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"Exhibit B. Edwards"
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EFTA00804326
Dataset 9
2018-02-25
2p
346w
Subject:
Jeffrey Epstein v. Scott Rothstein and Bradley J.
Edwards
, 15th
…and as further defined in the Policy. (c) The Limits of Liability Coverage: $5,000,000 each Claim; $5,000,000 Aggregate (d) Policy or coverage defenses: See enclosed Exhibit A (e) Copy of the policy: See enclosed
Exhibit B
EFTA00804326 Page 2 This letter addresses only those Policy provisions that appear pertinent at this time in light of the facts currently known and available to us, without accepting or implying that the allegations have any factual or legal merit…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804326.pdf
EFTA00207241
Dataset 9
2010-04-13
2p
369w
Subject:
Activity in Case 9:08-cv-80893-KAM Doe g Epstein Response in Opposition to Motion
From:
"
[email protected]
" <
[email protected]
>
To:
"flsd_cmecf
[email protected]
" <flsd_cmecf
[email protected]
>
…Electronic Filing The following transaction was entered by
Edwards
, Bradley on 4/13/2010 at 11:56 AM EDT and filed on 4/13/2010 Case Name: Doe v. Epstein Case Number: 9:08-cv-80893-KAM Filer: Jane Doe Document Number: 140 Docket Text: RESPONSE in Opposition re [130] Defendants MOTION for Summary Judgment with Incorporated Memorandum of Law Corrected as to Paragraph Numbering filed by Jane Doe. (Attachments: # (1) Exhibit A, # (2)
Exhibit B
, # (3) Exhibit D)(
Edwards
…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00207241.pdf
EFTA00808695
Dataset 9
2017-12-11
9p
1,996w
…the proceeding caused damage to Bradley
Edwards
, both because no probable cause ever existed. So it was both initiated and continued in the absence ofprobable cause. (12/5/17 Tr. 46:1-9.)I Additionally, the parties' Joint Pretrial Stipulation submitted after that hearing identified the continuation as an "issue[] of fact for determination at trial on
Edwards
' Counterclaim against Epstein": I Excerpts of the December 5, 2017, hearing transcript are attached as
Exhibit B
. 3 EFTA00808697 If Epstein had…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808695.pdf
EFTA00808738
Dataset 9
2011-02-25
14p
3,802w
…client of
Edwards
. Rather, this is a case about the economic windfall that
Edwards
seeks for his alleged "daily anxiety" and "emotional distress" that he began to suffer upon Epstein's filing of a Complaint against him in December 2009 -- more than eight years ago -- and has continued to suffer unabatedly through today due to his "destroyed reputation." Excerpts of the December 5, 2017, hearing transcript are attached as
Exhibit B
. 2 EFTA00808739 Interestingly, in January 2015,
Edwards
sued Alan…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808738.pdf
EFTA00801479
Dataset 9
2016-08-08
19p
2,944w
…company, firm or corporation, whether foreign or domestic, please state: (a) The name and address of the entity in which you own or have any beneficial propriety or security interest of any sort;
EXHIBIT B
EFTA00801488 Case No.: 502009CA040800XXXXMBAG Notice of Serving Net Worth Interrogatories (b) The serial number of each bond, share, stock certificate or other evidence of ownership or security; (c) The current fair market value of each such interest; (d) The manner in which such value was…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801479.pdf
EFTA01107639
Dataset 9
2013-01-09
14p
2,871w
…93 (Fla. 3d DCA 1996). 2 EFTA01107640 Here,
Edwards
fails to present any good cause in his Motion for Protective Order. and wholly disregards the requirement that he properly establish the alleged annoyance, embarrassment, oppression, or undue burden.
