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econd amended complaint (the "Fisher counterclaim"), is granted in all respects. The Soffer ejectment motion is granted as against deft Ron Soffer. Defls Jeffrey E. Epstein, Ivan S. Fisher, Ellyn Bank, Debra Elisa Cohen, Dianeataga?/a The Fisher Group, Fisher & Soffer a/k/a Fisher & Sophir, D. Gerzog, Robert Heilbum,
the house to the tenant we have selected should Mr. Epstein decide not to reoccupy the premises under the ne
on of the budding pursuant to the Foreign Missions Act, 22 U.S.C. § 4301 of seq. 0FM leased the building to defen- dant Jeffrey E. Epstein in 1992. Epstein sublet the building to defendant Ivan S. Fish- er in 1996, purportedly without the Govern- ment's consent. Fisher, in turn, sublet a portion of the
n personally liable because Epstein did not sign the con- tract as an agent or as a corporate officer. Epstein signed the contract as follows: /s/ Jeffery Epstein 1AG. Under New York law, a signature in a representative capacity would have been "Jeffrey Epstein for I.A.G." or "I.A.G., by Jeffrey Epstein". 2
atters extrinsic to the complaint. we will treat defendant Epstein's motion to dismiss as a motion for summary judg
RDERED. UNITED STATES of America, Plaintiff, I Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elis
RDERED. UNITED STATES of America, Plaintiff, I Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elise
e them rescheduled at a convenient location. CONCLUSION For all of the foregoing reasons, Defendants respectfully request that the Court grant its Motion for a Protective Order or such other relief as the Court deems appropriate. PFILM45448611 EFTA00187418 Dated: September 5, 2003 J. Fox AttorneyIdentification No. 152
y Lefkowitz in Support of Their Motion for a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's 3 EFTA00177813 A. The Applicability of Rule 410. Any assessment of the merits of the intervenors' contentions must begin with an understanding
tion agreement" ("the agreement") between the United States Attorney's Office for the Southern District of Florida (USAO/SDFL) and Jeffrey Epstein (Epstein) pursuant to the Crime Victims' Rights Act of 2004 (CVRA), 18 U.S.C. §3771. Under the agreement, Epstein agreed to (1) plead guilty to two then pend
the Southern District of Florida (USAO/SDFL) and Jeffrey Epstein (Epstein) pursuant to the Crime Victims'
ould render Rule 410 ambiguous and would violate Mr. Epstein's Fifth Amendment rights. The rule's central fea
ed: 04/17/2012) EFTA00177843 Case: 9:08-cv-80736-I<AM As of: 06/26/2013 07:08 PM EDT 14 of 16 04/17/2012 164 SUPPLEMENTAL Briefing in support of Motion for a Protective Order concerning Production, Use, and Disclosure of Plea Negotiations by Roy Black, Jay Lefkowitz, Martin G. Weinberg (IsXSee Image at DE Ufa ) (Entered:
F THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S MOTION FOR A PROTECTIVE ORDER Plaintiff/Counter-Defendant Jeffrey
OF LAW IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S MOTION FOR A PROTECTIVE ORDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, hereby files his Memorandum of Law in Opposition to Defendant/Counter-Plaintiff Bradley Edwards's ("Edwa
JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv
s are intended to annoy, embarrass, oppress, or unduly burden him, requiring that his Motion be denied. Next, Edwards's assertion in support of his Motion for a Protective Order that the requested information is "irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence" is equally de
Entities connected to both Jeffrey Epstein and Motion for a Protective Order

Bradley Edwards
PERSON
United States
LOCATION
Stephen Hawking
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONthe Southern District
LOCATION
New York
LOCATION
Chris Christie
PERSON