Michael R. Tein

⚠ what this page is about, and what it is not

This page records what a Miami lawyer filed, wrote and signed for Jeffrey Epstein between July 2008 and May 2009, and it stays inside that. It is not a biography, it carries no allegation against him of any kind, and it says nothing about his practice before or after. The women suing Epstein in these cases appear in the record as Jane Does or under initials and are not named, described or reconstructed here.

Role here	Counsel for Jeffrey Epstein: co-counsel of record in the civil suits brought against him in the Southern District of Florida, and the lawyer the U.S. Attorney’s Office wrote to about the Non-Prosecution Agreement12
Firm	Lewis Tein, PL, Coconut Grove, Florida. ⚠ The firm name is partly blacked out on the filings themselves3
First on the record	7 July 2008, by Notice of Appearance as Co-Counsel1
Last on the record	20 May 2009, when the court granted leave to withdraw and the docket recorded him terminated4
Span	317 days
Signed filings	At least fifteen distinct instruments, across six federal case numbers and one state case. ⚠ The true figure is higher and the page says why5
Signatures	Both kinds. Court filings carry a conformed electronic /s/; several also carry his signature in ink6
Bar	Florida Bar No. 993522, as printed in his own signature blocks1

The exchange that matters most

Two weeks into the engagement he was in correspondence with the U.S. Attorney’s Office about whether his client was keeping to the Non-Prosecution Agreement, and the next day that office declared the Agreement broken.

On 17 July 2008 the office wrote to him. Its letter puts an either/or: either Epstein does not intend to abide, in which case “the federal investigation can continue”, or he “intends to fully abide by the Non-Prosecution Agreement”, in which case the grand jury investigation stays suspended. It closes with a specific demand:

Please advise whether you intend to correct the representations to the Court regarding the status of the federal investigation.⁷

On 21 July 2008, by facsimile at 6:38 p.m., he answered. He took the either/or:

Thank you for your letter of July 17, 2008. In it, you ask whether Mr. Epstein “intends to fully abide by the Non-Prosecution Agreement.” The answer is yes.

He then argued that the stay of the civil suits was not a choice but a statutory command:

As you know, there is no provision in the Agreement referring in any way to Section 3509(k). By that statute, Congress imposed a mandatory obligation on federal district courts to stay certain civil cases. Its operation is not subject to the control or discretion of any party. Whether Title 18, United States Code, Section 3509(k) applies to this civil litigation is a question of law for resolution by Judge Marra. Accordingly, we are abiding by our ethical obligation to advise the Court of its statutory mandate under Section 3509(k).

He agreed to withdraw a pending motion to quash, and copied Jack Goldberger, Roy Black and Alex Acosta. The letter is signed in ink.²

⚠⚠ He did not answer the question the letter closed with. The office asked whether he intended to correct the representations already made to the Court. His reply addresses whether Epstein would abide, and why the stay was mandatory, and says nothing about correcting anything. An earlier version of this page reported the office as having asked only the abide question, which is how his own letter frames it. That was this desk adopting one side’s summary of a document it had.⁷

The next day the United States Attorney answered, and took the opposite view of the same act. Over Acosta’s name, addressed “Dear Mr. Tein”:

that the United States Attorney has determined, based upon reliable evidence, that, during the period of the Non-Prosecution Agreement, Jeffrey Epstein has willfully violated the conditions of the Agreement.

and, in a sentence that points straight back at the letter of the day before:

By seeking to stay all civil litigation, during what you assert is the term of the Non-Prosecution Agreement, Mr. Epstein is avoiding that essential contractual term.⁸

So the disagreement is this. Counsel says the stay is compelled by statute and that telling the court so is an ethical duty. The United States Attorney says seeking that stay is itself the breach. One day apart, both in writing, both in this release.

