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EFTA00725918
Dataset 9
8p
2,098w
…has properly stated a cause of action. Conclusion For all these reasons, the Court allow ■ to proceed on her first cause of action and deny with prejudice Epstein's motion for summary judgment on
Count I
. EFTA00725924 CERTICATE OF SERVICE I HEREBY CERTIFY that the original of the above and a copy of the foregoing has been provided this7-)t.) day of March 2010 via U.S. Mail and email transmittal to all those on the attached service list…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725918.pdf
EFTA01810109
Dataset 10
2008-07-21
9p
2,742w
…position as they would have been had Mr. Epstein been convicted at trial. No more; no less. Compl. ¶ 19. In
Count I
- Cause of Action Pursuant to 18 U.S.C. § 2255, Plaintiff alleges as follows: In late May or early June of 2002, Plaintiff was brought to Defendant's residence by her female 3 EFTA_R1_00170932 EFTA01810111 Case 9:08-cv-80811-KAM Document 168 Entered on FLSD Docket 12/10/2009 Page 4 of 9 friend. Compl…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01810109.pdf
EFTA00222420
Dataset 9
2007-07-09
8p
1,525w
…450 F.3d at 1320. I.
Count I
Fails to State a Cause of Action For Assault Recoenized by Florida Law. The plaintiff attempts to plead a cause of action against Mr. Epstein for "sexual assault"
based
on a "violation of Chapter 800 of the Florida Statutes"2 for the "lewd and lascivious acts committed by Epstein upon Jane Doe." (Compl. 18.) Plaintiff cannot assert a cause of action for "violation of Chapter 800, Florida Statutes" because there is no…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00222420.pdf
EFTA00731326
Dataset 9
2008-07-21
9p
2,742w
…that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less. Compl. 19. In
Count I
- Cause of Action Pursuant to 18 U.S.C. § 2255, Plaintiff alleges as follows: In late May or early June of 2002, Plaintiff was brought to Defendant's residence by her female 3 EFTA00731328 Case 9:08-cv-80811-KAM Document 168 …
https://www.justice.gov/epstein/files/DataSet%209/EFTA00731326.pdf
EFTA00221985
Dataset 9
2008-09-22
4p
1,000w
…the State generally give rise to a civil claim for intentional tort.
Count I
does not purport to bring a separate civil claim for violation of a strictly criminal statute. 3 Assault and battery are closely related common law intentional torts that are commonly alleged together. See Herzfeld'. Herzfeld, 781 So.2d 1070 (Fla.2001) (noting that plaintiff alleged intentional tort of "assault and battery"
based
on allegations of sexual abuse). Sullivan Atlantic Federal Savings & Loan 454 So.2d 52…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00221985.pdf
EFTA00725607
Dataset 9
2009-08-12
10p
2,943w
…Complaint, ("memorandum"), dated August 12, 2009. In support of dismissal of
Count I
— "Sexual Assault and Battery" and Count III — "Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422,"
based
on the statute of limitations, Defendant replies: Introduction Defendant's position is that Counts I and III are each barred by the applicable statute of limitations. Since the issues in parts I and II of Plaintiff's memorandum overlap, Defendant will address those parts together…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725607.pdf
EFTA01307468
Dataset 10
96p
56,087w
…Average Dady Balance and APY values n the Deposit Account APY section or your December statement were misstated January statement values haw Sources of your account growth been corrected Tracking the value of your account during 2019 Yaw of your &
count I
Thousands at year end 2018 S11.82870 Net depositsand 962 87.5 wthdraevals -14.00)C0 Your imestnent reium: Chinclervi and 489 interest income $336 Change in 168 marbei value $000 78 Value of your moan on Jan…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01307468.pdf
EFTA02401836
Dataset 11
2015-10-17
3p
576w
Subject:
Re:
From:
>
To:
Jeffrey E.
…meeting ???! I was just telling you =omething that happened to a friend of mine and you hang =p on me... This is really not nice. II sabato 17 ottobre 2015 > ha scritto: Even if my opinion=doesn't
count I
have the right to have one, EVEN if I'm wrong= please note The information con=ained in this communication is confidential, may be attorney-client pri=ileged, may constitute inside information, and is intended only for =he use of the addressee…
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02401836.pdf
EFTA02483432
Dataset 11
2015-10-17
2p
447w
Subject:
Re:
From:
jeffrey E. <
[email protected]
>
…meeting ???! I was just telling=you something that happened to a friend of mine and you =ang up on me... This is really not nice. II sabato 17 ottobre=2015, > ha scritto: Even if my opinion doesn't
count I
have the right =o have one, EVEN if I'm wrong. <=r>please note The information contained in this communication is con=idential, may be attorney-client privileged, may constitute inside info=mation, and is intended only for the use of the addressee. It…
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02483432.pdf
EFTA00296277
Dataset 9
2017-06-05
36p
7,010w
…and threats were made solely for the purpose of coercing and otherwise EFTA00296303 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 26 of 31 inducing Plaintiff into prolonged sexual compliance. Defendants knowingly benefitted financially and received things of value as a result of their-coercing and inducing Plaintiff into sexual compliance and otherwise participating in their illegal venture and enterprise.