Edwards
asserts impermissible one-word. conclusory objections in support of his claim for a protective order: to wit: "overly broad, irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence." See
Exhibit B
. These legal conclusions, which are actually…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01107639.pdf
EFTA00808590
Dataset 9
2017-12-05
19p
5,443w
…
Edwards
urges the Court in the interest of justice to continue upholding its July 20, 2017 and November 27, 2017 orders. Discovery is closed. Pretrial deadlines have passed. Both parties have represented on the record that they have been ready to try this case since March 8, 2018, and the Court should require the parties to stick to their word. 4 A copy of the Court's November 20, 2017 Order is attached hereto as
Exhibit 'B
'. 6 EFTA00808595
Edwards
…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808590.pdf
EFTA00805475
Dataset 9
2017-11-10
8p
1,925w
…something — this guy must be guilty of something." (
Edwards
' 5/15/13 Tr. 56:12-16.) "As I said then, have I done a good job at resurrecting whatever damage was done? Yes, I did." (
Edwards
' 10/10/13 Tr. 233:17-19.)° 2 Excerpts of Dr. Jansen's December 1, 2017, Deposition Transcript are attached as
Exhibit B
. Excerpts of Mr.
Edwards
' May 15, 2013, Deposition Transcript are attached as Exhibit C. 'Excerpts of Mr.
Edwards
' October 10…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00805475.pdf
EFTA00808686
Dataset 9
2018-04-04
9p
2,509w
…Bankruptcy Court. 3Edwards filed the Motion on behalf of Farmer, Jaffe, Weissing,
Edwards
, Fistos & Lehrman, M., and then joined the Motion individually. For purposes of this Motion, Fanner Jaffee and
Edwards
shall be collectively referred to as "
Edwards
." 4A copy of the April 13, 2018, Bankruptcy Court hearing transcript is attached as
Exhibit B
. 5A copy of the April 20, 2018, Order to Show Cause is attached as Exhibit C. 5 EFTA00808690 3. This Court Has Already Ordered that Epstein…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808686.pdf
EFTA00691823
Dataset 9
2013-01-09
8p
1,780w
…2d 93 (Fla. 3d DCA 1996). Here,
Edwards
fails to present any good cause in his Motion for Protective Order, and wholly disregards the requirement that he properly establish the alleged annoyance, embarrassment, oppression, or undue burden.
Edwards
asserts impermissible one-word, conclusory objections in support of his claim for a protective order; to wit: "overly broad, irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence." See
Exhibit B
. These legal conclusions, which are actually objections…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00691823.pdf
EFTA00582649
Dataset 9
2014-12-30
23p
6,729w
…non-prosecution agreement (the "NPA") with Epstein, who allegedly subjected them to various sexual crimes when they were minors. On December 30, 2014 — more than eight years after the Federal Action began —
Edwards
and Cassell filed a motion to allow a third alleged victim, Jane Doe No. 3, to join in the suit as an additional plaintiff (the "Joinder Motion"). See
Exhibit B
. The Joinder Motion alleges that Jane Doe No. 3 first met Epstein in 1999 and that Epstein …
https://www.justice.gov/epstein/files/DataSet%209/EFTA00582649.pdf
EFTA00805158
Dataset 9
2018-01-05
31p
6,526w
…com West Palm Beach, FL 33401 Co-Counselfor Plaintiff/Counter-Defendant
[email protected]
Jeffrey Epstein KaraelinIcrocklaw.com
[email protected]
TinaQIinkrocklaw.corn Trovelinkrocklaw.com Tanvaelinkrocklaw.com Eservicealinkrocklaw.com Trial Counselfor Plaintiff/Counter-Defendant Jeffrey Epstein EFTA00805175
EXHIBIT B
EFTA00805176 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. SCOTT ROTHSTEIN, individually, BRADLEY
EDWARDS
, individually, Defendants/Counter-Plaintiff. VOLUME I TRANSCRIPT OF PROCEEDINGS…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00805158.pdf
EFTA01085249
Dataset 9
2012-04-10
7p
1,275w
…of Investigation, (d) and (e) any other news employees or reporters. See Exhibit A. The Order further avowed that Defendant
Edwards
was permitted to assert any alleged privilege by filing "a privilege log specifically identifying such documents." See
Exhibit B
.
