This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →
FBI VOL00009
EFTA00233329
549 pages
Page 301 / 549
it has specifically failed to do so. The trial court did not depart from the essential requirements of law in holding that Petitioner failed to demonstrate a compelling interest in closure. Epstein next asserts that closure is warranted to protect the interest of "innocent third parties" and identifies those third parties as Mr. Epstein's co- conspirators. (Petition at 15). Again, Mr. Epstein lacks standing to assert the interests of third parties. Doe'. Museum of Science and History of Jacksonville, Inc., Case No. 92-32567, 1994 WL 741009 (Fla. 7th Jud. Cir. June 8, 1994) (plaintiff lacks standing to assert privacy interest of third party, minor victims of sexual assault by defendant's former employee, who had been convicted) (copy attached at Supp.A.-4). In addition, even if the third parties Mr. Epstein identifies — his purported co-conspirators — were before the Court, they would have no privacy interest in matters pertaining to their criminal conduct. Post-Newsweek Stations, Florida, Inc.'. Doe, 612 So. 2d 549 (Fla. 1992) (Does, whose names were implicated in criminal prostitution scheme, had no right to privacy by virtue of their participation in a crime and thus their names could not be redacted from records provided to the public). Thus, the trial judge did not depart from the essential requirements of law in finding insufficient third-party interests to justify closure. 17 EFTA00233629
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The third interest Epstein seeks to invoke is his own right to privacy. See Petition at 15. While Epstein actually does have standing to assert his own right to privacy, Florida law is clear that closure is only proper to protect a "substantial injury to a party by disclosure of matters protected by a common law or privacy right not generally inherent in the specific type of proceeding sought to be closed." Ha. R. Jud. Admin. 2.420(c)(9)(A)(vi) (emphasis added). Epstein argues disclosure of a plea agreement is not generally inherent in a state court plea hearing See Petition at 16. That argument is absurd. Of course Epstein's plea agreement is generally inherent in his criminal prosecution. It is the very reason that prosecution ended, and as the lower court recognized in accepting the plea, it was a "significant inducement" to Petitioner to take the state's deal. (A-7 at p. 39, II. 19- 21.; p. 40,11. 10-13.) Moreover, Florida's constitutional right to privacy is expressly subordinate to the rights of Floridians to access the records of their government. To wit, Article I, § 23, which sets forth the right to privacy, further provides: "[t]his section shall not be construed to limit the public's right of access to public records and meetings as provided by law." Fla. Const. Art. I, § 23. As the Florida Supreme Court has recognized, the privacy amendment has not been construed to protect names and addresses contained in public records. Post Newsweek, 612 So. 18 EFTA00233630
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2d at 552. The trial court, having reviewed the NPA in camera, certainly had an
opportunity to assess whether a privacy interest not inherent in his criminal
prosecution for felony solicitation of children for prostitution is implicated by the
NPA. It cannot in good faith be argued that the trial court departed from the
essential requirements of law in determining that no such privacy interest was
implicated.
2. The Federal Court's Decisions in Case No. 08-80736
(S.D. Ha. 2008) Did Not Preclude the Lower Court's
Orders Unsealing the NPA.1°
Nor did the trial court's rejection of Petitioner's comity argument depart
from the essential requirements of law. In the Southern District of Florida, one of
the minor victims of Epstein filed a Petition for Enforcement of Crime Victim's
Rights Acts (A-I)." The victim also asked the federal court to allow her to share
the NPA with third parties (A-3). Judge Marra denied the motion, finding — as the
U.S. Government had argued (A-4) — that the NPA was 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 the record below. If the
Court is inclined to consider these federal court pleadings, then in fairness it must
consider those related pleadings which are attached hereto as Supp.A.-5 through
Supp.A.-7 of the Post's Supplemental Appendix.