⚠ This page takes no position on which reading of the Agreement was right. ⚠ The breach notice’s stated grounds include a statement made to a newspaper by Epstein’s publicist, not by counsel. It is set out on that document’s own page and deliberately not restated here, because putting it beside this man’s name would place words near him that are not his.⁸

What the stay motion actually argued, and how it ended

The argument is not missing from the release, and this page does not have to guess at it. And the sealed reply of 28 July 2008 is in the release too, eight times over, which means the argument can be given from the parent document rather than inferred from neighbouring ones.⁹ The firm’s stay briefing was filed under seal in July 2008 and unsealed on 3 September 2008; a companion brief was filed in a second case. Both move expressly under 18 U.S.C. § 3509(k) and § 1595(b)(1).¹⁰

⚠ A correction of this desk’s own reading. An earlier draft glossed § 1595 as “the provision giving trafficking victims a civil claim for damages”. That is the wrong half of the statute for this argument. § 1595(b)(1) is the stay provision: it directs that a civil action be stayed while a related criminal action is pending. The briefs use it as a stay mandate, not as a cause of action, and a page that described it the other way would have inverted the argument it was reporting.¹⁰

What the sealed reply argued

The reply’s case is that the federal criminal action against Epstein had never stopped. That is what would make the civil stay mandatory, and the brief builds it out of the Agreement’s own terms. It begins from the statute’s definition:

In enacting § 1595, Congress specifically intended that the term “criminal action” would be applied extremely broadly. Accordingly, Congress took pains to ensure that courts would give it the broadest possible construction and, for that reason, specified in the definition provision that “criminal action” also “includes investigation.” 18 U.S.C. § 1595(b)(2).

and then lists six features of the Non-Prosecution Agreement: that the grand jury’s subpoenas remain “outstanding”, are “held in abeyance”, are not “withdrawn”, that the parties must “maintain their evidence” (“which would be entirely unnecessary if the investigation against Epstein were closed”), that “any” existing “charges” will not “be dismissed” until Epstein has “timely fulfill[ed]” the Agreement, and that prosecution “shall be deferred” but not closed or dismissed. From which:

then, the only reasonable conclusion is that the Federal Criminal Action remains “pending.”

Set beside the letter of seven days earlier, that is the whole position in two documents. To the prosecutor he wrote that Epstein intended to fully abide by the Agreement. To the court his firm argued that the Agreement’s own terms showed the federal criminal action was still live, and that the victims’ civil suits therefore had to stop. The United States Attorney’s answer to the first was that the second was the breach.⁹

⚠ The reply was sealed for a stated reason, printed on its own first page: the agreement “contains a confidentiality clause”.⁹

⚠ And the motion he was replying in support of was not his own. It is 08-80119 DE 12, filed 20 June 2008, seventeen days before he appeared in these cases. He inherited the stay motion and wrote the reply for it.¹¹

It did not work, and the docket dates the defeat. Signed by Judge Kenneth A. Marra on 5 August 2008 and entered the next day: “ORDER DENYING MOTION TO STAY and denying as moot 2 Motion for Hearing.” A later filing by the opposing side puts the reasoning:

The Court has since denied Defendants’ motion, holding a stay of this proceeding is not warranted under either the statute or the Court’s discretion.

Under the statute and under the court’s discretion, both. The mandatory-obligation reading did not survive.¹²

⚠ And it was refused twice. A “RELEVANT PLEADINGS” index for the lead Jane Doe action shows the stay denied there as well, at DE 33, also on 5 August 2008, so the sequence across the two actions is sealed 28 July, denied 5 August, unsealed 12 August. The same index records that the firm moved for a stay again on 25 March 2009, the third such motion it filed, and replied in support on 13 May 2009, six days before it moved to withdraw.¹¹

The 317 days

On 7 July 2008 the law firm Lewis Tein, PL entered its appearance as co-counsel for Jeffrey Epstein. The notice is one sentence:

NOTICE IS HEREBY GIVEN that the law firm of ▮ Tein, P.L. enters its appearance as co-counsel for Defendant Jeffrey Epstein in these proceedings.¹

A second appearance was filed the same day in 08-80380, and others in the remaining suits over the following days.

