no direct or indirect contact” with the Plaintiffs. (D.E. 238). 8. The Motions

er sources of media rant the story. The Daily news article read as follows: Palm Beach billionaire Jeffrey Epstein pleaded guilty Monday morning in Palm Beach Circuit Court to felony charges that he solicited underage girls for prostitution. Judge Deborah Dale Pucillo sentenced Epstein, 55, to 18 months at the Palm Bea

Epstein became a convicted sex offender, he was not to have contact with any of his victims. During the course of his guilty pleas on June 30, 2008, Palm Beach Circuit Court Judge Deborah Dale Pucillo ordered Epstein "not to have any contact, direct or indirect" with any victims. She also expressly stated that her no-co

er sources of media rant the story. The Daily news article read as follows: Palm Beach billionaire Jeffrey Epstein pleaded guilty Monday morning in Palm Beach Circuit Court to felony charges that he solicited underage girls for prostitution. Judge Deborah Dale Pucillo sentenced Epstein, 55, to 18 months at the Palm Bea

s original jurisdiction over this action pursuant to 28 U.S.C. § 1332(a)(1). WHEREFORE, the defendants, Jeffrey Epstein and remove this case from Palm Beach Circuit Court to the United States District Court for the Southern District of Florida. Respectfully submitted, LEWIS TEIN, P.L. 3059 Grand Avenue, Suite 340

er sources of media rant the story. The Daily news article read as follows: Palm Beach billionaire Jeffrey Epstein pleaded guilty Monday morning in Palm Beach Circuit Court to felony charges that he solicited underage girls for prostitution. Judge Deborah Dale Pucillo sentenced Epstein, 55, to 18 months at the Palm Bea

to pay the legal tab constitutes "a material breach" of the agreement that allowed Epstein to avoid federal charges and receive a light sentence in Palm Beach Circuit Court, Podhurst attorney Steven Marks said today. After waiting for more than 20 months for Epstein to pay up, the firm had no choice but to file suit, he

Deputy A/G concluded that the U.S. Attorney did not abuse his discretion in pursuing the case. On June 20, 2008, Epstein entered pleas of guilty in Palm Beach Circuit Court, in accordance with the terms of the NPA. On July 7, 2008, Jane Does 1 and 2 filed their CVRA lawsuit. We are seeking responsive emails for the per

represented Jane Doe No. 1 and Jane Doe No. 2. (a) This placed both petitioners on notice that Epstein would be pleading guilty on June 30, 2008, in Palm Beach Circuit Court. I. THE GOVERNMENT DID NOT VIOLATE PETITIONERS' § 3771(a)(2) RIGHT TO REASONABLE, ACCURATE, AND TIMELY NOTICE Supreme Court has repeatedly emphas

ng criminal action derived from the same underlying allegations. See 18 U.S.C. § 3509(k). Discussion The parallel state criminal action pending in Palm Beach Circuit Court is still in the discovery phase. State of Florida v. Jeffi-ey Epstein, Case No. 2006 CF 09454 AXX (Fifteenth Judicial Circuit, Palm Beach County).

tein in their pending 3 EFTA00222249 Case 9:08-cv-80119-KAM Document 145 Entered on FLSD Docket 06)08:2009 Page 4 of 7 actions. In June 2008, Palm Beach Circuit Court Judge Pucillo ordered Defendant Epstein "not to have any contact, direct or indirect," with any of his victims. Judge Pucillo clarified that forbid

ION Defendant Jeffrey Epstein's Motion to Stay this action is based on the incorrect premise that there are criminal actions pending against him in Palm Beach Circuit Court, State of Florida. Jeffrey Epstein, Case No. 2006 CF 09454 AXXMB (Fifteenth Judicial Circuit, Palm Beach County), and in the Southern District of F

ng criminal action derived from the same underlying allegations. See 18 U.S.C. § 3509(k). Discussion The parallel state criminal action pending in Palm Beach Circuit Court is still in the discovery phase. State of Florida v. Jeffi-ey Epstein, Case No. 2006 CF 09454 AXX (Fifteenth Judicial Circuit, Palm Beach County).