EFTA00086375Set 9
2017-05-30143p34,595w
court order."
Exhibit 4 at DE212-1 pp. 1, 6.
15. There was extensive litigation regarding the privilege log, including the assertion
of the confidentiality of grand jury materials. Judge ... potential conflict of interest in your representation of Ms.
In case of future litigation regarding this issue, please provide me with information
regarding who is paying (directly or indirectly ... handwritten notes subject to privacy rights of
victims who are not parties to
this litigation
Box #1 File folder entitled "Ritz Compact Flash SW" 6(e)
P-000550 containing copies
https://www.justice.gov/epstein/files/DataSet%209/EFTA00086375.pdf
EFTA00311151Set 9
2012-04-1074p23,416w
CDRC, Annual Dispute Resolution
Policy Conference, 2010, 2008; California Judges Assoc/Rutte
r Group, Employment Litigation, 2010;
AAA Webinar, Current Issues in Employment Arbitration: The
Arbitration Fairness Act of 2009
Legislation ... civil practice from 1960 to appointment to Superior Court in 1972, with emphasis on
litigation and probate. Awards include the 1991-92 Los Angeles County Bar Association Trial Jurist ... District of California, 1965.
Professional Associations California Bar Association; Los Angeles County Bar Association
(Litigation Section, Past Executive Committee; Family Law Section, Past Executive Committee);
Beverly Hills Bar Association; Association
https://www.justice.gov/epstein/files/DataSet%209/EFTA00311151.pdf
EFTA01082923Set 9
2011-07-13194p59,682w
prosecution agreement, quote, "for
4 the purpose of upping the stakes of the litigation." Now,
5 the non-prosecution agreement is the agreement that
6 Mr. Epstein entered into with ... told that the damages constitute fees and costs
12 incurred in the underlying litigation, any claim for which
13 was released in the underlying litigation. We will ... claim as damages, in this case, fees and costs incurred in
20 the underlying litigation, if they could possibly form the
21 basis of any claim of liability in light
https://www.justice.gov/epstein/files/DataSet%209/EFTA01082923.pdf
EFTA01070213Set 9
2011-07-1341p38,837w
allegations of the complaint as true. the purpose of upping the stakes of cho litigation." sou.
9
if all he know was, because there were a lot of people ... process, which moans the filing of a complaint, the 12 Incurred in the underlying litigation, any claim for which
13 filing of an answer to a complaint, the filing ... some 13 was released in the underlying litigation. No will ask the
19 pleading or a subpoena. The only category that could
19 Court co cake judicial notice
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070213.pdf
EFTA00612144Set 9
2013-07-176p3,456w
July 17, 2013.
tit Process
4aPrivileges
Synopsis
Background: Partner in a limited liability company Litigation privilege barred abuse of process
(LLC) brought abuse of process and malicious claim brought ... judicial proceedings.
Holdings: The District Court of Appeal, Rothenberg, J.,
held that:
III litigation privilege barred the abuse of process claim,
and Malicious Prosecution
-SNature and Elements of Malicious ... litigation privilege bared the malicious prosecution Prosecution in General
claim.
The elements for a malicious prosecution cause
of action are that a judicial proceeding: (1) was
Affirmed. commenced against
https://www.justice.gov/epstein/files/DataSet%209/EFTA00612144.pdf
EFTA01115108Set 9
2007-09-135p3,003w
Weekly D1540a
Torts -- Abuse of process -- Malicious prosecution -- Litigation privilege applies to claims for abuse of
process and malicious prosecution against attorneys who filed complaint and briefly prosecuted case
against ... ROTHENBERG, JJ.)
(ROTHENBERG, J.) The issue in this appeal is whether the litigation privilege, which protects actions taken
in the course of and related to a judicial proceeding from civil ... abuse of process; and (2) malicious prosecution. Because the law is clear that the litigation privilege applies
to abuse of process, we affirm the trial court's order granting judgment
https://www.justice.gov/epstein/files/DataSet%209/EFTA01115108.pdf
EFTA01416838Set 10
2017-06-19122p23,787w
Rule 23." In
re Gen. Motors
Corp. Pick-Up Truck Fuel Tank Products Liab. Litig. ("GM Truck Prods."), 55
F.3d 768, 797
(3d Cir. 1995). Under Rule ... relevant evidence and
arguments presented
by the parties." In re Hydrogen Peroxide Antitrust Litig., 552 F.3d 305, 306
(3d Cir. 2008).
1. Numerosity
Rule 23(a)(1) requires that ... significant unique or
atypical defenses
to her claims." In re Schering Plough Corp. ERISA Litig., 589 F.3d 585,
597-98 (3d Cir.
