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MEMORANDUM TO RDC FROM JMB RE Epstein — Punitive Damages DATE April 8, 2009 Bob: You requested that I put together a general overview/outline of issues which will present themselves
neral overview/outline of issues which will present themselves to us in connection with Plaintiffs' claims for punitive damages against our client, Jeffrey Epstein. The following is not intended to be exhaustive and I am sure specific issues will present themselves, which will require additional research and b
claims for punitive damages against our client, Jeffrey Epstein. The following is not intended to be exha
mages brought in State and Federal Court against Mr. Epstein. I. STATE State claims for punitive damages ar
claimant discovery of evidence which appears reasonably calculated to lead to admissible evidence on the issue of punitive damages. EFTA00727535 Epstein Memo re: Punitive Damages Page 2 of 6 No discovery of financial worth shall proceed until after pleading concerning punitive damages is permitted. It
NY) (FBI)" <I To: (FBI)" Subject: Fw: DOJ/FBI Epstein Memo Date: Tue, 08 Jul 2025 13:36:52 +0000 Impo
From: (NY) (FBI)" <I To: (FBI)" Subject: Fw: DOJ/FBI Epstein Memo Date: Tue, 08 Jul 2025 13:36:52 +0000 Importance: Normal See link below. https://www.justice.goviopa/media/1407001/dl?inline EFTA01649014
20 •:. .> Subject: Dal/FBI Epstein Memo For those who haven't seen it yet, below is the final D0J/FBI memo released today related to the follow up Epstein investigation that has occurred over the past several months, in which most of C-20 and even the entire New York office had been involved with at so
Date: Mon, 07 Jul 2025 19:55:22 +0000 Importance: Normal From: (NY) (FBI) Sent: Monday, July 7, 2025 3:11 PM To: NY-C20 •:. .> Subject: Dal/FBI Epstein Memo For those who haven't seen it yet, below is the final D0J/FBI memo released today related to the follow up Epstein investigation that has occurred
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