In late December 2008 the firm noticed its withdrawal as co-counsel in two of the cases. But that was not the end of it: on 19 May 2009 it moved for leave to withdraw in all four, and the court granted that motion on 20 May 2009, the docket recording “Attorney Michael Ross Tein terminated”. The May motion stated that absent a court order the firm “will continue to be listed as counsel for Mr. Epstein on the CM/ECF” system. Between the December notices and the May motions it filed a sealed stay motion in January 2009.⁴

⚠⚠ CORRECTION, made before this page was published. A draft of this page gave the engagement as 8 July to 30 December 2008, 175 days, and built a section around that figure. Both ends were wrong. The first appearance is a day earlier and in a different case; the December notices were not the end, because the firm itself said it remained counsel of record until the court released it. 7 July 2008 to 20 May 2009 is 317 days. ⚠ And a draft of this very correction put the end at 19 May, the date he asked rather than the date the court released him. That is the same error a third time, inside the fix for the second. The error came from taking the first and last documents a search returned as the first and last documents there are.⁴

The signatures, and a correction about them

Most of the court filings carry the typed string /s/ Michael R. Tein. This is a CM/ECF conformed signature, the electronic-filing convention by which a filer’s login stands for their hand, and this page does not call a /s/ ink.

⚠⚠ But several of these documents are signed in ink, and an earlier draft of this page said none was. On one sheet of the stay motion his signature appears twice in ink, once under a certificate of compliance and once under a certificate of service; the notice of removal in the same case carries two more. The 21 July 2008 letter to the U.S. Attorney’s Office is signed in ink as well.⁶

The draft said “there is no ink anywhere in this material”, then narrowed it to “no ink on the court filings”, and both were false. ⚠⚠ AND THE SAME MISTAKE THEN HAPPENED TWICE MORE, ABOUT DOCUMENTS RATHER THAN SIGNATURES. Two footnotes said a document was “not in the release” when it was: the motion this page’s subject was answering, and the pleading whose counts he moved to dismiss. Four false absences on one page, two of them written inside a correction of the previous one. The rule the page had already written for signatures is the rule for all of it: an absence found by searching is a statement about the search. Before writing that something is not in the release, name the control that proves the query would have found it.

In every one of these cases the gap was never a category of document that had not been searched. It was documents that had not been opened. The sealed reply of 28 July was found on the fourth pass by opening thirteen search results that three earlier passes had left closed. A universal negative about what a signature looks like cannot be established from a text layer at all: the text layer cannot see ink.

What he filed

Docketed	Filing	Case
7 Jul 2008	Notice of Appearance as Co-Counsel	08-803811
8 Jul 2008	Notice of Appearance as Co-Counsel; Reply in Support of Motion	08-802325
25 Jul 2008	Motion for Enlargement of Time to Answer or Otherwise Respond; Request for Oral Argument	08-80804, 08-801195
25 Jul 2008	Motion for Stay, filed under seal, unsealed 3 Sep 2008, 45 pages	08-8080410
29 Jul 2008	Defendant’s Notice of Filing Exhibits	four Jane Doe cases13
6 Aug 2008	Joint Motion to Approve Stipulation for Acceptance of Service of Process	5
8 Aug 2008	Opposed Motion to Align Response Date	08-808045
18 Aug 2008	Joint Discovery Plan / Scheduling Report	08-8081114
22 Aug 2008	Epstein’s Response to Motion to Preserve Evidence	08-8080415
4 Sep 2008	Motion to Dismiss Counts I, II and IV of the amended complaint	08-8080416
30 Dec 2008	Notice of Withdrawal as Co-Counsel	08-80119, 08-802324
7 Jan 2009	Motion for stay, sealed	4
19 May 2009	Motion for leave to withdraw, all four cases	4

⚠ And one entry that is not his: on 20 May 2009 the court granted the motion and the docket recorded “Attorney Michael Ross Tein terminated”. That is the court’s act, not a filing of his, which is why it is not a row in the table above.⁴

⚠ This table is a floor. See [^count] for why the number cannot be stated precisely.

The filing worth reading on its own

On 29 July 2008 he filed two exhibits into the record of four women’s lawsuits against Epstein:

A. Exhibit “A” is the July 9, 2008 Declaration of Assistant United States Attorney Ann ▮ C. Villafana, previously filed by the United States in In re: Jane Doe, Case No. 08-80736-CIV-Marra/▮ (S.D. Fla.) (DE 14).

B. Exhibit “B” is a copy of Title 18, United States Code, section 1595.

These exhibits were inadvertently omitted from the reply memorandum.

