EFTA00183935

- Not an Official Document 
Page 3 of I I 
(Docket Text: 
'none. 
I 
2 
JDN - JUDICIAL NOTES 
Filing Date: 
27-JUN-2008 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
SET CASE FOR 6/30/08 @ 8:30 AM FOR STATUS CHECK 
LEVHLD - EVENT HELD 
Filing Date: 
30-JUN-2008 
Filing Party: 
J EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
CR-DAMES. PLEAD & ADJ GUILTY 
SEXUAL OFFENDER. PBCJ 6 
CONSECUTIVE W/06-9454AXX. 
12 MOS PROB. DEFT MUST REGISTER 
OFFENDER W/IN 48 HRS OF RELEASE. 
AS CHARGED. STIP/FOUND: 
MOS W/CD FOR 1 DAY, TO RUN 
PBCJ SENTENCE FOLLOWED BY 
AS A SEXUAL 
DNA SWAB. MER 
2 A 
GUIL - JUDGMENT OF GUILTY 
[Filing Date: 
30-JUN-2008 
[Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
none. 
2 B 
IFNGR - FINGERPRINTS 
Filing Date: 
30-JUN-2008 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
none. 
2C 
ISORD-SENTENCE ORDER 
Filing Date: 
30-JUN-2008 
Filing Party: 
J EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
none. 
2 D 
SORC - 
CONTINUED 
SENTENCE ORDER -
Filing Date: 
f30-JUN-2008 
Filing Party: 
IEPSTEIN, JEFFREY E 
Disposition Amount: 
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dktrpt_docket_report?b... 8/4/2009 
EFTA00183995

- Not an Official Document 
Page 4 all 
Docket Text: 
lInone. 
2 E 
RITE - WAIVER OF RIGHTS 
Filing Date: 
30-JUN-2008 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
j 
none. 
2 F 
I PLS - PLEA SHEET 
Ifiling Date: 
30-JUN-2008 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
J none. 
2 G 
J GLSS - GUIDELINE SCORESHEET 
Filing Date: 
30-JUN-2008 
Filing Party: 
d
EPSTEIN, JEFFREY E 
Disposition Amount: 
!Docket Text: 
none. 
2 H 
OAFC - 
FEES/COST 
ORDER ASSESSING 
Filing Date: 
30-JUN-2008 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
(JUDGE PUCILLO FOR MCSORLEY) IN THE AMOUNT OF $473.00 
AS CONDS OF PROB. MER 
3 
AREC - ARREST RECORD 
Filing Date: 
01-JUL-2008 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 1 
Docket Text: 
RECOMMIT 
RCMIT - RECOMMITMENT 
Filing Date: 
01-JUL-2008 
Filing Party: 
Disposition Amount: 
Docket Text: 
none. 
CLSD - CLOSED CASE 
http://courtcon.co.palm-beackfLus/p1s/jiwp/ck_public_qry_doct.cp_dktrpt docket report?b... 8/4/2009 
EFTA00183996

- Not an Official Document 
Page 5 of I I 
Filing Date: 
08-JUL-2008 
Filing Party: 
'Disposition Amount: 
Docket Text: 
il none 
RCPT - RECEIPT FOR PAYMENT 
Filing Date: 
14-JUL-2008 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
Iii Payment of -$473.00 was made on receipt CFMB30200. From 
Bond ID: 00073142 
4 
ORD - ORDER 
Filing Date: 
21-JUL-2008 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
(JUDGE MCSORLEY) OF PROBATION..NUNC PRO TUNC 6/30/08 
5 
PROC - 
TRANSCRIPT 
CRT REPORTER 
OF 
Filing Date: 
22-JUL-2008 
Filing Party: 
EPSTEIN, JEFFREY E 
IDisposition Amount: 
Docket Text: 
PLEA CONFERENCE, TAKEN 6/30108 
6 
MOT - MOTION 
Filing Date: 
I -DEC-2008 
Filing Party: 
_ EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
TO CLARIFY SENTENCE TO CORRECT SCRIVENER'S ERROR 
FILED BY JACK GOLDBERGER 
Filing Date: 
04-MAY-2009 
Filing Party: 
I EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
(JUDGE COLBATH) THAT THE ORDER OF COMMUNITY 
CONTROL IS CORRECTED TO DELETE SPECIAL CONDITION 
#26 AND #27. 
1-8-
 