19
EFTA00233631
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case, under seal or otherwise."). The federal court also declined to provide any relief from restrictions on the parties' use and dissemination of the discovery document without prejudice. (A-6 at p.2.) Petitioner argues that the Post should be required to seek relief in Judge Marra's court. He mischaracterizes the nature of the proceedings there. There is no document to unseal in Judge Marra's court. The NPA is not a record of that court, and thus any effort by the Post to obtain access to the NPA there would be futile, and any order requiring it be unsealed by the lower court herein does not conflict with any decision of the federal court. (A-16 at p.3.) In fact, when Judge Marra has been asked to seal records of his court that quote the NPA, he has refused to do so, and has required such records to be filed in the public court file (Supp.A.-5 through Supp.A.-7)12 Thus, though the NPA is not a record of the federal court, the federal court has rejected attempts to file portions of it under seal. As a result, portions of the NPA appear in the public court file in 12 Page 4 of Supp.A.-5 and paragraph 5 of Supp.A.-6, both publicly on file in the federal court, quote from the NPA. In addition, Epstein's own lawyers quoted extensively from the NPA in seeking to stay one of the civil suits against him. (A- 11 at 116; A-18, p. 35, I. 18 — p. 36,1. 1 (inc rporating by reference Supp.A.-5 I through Supp.A-6 and Supp.A.-7 (C.M.A. I. Epstein, Case No. 08-cv-8081 I (S.D. Fla. 2008) at Dkt. 33 pp. 2-5)).) 20 EFTA00233632
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the federal civil litigation against Epstein. (Supp.A-5 at p. 4; Supp.A.-6 at ¶ 5; Supp.A.-7 at pp. 2-5.) The proverbial cat is already out of the bag. Notwithstanding, the NPA is a record of this lower court. The lower court did not enter an order conflicting with Judge Marra's rulings (A-16 at p. 3 — expressly noting lack of conflict with Judge Marra's orders) and did not depart from the essential requirements of law in unsealing the NPA. 3. Federal Rule of Criminal Procedure 6 Did Not Preclude the Lower Court's Orders Unsealing the NPA.t3 Finally, unsealing the NPA did not conflict with federal law. Records available under state law are sealed by federal law only when federal law absolutely conflicts with state law and requires confidentiality of the records. The Supremacy Clause of the United States Constitution, Art. VI, U.S. Const., comes into play only when federal law clearly requires the records to be closed, and the state is clearly subject to its provisions. E.g., Wallace,. Guzman, 687 So. 2d 1351, 1353 (Fla. 3d DCA 1997) (exemptions to federal Freedom of Information Act do not apply to state agencies); Hous. Auth. of the City of Daytona Beach'. Gomillion, 639 So. 2d 117 (Fla. 5th DCA 1994) (Federal Privacy Act does not exempt from disclosure records of housing authority which are open for inspection 13 The Post adopts and incorporates E.W.'s arguments and analysis on this issue in addition to the arguments it sets forth herein. 21 EFTA00233633
