077.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 2008CF009381A
STATE OF FLORIDA
vs.
JEFFREY EPSTEIN,
Defendant.

FILED
2009 NOV 25 PM 12:32
SHARON R. BOCK
CLERK & COMPTROLLER
PALM BEACH COUNTY, FL
CIRCUIT CRIMINAL

MOTION FOR AUTHORIZATION TO TRAVEL

COMES NOW the Defendant, JEFFREY EPSTEIN, by and through his undersigned attorney and moves this Honorable Court to enter an Order authorizing the Defendant to travel to New York on December 3, 2009 and December 12, 2009. In support thereof the Defendant would state as follows:

1. The Defendant has been on community control since July 22, 2009.
2 The Defendant has been in complete compliance with his conditions of community control since being placed on supervision.
3 At a hearing on November 18, 2009 concerning the status of a No Contact Order, the Defendant, through counsel, requested this Honorable Court to allow the Defendant to travel for business purposes as long as he received the prior approval of his probation officer. The Court denied the motion at that time without prejudice and indicated that when there is a specific business trip planned for the Defendant to bring the matter back before the Court and it would be considered.
4 The Defendant desires to travel to New York on December 3, 2009 and to return to West Palm Beach on the same date. The purpose of the meeting is for the Defendant to meet with his attorney, Stephen Susman at the Law Office of Davis Polk and Wardwell, located at 450 Lexington Avenue, New York, New York 10017. The purpose of the meeting is for Mr. Epstein and his attorney to review documents at the Davis Polk Law Offices. Attached hereto as Exhibit “A” is a letter from the Defendant’s civil counsel, Stephen Susman, confirming the need for the meeting to take place at the Davis Polk Law Office in New York.

5 The Defendant would travel to New York on the morning of December 3, 2009 and would return to West Palm Beach on the evening of December 3, 2009. The Defendant would confirm the specific times of his travel with his probation officer prior to travel.
6. The Defendant also needs to travel to New York on December 12, 2009 for a meeting with a governmental official from a foreign country. Once again, the Defendant would travel to New York on the morning of December 12, 2009 and would return the evening of December 12, 2009. The Defendant would once again confirm the specific travel times with his probation officer prior to travel.

WHEREFORE, the Defendant moves this Honorable Court to enter an Order authorizing the Defendant to travel for the day on December 3, 2009 and December 12, 2009.

I HEREBY CERTIFY that a copy of the foregoing has been furnished by mail to Barbara Burns, Esquire, State Attorney’s Office, 401 North Dixie Highway, West Palm Beach, Florida 33401 and to Carmen Sloane, Department of Corrections, 423 Fern Street, West Palm Beach, Florida 33401, this 24th day of November, 2009.

[Signature]
JACK A. GOLDBERGER, ESQ.
Atterbury, Goldberger & Weiss, P.A.
250 Australian Avenue South
Suite 1400
West Palm Beach, Florida 33401
(561) 659-08300
Florida Bar No. 262013

[PAGE 3 - EXHIBIT A]
SUSMAN GODFREY L.L.P.
A REGISTERED LIMITED LIABILITY PARTNERSHIP
SUITE 5100
1000 LOUISIANA
HOUSTON, TEXAS 77002-5096
(713) 651-9366
FAX (713) 654-6666
WWW.SUSMANGODFREY.COM

STEPHEN D. SUSMAN
DIRECT DIAL (713) 653-7801

November 24, 2009
VIA EMAIL
Mr. Jeffrey Epstein
3901 East 66 Street, 10B
New York, NY 10065

Re: Potential Claims against D.B. Zwirn

Dear Jeffrey:
I need you to come to New York City on December 3rd to meet with me and go to Davis Polk’s office to review some documents that they will only show us in their office. They claim they are subject to confidentiality agreements. This is necessary to help us evaluate the above claim.

Sincerely,
[Signature]
Stephen D. Susman

cc: Daryl Indyke
Harry Susman
994707v1/011585