EFTA00607567Set 9
2009-12-0716p3,558w
EPSTEIN, in the above-styled matter on December 7, 2009 as follows:
ANSWER
GENERAL ALLEGATIONS
1. Defendant, EDWARDS, denies the allegations contained in Paragraph 1 and
demands strict proof thereof ... Defendant, EDWARDS, admits the allegations contained in Paragraph 2.
3. Defendant, EDWARDS, admits the allegations contained in Paragraph 3.
4. Defendant, EDWARDS, admits the allegations contained in Paragraph ... Defendant, EDWARDS, is without knowledge to either admit or deny
tions and demands strict
allegations contained in Paragraph 5 and thereby denies these allega
proof thereof.
in Broward
6. Defendant
https://www.justice.gov/epstein/files/DataSet%209/EFTA00607567.pdf
EFTA00175717Set 9
2008-03-0558p16,603w
complaints.
However, there are distinctions in the four motions filed based on the complaint
allegations. For example, Defendant challenges the Plaintiffs' allegations as to assault
in all four actions ... challenges the battery allegations in JANE DOE NOS. 2 and 3,
but not in JANE DOE NOS. 4 and 5. Defendant moves to dismiss the §2422 count in all
four ... upon which relief can be granted. Rule 12(b)(6). Plaintiff has
failed to allege sufficient factual allegations in the Counts and instead alleges labels and
conclusions, and an attempted
https://www.justice.gov/epstein/files/DataSet%209/EFTA00175717.pdf
EFTA01100300Set 9
2009-12-0716p3,579w
EPSTEIN, in the above-styled matter on December 7, 2009 as follows:
ANSWER
GENERAL ALLEGATIONS
I. Defendant, EDWARDS, denies the allegations contained in Paragraph I and
demands strict proof thereof ... Defendant, EDWARDS, admits the allegations contained in Paragraph 2.
3. Defendant, EDWARDS, admits the allegations contained in Paragraph 3.
4. Defendant, EDWARDS, admits the allegations contained in Paragraph 4.
EFTA01100300 ... Defendant, EDWARDS, is without knowledge to either admit
tions and demands strict
allegations contained in Paragraph 5 and thereby denies these allega
proof thereof.
ard
6. Defendant, EDWARDS, admits that
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100300.pdf
EFTA00792343Set 9
57p11,385w
recommendation in
full, without hearing any further evidence, where Appellant disputes
numerous unprosecuted allegations contained therein and the District
Attorney, as representative of the State, disclaims the Board's
recommendation ... unreliable, based on allegations that were
determined to be not prosecutable, and not provable by clear and
convincing evidence?
3. In calculating Appellant's risk level under SORA ... Despite an extensive investigation by Florida
prosecutors regarding various other complaints alleged against him and
reported in police paperwork, Appellant was never charged with any
other crimes or prosecuted
https://www.justice.gov/epstein/files/DataSet%209/EFTA00792343.pdf
EFTA01299150Set 10
2013-10-0235p11,136w
CASE SUMMARY:
PROCEDURAL POSTURE: Defendants moved the court to dismiss plaintiffs complaint,
which alleged violations of 42 U.S.C.S. §§ 1983. 1985. and 1986, and 15 U.S.C.S. §§ 1
and 2
OVERVIEW: Plaintiff ... medical staff. a privilege granted to
most licensed physicians. He sued defendants, alleging that they had willfully and
maliciously acted to prevent him from practicing podiatry in certain public ... private
hospitals by withholding that privilege. Specifically. he alleged that defendants' actions had
deprived him of his civil rights in violation of 42 U.S.C.S. §§ 1983, 1985, and 1986. he also
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01299150.pdf
EFTA00084726Set 9
2021-11-0114p6,552w
President of & Associates, Inc., has evaluated or supervised over 1,000
evaluations of allegations of sexual victimization. He has testified as an expert witness in
forensic psychiatry on hundreds ... Abuse, 23 J. Child
Sexual Abuse 957, 974 (2014).
