EFTA01085249Dataset 9
2012-04-107p1,275w
…Order dated April 10, 2012. In support thereof, Plaintiff states: INTRODUCTION EFTA01085249 On March 9, 2012, Plaintiff Epstein served upon Defendant Edwards a Motion to Compel and to Amend and Lift a Protective Order. A true and correct copy of Plaintiff's Motion is attached hereto as "Exhibit A." On April 10, 2012, this Court entered an Order on Plaintiff's Motion to Compel, stating that "within twenty (20) days of the date of this Order, the Defendant EDWARDS shall…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01085249.pdf
EFTA01085233Dataset 9
2012-04-1016p3,608w
…previous Order dated April 10, 2012. In support thereof, Plaintiff states: INTRODUCTION On March 9, 2012, Plaintiff Epstein served upon Defendant Edwards a Motion to Compel and to Amend and Lift a Protective Order. A true and correct copy of Plaintiff's Motion is attached hereto as "Exhibit A." On April 10, 2012, this Court entered an Order on Plaintiff's Motion to Compel, stating that "within twenty (20) days of the date of this Order, the Defendant EDWARDS shall…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01085233.pdf
EFTA00310004Dataset 9
2010-08-1026p8,275w
…Inc. Page 0 dispute as outlined by either party herein counsel a ruling for Defendant. The only factor favoring Plaintiffs is one of "convenient" relief. HI. THE FIRST AMENDED COMPLAINT DOES NOT SUFFICIENTLY ESTABLISH A CAUSE OF ACTION FOR BREACH OF A THIRD PARTY BENEFICIARY CONTRACT AND THE NEGLIGENCE ON THE PART OF DEFENDANT IN THIS COURT. In Plaintiffs' First Amended Complaint, they allege the separate contracts between Plaintiff Epstein and Molyneux, then between Molyneux and Defendant Fancelli. FAC, para…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00310004.pdf
EFTA01117008Dataset 9
2012-04-106p1,194w
…s Request for Production. Plaintiff likewise requests that this Court order sanctions against Defendant Edwards for his direct and flagrant disregard of this Court's previous Order dated April 10, 2012. In support thereof, Plaintiff states: INTRODUCTION On April 12, 2010, Plaintiff Epstein served Defendant Edwards with his initial Request for Production, including therein a request for: [a]ll e-mails, data, correspondence, and similar documents dated April 1, 2008 through August 1, 2010 by and between Bradley J. Edwards…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01117008.pdf
EFTA00235286Dataset 9
2010-09-0210p2,765w
…s Office regarding the investigation, negotiation and settlement of potential criminal charges against Mr. Epstein. DESCRIPTION OF INTENDED USE Epstein respectfully submits that a brief description of the proceedings that counsel for the Plaintiff has stated that they intend to use the Correspondence will be helpful to the court: A. Epstein v. Edwards. Case No. 502009 CA040800XXXXMB AG The Plaintiff Epstein commenced an action on December 7, 2009 seeking damages against Defendants, Scott Rothstein, Bradley J. Edwards, and LM,' based…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00235286.pdf
EFTA01113966Dataset 9
2008-06-3010p1,852w
… JUDGE: DAVID CROW VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, EPSTEIN'S OBJECTIONS TO EDWARDS'S REVISED EXHIBIT LIST Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Paragraph D4 of this Court's Order Setting Jury Trial and Directing Pretrial and Mediation Procedures, hereby objects to the following of Defendant/Counter-Plaintiff Bradley Edwards's trial exhibits (numbered in order as they appeared in Edwards's Revised Exhibit List…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01113966.pdf
EFTA01099088Dataset 9
2010-08-1021p5,745w
…either party herein counsel a ruling for Defendant upon consideration of fair play and substantial justice. The only factor favoring Plaintiffs is one of "convenient" relief. III. THE FIRST AMENDED COMPLAINT DOES NOT SUFFICIENTLY ESTABLISH A CAUSE OF ACTION FOR BREACH OF A THIRD PARTY BENEFICIARY CONTRACT AND THE NEGLIGENCE ON THE PART OF DEFENDANT IN TIIIS COURT. In Plaintiffs' First Amended Complaint, they allege the separate contracts between Plaintiff Epstein and Molyneux, then between Molyneux and Defendant Fancelli. FAC, …
https://www.justice.gov/epstein/files/DataSet%209/EFTA01099088.pdf
