EFTA00231917

20 
1 
of this, but under Rule 9.310, if your 
2 
Honor were to issue such a stay, we would 
3 
point out the provision C of the rule, 
4 
which requires a posting of the bond. 
5 
We not only agree with your Honor's 
6 
ruling, but we believe such appeal they are 
7 
filing is absolutely frivolous and we are 
8 
going to be requesting fees and cost for 
9 
the filing of that appeal, so as a result, 
10 
we are requesting a bond be posted if a 
11 
stay of any type is issued in this case 
12 
because of the fact that we want to make 
13 
sure that our attorneys' fee and costs are 
14 
covered for the frivolous nature of the 
15 
appeal. And it's dictated strictly in 
16 
subsection A. It gives the Court the 
17 
authority. It says: 
18 
A stay pending review may be 
19 
conditioned upon a good and sufficient 
20 
bond, other conditions or both. Therefore, 
21 
we believe your Honor does have the 
22 
authority to issue such a requirement that 
23 
the posting of a bond be issued. 
24 
THE COURT: All right. Thank you 
25 
very much. 
I will deny the motion to stay. 
SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER 
EFTA00232537

21 
1 
I will delay the release of the documents 
2 
until noon Thursday. I will deny the 
3 
request to compel the movant, the 
4 
defendant, Mr. Epstein, to post a bond, and 
5 
I'll let the appellate court tell us and 
6 
teach us what the law on this case will be. 
7 
It's always interesting how these 
8 
cases unfold and come to us a little 
9 
different than everyone else. Now, let me 
10 
have the attorneys come up here and 
11 
approach. 
12 
(The following proceedings were held 
13 
sidebar, out of the hearing of the jury.) 
14 
THE COURT: I reviewed the two 
15 
documents, I didn't see any kids' names in 
16 
there. Everybody was hinting the 
17 
children's names or the initials' names. I 
18 
had my big black highlighter out, I don't 
19 
see anything worth redacting, so. 
20 
MR. GOLDBERGER: it's the plaintiff's 
21 
document that identifies the children's 
22 
names. It's a letter to me actually. 
23 
THE COURT: I was wondering if 
24 
everybody thought there was something in 
25 
there that wasn't in there. 
SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER 
EFTA00232538

22 
1 
MR. CRITTON: It's a test of your 
2 
skills, your Honor. 
3 
THE COURT: You're right, exactly. 
4 
One is page one through seven, and the 
5 
second one is just two pages that's not 
6 
even signed by everybody. 
7 
MR. GOLDBERGER: While we're all up 
8 
here chatting, there are references to 
9 
other names up here. 
10 
THE COURT: Yes, Mr. Goldberger, and 
11 
no one has identified in the document says 
12 
these are people that are not going to be 
13 
prosecuted. Mr. Kuvin made the argument 
14 
that these are co-conspirators. These are 
15 
innocent people that have nothing to do 
16 
with these proceedings. They have nothing 
17 
to do with 
18 
MS. SHULLMAN: They have a standing. 
19 
THE COURT: I will renew my ruling 
20 
that I gave you yesterday, and deny your 
21 
request to redact those names out of there. 
22 
All right, so I'll hang on to these till 
23 
Thursday at noon, and anybody that comes 
24 
wants to come and get them, I don't know if 
25 
there's a mechanism for -- I stand on the 
SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER 
EFTA00232539

23 
1 
courthouse steps and pass them out. 
2 
MS. SHULLMAN: If there are no 
3 
redactions to be made. 
4 
THE COURT: No redaction. 
5 
MS. SHULLMAN: I would do an order 
6 
directing the Court to release them and 
7 
they may become unsealed. You don't 
8 
need --
9 
MS. COMPIANI: Your Honor, are you 
10 
going to write up a written order 
11 
denying --
12 
MR. GOLDBERGER: Are you going to do 
13 
that? 
14 
THE COURT: Put together a written 
15 
order? 
16 
MS. SHULLMAN: Denying the stay? 
17 
THE COURT: Yes, A, denying the stay; 
18 
B, delaying the disclosure or unsealing of 
19 
these documents until noon Thursday; C, 
20 
denying the motion for bond. 
21 
MR. GOLDBERGER: And you'll need that 
22 
order quickly. 
23 
THE COURT: Yeah, fax that and we'll 
24 
get it signed quick today. 
25 
MR. GOLDBERGER: Are you forcing the 
SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER 
EFTA00232540