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under Florida Public Records Act); Fla. Sugar Cane League, Inc.'. Fla. Dept. of Envtl. Reg., Case No. 91-2108 (Fla. 2d Jud. Cir. Sept. 20, 1991), per curiam affirmed 606 So. 2d 1267 (Fla. 1st DCA 1992 (documents received by state agency in course of settlement negotiations to resolve federal lawsuit and confidential settlement agreement with U.S. Department of Justice open to inspection because federal law did not clearly require confidentiality) (Supp.A.-8.) Federal law imposes no such preemption of the Florida constitution and common law in this case. In particular, Federal Rule of Criminal Procedure 6(e) does not restrict access to the NPA. Federal Rule 6(e) restrains grand jurors, court reporters, government attorneys, interpreters and the like from disclosing matters occurring before the grand jury. Petitioner — apparently the former target of the grand jury — is none of these persons. His actions in filing the NPA under seal do not implicate Rule 6(e) no matter what information the NPA contains. The lower court's actions in unsealing the NPA likewise do not implicate Rule 6, because the lower court also is not restrained by Rule 6(e). Moreover, the information contained in the NPA does not constitute "matters occurring before the grand jury" within the meaning of Rule 6. The secrecy rule is limited to such matters for the purpose of "preventing targets of an 22 EFTA00233634
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investigation from fleeing or tampering with witnesses or grand jurors, encouraging witnesses to appear voluntarily and speak fully and frankly, avoiding damage to the reputation of subjects or targets of the investigation who are not indicted, and encouraging grand jurors to investigate suspected crimes without inhibition and engage in unrestricted deliberations." Lockhead Martin Corp.'. Boeing Co., 393 F. Supp. 2d 1276, 1279 (M.D. Fla. 2005). The rule aims to "prevent disclosure of the way in which information was presented to the grand jury, the specific questions and inquiries of the grand jury, the deliberations and vote of the grand jury, the targets upon which the grand jury's suspicion focuses, and specific details of what took place before the grand jury." In re Grand Jury Investigation of Ven-Fuel, 441 F. Supp. 1299, 1302-03 (M.D. Fla. 1977). In other words, Rule 6 is implicated if disclosure would reveal secret inner workings of the grand jury. U.S. . Rosen, 471 F. Supp. 2d 651, 654 (E.D. Va. 2007). Disclosure of details of a government investigation that is independent of a parallel grand jury proceeding does not violate Rule 6. Id. Statements by a prosecutor's office about its own investigation, therefore, are not covered by the secrecy rule. Id. at 655. Likewise, the mere mention of other targets of an investigation does not implicate the grand jury secrecy rule. E.g., In re Interested Party, 530 F. Supp. 2d 136,140-42 (D.D.C. 2008) (government not prohibited by 23 EFTA00233635
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Rule 6 from disclosing plea agreement and other materials); Doe y. Hammond, 502 F. Supp. 2d 94, 99-101(D.D.C. 2007) (same). Moreover, "when the fact or document is sought for itself, independently, rather than because it was stated before or displayed to the grand jury, there is no bar of secrecy." In re Grand Jury Investigation of Ven-Fuel, 441 F. Supp. at 1304. Here, the Post seeks to review the NPA for its own intrinsic value, and not for the purpose of discerning what transpired before the grand jury now more than a year ago. It is clearly well within the public's right and interest to review the NPA, given the circumstances surrounding the investigation and prosecution of Petitioner as well as the civil claims by women who say Epstein sought to make them his child prostitutes. These facts clearly constitute a proper basis for unsealing these improperly sealed documents. Finally, and even assuming for a moment that the NPA contains grand jury information — which the Post doubts — when the grand jury's work has concluded, and the accused apprehended, the veil of secrecy no longer is necessary and safely may be lifted. In re Grand Jury Investigation of Ven-Fuel, 441 F. Supp. at 1303. Here, Petitioner has been convicted, and nothing in the record suggests the grand jury's work is ongoing. Consequently, no basis exists for finding that the trial court departed from the essential requirements of law. 24 EFTA00233636