--I MOT - MOTION 
I 
http://courteon.co.palm-beachnus/p1s/jiwplek_public qry_doct.ep_dktrpt_docket_report5... 8/4/2009 
EFTA00183997

- Not an Official Document 
Page 6 of I I 
!Filing Date: 
112-MAY-2009
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
(NONPARTY E VVS) TO VACATE 
AND UNSEAL RECORDS. 
ORDER SEALING RECORDS 
ORSH - ORDER SETTING HEARING 
Filing Date: 
[15-MAY-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
SET FOR 5/29/09 RE:MOTION 
UNSEAL RECORD 
TO VACATE ORDER TO SEAL AND 
I 
EVSCH 
SCHEDULED 
- HEARING EVENT 
Filing Date: 
19-MAY-2009 
Filing Party: 
Disposition Amount: 
Docket Text: 
none. 
10 
j 
NOH - NOTICE OF HEARING 
Filing Date: 
26-MAY-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
SET FOR 5/29/09 10:30 
12 
I PONG - PLEA OF NOT GUILTY 
Filing Date: 
29-MAY-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
_ 
Disposition Amount: 
Docket Text: 
none. 
EVSCH 
SCHEDULED 
- HEARING EVENT 
Filing Date: 
01-JUN-2009 
Filing Party: 
Disposition Amount: 
Docket Text: 
NON PARTY 
'S MOTION TO 
RECORDS A 
NSEAL RECORDS 
VACATE ORDER SEALING 
EVCAN EVENT 
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dIctrpt_docket report?b... 8/4/2009 
EFTA00183998

- Not an Official Document 
Page 7 of 11 
J 
CANCELLED/SETTLED 
Filing Date: 
01-JUN-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
none. 
11 
RNOH - RE-NOTICE OF HEARING 
Filing Date: 
01-JUN-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
SETTING CASE FOR OTHER HEARING ON 6/10/2009 AT 10:30 
AM FILED BY BRADLEY EDWARDS, ESQ. RE: NON PARTY 
'S
R
MOTION TO VACATE ORDER SEALING RECORDS AND UN 
L 
RECORDS, HEARING SEET FOR 5/29/2009 IS CANCELLED 
13 
MOT - MOTION 
Filing Date: 
03-JUN-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
TO VACATE ORDER SEALING RECORD AND UNSEAL RECORDS 
FILED BY BRADLEY EDWARDS, ESQ. 
14 
I MOT - MOTION 
Filing Date: 
J 03-JUN-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
PALM BEACH POST'S MOTION TO INTERVENE AND PETITION 
FOR ACCESS FILED BY DEANNA SHULLMAN, ESQ. 
EVRST EVENT RESET 
Filing Date: 
10-JUN-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
CR-BELTRAN. MOTION TO INTERVENE-GRANTED. NO ACTION 
ON MOTION TO UNSEAL. RESET FOR MOTION HRG ON 6/25/09. 
BLE 
15 
ORD - ORDER 
Filing Date: 
10-JUN-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
http://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_public_qry_doctcp_dlctrpt_docket_report?b... 8/4/2009 
EFTA00183999

- Not an Official Document 
Page 8 of I I 
'Docket Text: 
II(COLBATH) 
16 
CEF - COURT EVENT FORM 
Filing Date: 
10-JUN-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Lissposition Amount: 
'Docket Text: 
none. 
17 
ORD - ORDER 
Filing Date: 
10-JUN-2009 
Filing Party 
EPSTEIN, JEFFREY E 
'Disposition Amount: 
iDocket Text: 
(COLBATH) 
EVSCH 
SCHEDULED 
- HEARING EVENT 
Filing Date: 
11-JUN-2009 
Filing Party: 
Disposition Amount: 
Docket Text: 
none. 
19 
MOT - MOTION 
Filing Date: 
11-JUN-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
'Disposition Amount: 
Docket Text: 
TO MAKE COURT RECORDS CONFIDENTIAL. 
GOLDBERGER, ESQ 
FILED BY J. 
18 
MOT - MOTION 
Filing Date: 
11'5-JUN-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
TO INTERVENE AND SUPPORTING 
FILED BY S. KUBIN, ESQ 
MEMORANDUM OF LAW. 
EVSCH 
SCHEDULED 
HEARING EVENT 
Filing Date: 
25-JUN-2009 
Filing Party: 
Disposition Amount: 
Docket Text: 
 