They were exhibits to Epstein’s Reply in Support of Motion to Stay.¹³ Read alongside the stay briefing above, the choice of exhibits is legible: § 1595 is in the record because § 1595(b)(1) was one of the two statutes the motion relied on.

One name is blacked out and the other is not

On the copies of the signature blocks cited by this page, the firm’s name is barred so that it reads ”▮ Tein, P.L.”; the first partner reads “GUY A. ▮”, surname barred; a further bar covers the line below; and “MICHAEL R. TEIN” is unbarred.³

⚠ That is a statement about these copies, not about the filings. A redaction is applied to a scan, and the same filing exists in the release in more than one production. An earlier draft of this page said the pattern “repeats across the filings”, which claimed more than any set of scans can show. This page says what the sheets it cites print, and does not compare one copy with another.³

⚠⚠ A WARNING FOR ANYONE WORKING THESE DOCUMENTS FROM SEARCHABLE TEXT. The extraction closes the gap where the bars are, so a signature block that shows barred names on the image comes out of the text layer reading as continuous text. A reader working from extraction alone will not know a redaction was there. Every redaction statement on this page was made at the image.

⚠ This page does not supply anything under a bar, and does not reproduce the professional identifier printed beside the barred surname. That the bar and the identifier sit on one sheet is an instance of the failed-redaction class already before the editor; it is recorded, not exhibited.

A certificate of service dated a year early

The 29 July 2008 notice carries a Certificate of Service beginning “I HEREBY CERTIFY that on July 29, 2007, I electronically filed the foregoing document”. The court’s own header on the same sheet reads Entered on FLSD Docket 07/29/2008. The certificate is wrong by exactly one year.¹³

⚠ A typing error in a form paragraph, recorded because a date lifted from it into a timeline would be wrong by a year.

What the release contains about him that this page does not use

The corpus holds material concerning Michael R. Tein that is unrelated to Epstein. It consists of unresolved civil allegations against him, with contemporaneous press. The release contains no disposition of any kind: no judgment, no order disposing of it, no dismissal, no settlement, no withdrawal.

This page will not carry them. An allegation published without its outcome does not inform a reader, it misleads one, because the reader supplies the outcome the allegation implies. Where this desk cannot state the end of a thing, it does not state the beginning of it either.

⚠ That absence has been measured twice, not assumed. A page-by-page read of every document in the release matching the matter, and a separate sweep intersecting the whole 384-document name universe against sixteen disposition terms, both returned nothing. Two apparent hits were checked and are unrelated.¹⁷

⚠ What is documented, and is about Epstein’s office rather than about him, is that the material reached Epstein’s circle: another lawyer in Epstein’s orbit forwarded the press coverage to his office the day after it appeared, and Epstein’s files kept it.¹⁸

Related

• Guy Lewis: his law partner; the payments from Epstein to the firm are set out there
• EFTA00189907: the breach notice addressed to him, in full
• Jeffrey Epstein
• Jack A. Goldberger: co-signatory on the same filings
• A. Marie Villafaña
• Epstein’s defence team
• Epstein civil litigation strategy

Footnotes

Footnotes

1. Notice of Appearance as Co-Counsel, Jane Doe No. 5 v. Jeffrey Epstein, No. 08-CV-80381-MARRA-JOHNSON (S.D. Fla.), Document 16, Entered on FLSD Docket 07/07/2008, p.1 of 2. EFTA02741554 p.1, read at the image at 300 dpi. The quoted sentence is the whole of the notice’s body. A further appearance in Jane Doe No. 3, No. 08-CV-80232, Document 12, docketed 07/08/2008, is at EFTA02739279 p.1, also read at the image. The signature blocks print “MICHAEL R. TEIN” and “Fla. Bar No. 993522”. ⚠ The telephone, facsimile and e-mail values on those blocks are not reproduced here, for him or anyone else on the sheet. ⚠ The magistrate’s name in one caption is barred and is not supplied. ↩ ↩² ↩³ ↩⁴ ↩⁵

