081.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 DEC 17 PM 2:40
SHARON R. BOCK, CLERK
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’s travel for business purposes related to ongoing litigation. 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. The Defendant was given permission to travel to New York on December 3, 2009 for the purposes of meeting with his attorney, Harry Susman.
4. After being granted permission, the Defendant arranged his travel plans with his community control officer, Carmen Sloane, and traveled to New York in complete compliance with the rules set forth by his community control officer.
5. The Defendant needs to travel out of state for additional meetings with his attorneys to continue to review documents. See letter from Harry Susman attached hereto as Exhibit “A”.
6. Given the Defendant’s complete compliance with the terms of supervision since being placed on community control on July 22, 2009, the Defendant’s community control officer, Carmen Sloane, has no objection to the Defendant being given permission to travel for purposes related to his ongoing litigation as long as the dates and times of travel are cleared in advance and approved by his community control officer.

WHEREFORE, the Defendant moves this Honorable Court to enter an Order authorizing the Defendant to travel for business purposes related to ongoing litigation as long as it is approved in advance by his community control officer.

I HEREBY CERTIFY that a copy of the foregoing has been furnished by fax and 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, 3444 South Congress Avenue, Lake Worth, Florida 33461, this 16th day of December, 2009.

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

[NOT A CERTIFIED COPY watermark appears throughout]

[Exhibit A]
SUSMAN GODFREY L.L.P.
A REGISTERED LIMITED LIABILITY PARTNERSHIP
SUITE 5100
1000 LOUISIANA STREET
HOUSTON, TEXAS 77002-5096
(713) 651-9366
WWW.SUSMANGODFREY.COM

HARRY P. SUSMAN
DIRECT DIAL (713) 653-7875
E-MAIL HSUSMAN@SUSMANGODFREY.COM

December 7, 2009

Via E-mail & First Class Mail

Jack Goldberger, Esq.
Atterbury Goldberger & Weiss, P.A.
250 Australian Avenue South, Suite 1400
West Palm Beach, FL 33401-5012

Re: Jeffrey Epstein

Dear Jack:

On December 3, 2009, Jeffrey Epstein and I met with opposing counsel in New York City, New York on a matter to review certain confidential documents, which counsel only would provide for our review in his offices. The meeting was very helpful, but necessary time with Mr. Epstein was cut short due to his obvious time constraints.

It is clear that the case requires considerable time, and is at the stage that we must review considerable additional documents and attempt to interview potential witnesses. It is impractical to bring the lawyers for the other side with their documents to Florida and Mr. Epstein’s presence is required to prepare for and interview potential witnesses, who live in the New York area. We will need three more days of meetings with Mr. Epstein to determine our next course of action.

As a result, I would request that you provide me with a period of three days when Mr. Epstein can be available in New York to continue to work with us on this matter.

Thank you.

Sincerely,
Harry P. Susman

cc: Jeffrey Epstein