In an articular population of alleged victims, patients, or plaintiffs—including those
whom Dr. has treated or evaluated—the determination ... lore derived from the
frequent observation of highly vulnerable children among those children who allege sexual
abuse, but it is not based on empirical data regarding the likelihood of abuse
https://www.justice.gov/epstein/files/DataSet%209/EFTA00084726.pdf
EFTA00084982Set 9
2021-11-0114p6,554w
Abuse, 23 J. Child
Sexual Abuse 957, 974 (2014).
In an articular population of alleged victims, patients, or plaintiffs—including those
whom Dr. has treated or evaluated—the determination ... lore derived from the
frequent observation of highly vulnerable children among those children who allege sexual
abuse, but it is not based on empirical data regarding the likelihood of abuse ... psychopathology, less prior
trauma, no substance use, and higher resilience are less likely to allege abuse than the more
vulnerable, the generalization could be proved weak or false, if only
https://www.justice.gov/epstein/files/DataSet%209/EFTA00084982.pdf
EFTA00593727Set 9
2015-09-2120p4,228w
Prior Proceedings
Plaintiff filed a complaint in this Court on September 21,
2015, alleging a single defamation claim. See Compl.' Defendant
sought an extension of her time to answer, move ... Standard
On a motion to dismiss pursuant to Rule 12(b)(6), all
factual allegations in the complaint are accepted as true, and
all inferences are drawn in favor ... court
to draw the reasonable inference that the defendant is liable
for the misconduct alleged." Iqbal, 556 U.S. at 663 (quoting
Twombly, 550 U.S. at 556). In other words
https://www.justice.gov/epstein/files/DataSet%209/EFTA00593727.pdf
EFTA01070055Set 9
2011-07-13158p39,441w
very different from what we were looking at previously.
7 Indeed, the only allegation that attempts to associate
8 Bradley Edwards with anything having to do with Rothstein ... case
17 files, were being shown and touted to investors."
18 Now, no allegation that he knew or reasonably should
19 have known that they were part of a Ponzi ... motion to dismiss relating to that
Orange Reporting
407.898.4200
EFTA01070059
6
1 allegation is so what. A law firm has every right to raise
2 funds to prosecute legitimate claims
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070055.pdf
EFTA01069530Set 9
2015-09-2120p4,220w
Prior Proceedings
Plaintiff filed a complaint in this Court on September 21,
2015, alleging a single defamation claim. See Compl.' Defendant
sought an extension of her time to answer, move ... Standard
On a motion to dismiss pursuant to Rule 12(b)(6), all
factual allegations in the complaint are accepted as true, and
all inferences are drawn in favor ... court
to draw the reasonable inference that the defendant is liable
for the misconduct alleged." Iqbal, 556 U.S. at 663 (quoting
Twombly, 550 U.S. at 556). In other words
https://www.justice.gov/epstein/files/DataSet%209/EFTA01069530.pdf
EFTA01120533Set 9
2010-06-3029p8,593w
against EDWARDS;
1. was filed in the total absence of evidence to support any allegation of wrongdoing
on the part of EDWARDS;
2. was filed in the total absence ... those governing a motion to
dismiss, where the truth of the plaintiff's allegations are assumed, and not the
more rigorous summary judgment standard, where the opposing party must show ... clients could serve as the basis for a civil lawsuit against him. Allegations about Edwards's
participation in or knowledge of the use of the civil actions against Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA01120533.pdf
EFTA00201190Set 9
2009-03-1221p6,896w
support of dismissal, Defendant states:
The First Amended Complaint attempts to allege 32 counts. Counts I through
XXX are purportedly brought pursuant to 18 U.S.C. §2255 - Civil Remedies for
Personal ... entitled
"Conspiracy to Commit Tortious Assault only against Defendant," Under
the heading "Factual Allegations" of the First Amended Complaint, Plaintiff also
references numerous federal and state criminal statutes, but fails ... allege whether or
not she is attempting to assert claims based on these statutes. (¶15, 1st Am. Comp.).
EFTA00201190
Case 9:08-cv-80811-KAM Document 47 Entered on FLSD
https://www.justice.gov/epstein/files/DataSet%209/EFTA00201190.pdf