2. Letter, Michael R. Tein to the U.S. Attorney’s Office, Southern District of Florida, 21 July 2008, on Lewis Tein PL letterhead, sent by facsimile, transmission stamp 7/21/2008 6:38:17 PM. Cited at the discrete court-exhibit copy, filed as Exhibit 121 in No. 9:08-cv-80736-KAM, Document 362-51: EFTA02756945 p.2, the cover sheet being p.1. The desk read the letter at the image at 400 dpi. ⚠ The signature is ink, a full handwritten signature over the typed “Michael R. Tein”. The cc line reads “Jack Goldberger, Esq. / Roy Black, Esq. / Alex Acosta, Esq.” ⚠⚠ The addressee is barred in both the address block and the salutation, and this page does not supply her name, describing her by role instead. A name barred on the sheet being cited is not written here, whatever any other source may hold. ⚠ No contact value is reproduced.

   A pin withdrawn, on hygiene grounds. An earlier draft cited this letter inside a 446-page compilation run and pinned readers to that run’s p.35, which is a fax cover sheet whose entire content is a name and a facsimile number. A citation should not land a reader on a sheet of contact values, and a discrete court exhibit is better provenanced than an interior page of a container. ⚠⚠ A producer-side exposure affecting this letter has been logged for the editor as an addendum to the failed-redaction class. Neither what it exposes nor where it can be reached is stated here or anywhere on this wiki. ↩ ↩²

3. The redaction pattern on the copies cited, read at the image. On EFTA02739350 p.2, EFTA02739279 p.1 and EFTA02741554 p.1, at 300-400 dpi: the firm name carries a solid bar leaving ”▮ Tein, P.L.”; the first partner’s line reads “GUY A. ▮” with the surname barred; a further bar covers the line below; “MICHAEL R. TEIN” is unbarred; the footer logo block is barred the same way. ⚠⚠ This describes these scans and no others. A redaction is applied to a copy, the same filings exist in more than one production, and an earlier draft said the pattern “repeats across the filings”, which is a claim about the filings that no set of scans can support. ⚠ This page does not set one copy beside another. ⚠⚠ The text extraction closes these gaps, so the redactions are invisible to a search-based reading. ⚠ The professional identifier printed beside the barred surname is not reproduced. ↩ ↩² ↩³

4. The end of the engagement, and why it is not December. Notices of Withdrawal as Co-Counsel of 30 December 2008 in Jane Doe No. 3, No. 08-80232, Document 47 (EFTA02739457 p.1, read at the image at 300 dpi) and in Jane Doe No. 2, No. 08-80119 (EFTA00222480). ⚠⚠ But the firm remained counsel of record. On 19 May 2009 it moved for leave to withdraw in all four cases, its own motion stating that absent a court order the firm “will continue to be listed as counsel for Mr. Epstein on the CM/ECF”: EFTA02739944 p.1. A sealed motion for stay was filed on 7 January 2009, between the two. The court granted the May motion to withdraw the next day. Three independent copies of the court-filed docket carry the same line: “05/20/2009 | 107 | ORDER granting 105 Motion to Withdraw as Attorney. Attorney Michael Ross Tein terminated. Signed by Judge Kenneth A. Marra on 5/20/2009.” EFTA00175589 p.16, EFTA00226849 p.70, EFTA01660040 p.12. Nothing after that date is an act of his: every CM/ECF header on the Tein-name pages was parsed, seventeen later entries exist, and none is him acting; a plaintiff’s filing two days later calls him “former counsel”. 7 July 2008 to 20 May 2009 is 317 days. ⚠ An earlier draft of this page gave 175 days, from 8 July to 30 December 2008. Both endpoints were wrong, and the error was of one kind: treating the first and last documents a search returned as the first and last documents that exist. Found by the verification pass, 2026-09-19, before publication. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷

