EFTA00079409Set 9
2007-07-2592p17,481w
entering and leaving
the restaurant and arrested him.
Sentence 13 months; appeals conviction
& sentence. Affirmed.
2
EFTA00079415
kr.,/14H-,?3c4 2iitat t:,.‘, ;i: .f-At:. T,, - i‘26-0 6AulthalienT ... which he had
sent to the 14 yr-old via email.
Conviction affirmed but 81 month
sentence vacated to be reconsidered in
light of Booker.
3
EFTA00079416
CllURT
' zettaa;pette ... have oral sex
with him; all through the Internet.
Pled guilty — 88 month sentence
Affirmed.
6
EFTA00079419
:.,...., i,. . ,, c ; rct., ....c..,--,;%...1-,,, ..p47.5,:„ : ...-;
,_„,____ A 4 4..› ,• .. .t-. :x.1.7 ..•
:MINtrt
https://www.justice.gov/epstein/files/DataSet%209/EFTA00079409.pdf
EFTA00724884Set 9
2008-07-2421p5,456w
Defendant denies each and every
21 allegation contained therein.
22 AFFIRMATIVE DEFENSES
23
24 FIRST AFFIRMATIVE DEFENSE
25 (Truth)
26 123. As a first affirmative defense, Defendant contends that ... Document 30 Filed 02/27/08 Page 14 of 21 Page ID #:359
1 SECOND AFFIRMATIVE DEFENSE
2 (Statute of Llmitations)
3 124. As a second affirmative defense, Defendant asserts that ... limited to
5 Code of Civil Procedure §§ 340(c), 335.1 and 343.
6 THIRD AFFIRMATIVE DEFENSE
7 (Opinion)
8 125. As a third affirmative defense, Defendant asserts that some
https://www.justice.gov/epstein/files/DataSet%209/EFTA00724884.pdf
EFTA00175835Set 9
2008-04-1457p16,565w
Exhibit t(Critton, Robert) (Entered: 04/02/2009)
04/02/2009 n Defendant's ANSWER and Affirmative Defenses to Amended Complaint
(Second) by Jeffrey Epstein.(Critton, Robert) (Entered: 04/02/2009)
04/03/2009 22 Unopposed MOTION ... Kremer, 411 So.2d 1347 (Fla. 1st DCA
1982). It must be premised upon an affirmative act - a threat to use force, or the actual
exertion of force. See 3A FIa.Jur ... JOHNSON
JANE DOE NO. 5
Plaintiff,
1.
JEFFREY EPSTEIN,
Defendant.
DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE
DEFENSES TO PLAINTIFF'S SECOND AMENDED COMPLAINT
Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through
https://www.justice.gov/epstein/files/DataSet%209/EFTA00175835.pdf
EFTA00175717Set 9
2008-03-0558p16,603w
Exhibit B, # a
Exhibit CXCritton, Robert) (Entered: 04/02/2009)
04/02/2009 61 Defendant's ANSWER and Affirmative Defenses to Amended Complaint
(Second) by Jeffrey Epstein.(Critton, Robert) (Entered: 04/02/2009)
04/03/2009 62 Unopposed ... Kremer, 411 So.2d 1347 (Fla. 1st DCA
1982). It must be premised upon an affirmative act - a threat to use force, or the actual
exertion of force. See 3A Fla.Jur ... CV.80232-MARRA-JOHNSON
JANE DOE NO. 3
Plaintiff,
JEFFREY EPSTEIN,
Defendant.
DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE
DEFENSES TO PLAINTIFF'S SECOND AMENDED COMPLAINT
Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through
https://www.justice.gov/epstein/files/DataSet%209/EFTA00175717.pdf
EFTA00175775Set 9
2008-04-1460p17,746w
Exhibit I(Critton, Robert) (Entered: 04/02/2009)
04/02/2009 76 Defendant's ANSWER and Affirmative Defenses to Amended Complaint
(Second) by Jeffrey Epstein.(Critton, Robert) (Entered: 04/02/2009)
04/03/2009 72 Unopposed MOTION ... Kremer, 411 So.2d 1347 (Fla. 1st DCA
1982). It must be premised upon an affirmative act - a threat to use force, or the actual
exertion of force. See 3A Fla.Jur ... JOHNSON
JANE DOE NO. 4
Plaintiff,
1.
JEFFREY EPSTEIN,
Defendant.
DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE
DEFENSES TO PLAINTIFF'S SECOND AMENDED COMPLAINT
Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through
https://www.justice.gov/epstein/files/DataSet%209/EFTA00175775.pdf
EFTA01085328Set 9
2012-04-0422p4,448w
84/84/2012 16:33 MOORE DODSON RUSSELL PAGE 13/23
case
As and for its second affirmative defense, Deft al asserts that this Court lacks
jurisdiction over the subject matter ... contract ly, but generally otherwise) and over
the person of Defendant.