ITO STAY DISCLOSURE 
http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry doct.cp_d1ctrpt_docket_report?b... 8/4/2009 
EFTA00184000

- Not an Official Document 
Page 9 of I I 
EVHLD EVENT HELD 
Filing Date: 
Filing Party: 
25-JUN-2009 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
CR-WIGGINS (COLBATH) DEFT PRES W/J.GOLDBERGER, 
GRANTED, CASE RESET FOR MOTION TO STAY DISCLOSURE 
_EVSCH HEARING EVENT 
SCHEDULED 
Disposition Amount: 
Docket Text: 
Filing Date: 
Filing Party: 
Disposition Amount: 
Docket Text: 
none. 
21 
I MOT - MOTION 
Filing Date: 
25-JUN-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
TO STAY DISCLOSURE OPF THE NON- PROSECUTION 
AGREEMENT AND ADDENDUM PENDING REVIEW. FILE BY R. 
CRITON, PA 
EVHLD - EVENT HELD 
Filing Date: 
26-JUN-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
CR-WIGGINS. MOTION TO STAY, DENIED. WRITTEN ORDER TO 
FOLLOW. DOCUMENTS IN QUESTION ARE DELAYED UNTIL 
NOON ON THURSDAY 02-JUL-2009. MOTION TO COMPEL THE 
DEFT TO POST BOND - DENIED. 
25 
-"MOT - MOTION 
Filing Date: 
26-JUN-2009 
1Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
http://courtcon.co.palm-beach.fl.us/pIs/jiwp/ck_public qry_doct.cp_dktrpt_docket_report?b... 8/4/2009 
EFTA00184001

- Not an Official Document 
Page 10 of I I 
Docket Text: 
"FOR ATTY'S FEES AND COSTS. FILED BY D. SHULLMAN, PA 
31 
CEF - COURT EVENT FORM 
Filing Date: 
26-JUN-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
none. 
32 
f
ORD - ORDER 
Filing Date: 
26-JUN-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
(JUDGE COLBATH) THAT THE 
RECORDS ARE DENIED. THE 
GRANTED. THE MOTION TO UNSEAL 
GRANTED. 
MOTIONS TO SEAL THE COURT 
MOTIONS TO INTERVENE ARE 
THE DOCUMENTS IS 
23 
RESP - RESPONSE TO: 
Filing Date: 
29-JUN-2009 
'Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
MOTION TO STAY AND SUPPORTING 
FILED BY S. KUVIN, ESQ 
MEMORANDUM OF LAW. 
24 
ODMO - ORDER DENYING MOTION 
Filing Date: 
29-JUN-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
(COLBATH) TO STAY DISCLOSURE AGREEMENT 
26 
PROC - 
TRANSCRIPT 
CRT REPORTER 
OF 
Filing Date: 
01-JUL-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
PROCEEDINGS BEFORE THE COURT, 
27 
1 PROC - 
TRANSCRIPT 
CRT REPORTER 
OF 
Filing Date: 
01-JUL-2009 
Filing Party: 
'EPSTEIN, JEFFREY E 
I 
http://courtcon.co.palm-beach.fi.us/p1s/jiwp/ck_public_qry_doct.cp_dIctrpt_docket_report?b... 8/4/2009 
EFTA00184002