5. The count, and why it is a floor. "Michael R. Tein" returns 231 documents; the plain form "Michael Tein" returns 79. ⚠ The middle initial is load-bearing, and this is the fourth subject on this wiki for which that has been true. ⚠⚠ BUT THE SIGNATURE COUNT CANNOT BE STATED PRECISELY, AND AN EARLIER DRAFT STATED IT AS 17. That figure came from deduplicating the documents containing the literal string /s/ Michael R. Tein. The literal string is an OCR artefact. The mark is extracted variously as Is/, Isl, Zs/, Id and bare s/, and relaxing the pattern adds fourteen further documents, including this page’s own flagship filing and all four of the 19 May 2009 withdrawal motions. The literal-string pool undercounts by roughly 29% on this name. Nor does any single tokenisation reproduce both numbers the draft gave. This page therefore states a floor and does not pretend to a total. ⚠ An earlier draft’s floor of twelve was below the page’s own table, which lists fifteen instruments across its filing rows; a floor a reader can disprove by counting the table is not a floor. ⚠ “Seven case numbers” was wrong as stated and is now six federal, plus one state. 08-80736 is a case named inside the 29 July notice and is not one he filed in. But he did appear in a seventh court: the Circuit Court of the 15th Judicial Circuit, Palm Beach County, case 50 2008 CA 006596, notice of appearance at EFTA00234108 pp.63-64: the state action that was then removed to federal court as 08-80804. ⚠ A count of federal case numbers is not a count of courts. ⚠ Firm-block signatures are not counted as his. ⚠ EFTA00175589 is a docket sheet, not a filing of his, and an earlier draft listed it among them. Individual filings not footnoted elsewhere: EFTA00221651, EFTA00222397, EFTA02741567, EFTA02743666, EFTA02750117, EFTA02750121, EFTA02750135, read at the text layer. ↩ ↩² ↩³ ↩⁴ ↩⁵

6. The ink signatures. On the stay motion in Jane Doe v. Epstein, No. 9:08-cv-80804-KAM, Document 18, Entered on FLSD Docket 09/03/2008, page 22 of 45: EFTA02750210 p.22, read at the image at 400 dpi. Two ink signatures appear on that one sheet, over the typed name “Michael R. Tein”: beneath a Certificate of Compliance with Local Rule 7.1.D.3, and beneath a Certificate of Service dated July 25, 2008. Two further ink signatures are on the notice of removal in the same case at EFTA00230786 pp.250-251. The 21 July 2008 letter is signed in ink, see [^july21]. ⚠ A text layer cannot see ink, which is why no absence of a handwritten signature should ever be asserted from a search. ↩ ↩²

7. Letter, U.S. Attorney’s Office, S.D. Fla., to Michael Tein, Esq., 17 July 2008, 2 pages; the passage quoted is on the second. EFTA00013666 p.2. ⚠ Read at the text layer. The letter sets out an either/or on whether Epstein intends to abide by the Agreement and closes with the request quoted above. ⚠ An earlier draft read the closing block as a cc line. It is the office’s own signature block, over R. Alexander Acosta’s name as United States Attorney, with Jack Goldberger copied. ⚠ The identifier is a five-page run and only p.2 carries the letter’s text; pp.3-5 are transmission records, which is the same hazard as the fax-cover pin withdrawn at [^july21], so the citation is given as p.2 of 5. ⚠ This page notes, and does not resolve, that the 21 July reply does not address the closing request. ⚠ An earlier draft summarised this letter as asking only whether Epstein intended to abide, which is how the reply characterises it; the letter asks for more than that. ↩ ↩²

8. Notice of breach, U.S. Attorney’s Office, S.D. Fla., to Michael R. Tein, 22 July 2008, “VIA FACSIMILE”, over the name of R. Alexander Acosta, United States Attorney. EFTA00189907 p.1, read at the image at 300 dpi; further copies at EFTA00215372 and EFTA00215384, and within EFTA00190318 at pp.50 and 273. ⚠ A further copy exists that this page does not link, because the desk has barred that identifier outright; the bar is an editor decision recorded elsewhere and is not revisited here. This wiki already has a page for the document itself at EFTA00189907, published before this one, which sets out its full contents including the publicist’s statement and the victim-notification history; this page does not restate it. ⚠ Several individuals the letter identifies as victims are barred throughout, and nothing about them is reproduced, reconstructed or counted here. ⚠ The letter is the office’s assertion, not a court ruling, and neither page treats it as one. ↩ ↩²