2009).
Plaintiffs' claims, "for settlement purposes only
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01416838.pdf
EFTA00583780Set 9
15p4,660w
most important, Mohawk involved an attempted
interlocutory appeal by a party to the litigation, which this case does not. Second, Mohawk was
concerned with an interlocutory appeal under the collateral ... adverse attorney-client
rulings would unduly delay the resolution of district court litigation and needlessly burden the
Courts of Appeals" (emphasis added)). In holding that an interlocutory appeal would ... Mohawk Court concluded that
postjudgment appeals generally suffice to protect the rights of litigants and ensure the
vitality of the attorney-client privilege. Appellate courts can remedy the improper
disclosure
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583780.pdf
EFTA01072169Set 9
2013-07-1225p5,750w
rights under the CVRA, 18 U.S.C. §3771. Epstein is not
a party to that litigation. He had no obligations to either Jane Doe No. 1 or Jane ... Date Filed: 07/12/2013 Page: 8 of 25
During the course of civil litigation against Mr. Epstein, Mr. Epstein was
ordered, over his strenuous objection, to produce documents given ... MARRA, Doc. 462. Thus, the plaintiffs' statement
that during that civil litigation, "Epstein's counsel produced to the victims' counsel
significant parts of the correspondence by his attorneys concerning
https://www.justice.gov/epstein/files/DataSet%209/EFTA01072169.pdf
EFTA00084801Set 9
2019-02-286p2,855w
connection with the matter v. Ghislaine Maxwell, et al.
(a), (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A.
Background
As described in the Application, the Government ... Schiller") requiring the production of
copies of discovery and related materials related to the Litigation. The Subpoena was validly
issued pursuant to an ongoing investigation into Jeffrey Epstein and others ... Government has been advised that Boies Schiller, which is counsel for plaintiffs in the
Litigation, does not intend to contest the Subpoena. However, the Government is advised that
although Boies
https://www.justice.gov/epstein/files/DataSet%209/EFTA00084801.pdf
EFTA00070824Set 9
2019-02-286p2,841w
Epstein, et al. ("Jane Doe"),
17 Civ. 616 (JGK) (SN) (the "Litigation"), a copy of which is attached hereto as Exhibit A.
Background
As described in the Application, the Government ... Schiller") requiring the production of
copies of discovery and related materials related to the Litigation. The Subpoena was validly
issued pursuant to an ongoing investigation into Jeffrey Epstein and others ... Government has been advised that Boies Schiller, which is counsel for plaintiffs in the
Litigation, does not intend to contest the Subpoena. However, the Government is advised that
although Boies
https://www.justice.gov/epstein/files/DataSet%209/EFTA00070824.pdf
EFTA00088205Set 9
2020-08-246p2,973w
Court of Appeals and a separate district court in this same court (the "Civil
Litigation") the fact that her adversary in the civil case pending in those two fora already ... dark about the fact and method of the
disclosure. They claim the civil litigation is "unrelated," that issuance of the subpoena was
"standard practice," and that disclosure will jeopardize ... vast swath of materials." Each of the government's arguments lack
merit.
The Civil Litigation is Not "Unrelated":
First, the government claims the civil action is "unrelated." Resp
https://www.justice.gov/epstein/files/DataSet%209/EFTA00088205.pdf
EFTA00212253Set 9
2008-10-0150p18,079w
where the allegations relate
to the exercise of the attorney's authority to investigate, litigate, or provide legal
advice. This includes allegations relating to the actions of the Department ... during the course of the investigation in order to better assess
2
EFTA00212256
the litigation impact of the alleged misconduct and to permit the Attorney General
and Deputy Attorney General ... matters outside the jurisdiction of OPR;
sought review of issues that were being litigated or that had already been
considered and rejected by a court; were frivolous, vague, or unsupported
https://www.justice.gov/epstein/files/DataSet%209/EFTA00212253.pdf
EFTA00607428Set 9
2008-01-017p1,761w
THEI-1P1EENTH
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro.1201
Plaintiff,
v. Case No. 50 2009 CA 040800XXXXMB AG
SCOTT ROTHSTEIN ... purporting to be
affiliated with RRA or Fanner Jaffe regarding any pending or contemplated litigation, past or settled
litigation, investigations, surveillance, incidents of misconduct or claims in any way involving ... purporting to be
affiliated with RRA or Fanner Jaffe regarding any pending or contemplated litigation, past or settled
litigation, investigations, surveillance, incidents of misconduct or claims in any way involving
https://www.justice.gov/epstein/files/DataSet%209/EFTA00607428.pdf