24 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
court reporter to work over the weekend so 
we can get a transcript? 
MR. CRITTON: Thank you, your Honor, 
for moving us this morning. 
(Side bar conference held outside the 
hearing of the jury concluded.) 
SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER 
EFTA00232541

25 
1 
2 
3 
4 
THE STATE OF FLORIDA, 
5 
COUNTY OF PALM BEACH. 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
June 2009. 
19 
20 
21 
22 
23 
24 
25 
CERTIFICATE 
I, SUSAN S. WIGGINS, R.P.R., Official 
Court Reporter for the Fifteenth Judicial Circuit, 
Criminal Division, in and for Palm Beach County, 
Florida; do hereby certify that I was authorized 
to and did report the foregoing proceedings before 
the Court at the time and place aforesaid; and 
that the preceding pages numbered from 1 to 24, 
inclusive, represent a true and accurate 
transcription of my stenonotes taken at said 
proceedings. 
IN WITNESS WHEREOF, I have hereunto 
affixed my official signature this 29th day of 
SUSAN S. WIGGINS,R.P.R. 
SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER 
EFTA00232542

CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that a copy of the foregoing has been sent by E-Mail 
and Federal Express this 300-4 day of June, 2009, to: 
JEFFREY H. SLOMAN 
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 33394 
Counsel for 
SPENCER T. KUVIN 
LEOPOLD-KUVIN, P.A. 
2925 PGA Boulevard, Suite 200 
Palm Beach Gardens, FL 33410 
Counsel fore. 
JUDITH STEVENSON ARCO 
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 
Palm Beach County Courthouse 
205 North Dixie Highway 
Room 11F 
West Palm Beach, FL 33401 
ROBERT D. CRITTON 
BURMAN, CRITTON, LUTTIER & COLEMAN 
515 North Flagler Drive, Suite 400 
West Palm Beach, FL 33401 
and 
JACK A. GOLDBERGER 
ATTERBURY, GOLDBERGER & 
P.A. 
250 Australian Avenue South, Suite 1400 
W t Pal 
ch, FL 33401 
and 
EFTA00232543

Counsel for Petitioner 
JANE KREUSLER-WALSH and 
BARBARA J. COMPIANI of 
KREUSLER-WALSH, COMPIANI & VARGAS, P.A. 
501 South Flagler Drive, Suite 503 
ch, FL 33401-5913 
NE 1=1.7;
14
2.-VVALSH 
lorida Bar No. 
EFTA00232544

EFTA00232545

MARTIN G. WEINBERG, 
ATTORNEYELAW 
20 PARK PLAZA SUMS/OM 
EMAIL ADDRESSES: 
IfdriTON, MASSACHUSETTS 02116 
FAX 
July 22, 2011 
Assistant United States Attorney 
United States Attorney's Office 
Southern District of Florida 
500 S. Australian Ave. Suite 400 
West Palm Beach, Florida 33401 
Re: 
Jeffrey Epstein 
Dear Ms. MB 
Roy Black forwarded to me your letter to him dated July 21, 2011, from the District 
Attorney of the County of New York. We thank you for providing notice of the intended 
disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related 
list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an 
enforceable subpoena - which we would have the right to move to quash in the Court from which 
it was issued - there exists no right or duty to disclose the confidential Non-Prosecution 
Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the 
NPA. Further, given that the witness/victim list was compiled based on the federal grand jury 
investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court 
order. 
Very truly yours, 
471a.,t 2gi 
Martin G. Weinberg 
cc: Roy Black 
EFTA00232546

07/22/2011 15:55 
3053582006 
BSKS 
PAGE 02 
ZO PARK PLAZA, MIMI MN 
mem% MASUClitUrt9.92116 
NUM' LIVERMICY: 
017), II4i71 
MARTIN G. WEINBERG, P.C. 
A 7TORNEMIAW 
Assistant United States Attorney 
United States Attorney's Office 
Southern District of Florida 
500 S. Australian Ave. Suite 400 
West Palm Beach, Florida 33401 
Re: 
Jeffrey Epstein 
Dear Ms. 
July 22, 2011 
RAM 1): ADDRESSES" 
Roy Black forwarded to me your letter to him dated July 21, 2011, from the District 
Attorney of the County of New York. We thank you for providing notice of the intended 
disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related 
list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an 
enforceable subpoena - which we would have the right to move to quash in the Court from which 
it was issued - there exists no right or duty to disclose the confidential Non-Prosecution 
Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the 
NPA. Further, given that the witness/victim list was compiled based on the federal grand jury 
investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court 
order. 
Very truly yours, 
411 DS 
i9 
Martin G. Weinberg 
cc: Roy Black 
EFTA00232547