Edwards
not only failed to provide the items requested, but also failed to provide a privilege log as mandated. It is well-settled law that if a party alleges that information requested from it is protected by privilege, then a…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01085249.pdf
EFTA00801570
Dataset 9
2015-12-03
6p
1,349w
…
Edwards
's actions prejudice the administration of justice, thwart Epstein's ability to timely receive 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301. 954.467.1223 EFTA00801571 discovery and adequately prepare for trial, and blatantly violate the Court's Order. ITEMS TO BE STRICKEN OR AMENDED TO INCLUDE PROPER RESPONSES
Edwards
's witness list contains twenty-eight (28) numbered paragraphs. A true and correct copy of same is attached hereto as "
Exhibit B
." Paragraphs one…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801570.pdf
EFTA01139292
Dataset 9
2015-12-11
26p
5,632w
… That is A, B, C, D, E, as I said, those 12:13:40 EFTA01139307
EXHIBIT B
EFTA01139308 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072
EDWARDS
, et al., Plaintiffs / Counterclaim Defendants, v. DERSHOWITZ, Defendant / Counterclaim Plaintiff. AFFIDAVIT OF ALAN M. DERSHOWITZ REGARDING MEETINGS WITH DAVID BOIES A. Introduction 1. My name is Alan M. Dershowitz. I make this declaration on personal knowledge concerning my discussions with David…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01139292.pdf
EFTA00191264
Dataset 9
2007-06-07
132p
38,225w
…offense. and-as-senteene-preteeted-by-the-GVRA: 5. On about August 11, 2007, Jane Doe #2 received a standard CVRA victim notification letter. See
Edwards
Declaration,
Exhibit "B
." The notification promised that the Justice Department would makes its "best efforts" to protect Jane Doe #2's rights, including "[t]he reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the district court involving . . . plea…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00191264.pdf
EFTA00213945
Dataset 9
2009-08-05
3p
436w
Subject:
Activity in Case 9:08-cv-80119-ICAM Doe v. Epstein Response/Reply (Other)
…Response to Motion, to Identify Plaintiffs by Jeffrey Epstein. (Attachments: # (1) Exhibit A, # (2)
Exhibit B
, # (3) Exhibit C, # (4) Exhibit D, # (5) Exhibit E, # (6) Exhibit F, # (7) Exhibit G)(Pike, Michael) 9:08-cv-80119 Notice has been electronically mailed to: Adam D. Horowitz Bradley James
Edwards
Isidro Manuel Garcia Jack Alan Goldberger Jack Patrick Hill Jeffrey Marc Herman Katherine Warthen Ezell EFTA00213945 Michael James Pike Paul G. Cassell ■ Richard Horace Willits Robert C. Josefsberg Robert Deweese…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00213945.pdf
EFTA00206943
Dataset 9
2007-06-07
21p
3,665w
…5. On about August 11, 2007, Jane Doe #2 received a standard CVRA victim notification letter. See
Edwards
Declaration,
Exhibit "B
." The notification promised that the Justice Department would makes its "best efforts" to protect Jane Doe #2's rights, including "Mlle reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the district court involving ... plea ...." The notification further explained that "[a]t this time…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00206943.pdf
EFTA00207229
Dataset 9
2010-04-12
2p
361w
Subject:
Activity in Case 9:08-cv-80893-KAM Doe 1 Epstein Response to Motion
From:
"
[email protected]
" <
[email protected]
>
To:
"flsd_cmecf
[email protected]
" <flsd_cmecf
[email protected]
>
…The following transaction was entered by
Edwards
, Bradley on 4/12/2010 at 6:33 PM EDT and filed on 4/12/2010 Case Name: Doe I. Epstein Case Number: 9:08-cv-80893-ICAM Filer: Jane Doe Document Number: 138 Docket Text: RESPONSE to Motion re [130] Defendant's MOTION for Summary Judgment with Incorporated Memorandum of Law filed by Jane Doe. Replies due by 4/22/2010. (Attachments: # (1) Exhibit A, # (2)
Exhibit B
, # (3) Exhibit D)(
Edwards
…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00207229.pdf
EFTA01079203
Dataset 9
2016-01-12
60p
13,979w
…See Motion to Quash, attached hereto as Exhibit A did not move to seal the deposition transcript and the resulting order did not seal it, but instead directed that "a confidentiality order shall be entered." See November 4, 2015 Email from Judicial Assistant attached hereto as
Exhibit B
and November 12, 2015 Order, attached hereto as Exhibit C. The Confidentiality Order then prepared by counsel and consented to by all parties includes a provision stating that "Dille deposition testimony of…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01079203.pdf
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