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tion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration o i 6(e) Box #3 P-
hibit 6. 17. In the declaration, Ms. makes a number of assertions, including that "there could not have been any doubt in anyone's mind .. . that Epstein sexually molested me as a minor"; "I believed that if I told the truth about what happened at Epstein's house, the police "; "I had been greatly in
/2013 Page 19 of 23 Bates Range Description Privilege(s) Asserted Box #3 P-011923 Thru P-011966 Folder entitled "Responses to Arguments from JE Counsel" containing: Work product Deliberative process 6(e) Attorney-Client Privilege ■ 7/13/2007 letter from to with handwritten attorney (
tified as a potential victim of the lead target, Jeffrey Epstein. 2. After service of the subpoena, Ms.=
have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push
d-faith settlement cases, where "mental impressions [of the underlying counsel] are the pivotal issue in the current litigation." Holmgren v. State Farm Mut. Auto. Ins. Co., 976 F.2d 573, 577 (9th Cir. 1992). Other than by analogizing to bad-faith actions, Petitioners have not demonstrated how delving i
tein 12889705 NCA customised Closed - liit 16/06/2017 BIS RESULTS: Negative Media: Mali On I ine MailOnline May 24, 2017 Wednesday 10:53 PM GMT Jeffrey Epstein's 'sex slave' settles her defamation lawsuit against British socia xwell who 'passed her around for sex' and trained her to be 'everything a man wa
recruited her as a sex slave when she was 15 for convicted pedophile billionaire Jeffrey Epstein and passed around to his friends Maxwell, who was Epstein's girlfriend at the time, is also accused of forcing her to have sex with Maxwell and other underage girls The 55-year-old responded to the allegat
ion of Reed Elsevier Inc. All Rights Reserved. Date:6/16/2017 Report processed by: DEUTSCHE BANK AGII Full Name Address County Phone EPSTEIN. JEFFERY E 9 E 71ST ST NEW YORK (212) 750-9895 NEW YORK. NY 10021-4102 (212) 249.1122 NEW YORK COUNTY (212) 772-9416 ADDITIONAL PERSONAL INFORMATION SSN
2546965 (Age 64) Subject Summary Name Variations 1: EDWARDS. JEFFERY 2: EPSTEIN, J 3: EPSTEIN, JEFFERY 4: EPSTEIN, JEFFERY E 5: EPSTEIN, JEFFREY 6: EPSTEIN. JEFFREY E 7: EPSTEIN. JERRERY 8: EPSTIEN, JEFFERY 9: EPTSTEIN. JEFFERY SSNs Summary No. SSN 1: 090-44-XXXX DOBs Reported DO
N. MARK L SSN:117-444OOCX DOB:1955 (Age: 62) EPSTEIN, PAULA A Deceased • AKA EPSTEIN, PAULINE SSN:050-09-XXXX DOB:10/1918 (Age: 98) TUCKER. ELLYN EPSTEIN • AKA EPSTEIN, ELLY • AKA EPSTEIN, ELLYN ELLYN • AKA EPSTEINTUCKER. ELLYN EPSTEIN • AKA EPSTEIN. E • AKA TUCKER. EPSTEIN ELLYN • AKA EPSTEIN-TU
ad-faith settlement cases, where "mental impressions [of the underlying counsel) are the pivotal issue in the current litigation." Holmgren v. State Farm Mut. Auto. Ins. Co., 976 F.2d 573, 577 (9th Cir. 1992). Other than by analogizing to bad-faith actions, Petitioners have not demonstrated how delving i
DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR PROSPECTIVE LIMITED INTERVENTION AT THE REMEDY STAGE OF THESE PROCEEDINGS Jeffrey Epstein hereby moves, pursuant to Fed. R. Crim. P. 24(a)(2) a
the stage at which the Court will consider what remedy to order if it finds that the government violated the plaintiffs' rights under the CVRA. Mr. Epstein does not seek to intervene generally in the case, as the duties and obligations imposed by the CVRA apply solely to the government; the statutory r
UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR PROSPECTIVE LIMITED INTERVENTION AT
violated the plaintiffs' rights under the CVRA. Mr. Epstein does not seek to intervene generally in the case,
