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e allegations are wholly impertinent to the issues in the Joinder Motion or the Federal Action more generally. Indeed, United States District Judge Kenneth Marra has already concluded — in an unchallenged order that is binding on Edward and Cassell in this action — that the allegations were "unnecessary," "i
r at the very least were "grossly negligent" in defaming Dershowitz, which would support his claim for punitive damages: • On April 7, 2015, Judge Marra expressly held that "lurid" allegations about Dershowitz are "impertinent" to the issues in the federal proceeding and ordered them to be stricken
claim for punitive damages: • On April 7, 2015, Judge Marra expressly held that "lurid" allegations about D
Amended Counterclaim, which expands on the factual allegations of Edwards's and Cassell's tortious conduct in several ways: • First, the proposed Second Amended Complaint asserts an additional count for defamation based on the attorneys' actions in asserting the unsubstantiated and irresponsible allegation that Dersh
arra. 4. On 411k 25, 009 and on April 23, 2009, Judge Marra entered detailed orders 0 in this matter of hic
ARD MORSE and CAROL MORSE, Petitioners. O C. Appeal from the United States District Court for the Southern District of Fl In der Seal- Civ-Marra), Kenneth A. Marra, Judge. PETITIONERS' MOTION FOR EMERGENCY WRIT OF MANDAMUS Petitioners, EDWARD MORSE and CAROL MORSE, by and through their undersigned counsel, fi
3. This nutter is pen4t, Ifore the Honorable United States District Court Judge, Kenneth Marra. 4. On 411k 25, 009 and on April 23, 2009, Judge Marra entered detailed orders 0 in this matter of hich are attached hereto and incorporated by reference herein. t forth in the Orders, Judge Mama order
aint in April 2009, after EDWARDS joined RRA, the allegations against EPSTEIN in <SL7 complaint became even more salacious. In paragraph 12 of .'s Second Amended Complaint, L.M. alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . . .the then minor Plaintiff to commit various acts of sexu
he signatures of U.S. District Judge, Kenneth A. Marra and U.S. Circuit Court Judge, Susan H. Black, 11t
Rothstein's scheme went so far as to manufacture false and fraudulent Court opinions/orders including forging the signatures of U.S. District Judge, Kenneth A. Marra and U.S. Circuit Court Judge, Susan H. Black, 11th Circuit in other cases. It is not yet known if he forged similar documents in Espteln related mat
int In April 2009, after EDWARDS Joined RRA, the allegations against EPSTEIN in ■.'s complaint became even more salacious. In paragraph 12 of ■.'s Second Amended Complaint, II. alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . . .the then minor Plaintiff to commit various acts of sexu
nt, in Jane Doe v. Epstein, Case No. 08-CV-80893- Marra/Johnson. The motion was reported in the press as
int in April 20O9, after EDWARDS joined RRA, the allegations against EPSTEIN in ■.'s complaint became even more salacious. In paragraph 12 of ■.'s Second Amended Complaint, ■. alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . .the then minor Plaintiff to commit various acts of sexual
nt, in Jane Doe v. Epstein, Case No. 08-CV-80893- Marra/Johnson. The motion was reported in the press as
int in April 20O9, after EDWARDS joined RRA, the allegations against EPSTEIN in ■.'s complaint became even more salacious. In paragraph 12 of ■.'s Second Amended Complaint, alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . .the then minor Plaintiff to commit various acts of sexual mi
UTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY
s ability to earn a living and be self-supporting has not only a financial component, but also an emotional/psychological/mental component. In her Second Amended Complaint, Plaintiff attempts to allege claims in Count I for "Sexual Assault and Battery," Count II for "Intentional Infliction of Emotional Distress," and
UTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY
nfidentiality of the information obtained through discovery. The evidence sought is relevant based on the facts and theories of this action. In her Second Amended Complaint, Plaintiff attempts to allege claims in Count I for "Sexual Assault and Battery," Count II for "Intentional Infliction of Emotional Distress," and
Entities connected to both Kenneth Marra and Second Amended Complaint

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONLeon Black
PERSON
George W. Bush
PERSONMaria Farmer
PERSONSouthern District
LOCATION
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSONMichael J. Pike
PERSONScott Rothstein
PERSON
Bill Clinton
PERSON
Adam D. Horowitz
PERSON
Palm Beach County
LOCATION