COUNT I
CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO 18 U.S.C. § 1595 76 …
https://www.justice.gov/epstein/files/DataSet%209/EFTA00296277.pdf
EFTA01099943
Dataset 9
2006-07-26
32p
10,791w
…Plaintiff JANE DOE NO. 3's Second Amended Complaint [D.E. 50), dated February 27, 2009, attempts to assert three causes of action.
Count I
and Count II, respectively, attempt to allege state law claims under Florida law for "Sexual Assault and Battery," and "Intentional Infliction of Emotional Distress." Count III, which is the subject of this motion, is entitled "Coercion and Enticement to Sexual Activity in EFTA01099944 Jane Doe No. 3 v. Epstein Case No. 08-CV-80232-Marra…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01099943.pdf
EFTA00201190
Dataset 9
2009-03-12
21p
6,896w
…DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS FIRST AMENDED COMPLAINT FOR FAILURE TO STATE A CAUSE OF ACTION, AND MOTION FOR MORE DEFINITE STATEMENT; MOTION TO STRIKE, AND SUPPORTING MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, moves to dismiss
Count I
through XXXI of Plaintiffs First Amended Complaint for failure to state a cause of action, and for more definite statement, or to strike, as specified herein. Rule 12(b)(6), (e) and (f)…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00201190.pdf
EFTA00207677
Dataset 9
2006-07-26
36p
12,694w
…all affirmative defenses to this action and to file additional summary judgment motions
based
on such defenses as this case progresses. 3. Defendant by separate motion is also seeking summary judgment of Plaintiff's §2255 claim (Count II) as the pleadings and discovery on file show that Plaintiff can not establish a violation of her alleged requisite predicate acts. This motion should be decided first. 4.
Count I
attempts to allege a state law claim under Florida law for "Sexual…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00207677.pdf
EFTA00728400
Dataset 9
2010-05-17
4p
939w
…Plaintiff, Podhurst Orseck, P.A. ("Podhurst"), filed a Two Count Complaint against Epstein seeking money damages for Breach of Third Party Agreement (
Count-I
) and Breach of Covenant of Good Faith and Fair Dealing (Count — II). DE 1. 2. In the Complaint, Plaintiff claims money damages in excess of $2,000,000, which allegedly represents attorneys' fees and costs incurred by Podhurst in connection with its representation of certain individuals against Epstein and Epstein's alleged breach of that certain…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728400.pdf
EFTA01109699
Dataset 9
8p
2,131w
…stated a cause of action. Conclusion For all these reasons, the Court allow L.M. to proceed on her first cause of action and deny with prejudice Epstein's motion for summary judgment on
Count I
. EFTA01109705 CERTICATE OF SERVICE I HEREBY CERTIFY that the original of the above and a copy of the foregoing has been provided this7T day of March 2010 via U.S. Mail and email transmittal to all those on the attached service list. Farmer, Jaffe…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01109699.pdf
EFTA01100005
Dataset 9
2006-07-26
43p
14,726w
…7's Amended Complaint [D.E. 19), dated February 27, 2009, attempts to assert three causes of action.
Count I
and Count II, respectively, attempt to allege state law claims under Florida law for "Sexual Assault and Battery," and "Intentional Infliction of Emotional Distress." Count HI, which is the subject of this motion, is entitled "Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422," and attempts to assert a claim pursuant to 18 U.S…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100005.pdf
EFTA01099901
Dataset 9
2006-07-26
31p
10,619w
…Plaintiff JANE DOE NO. 2's Second Amended Complaint [D.E. 56], dated February 27, 2009, attempts to assert three causes of action.
Count I
and Count II, respectively, attempt to allege state law claims under Florida law for "Sexual Assault and Battery," and "Intentional Infliction of Emotional Distress." Count 111, which is the subject of this motion, is entitled "Coercion and Enticement to Sexual Activity in EFTA01099902 Jane Doe No. 2 v. Epstein Case No. 08-CV-80119-Marra…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01099901.pdf
EFTA00728100
Dataset 9
2010-05-17
4p
924w
…2010, Plaintiff, Podhurst Orseck, P.A. ("Podhurst"), filed a Two Count Complaint against Epstein seeking money damages for Breach of Third Party Agreement (
Count-I
) and Breach of Covenant of Good Faith and Fair Dealing (Count — II). DE 1. 2. In the Complaint, Plaintiff claims money damages in excess of $2,000,000, which allegedly represent attorneys' fees and costs incurred by Podhurst in connection with (a) its representation of certain individuals, (2) that certain Non-Prosecution Agreement and Addendum…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728100.pdf
EFTA00843414
Dataset 9
2015-10-17
2p
443w
Subject:
Re:
From:
"jeffrey E." <
[email protected]
>
…??! I was just telling you something that happened to a friend of mine and you hang up on me... This is really not nice. II sabato 17 ottobre 2015, ha scritto: Even if my opinion doesn't
count I
have the right to have one, EVEN if wrong. please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00843414.pdf
EFTA00727755
Dataset 9
7p
2,004w
…710 So.2d at 185 -86 (emphasis added). Of course, exactly the same conditions applies here: The criminal statutes at issue were designed to protect a class of persons (minors) against a particular type of harm (sexual abuse). Accordingly, L.M. has properly stated a cause of action. Conclusion For all these reasons, the Court allow L.M. to proceed on her first cause of action and deny with prejudice Epstein's motion for summary judgment on
Count I
. EFTA00727761
https://www.justice.gov/epstein/files/DataSet%209/EFTA00727755.pdf
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