cr S DATE: June 25, 2009 RE: Epstein: Motion to Stay You asked me to provide you with a brief summary of the law regarding stays pending appeal. Florida Rule of Appellate Procedure 9.310(a) allows the trial court to stay an order pending appeal. Whether to grant a stay is discretionary with the trial court. See Pabia

203882 62 1SE 5th Street Pompano Beach, FL 33060 Phone: EFTA00792300 CERTIFICATE OF COMPLIANCE I HEREBY CERTIFY that this brief complies with Florida Rule of Appellate Procedure 9.210(a) (2), requiring fourteen-point Times New Roman Font. /s/ Joe Titone Joe Titone Attorney for Appellant Florida Bar No. 203882

S RESPONSE IN OPPOSITION TO RESPONDENT BRADLEY J. EDWARDS' MOTION FOR PARTIAL RELIEF FROM STAY Petitioner, Jeffrey Epstein ("Epstein"), pursuant to Florida Rule of Appellate Procedure 9.300, responds in opposition to the Motion for Partial Relief from Stay filed by Respondent, Bradley J. Edwards ("Edwards")', on March 1

, Respondents/Defendants. MOTION TO STRIKE UNAUTHORIZED AND INAPPROPRIATE "JOINDER" FILED BY NON-PARTIES Petitioner, Jeffrey Epstein, pursuant to Florida Rule of Appellate Procedure 9.300, moves to strike the "Joinder by Victims in Edwards' Motion for Partial Relief from Stay with Request for Expedited Consideration"

N, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. REQUEST FOR ORAL ARGUMENT Petitioner, Jeffrey Epstein, pursuant to Florida Rule of Appellate Procedure 9.320, requests oral argument in the consolidated appeals (Case Nos. 4D18-0762 and 4D18-0787) and as grounds states: Petitioner respectf

ourt to impose an award of attorney's fees and costs as a sanction under the authority of 15th Judicial Circuit Administrative Order 2.303-9/08 and Florida Rule of Appellate Procedure 9.410. Neither supports an award of appellate fees and costs. 09/12/2079 I CONFPIT5E4NTIAL Agency to Agency Requet: 19-011 SDNY_GM_00

GENCY MOTION TO REVIEW ORDER DENYING STAY OF DISCLOSURE OF FEDERAL NON-PROSECUTION AGREEMENT AND ADDENDUM Petitioner, JEFFREY EPSTEIN, pursuant to Florida Rule of Appellate Procedure 9.310(O, requests this Court review the order denying his Motion to Stay Disclosure of Federal Non-Prosecution Agreement and Addendum pen