9. Epstein’s Reply in Support of Motion to Stay, filed under seal 28 July 2008 and entered on the public docket 12 August 2008 (a separate unsealing from the 08-80804 stay motion, which was entered 3 September), thirteen pages, captioned in all four Jane Doe actions. EFTA02741665 pp.1, 4, 5 and 13, read at the image at 400 dpi; the ink certificate of service is on p.13. The clerk’s ink stamp reads “JUL 2 8 2008 / STEVEN M. LARIMORE / CLERK U.S. DIST CT / S.D. OF FLA. MIAMI”, with “Sealed” written beside it by hand. The reason for sealing is printed on the first page: the agreement “contains a confidentiality clause”. The release holds eight copies of this filing across the four case dockets. ⚠⚠ QUOTE THIS DOCUMENT FROM THE IMAGE ONLY: its text layer interleaves and reverses words. ⚠⚠ IT CARRIES NO /s/ AT ALL. It was served by U.S. mail, and its certificate of service is signed in ink: the fifth and sixth ink signatures on this page. That is why no signature query the desk runs would ever have found it, and one of the eight copies does not contain the string “Tein” anywhere. ⚠ Two party names are barred inside a string of case citations in its footnote 3, apparently mechanically, and are not supplied. ⚠ The printed folio and the ECF page number differ by one on this document. ↩ ↩² ↩³

10. The stay briefing. Jane Doe v. Epstein, No. 9:08-cv-80804-KAM, Document 18, filed under seal 25 July 2008 and entered on the public docket 09/03/2008, 45 pages: EFTA02750210. A companion brief in No. 08-80811, Document 33, 41 pages, is at EFTA02729255. Both move expressly under 18 U.S.C. § 3509(k) and § 1595(b)(1). ⚠ Provenance, stated exactly: EFTA02750210 pp.2 and 22 were read at the image at 400 and 300 dpi; the rest of that brief, and the whole of EFTA02729255, were read at the text layer. ⚠⚠ A CORRECTION OF THIS DESK’S OWN GLOSS: § 1595(b)(1) is the stay provision: it directs that a civil action be stayed while a related criminal action is pending, not, in this argument, the trafficking victims’ cause of action. An earlier draft described it as the latter, in a paragraph that promised not to guess at an argument it had not read. The argument was in the release the whole time. ↩ ↩² ↩³

11. “RELEVANT PLEADINGS” index for Jane Doe No. 2 v. Epstein, No. 08-80119, two pages, listing docket entries DE 12 to DE 99. EFTA00222616. ⚠ Read at the text layer. It supplies the second denial, the sealed-to-unsealed sequence, the 17 July “Notice of Continued Pendency” that the U.S. Attorney’s letter attacks, and a third stay motion of 25 March 2009 with a reply of 13 May 2009. ⚠ An index is a list of filings, not the filings; nothing here is quoted from a document this page has not opened. ↩ ↩²

12. The outcome, dated from the docket. The court-filed docket for No. 9:08-cv-80804-KAM records at DE 7: “08/06/2008 … ORDER DENYING MOTION TO STAY and denying as moot 2 Motion for Hearing. Signed by Judge Kenneth A. Marra on 8/5/08.” EFTA00175521 p.4. The same docket page shows DE 18, the stay motion, filed 07/25/2008 and entered on the public docket 09/03/2008, over the filer name “(Tein, Michael)”. ⚠ An earlier draft dated the denial not at all and sourced it only to the passage below. That passage is the opposing party’s characterisation, from Plaintiff’s Motion to Remand, No. 08-80804 Document 11, 08/18/2008, and is quoted as such: “Defendants also argue that Plaintiff named ▮ as a defendant to prevent entry of a stay in this matter pursuant to 18 U.S.C. § 3509(k). The Court has since denied Defendants’ motion, holding a stay of this proceeding is not warranted under either the statute or the Court’s discretion. (Order Denying Motion to Stay, DE 7).” EFTA00234424 p.2, with a second copy at EFTA02750166 p.2. ⚠ Provenance: EFTA00234424 p.2 was read at the image and the quotation is exact; the second copy was not rendered. ⚠ A party’s name is barred in the sentence and is not supplied. ⚠ An earlier draft of this page reported the stay argument with no outcome at all, which left a reader to assume one. ↩