- Not an Official Document 
Page I I of 1 1 
[Disposition Amount: 
Docket Text: 
PROCEEDINGS BEFORE THE COURT 
22 
ORD - ORDER 
Filing Date: 
02-JUL-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
THAT THE MOTION TO FILE UNDER SEAL IS GRANTED. 
ORDERED FURTHER THAT THIS COURT GRANTS THE MOTION 
TO USE ONE APPENDIX TO SUPPORT THE EMERGENCY 
PETITION FOR WRIT OF CERTIORARI AND EMERGENCEY 
MOTION TO REVIEW DENIAL OF STAY. ORDERED FURTHER 
THAT THIS COURT GRANTS PETITIONERS EMERGENCEY 
MOTION TO REVIEW THE ORDER JUNE 26, 2009, THAT DENIES 
THE MOTION FOR STAY. THE JUNE 25, 2009 ORDER GRANTING 
THE MOTION TO UNSEAL IS STAYED PENDING FURTHER 
ORDER OF THE COURT. ORDERED FURTHER THAT WITHIN 
TEN (10) DAYS OF THIS ORDER RESPONDENT SHALL SHOW 
CAUSE WHY THE PETITION SHOULD NOT BE GRANTED. 
RESPONDENT SHALL ADDRESS THIS COURTS JURISDICTION 
TO REVIEW THE ORDER AS WELL AS THE MERITS OF THE 
PETITION. ORDERED FURTHER THAT PETITIONER MAY HAVE 
TEN (10) DAYS THEREAFTER TO REPLY. 
28 
MOT - MOTION 
Filing Date: 
06-JUL-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
NONPARTY M.'S MOTION FOR ATTORNEYS FEES AND 
COSTS FILED BY W. BERGER 
29 
RESP - RESPONSE TO: 
Filing Date: 
06-JUL-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
(NTERVENER'S) MOTION TO STAY AND SUPPORTING 
MEMORANDUM OF LAW. FILED BY S. KUVIN, ESQ 
30 
EXLT - EXHIBIT LIST 
Filing Date: 
08-JUL-2009 
Filing Party: 
EPSTEIN, JEFFREY E 
Disposition Amount: 
Docket Text: 
none. 
htm://courtcon.co.palm-beach.fl.us/pls/jiwp/ckpublic_qry_doct.cp_dkupt_clocket_report?b... 8/4/2009 
EFTA00184003

07/20/2009 15:22 FAX 
USA° WPB 
07-20-'09 14:21 
5 & LOCICERO 
T-113 P002/00P-137 
IN THE DISTRICT COURT OF APPEAL 
FOURTH DISTRICT OF FLORIDA 
CASE NO. 4D09-2554 
JEFFREY EPSTEIN, 
Petitioner, 
vs. 
STATE OF FLORIDA, LALM BE
 NEWSPAPERS, INC., 
,and I., 
Respondents. 
Pending in the Fifteenth Judicial Circuit in and for Palm Beach County, Florida, 
Case Nos. 2006 CF 9454AMB, 2008 CF 9381AMB 
PALM BEACH NEWSPAPERS, INC. d/b/a THE PALM BEACH POSTS 
MOTION FOR APPELLATE ATTORNEYS' FEES AND COSTS 
THOMAS, LoCICERO 8t BRALOW PL 
Deanna K. Shullman 
James B. Lake 
101 N.E. 3rd Avenue, Suite 1500 
Ft. Lauderdale, Florida 33301 
EFTA00184004

07/20/2009 15:22 FAX 
USAO WP 
goo4 
27-20-'09 14:22 FROM-THOMAS & LOCICERO 
T-113 P003/007 F-937 
RESPONDENT PALM BEACH POST'S 
MOTION FOR APPELLATE ATTORNEYS' FEES AND COSTS 
Pursuant to Florida Rules of Appellate Procedure 9.400 and 9.410 and 
Administrative Order Number 2.303 of the Fifteenth Judicial Circuit of Florida, 
Respondent Palm Beach Newspapers, Inc., d/b/a The Palm Beach Post (the "Pose') 
moves this Court for an award of attorneys' fees and costs in connection with this 
review proceeding. In support thereof, the Post states: 
1. 
The Post is a daily newspaper that has covered this matter and related 
proceedings. In an effort to inform its readers concerning these matters, the Post 
relies upon (among other things) law enforcement records and judicial records. 
2. 
On June 10, 2009, the trial court granted the Post's Motion to 
Intervene in this action for the purpose of seeking access to court records. 
Specifically, the Post sought access to a non-prosecution agreement that was 
docketed on July 2, 2008, and an addendum docketed on August 25, 2008. 
3. 
On June 25, 2009, the trial court heard oral argument on the Post's 
(and other non-parties') motions. The Court found that the documents had not 
properly been sealed in the first instance and further denied Petitioner Jeffrey 
Epstein's Motion to Make Court Records Confidential dated June 11, 2009. 
2 
EFTA00184005