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CONCLUSION The trial court was correct in unsealing the non-prosecution agreement and its addendum. These materials were not properly sealed in the first instance. Moreover, Epstein has not and cannot provide any basis for closure at this juncture. The trial court did not depart from the essential requirements of law in unsealing the NPA. Its order should be affirmed, and the Post should be awarded its fees and costs and such other further relief as this Court deems proper. Respectfully submitted, THOMAS °CICERO & BRALO , PL D nna K. Shullman James B. Lake I•1 Attorneys for The Palm Beach Post 25 EFTA00233637
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CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via U.S. Mail to: Hon. Jeffrey Colbath, Palm Beach County Courthouse, 205 N. Dixie Highway, Room 11F, West Palm Beach, FL 33401; 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.,■ Robert D. Critton, Esq., Burman, Critton, Luttier & Coleman, Jane Kreusler-Walsh, Esq., Spencer T. Kuvin, Esq., Leopold-Kuvin, nd Bradley J. Edwards, Esq. and William J. Berger, Esq., Rothstein Rosenfeldt Adler, 4 day of July, 2009. 26 on this 10ffi EFTA00233638
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CERTIFICATE OF TYPE, SIZE AND STYLE Counsel for Petitioners certifies that this Petition is typed in 14 point (proportionately spaced) Times New Roman. 27 EFTA00233639
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- Not an Official Document Page 1 of 11 Report Selection criteria Case ID: Docket Start Date: Docket Ending Date: Case Description Case ID: Case Caption: Division: Filing Date: Court: Location: Jury: Type: Status: 502008CF009381AXXXMB 502008CF009381AXXXMB EPSTEIN, JEFFREY E W - COLBATH Thursday , June 26th, 2008 CF -FELONY MB - MAIN BRANCH N-Non Jury CF -FELONY CLSD - CLOSED CASE Related Cases No related cases were found. Case_EventSchedule No case events were found. Case Parties Sea • Assoc Expn Date Type ID Name 2 JUDGE W COLBATH, JUDGE JEFFREY Aliases: none 3 I DEFENDANT 24167391 EPSTEIN, JEFFREY E Aliases: none 4 3 30-JUN- 2008 ATTORNEY 0262013 GOLDBERGER , ESQ, JACK A Aliases: none O_acket Entries http://courtcon.co.palm-beachnus/p1s/jiwp/ck_public_qry_doct.cp_dktrpt_docket_report?b... 8/4/2009 EFTA00233640
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- Not an Official Document Page 2 of I I Docket Number Docket Type Book and Page No. Attached To: 0000C - CASE INITIATED TIMELINESS RPT Filing Date: 26-JUN-2008 Filing Party: Disposition Amount: Docket Text none. 1 INFO - INFORMATION SHEET Filing Date: J26-JUN-2008 Filing Party: EPSTEIN, JEFFREY E Disposition Amount: Docket Text: ARISES FROM 2006CF009454AXX 1 A AREC - ARREST RECORD Filing Date: 26-JUN-2008 iFiling Party: EPSTEIN, JEFFREY E Amount: L Disposition Docket Text: J none. 1B I TEXT - SEE DESCRIPTION DOCUMENT Filing Date: 26-JUN-2008 Filing Party: EPSTEIN, JEFFREY E Disposition Amount: Docket Text: ROUGH ARREST - NO PROBABLE CAUSE FILED 1 C il WOAR - WAIVER OF ARRAIGNMENT Filing Date: 26-JUN-2008 Filing Party: EPSTEIN, JEFFREY E Disposition Amount: Docket Text: J FILED BY JACK GOLDBERG EVSCH HEARING EVENT SCHEDULED Filing Date: 27-JUN-2008 Filing Party: I 1 Disposition Amount: http://courtcon.co.palm-beach.fl.us/p1s/jiwpktpublic_gry_doct.ep_dktrpt_docket_report?b... 8/4/2009 EFTA00233641