377, 394 (1968) ("[W]e find it intolerable that one constitutional right should have to be surrendered to assert another"); Tomai-Minogue v. State Farm Mut. Auto Ins. Co., 770 F.2d 1228, 1232 (4th Cir. 1985) (finding it a "questionable line of argument . . . [that] to assert her rights as a matter of p
J. EDWARDS, Defendants/Counter-Plaintiffs. / ORDER GRANTING MOTION FOR FEES AND COSTS THIS CAUSE came before the Court on Counter-Defendant's, Jeffrey Epstein's, Motion for Fees and Costs filed on June 2, 2014. A hearing was held on December 8, 2014, at which counsel presented argument on the Motion. On Dec
iff/Counter-Defendant Jeffery Epstein's lawsuit against Defendants/Counter-Plaintiffs Bradley Edwards and Scott Rothstein. Edwards then countersued Epstein for malicious prosecution. Epstein voluntarily dismissed his initial suit. On August 25, 2011, Epstein served an Offer of Judgment ("Offer") on Edwa
L CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, CASE NO.: 2009CA040800XXXXMB CIVIL DIV
al for settlement." Id. at 629. Releases are generally treated as conditions or nonmonetary terms that must be described with particularity. State Farm Mut. Auto. Ins. Co. v. Nichols, 932 So. 2d 1067, 1078 (Fla. 2006). A proposal for settlement can contain either the proposed release or a summary of the
L CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, CASE NO.: 2009CA0408003OOOCMB CIVIL DI
APPENDIX 1. Order Granting Fees and Costs of February 3, 2015 2. Epstein's Motion for Fees and Costs with attached pleadings dated June 2, 2014. EFTA00617978 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN A
ADLEY J. EDWARDS. Defendants/Counter-Plaintiffs. ORDER GRANTING MOTION FOR FEES AND COSTS THIS CAUSE came before the Court on Counter-Defendant's, Jeffrey Epstein's, Motion for Fees and Costs filed on June 2, 2014. A hearing was held on December 8, 2014, at which 't counsel presented argument on the Motion. On
posal for settlement.'?. at 629. Releases are generally treated as conditions or nonmonetary terms that must be described with particularity. State Farm Mut. Auto. Ins. Co. v. Nichols, 932 So. 2d 1067, 1078 (Fla, 2006). A proposal for settlement can contain either the proposed release or a summary of the
ed: The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses
ating the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution agreement between the Government and Epstein. (DE I). The parties and intervenors d
o every privilege asserted. (DE 265). Intervenor Jeffrey Epstein supports the Government's assertion that
d-faith settlement cases, where "mental impressions [of the underlying counsel] are the pivotal issue in the current litigation." Holmgren v. State Farm Mut. Auto. Ins. Co., 976 F.2d 573, 577 (9th Cir. 1992). Other than by analogizing to bad-faith actions, Petitioners have not demonstrated how delving i
ed: The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses
ating the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution agreement between the Government and Epstein. (DE 1). The parties and intervenors d
o every privilege asserted. (DE 265). Intervenor Jeffrey Epstein supports the Government's assertion that
d-faith settlement cases, where "mental impressions [of the underlying counsel] are the pivotal issue in the current litigation." Holmgren v. State Farm Mut. Auto. Ins. Co., 976 F.2d 573, 577 (9th Cir. 1992). Other than by analogizing to bad-faith actions, Petitioners have not demonstrated how delving i
Entities connected to both Jeffrey Epstein and Farm Mut
Leon Black
PERSON
Eric Trump
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
Jay Lefkowitz
PERSON
Scarlett Johansson
PERSONEmmy Taylor
PERSONRoy Black
PERSON
Michael Jackson
PERSON