13. Defendant’s Notice of Filing Exhibits, captioned in four consolidated actions, Jane Doe No. 2, No. 3, No. 4 and No. 5 v. Jeffrey Epstein, Nos. 08-80119, 08-80232, 08-80380 and 08-80381-CIV-KAM-LRJ, Document 26, Entered on FLSD Docket 07/29/2008, pp.1-2 of 3. EFTA02739350 pp.1-2, read at the image at 400 dpi. The signature block, the “Attorneys for Defendant Jeffrey Epstein” line and the Certificate of Service are on p.2, which carries /s/ Michael R. Tein twice. The Certificate reads “July 29, 2007” against a docket stamp of 07/29/2008. ⚠ Ann C. Villafana’s middle name is barred on this copy, as is the magistrate’s name in the referenced case number; neither is supplied. ⚠ This filing is produced in the release more than twice, which is part of why the count in [^count] is given as a floor. ↩ ↩² ↩³

14. Joint Discovery Plan / Scheduling Report. No. 08-80811-CIV-BLOCH/SNOW, Document 16, Entered on FLSD Docket 08/18/2008, 8 pages. EFTA00234060. ⚠ Read at the text layer; not rendered. ⚠ The plaintiff in this action appears in the caption under initials only and is not named, expanded or described anywhere on this wiki. ⚠ The extraction renders the docket date as 08'18'2008 and the judge’s name as bLOCH; both were read against the case number rather than from the damaged span. ↩

15. Epstein’s Response to Motion to Preserve Evidence. Jane Doe, a/k/a Jane Doe #1 v. Jeffrey Epstein, No. 08-80804-CIV-MARRA/JOHNSON, Document 14, Entered on FLSD Docket 08/22/2008, 4 pages. EFTA00234469. ⚠ Read at the text layer; not rendered. A co-defendant’s name is barred in the caption and is not supplied. ⚠⚠ CORRECTION: an earlier draft said “the motion it answers is not in the release”. It is, twice. Plaintiff’s Motion to Preserve Evidence and Expedite Certain Discovery, the same case’s Document 12, docketed 08/21/2008, is at EFTA00234456 and again at EFTA02750185. The contents of the response are still not characterised here, but the reason is now that this desk has not read them, not that the other side of the exchange is missing. ↩

16. Motion to Dismiss. Same case, Document 19, Entered on FLSD Docket 09/04/2008, 11 pages. EFTA02750255. ⚠ Read at the text layer; not rendered. It moves under Rule 12(b) to dismiss Counts I, II and IV of the plaintiff’s amended complaint. ⚠⚠ CORRECTION: an earlier draft said “the amended complaint is not in the release”. It is. It was produced as an exhibit to the removal papers, EFTA00234108 p.101, headed AMENDED COMPLAINT in the Circuit Court of the 15th Judicial Circuit, Palm Beach County, case 50 2008 CA 006596. ⚠⚠ NO READER IS PINNED PAST THAT HEADING. The pages following it are graphic survivor allegations, and this page does not cite, quote, summarise or describe them. Count IV is identified here instead from Tein’s own removal notice, which calls it the claim for “civil remedies for criminal practices or racketeering (‘civil RICO’)”: EFTA00234224 p.19. The page still does not set out Counts I and II, because the only sheet that would supply them is the one it will not send a reader to. ⚠ The text layer renders the defendant’s surname as “EPSTa” at one point; no reading was taken from a damaged span. ↩

17. The absence of any disposition, measured twice. First, a page-by-page read of every document in the release matching the unrelated matter. Second, an independent sweep intersecting the full 384-document Tein / Lewis Tein name universe against sixteen disposition terms; not one hit belongs to that matter. Two apparent hits were opened and are unrelated: one recites a different person’s 2009 disbarment, the other is a file-index line about a bar complaint in an unrelated Epstein matter. ⚠ This says nothing about how the matter ended in the world. It says the release does not record it, which is the only claim this desk can make. ↩

18. What Epstein’s office kept. The press coverage of the unrelated matter was forwarded to Epstein’s office by another lawyer in his orbit on the day after publication, and the material is in Epstein’s files. This footnote deliberately does not identify the matter, quote the coverage, or name its allegations. The documented fact is about Epstein’s collection practice, which is the subject this wiki covers; the underlying dispute is not. ↩