,Third Affirmative
As and for its third affirmative defense, Defend asLerts that Plaintiffs' claims are
barred in whole ... reasonably prudent person under L-cumstances.
Fourth Aflirnuitive D
As and for its fourth affirmative defense, Defend asserts that Plaintiffs' claims are
barred in whole or in part
https://www.justice.gov/epstein/files/DataSet%209/EFTA01085328.pdf
EFTA00221236Set 9
2009-06-1010p2,695w
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
I
DEFENDANT EPSTEIN'S FIRST AMENDED ANSWER & AFFIRMATIVE
DEFENSES TO PLAINTIFF'S (FIRST) AMENDED COMPLAINT
Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his
undersigned ... Jane Doe No. 7 v. Epstein
Page 2
.. a civil defendant who raises an affirmative defense is not precluded from asserting
the privilege [against self-incrimination], because affirmative defenses ... constitute
the kind of voluntary application for affirmative relief" which would prevent a plaintiff
bringing a claim seeking affirmative relief from asserting the privilege.
3. As to the allegations
https://www.justice.gov/epstein/files/DataSet%209/EFTA00221236.pdf
EFTA00292118Set 9
2003-04-1435p15,282w
person or by proxy, shall constitute a quorum. If a quorum is present, the
affirmative vote of the majority of shares represented and voting at the meeting (which shares
voting ... affirmatively also constitute at least a majority of the required quorum) shall be the act of
the shareholders, unless the vote of a greater number or voting by classes ... adjourned from time to time, whether or not a quorum is present, by the
affirmative vote of a majority of shares represented at such meeting either in person
https://www.justice.gov/epstein/files/DataSet%209/EFTA00292118.pdf
EFTA01138929Set 9
2007-01-0633p8,537w
complaint was dismissed and final judgment was entered. The
United States Circuit Court affirmed the dismissal.
Wolfe, Harold E. Wolfe, Jr., P.A., and Harold E. Wolfe, Jr., Revocable
Trust (collectively ... Wolfe, 128 So. 3d at 68. On appeal by Wolfe, the Third District affirmed.
The Third District commenced its analysis with an examination of the history
of the litigation privilege ... Guarantee Title & Trust Co., 748 So. 2d 1054, 1055 (Fla.
4th DCA 2000) (affirming the trial court's order granting summary judgment in favor
4
EFTA01138932
of the law firm
https://www.justice.gov/epstein/files/DataSet%209/EFTA01138929.pdf
EFTA02689568Set 11
2005-05-0528p10,687w
Fear 7
Well-Founded Fear 7
Mixed Motives 8
Process of Requesting Asylum 8
Affirmative Applications 8
Defensive Applications 9
Expedited Removal 9
Aliens Arriving by Sea 10
Background Checks ... current policy, discussing the concepts of "credible
fear" and "well-founded fear," explaining affirmative and defensive avenues to seek
asylum, and describing key procedures such as background checks and expedited ... applicant is currently in removal proceedings, two avenues exist
to seek asylum: "affirmative applications" and "defensive applications." The
affirmative and defensive applications follow different procedural paths, but draw
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02689568.pdf
EFTA01084920Set 9
2013-02-1410p2,387w
BRADLEY J, EDWARDS,
individually. JUDGE: CROW
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S AMENDED ANSWER
AND AFFIRMATIVE DEFENSES TO DEFENDANT/COUNTER-PLAINTIFF
BRADLEY EDWARDS'S FOURTH AMENDED COUNTERCLAIM
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein ... Florida Rules of Civil Procedure,
hereby files this Amended Answer and Affirmative Defenses to DefendanUCounter-Plaintiff
Bradley Edwards's ("Edwards") Fourth Amended Counterclaim ("Counterclaim"), and states:
1. Epstein admits that ... demand made in his "WHEREFORE"
clause, including any assertion of alleged Punitive Damages.
AFFIRMATIVE DEFENSES
FIRST AFFIRMATIVE DEFENSE
For his First Affirmative Defense, Epstein states that Edwards' Abuse of Process
https://www.justice.gov/epstein/files/DataSet%209/EFTA01084920.pdf
EFTA00798007Set 9
2019-04-016p1,264w
ndant, they are specifically
denied.
33. Denied.
34. Denied as stated.
35. Denied.
FIRST AFFIRMATIVE DEFENSE
Plaintiffs' injuries, if any, to the extent not solely attributabl
e to Plaintiffs were ... acts or omissions of third parties over whom Defe
ndant had no control.
SECOND AFFIRMATIVE DEFENSE
The Complaint fails to state a cause of action upon which relief ... granted.
