IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICAL CIRCUITO
IN AND FOR PALM BEACH COUNTY
FLORIDA, CRIMINAL DIVISION

2009 JUL-6 AM 11:26

FILED

STATE OF FLORIDA,

VS.

Case Nos

JEFFREY EPSTEIN,

Defendant.

NONPARTY

[ ] a nonparty, moves pursuant to Administrative Rule 2.303 for attorneys fees

and costs on the following grounds:

1. [ ] is filed a motion to vacate the agreed rder sealing records and to unseal

the nonprosecutuion agreement and addendu in this file. Also, [ ] opposed

defendant's motion to unseal said recor motion was granted and defendant's

was denied at hearing on June 26, 20

2. is entitled to an award of reasonable attorneys fees and costs pursuant to

said Administrative Rule. Defendant's motion to seal and his opposition to Administrative Rule.

motion were not made in good faith and were not supported by a sound legal or factual were not made in
ONA
basis.

3.1 3.1 adopts adopts and incorporates by reference all arguments in the motion for fees and

filed by The Palm Beach Post.

I HEREBY CERTIFY that a true and correct copy of the foregoing has been served via U.S. Mail this Jrd.. day ofJuly, 2009 to: Jack Alan Goldberger, Esq., Atterbury Goldberger et al., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401;

Michael McAuliffe, Esq. and Judith Stevenson Arco, Esq., State Attorney's Office-West Palm Beach, 401 North Dixie Highway, West Palm Beach, FL 33401; and Deanna K. Shullman, Esq. and James B. Lake, Esq., 101 N.E. Third Avenue, Suite 1500, Fort Lauderdale, FL 33301.

ROTHSTEIN ROSENFELDT ADLER
Attorneys for E.W.
401 East Las Olas Blvd., Suite 1650
Fort Lauderdale, Florida 33394
Telephone (954) 522-3456
Telecopier (954) 527-8663
By: <signature>
for William J. Berger
Florida Bar No. 197701
wberger@rra-law.com

H:\swrdocs\09-22784 Wild v. Epstein\EPSTEIN M-FEES.doc H:\swrdocs\09-22784 Wild v. Epstein\EPSTEIN M-FEES.doc

NOTA

ROTHSTEIN ROTHSTEIN ROSENFELDT ADLER ROSENFELDT
Attorneys for E.W. Attorneys
401 East Las Olas Blvd., Suite 1650 401
Fort Lauderdale, Florida 33394 Fort
Telephone (954) 522-3456 Telephone
Telecopier (954) 527-8663 Telecopier (954)

CERTIFOLY

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