07/22/2011 15:55 
3853582006 
BSKS 
PAGE 
81 
BLACK 
SPEBNICK 
KOPNSPAN 
STUMPF 
TO: 
RE: 
Afffee9 ep54eio-
DATE: 
July 22, 2011 
SENDER: 
Jackie Perczek 
NO. OF PAGES (INCLUDING TRANSMITTAL SHEET): 
MESSAGE: 
Wr\ibLAI 
TRIAL ATTORNEYS 
Roy Black 
Howard M. Srebnick 
Scott A. Komspan 
Larry A. Stumpf 
Maria Neyra 
Jackie Peraek 
Mark A.J. Shapiro 
Jared= 
Marcos Beaton, Jr. 
Jessica Fonseca-Nader 
Kathleen P. Phillips 
Jenifer J. Soulikias 
Noah Fox 
Joshua Shore 
FACSIMILE TRANSMITTAL SHEET 
FAX: 
TELEPHONE: 
AUSA 
, Esq. 
N.•/- TARS, 
11/Jo 
"IF YOU DO NOT RECEIVE ALL PAGES, PLEASE CALL 
THIS ractosms COlteATIMPERRIOSOISS ARE COMIthENTIAL DITORMATION. INTENDED ONLY. FOR PRE VSE-PII TW 
INDIVISKIAt. OR tIttnYEAMED ABOVE. PP THE READER OF THIS FACED= IB ROT TEE trots= RECIPIENT„ OR THE 
EMPLOYEE OR Assn. RESPONSIBLE FOR DELIVERING rr TO TEE INTERDED:gettpan, YOU ARE REMIT Norm= 
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AT THE ABOVE ADDRESS VIA THE DE POSTAL SERVICE. TRAM YOU. 
• 
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201 8. Biscayne Boulevard, Suite 1300, Miami, Florida 33131 1(P) 
1(F) 
I www royblack.com 
EFTA00232548

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 S Australian Ave, Ste 400 
West Palm Beach, FL 33401 
Facsimile: 
July 27, 2011 
DELIVERY BY FACSIMILE 
Martin G. Weinberg, Esq. 
20 Park Plaza, Suite 1000 
Boston, MA 02116 
Re: 
Jeffrey Epstein 
Dear Mr. Weinberg: 
Thank you for your letter of July 22, 2011. In order to review and address the objections that 
you raised in that letter, the Office deferred making its planned disclosure to the District Attorney 
of the County of New York of the Non-Prosecution Agreement ("Agreement") and the list of 
identified victims that was provided to Mr. Epstein pursuant to the Agreement. Nonetheless, after 
completing a full review of your objections, the Office still intends to proceed with the planned 
disclosures. 
The Agreement requires the Office only to provide Mr. Epstein with notice prior to a 
disclosure of the Agreement "[Of the United States receives a Freedom of Information Act request 
or any compulsory process"; the Agreement does not require Mr. Epstein's concurrence in any 
disclosure. Contrary to your suggestion, the Agreement (including paragraph 13) also does not make 
the Agreement itself "confidential." On the contrary, the Agreement expressly contemplates that 
disclosures of the Agreement may be made, and the Agreement further contemplates, contrary to 
your suggestion, that such disclosures of the Agreement may be made other than in response to 
"compulsory process." Here, moreover, the District Attorney of the County of New York, as a local 
law enforcement agency, has provided a legitimate request for disclosure of the requested 
information, as well as a promise to maintain the confidentiality of the information, particularly the 
names of the minor victims. 
/ our objection pursuant toTederal Rule of Cnmrnai Procedure 6(e) also does not impact the 
planned disclosures. The victim list itself is not grand jury material, and, thus, disclosure of that list 
to the District Attorney's Office will not violate Rule 6(e). 
If you wish to supply any additional authority (other than citation to Rule 6(e) and to 
paragraph 13 of the Agreement) for your claims that the Office cannot disclose the Agreement and 
EFTA00232549

MARTIN WEINBERG, ESQ. 
JULY 27, 2011 
PAGE 2 OF 2 
the victim list to the District Attorney of the County of New York, we would be willing to consider 
those authorities before making any disclosure, provided that any such authorities are furnished to 
us before 5:00 p.m. on July 29, 2011. Otherwise, seeing no obstacle to the previously-planned 
disclosures, the Office will be disclosing copies of both the Non-Prosecution Agreement and the list 
of identified victims that was provided to Mr. Epstein to the District Attorney of the County of New 
York at 5:00 p.m. on July 29, 2011. 
Sincerely, 
Wifzedo A. Ferrer 
United States Attorney. 
By: 
Assistant United States Attorney 
cc: 
Chief, Northern Division 
Deborah L. Morse, Assistant District Attorney, County of New York 
Roy Black, Esq. 
EFTA00232550