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- Not an Official Document Page 3 of 11 'Docket Text: none. 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 EVHLD - EVENT HELD Filing Date: 30-JUN-2008 Filing Party: VEPSTEIN, JEFFREY E Disposition Amount: Docket Text: CR-DAMES. PLEAD & ADJ GUILTY AS CHARGED. STIP/FOUND: SEXUAL OFFENDER. PBCJ 6 MOS W/CD FOR 1 DAY, TO RUN CONSECUTIVE W/06-9454AXX. PBCJ SENTENCE FOLLOWED BY 1 12 MOS PROB. DEFT MUST REGISTER AS A SEXUAL OFFENDER W/IN 48 HRS OF RELEASE. DNA SWAB. MER 2 A 1GUIL - JUDGMENT OF GUILTY Filing Date: 30-JUN-2008 Filing Party: EPSTEIN, JEFFREY E 'Disposition Amount: Docket Text: none. 2 B FNGR - FINGERPRINTS Filing Date: 30-JUN-2008 Filing Party: EPSTEIN, JEFFREY E Disposition Amount: Docket Text: none. 2 C 1 SORD - SENTENCE ORDER Filing Date: 30-JUN-2008 Filing Party: EPSTEIN, JEFFREY E Disposition Amount: (Docket Text: (none. 2 D SORC - CONTINUED SENTENCE ORDER - Filing Date: j 30-JUN-2008 Filing Party: EPSTEIN, JEFFREY E Disposition Amount: I I http://courtcon.co.palm-beach.fl.us/pls/jiwpick_public qry_doct.cp_dktrpt_docket_report?b... 8/4/2009 EFTA00233642
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- Not an Official Document Page 4 of II 'Docket Text: Inone. 2E 1 RITE - WAIVER OF RIGHTS Filing Date: 30-JUN-2008 Filing Party: EPSTEIN, JEFFREY E Disposition Amount: Docket Text: none. 1 2F Filing Date: 30-JUN-2008 Filing Party: EPSTEIN, JEFFREY E Disposition Amount: Docket Text: none. 2G GLSS - GUIDELINE SCORESHEET Filing Date: 30-JUN-2008 Filing Party: !EPSTEIN, JEFFREY E Disposition Amount: Docket Text: none. 2H [ _OAFC - ORDER ASSESSING FEES/COST Filing Date: Filing Party: 30-JUN-2008 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: Docket Text: 'Filing Date: Filing Party: RECOMMIT RCMIT - RECOMMITMENT Docket Text: Disposition Amount: 01-JUL-2008 none. CLSD - CLOSED CASE http://courteon.co.palm-beach.fl.us/p1s/jiwp/ek_public_qry_doct.cp_dktrpt_docket_report?b... 8/4/2009 EFTA00233643
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- Not an Official Document Page 5 of 1 I 'Filing Date: 08-JUL-2008 Filing Party: Disposition Amount Docket Text: none. RCPT - RECEIPT FOR PAYMENT Filing Date: 14-JUL-2008 Filing Party: EPSTEIN, JEFFREY E Disposition Amount: Docket Text: A 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 Disposition Amount: Docket Text: PLEA CONFERENCE, TAKEN 6/30/08 6 MOT - MOTION Filing Date: 04-DEC-2008 Filing Party: EPSTEIN, JEFFREY E Disposition Amount: Docket Text: TO CLARIFY SENTENCE TO CORRECT SCRIVENER'S ERROR FILED BY JACK GOLDBERGER 7 1AGOR - AGREED ORDER Filing Date: 04-MAY-2009 Filing Party: JEPSTEIN, JEFFREY E Disposition Amount: Docket Text: (JUDGE COLBATH) THAT THE ORDER OF COMMUNITY CONTROL IS CORRECTED TO DELETE SPECIAL CONDITION #26 AND #27. 8 MOT - MOTION http://courteon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doctop_dktrpt_docket_report?b... 8/4/2009 EFTA00233644