EFTA00798010
Answer
Page 5
THIRD AFFIRMATIVE DEFENSE
The Complaint fails to state a cause of action for punitive
damages.
FOURTH AFFIRMATIVE DEFENSE
The Complaint fails to state a cause
https://www.justice.gov/epstein/files/DataSet%209/EFTA00798007.pdf
EFTA00266621Set 9
18p3,940w
PORT PIRIE, in the State of South Australia, make oath and say ! affirm and
declare' as follows:
1. I am a Constable of police ID No currently stationed ... Witnessed By:
(Signature of person tfefore whom affidavit 'sworn /
Dat 19 / 05/7,O(6 affirmed and declared)
Strike out whichever is inapplicable
navies& 9A/11//61S
EFTA00266624
)0•15-‘eDiOeSPOD ... Signature: Witnessed By:
(Signature ofperso efore whom affidavit 'sworn /
Date: Pt /05/ 7--Olb affirmed and declared)
* Strike out whichever is inapplicable
EFTA00266625
REFER TO P Raroc
https://www.justice.gov/epstein/files/DataSet%209/EFTA00266621.pdf
EFTA00610671Set 9
66p3,003w
Defendant Jessica Cadwell raised several affirmative defenses all of which are
legally insufficient and unsupported by fact or evidence. Defendant's affirmative defenses
contain assertions, but do not supply specific ... Beach, 318 So. 2d 175, 176 (Fla. 3rd DCA, 1975).
10. Defendant's first affirmative defense that Plaintiff failed to comply with the
foreclosure prevention loan servicing requirement imposed ... National
Housing Act (NHA), 12 U.S.C. 1701x(cX5) fails to state a valid affirmative defense. The NHA
offers no private right of action for failure to provide notice regarding homeownership
https://www.justice.gov/epstein/files/DataSet%209/EFTA00610671.pdf
EFTA00229842Set 9
2007-04-1719p12,425w
proven, although a reasonable belief that a person is over 18 is an affirmative
defense to a limited portion of § 2423(6). F6
In those instances where Epstein and/or ... include one thing implies the exclusion of the other). Section
2423(g) creates an affirmative defense to one portion of a violation of Section 2423(b). For purposes of
that ... subsection alone, a defendant may raise an affirmative defense, which he must prove, that the
defendant "reasonably believed that the person with whom the defendant engaged in the commercial
https://www.justice.gov/epstein/files/DataSet%209/EFTA00229842.pdf
EFTA01102240Set 9
7p1,369w
ROTHSTEIN, individually,
and BRADLEY J, EDWARDS,
individually.
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S ANSWER AND
AFFIRMATIVE DEFENSES TO DEFENDANT/COUNTER-PLAINTIFF
BRADLEY EDWARDS' COUNTERCLAIM
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his
undersigned ... Rule 1.110 of the Florida Rules of Civil Procedure
hereby files his Answer and Affirmative Defenses to Defendant/Counter-Plaintiff
Bradley Edwards' ("Edwards") Counterclaim, and states:
I. Epstein admits that the Counterclaim ... claim for damages that is contained
in Paragrapgh 33 and demands strict proof thereof.
AFFIRMATIVE DEFENSES
FIRST AFFIRMATIVE DEFENSE
For his First Affirmative Defense, Epstein states that Edwards' Abuse
https://www.justice.gov/epstein/files/DataSet%209/EFTA01102240.pdf
EFTA00589617Set 9
2015-02-1830p6,231w
Wolfe v. Foreman, 128
So. 3d 67, 68 (Fla. 3d DCA 2013) (affirming the determination that the litigation
2
EFTA00589622
privilege applied to plaintiff's malicious prosecution case ... Holland & Knight, LLP, 88 So.
3d 240, 243 (Fla. 3d DCA 2011) (affirming the finding that the litigation privilege
applied to plaintiff's abuse of process claim on a motion ... Process and Malicious Prosecution. Epstein
denied liability as to those claims and asserted various affirmative defenses thereto,
including the immunity afforded to Epstein for both causes of action under
https://www.justice.gov/epstein/files/DataSet%209/EFTA00589617.pdf
EFTA02445563Set 11
2010-05-1361p14,701w
Allen, No. 08-8513, 361 F. App'x 442 (4th Cir. Oct. 22, 2009) (affirming on the ground that
Kennedy was required to register under Maryland law independent ... duty under SORNA),
and affirm the judgment of the district court for the reasons given herein.
I
In December 1980, a federal jury in California convicted Michael Kennedy of raping ... treatment program. After Kennedy
objected to these conditions, the Commission's National Appeals Board affirmed them on
January 7, 2005. In response, Kennedy filed a pro se petition for habeas
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02445563.pdf