United States Attorney's Office 
Southern District of Florida 
500 S. Australian Ave., Suite 400 
West Palm Beach, FL 33401-6235 
DATE -1/4
7/2 0// 
TO: 
ItA/K77A) Ale/N,8m0 
ORGANIZATION 
FAX Si: 
SUBJECT: jerrim ElosrcliQ 
FROM: 
(Fax) 
NUMBER OF PAGES, INCLUDING THIS PAGE:  
COMMENTS: 
Original document: 
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To follow via hand delivery 
Nothireto follow, FAX -7. original 
EFTA00232551

Fax Send Report 
Date/Time 
Fax Number 
Fax Name 
Model Nacre 
NO. Name/Number 
: JUL-27-2011 03:01PM FLED 
: Phaser 33001.7P 
StartTime 
Time Mode 
Page 
Result 
246 
07-27 03:00PM 00'31 ECM 
003/003 CLR 
United Slates Attorney's Unite 
Southern District of Florida 
500 S. Australian Ave., Suite 400 
West Palm Beach, IN. 33401-6235 
DATE 7/42720c
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TO. 
ORGANIZATION: 
FAX IV: 
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FROM: 
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NUMBER OF PAGES. INCLUDING THIS PAGE: 3 _ 
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EFTA00232552

United States Attorney's Office 
Southern District of Florida 
500 S. Australian Ave., Suite 400 
West Palm Beach, FL 33401-6235 
DATE: .7/2 712.O(  
TO: beloo-al Mcvse 
ORGANIZATION: New fork bisfritti44 
FAX #: 
SUBJECT: s.71Fi 
FROM: 
(Fax) 
NUMBER OF PAGES. INCLUDING THIS PAGE: 3 
COMMENTS: 
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EFTA00232553

Fax Send Report 
Date/Time 
Fax Number 
Fax Plane 
Model Name 
: 
JUL-27-2011 03:03PM ',
No. 
Name/Number 
Phaser 3300MFP 
StartTime 
Time Made 
Page 
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NUMBER OF PAGES. INCLUDING THIS PAC,F 3_ _ . 
COMMENTS: 
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United States Attorney's Office 
Southern District of Florida 
SOO S. Australia° Ave., Sulu. 400 
West Palm Beach, F1.334014335 
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EFTA00232554

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 S. Australian Ave, Ste 400 
West Palm Beach, FL 33401 
Facsimile: 
July 21,2011 
DELIVERY BY ELECTRONIC MAIL 
Roy Black, Esq. 
Black Srebnick Komspan & Stumpf P.A. 
201 S. Biscayne Blvd, Suite 1300 
Miami, FL 33131 
Re: 
Jeffrey Epstein 
Dear Mr. Black: 
On July 17, 2011, the Office received a written request from the District Attorney of the 
County of New York for a copy of the signed Non-Prosecution Agreement and the list of identified 
victims that was provided to Mr. Epstein pursuant to the Non-Prosecution Agreement. Pursuant to 
the District Attorney's request, the U.S. Attorney's Office intends to disclose these items to Deborah 
L. Morse, Assistant District Attorney, at 5:00 p.m. on Friday, July 22, 2011. Pursuant to the terms 
of the Non-Prosecution Agreement, the Office is hereby giving you notice of this intended 
disclosure. 
Sincerely, 
Wifredo A. Ferrer 
United States Attorne 
By: 
Assistant United States Attorney 
cc: 
Chief, Northern Division 
Deborah L. Morse, Assistant District Attorney, County of New York 
EFTA00232555

United States Attorney's Office 
Southern District of Florida 
500 S. Australian Ave., Suite 400 
West Palm Beach, FL 33401-6235 
DATE: 7/21/20 
TO: 
.) Lc rkaki 
/(4OOe 
ORGANIZATION: biqrief
FAX #: 
SUBJECT: 
FROM: 
(Fax) 
NUMBER OF PAGES. INCLUDING THIS PAGE:  Z
COMMENTS: 
Original document: 
 
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To follow via Federal Express 
To follow via hand delivery 
NothiriTto follow, FAX = original 
EFTA00232556