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- Not an Official Document Page 6 of I I Filing Date: Filing Party: Disposition Amount: Docket Text: (NONPARTY E.WS) TO VACATE ORDER SEALING RECORDS AND UNSEAL RECORDS. 112-MAY-2009 EPSTEIN, JEFFREY E 9 ORSH - ORDER SETTING HEARING Filing Date: Filing Party: Disposition Amount: Docket Text: 15-MAY-2009 EPSTEIN, JEFFREY E SET FOR 5/29/09 RE:MOTION TO VACATE ORDER TO SEAL AND UNSEAL RECORD EVSCH - HEARING EVENT SCHEDULED Filing Date: Filing Party: Disposition Amount: Docket Text: 10 19-MAY-2009 none. NOH - NOTICE OF HEARING Filing Date: Filing Party: Disposition Amount: Docket Text: 12 Filing Date: 26-MAY-2009 EPSTEIN, JEFFREY E SET FOR 5/29/09 10:30 PONG - PLEA OF NOT GUILTY 29-MAY-2009 Filing Party: EPSTEIN, JEFFREY E Disposition Amount: Docket Text: linone. EVSCH - HEARING EVENT SCHEDULED Filing Date: Filing Party: Disposition Amount: Docket Text: 01 -JUN-2009 NON PARTY E.W.'S MOTION TO VACATE ORDER SEALING RECORDS AND UNSEAL RECORDS EVCAN - EVENT http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dktrpt_docket_report?b... 8/4/2009 EFTA00233645
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- Not an Official Document Page 7 of II IICANCELLED/SETTLED I Itting 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 AM FILED BY BRADLEY EDWARDS, MOTION TO VACATE ORDER RECORDS, HEARING SEET FOR ON 6/10/2009 AT 10:30 ESQ. RE: NON PARTY E.W.'S SEALING RECORDS AND UNSEAL 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 FILED BY BRADLEY EDWARDS, RECORD AND UNSEAL RECORDS ESQ. 14 1 MOT - MOTION Filing Date: 03-JUN-2009 Filing Party: EPSTEIN, JEFFREY E Disposition Amount: Docket Text: PALM BEACH POST'S MOTION 'FOR ACCESS FILED BY DEANNA TO INTERVENE AND PETITION SHULLMAN, ESQ. EVRST EVENT RESET Filing Date: 10-JUN-2009 Filing Party: EPSTEIN, JEFFREY E Disposition Amount: Docket Text: r CR-BELTRAN. MOTION TO INTERVENE ON MOTION TO UNSEAL. RESET BLE -GRANTED. NO ACTION FOR MOTION HRG ON 6/25/09. _J 15 FIORD -ORDER Filing Date: 10-JUN-2009 Filing Party: EPSTEIN 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 EFTA00233646
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- Not an Official Document Page 8 of I] 'Docket Text: (COLBATH) 16 CEF - COURT EVENT FORM Filing Date: 10-JUN-2009 Filing Party: PEPSTEIN, JEFFREY E Disposition Amount: Docket Text: none. 17 LORD -ORDER Filing Date: 10-JUN-2009 Filing Party: EPSTEIN, JEFFREY E IDisposition Amount: Docket Text: (COLBATH) EVSCH SCHEDULED - HEARING EVENT 'Filing Date: 11-JUN-2009 JI !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. FILED BY J. GOLDBERGER, ESQ 18 MOT - MOTION Filing Date: 15-JUN-2009 Filing Party: EPSTEIN, JEFFREY E Disposition Amount: Docket Text: TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW. FILED BY S. KUBIN, ESQ EVSCH SCHEDULED - HEARING EVENT Filing Date: 25-JUN-2009 Filing Party: Disposition Amount: Docket Text: ^TO STAY DISCLOSURE http://courtcon.co.palm-beach.fLus/pls/jiwp/ck_public_qry_doct.cp_dIctrpt_docket_report?b... 8/4/2009 EFTA00233647
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- Not an Official Document Page 9 of II I EVHLD - EVENT HELD Filing Date: 25-JUN-2009 Filing Party: EPSTEIN JEFFREY E Disposition Amount: Docket Text: CR-WIGGINS (COLBATH) DEFT PRES W/J.GOLDBERGER, GRANTED, CASE RESET FOR MOTION TO STAY DISCLOSURE EVSCH - SCHEDULED HEARING EVENT Filing Date: 25-JUN-2009 Filing Party: Disposition Amount: Docket Text: TO STAY DISCLOSURE 20 I CEF - COURT EVENT FORM Filing Date: 25-JUN-2009 Filing Party: EPSTEIN, JEFFREY E Disposition Amount: Docket Text: none. 21 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: !Filing Party: 26-JUN-2009 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 J MOT - MOTION Filing Date: 26-JUN-2009 Filing Party: EPSTEIN JEFFREY E ,I.Disposition Amount: http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dIctrpt_docket_report?b... 8/4/2009 EFTA00233648