EFTA01113986Dataset 9
2008-06-309p1,584w
… JUDGE: DAVID CROW VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, EPSTEIN'S OBJECTIONS TO EDWARDS'S REVISED EXHIBIT LIST Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Paragraph D4 of this Court's Order Setting Jury Trial and Directing Pretrial and Mediation Procedures, hereby objects to the following of Defendant/Counter-Plaintiff Bradley Edwards's trial exhibits: All applicable criminal statutes All applicable Florida Statutes All applicable Rules of…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01113986.pdf
EFTA00206609Dataset 9
2010-09-0210p2,727w
…s Office regarding the investigation, negotiation and settlement of potential criminal charges against Mr. Epstein. DESCRIPTION OF INTENDED USE Epstein respectfully submits that a brief description of the proceedings that counsel for the Plaintiff has stated that they intend to use the Correspondence will be helpful to the court: A. Epstein v. Edwards. Case No. 502009 CA040800XXXXMB AG The Plaintiff Epstein commenced an action on December 7, 2009 seeking damages against Defendants, Scott Rothstein, Bradley J. Edwards, and LM,' based…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00206609.pdf
EFTA00611765Dataset 9
2010-03-174p632w
…JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, JUDGE: DAVID CROW VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, EPSTEIN'S OBJECTIONS TO EDWARDS'S DEPOSITION DESIGNATIONS Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Paragraph M of this Court's Order Setting Jury Trial and Directing Pretrial and Mediation Procedures, hereby objects to certain portions of the following of Defendant/Counter-Plaintiff Bradley Edwards's deposition designations, and to save space is…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00611765.pdf
EFTA00602420Dataset 9
2012-07-197p1,278w
…1 EFTA00602425 AMENDED NOTICE OF MEETING OF COUNSEL PURSUANT TO RULE 26W Epstein. et al. v. Fancelli Paneling. Inc., et al. Page 4 Respectfully submitted, Dated this day of July, 2012. Denise Francois, Esquire Treston E. Moore, Esquire HODGE & FRANCOIS MOORE DODSON & RUSSELL, P.C. Counsel for Plaintiff Epstein, et al. Counsel for Defendant Fancelli Paneling, Inc. 1340 Taameberg P.O. Box 310, E.G.S. (I4A Norre Gade) St. Thomas, V.L 00802 St. Thomas, VI 00804-0310 PHONE: …
https://www.justice.gov/epstein/files/DataSet%209/EFTA00602420.pdf
EFTA00213902Dataset 9
2010-09-0210p2,781w
…s Office regarding the investigation, negotiation and settlement of potential criminal charges against Mr. Epstein. DESCRIPTION OF INTENDED USE Epstein respectfully submits that a brief description of the proceedings that counsel for the Plaintiff has stated that they intend to use the Correspondence will be helpful to the court: A. Epstein v. Edwards. Case No. 502009 CA040800XXXXMB AG The Plaintiff Epstein commenced an action on December 7, 2009 seeking damages against Defendants, Scott Rothstein, Bradley J. Edwards, and LM,' based…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00213902.pdf
EFTA00801993Dataset 9
94p19,003w
…Crow 0 I VI JEFFREY EPSTEIN, f. Ca) Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF EPSTEIN'S RESPONSE TO DEFENDANT EDWARDS' REOUEST TO PRODUCE Plaintiff/Counter-Defendant, Jeffrey Epstein, by and through his undersigned counsel and pursuant to the Florida Rules of Civil Proced lei this his Response to Request to Produce served on April 15, 2011 and states as fol la. Plaintiff does not have any documents between Plaintiff or his agents and William…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801993.pdf
EFTA01103261Dataset 9
7p1,815w
…— "... a civil defendant who raises an affirmative defense is not precluded from asserting the privilege [against self-incrimination], because affirmative defenses do not constitute the kind of voluntary application for affirmative relief' which would prevent a plaintiff bringing a claim seeking affirmative relief from asserting the privilege. 10. The complaint is the best evidence of the allegations asserted by the Plaintiff, Epstein, and Epstein denies the remaining allegations of paragraph 10. 11. Epstein denies any ulterior motive, purpose or any…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01103261.pdf