07/20/2009 15:23 FAX 
USAO WP 
07-20-'09 14:22 MI PR
EIO
S & LOCICEE0 
kboos 
T-113 P004/007 F-93/ 
4. 
The Post is entitled to its fees and costs in this matter pursuant to 
Administrative Order Number 2.303 of the Fifteenth Judicial Circuit of Florida.' 
Specifically, that order allows sanctions to be imposed against the moving party "if 
a motion to seal is not made in good faith and is not supported by a sound legal and 
factual basis." Admin. Or. 15th Jud. Cir. Fla. 2.303. 
5. 
The Post also is entitled to fees and costs in this matter pursuant to 
Florida Rule of Judicial Administration 9.410, which gives appellate courts 
discretion to impose sanctions if an appeal "presents no justiciable question and is 
so devoid of merit on the face of the record that there is little prospect it will ever 
succeed." E.g.. Visolv I Sec. Pac. Cred. Cow., 768 So. 2d 482, 490-91 (Fla. 3d 
DCA 2000) (citing Fla. R. App. P. 9.410). Frivolous appeals include those in 
which a case is found: 
a. 
to be completely without merit in law and not supported by a 
reasonable argument for an extension, modification or reversal 
of existing law; 
b. 
to be contradicted by overwhelming evidence; 
c. 
as having been undertaken primarily to delay or prolong the 
resolution of the litigation, or to harass or maliciously injure 
another; or 
d. 
as asserting material factual statements that are false. 
Id. at 491. 
A copy of Administrative Order 2.303 is attached at Tab 2 to the Post's 
Supplemental Appendix, which was filed with its response brief. 
3 
EFTA00184006

07/20/2009 15:23 FAX 
USAO SIP 
N 
01-20-'09 14:22 FROM-THOMAS & LOCICERO 
nocie 
T-113 P005/W0I F-9:17 
6. 
In this case, Mr. Epstein's certiorari petition like his initial filing of 
these documents under seal and his June 11, 2009 Motion to Make Court Records 
Confidential — was neither made in good faith nor supported by a sound legal and 
factual basis. The certiorari petition asserted three interests that ostensibly would 
be protected by closure but cited no recoid evidence in support of that assertion. 
Indeed, both in his motion below and at the hearing on the motion, Epstein made 
no genuine effort to demonstrate by evidence how and why any material interests 
would be served by closure. Instead, Epstein's arguments addressed extraneous, 
inapplicable issues that did not support closure and demonstrated his lack of good 
faith in bringing his motion. Moreover, Epstein's assertion that the trial court's 
orders contradicted and were preempted by federal court rulings was simply false. 
Epstein likewise failed to substantiate his arguments in this proceeding, instead 
again relying on red herrings and unsubstantiated blanket assertions to support his 
baseless claim that closure is or was proper in this case. 
7. 
Rather, it appears Epstein opposed unsealing of these records simply 
for the purpose of shielding from public view documents material to the resolution 
of criminal charges against him for soliciting children for prostitution. In other 
words, the petition to this Court was merely a ploy intended to delay the public 
access to judicial records that that the Florida Constitution and common law 
guarantee. 
4 
EFTA00184007

07/20/2009 15;23 FAX gm= 
USA0 NP 
07-20-'09 14:22 FROM-THOMAS & LOCICERO 
T-113 P006/007 F-937 
8. 
In sum, Epstein's arguments for restricting access to his non-
prosecution agreement and its addendum are without merit, Epstein's petition to 
this Court was likewise without support in fact or law, and the Post is entitled to an 
award of its fees and costs in defending its rights of access. 
WHEREFORE, the Post respectfully requests that this Court award to it its 
fees and costs and grant such other relief as the Court deems proper. 
Respectfully submitted, 
THOMAS, LOCICERO & BRALOW 
5 
PL 
De 
a K. Shull 
F rida Bar No.: 
James B. Lake 
Florida Bar No.: 
101 N.E. Third Avenue, Suite 1500 
Fort Lauder 
Telephone: 
Facsimile: 
deanna.shullman@uolawfirm.com 
Attorneys for The Palm Beach Post 
EFTA00184008

07/20/2009 15:23 FAX 
USAO WP 
07-20-'09 14:22 tilIRMS & LOCICERO 
goof( 
T-113 P007/007 F-937 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that a true and correct copy of the foregoing has been 
famished U.S. Mail to: Hon. Jeffrey Colbath, Palm Beach County Courthouse, 
205 N. Dixie Highway, Room 11F, West Palm Beach, FL 33401; and via facsimile 
and U.S. Mail to: R. Alexander Acosta, United States Attorney's Office - 
Southern District, 500 S. Australian Ave., Ste. 400, West Palm Beach, FL 33401; 
Barbara Burns, Esq., State Attorney's Office - West Palm Beach, 401 North 
Dixie Highway, West Palm Beach, FL 33401; Jack Alan Goldberger, Esq., 
Atterbury Goldberger, et al., 250 S. Australian Ave., Ste. 1400, West Palm Beach, 
FL 33401; Robert D. Critton, Esq., Burman, Critton, Luther & Coleman, 515 N. 
Flagler Drive, Suite 400, West Palm Beach, FL 33401; 
Esq., 501 S. Flagler Drive, Suite 503, West Palm Beach, FL 33401-5913; Spencer 
T. Kuvin, Esq., Leopold-Kuvin, P.A., 2925 PGA Boulevard, Suite 200, Palm 
Beach Gardens, FL 33410; and Bradley 3. Edwards, Esq. and William J. 
Berger, Esq., Rothstein Rosenfeldt Adler, 401 East Las Olas Blvd., Suite 1650, 
Fort Lauderdale, FL 33394 on this 20th day of July, 2009. 
6 
EFTA00184009

____Q7/20/2009 15:22 FAX 
USA° WPB CONFRM 
(41001 
United States Attorney's Office 
Southern District of Florida 
500 S. Australian Ave., Suite 400 
West Patin Beach, FL 33401-6235 
TO: 
ORGANIZATION: 
 
FAX #:  
SUBJECT:S
i 
FROM: 
•
 
x) 
NUMBER OF PAGES, INCLUDING THIS PAGE: 
COMMENTS: 
Original document: 
 
 To follow via regular mail . 
 
 To follow via Federal Express 
tz
_vio follow via hand delivery 
Nothing to follow, FAX := original 
EFTA00184010

07/20/2000 15:22 FAX 
USA° WP 
07 -2a -'09 14:21 ,WIRRS & LOCICERO 
I6 002 
Thai 
P1301/Idla 
r 
THOMAS LOCICERO
BR ALOW 
a
400 N. 
DriveeSuite 1100eTam 
FL 33602 
(Phone) 
(Fax) 
To Free: 
facsimile transmittal 
To: 
Marilyn, Judicial Assistant to Judge 
FAX 
Colbath 
It Alexander Acosta, Esq., USAO 
Barbara Burns, Esq., ASAO 
Jack Alan Goldberger, Esq. 
Bradley J. Edwards, Esq. 
William J. Berger, Esq. 
Robert D. Critton, Esq. 
Spencer T. Kuvin, Esq. 
Esq. 
From: 
Deanna K. Shullman, Esq. 
Re: 
State., J. Epstein 
Date: 
Peps: 
7 
Urgent 0 
Please see attached . 
For review 
Please comment U 
Please reply U 
Please recycle 
CONFIDENTIALITY STATESfEhtf 
This eltetroaie message transmission contains information from the law firm of Thomas, LoCiccro 
PL we is confidential or 
privileged. The informerion is intended to be for the use of the individual or entity earned above. If you are not the intended recipient, he await 
that any disclosure, espying, disuibtai 
contents of this information is prohibited. If you Iowa received this electronic transmission 
le error, please notify 1.15 by tckphonc 
immediately. Thank you for your cooperation 
IRS Circular 230 Dirclosurc, To the extent this conespondence contain: federal tax "Nice, such advice, WAS nee intended to be used, and cannot 
be vied by any taxpayer, for the purpose of 10 avoiding penalties under the Internal Revenue Code or (i) promoting, matketing, or 
mcarnmendlagm mother paro,r any uansactlon or mew addressed herein. If you would like of to prepare written tax advl ee designed to provide 
penalty 1,10=4ica. please eontba us and we will be happy to discuss the meter with you a more derail 
confidential 
EFTA00184011

IN THE DISTRICT COURT OF 
APPEAL OF THE 
STATE OF 
FLORIDA, FOURTH DISTRICT 
JEFFREY EPSTEIN, 
CASE NO. 4D09-2554 
PALM BEACH COUNTY 
Petitioner, 
L.T. CASE NO. 2008 CF 009381 A 
1. 
STATE OF FLORIDA, 
Respondent. 
AGREED MOTION TO FILE ONE REPLY SUPPORTING 
PETITION FOR WRIT OF CERTIORARI AND FOR THE TIME TO RUN 
FROM SERVICE OF THE LAST-FILED RESPONSE 
Petitioner, JEFFREY EPSTEIN, requests this Court's permission to file one 
reply supporting his petition for certiorari to the three separate responses filed by 
respondents and for the time to run from service of the last-filed response, for the 
following reasons: 
1. 
Mr. Epstein filed an Emergency Petition for Certiorari to review an 
order compelling disclosure of a confidential federal non-prosecution agreement 
and addendum. 
1 
EFTA00184012

2. 
On July 1, 2009, this Court ordered respondent to show cause within 
10 days why the petition should not be granted. This Court allowed Mr. Epstein 10 
days to reply. 
3. 
Three groups of respondents filed responses: (1) ■.; (2) M.; and 
(3) Palm Beach Newspapers, Inc. d/b/a Palm Beach Post ("the Post"). 
Each 
respondent is represented by different counsel. The responses were served by mail 
and on different days. 
4. 
Due to the overlap of arguments in the three responses, it would 
benefit the parties and this Court if Mr. Epstein filed one reply to the three 
responses. 
Accordingly, Mr. Epstein requests permission to file one reply to the three 
responses. Mr. Epstein requests this Court to order that the reply is due 10 days 
from service of the last-filed response. 
Opposing counsel has contacted counsel for respondents (William J. Berger 
for ■.; Diana L. Martin for M.; and Deanna K. Shullman for the Post), who 
have all advised they have no objection to this motion. 
2 
EFTA00184013

I HEREBY CERTIFY that a copy of the foregoing has been sent byAmail 
this  J4k.L, day of July, 2009, to: 
U.S. Attorney's Office-Southern District 
500 South Australian Avenue, Suite 400 
West Palm Beach, FL 33401 
WILLIAM J. BERGER 
ROTHSTEIN ROSENFELDT ADLER 
401 East Las Olas Boulevard, Suite 1650 
Fort Lauderdale. FL 33301 
Counsel for 
SPENCER T. KUVIN 
DIANA L. MARTIN 
LEOPOLD-KUVIN, P.A. 
2925 PGA Boulevard, Suite 200 
Palm Beach Gardens, FL 33410 
Counsel for M. 
State Attorney's Office-West Palm Beach 
401 North Dixie Highway 
West Palm Beach, FL 33401 
DEANNA K. SHULLMAN 
400 North 
Drive, Suite 1100 
P. O. Box 2602 (33601) 
Tampa, FL 33602 
Counsel for The Palm Beach Post 
HONORABLE JEFFREY COLBATH 
15th Judicial Circuit 
Palm Beach County Courthouse 
205 North Dixie Highway 
Room 11F 
West Palm Beach, FL 33401 
ROBERT D. CRITTON of 
BURMAN, CRITTON, LUTTIER & COLEMAN 
515 North Flagler Drive, Suite 400 
West Palm Beach, FL 33401 
and 
JACK A. GOLDBERGER of 
ATTERBURY, GOLDBERGER & WEISS, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, FL 33401 
and 
3 
EFTA00184014