EFTA00298455Set 9
2017-04-0610p4,709w
claim is barred by the statute of limitations; (c) the Complaint fails to allege personal jurisdiction
over Defendants; and (d) venue is improperly laid in the Southern District ... claim.
I. The Complaint Fails to State a Claim
The Complaint fails to allege facts demonstrating that the Plaintiff's alleged
"commercial" sexual acts occurred because the Defendants engaged ... coercion. To
sustain a Section 1595 claim, the Plaintiff must establish that her alleged sexual activity was the
product of "means of force, threat of force, fraud, coercion
https://www.justice.gov/epstein/files/DataSet%209/EFTA00298455.pdf
EFTA00592369Set 9
2017-03-3194p24,655w
just
4 doing ongoing work here. Well, the alleged number of articles
5 has more than doubled in his review. The alleged unique users,
6 which is his phrase ... shown to the jury to show that our client did
15 report her allegations to law enforcement and cooperated with
16 law enforcement. So your Honor, it comes ... hearsay exception and as nonhearsay to show
13 that Ms. did report her allegations to law enforcement
14 and cooperated with law enforcement.
15 Thank you, your Honor
https://www.justice.gov/epstein/files/DataSet%209/EFTA00592369.pdf
EFTA00175521Set 9
2008-07-1868p22,246w
Florida
Statute Section 772.103 against all three Defendants (DE 1). The facts, as alleged in the
Complaint, are as follows: At all relevant times, Epstein was an adult male ... citizen of Florida, complete diversity exists and this Court's jurisdiction is alleged to be proper.
As for Defendants claim that was fraudulently joined to defeat diversity
jurisdiction. (Notice ... district
courts in situations where a party removes a case from state court, alleging fraudulent joinder of
the non-diverse parties:
In a removal case alleging fraudulent joinder, the removing
https://www.justice.gov/epstein/files/DataSet%209/EFTA00175521.pdf
EFTA00181023Set 9
124p12,224w
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/EFTA00181023.pdf
EFTA00723017Set 9
20p4,948w
Second Amended Complaint and states:
1. Without knowledge and deny.
2. As to the allegations in paragraphs 2, Defendant asserts his Fifth Amendment
privilege against self-incrimination. See DeLisi ... bringing a claim seeking affirmative relief from asserting the privilege.
3. As to the allegations in paragraph 3, without knowledge and deny.
4. As to the allegations in paragraph ... bringing a claim seeking affirmative relief from asserting the privilege.
5. As to the allegations in paragraph 5, Defendant asserts his Fifth Amendment
privilege against self-incrimination. See DeLisi
https://www.justice.gov/epstein/files/DataSet%209/EFTA00723017.pdf
EFTA01105784Set 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/EFTA01105784.pdf
EFTA00309181Set 9
2010-11-2959p17,228w
Defendant") in the
above-captioned action misstates New York law, improperly relies upon allegations not
contained in Plaintiffs' first amended complaint ("FAC") and is unsupported by any affidavits or
exhibits ... reasons set forth below and accepting the factual allegations in the FAC as
true, drawing all reasonable inferences from them and construing them in a light most favorable ... operations. and the specific contact for communications with
Defendants' President relating to the matters alleged in the FAC. As documented by the attached
email from Mr. Christian Barthod, for example
https://www.justice.gov/epstein/files/DataSet%209/EFTA00309181.pdf
EFTA00582821Set 9
2017-06-3024p7,457w
demonstrated below, Edwards's Motion
is meritless should be denied, as the facts alleged on Epstein's Affidavit are entirely consistent
with his testimony, under oath, at his deposition ... Motion should be denied.
MEMORANDUM OF LAW
I. EPSTEIN'S TESTIMONY REGARDING THE ALLEGATIONS RELEVANT TO
THIS CASE HAS ALWAYS BEEN CONSISTENT WITH HIS JUNE 30, 2017
AFFIDAVIT
Epstein ... March 17, 2010 Deposition is attached hereto as "Exhibit B." Contrary to Edwards's allegations
in his Motion, the following questions were posed to, and answered by, Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00582821.pdf
EFTA00207722Set 9
2010-03-2929p9,495w
support of his motion,
Defendant states:
The Complaint attempts to allege 6 counts, all of which are purportedly brought
pursuant to 18 U.S.C. §2255 — Civil Remedies for Personal Injuries. Dismissal ... actual damages." (A.) Statutory Considerations: the statute does not allow for the
Plaintiff to allege multiple counts, six in this case, or multiple predicate act violations or
incidents ... required to be dismissed. (2) The statute in effect during the time of the alleged conduct
applies — the version in effect from 1999 to July 26, 2006, not the statute
https://www.justice.gov/epstein/files/DataSet%209/EFTA00207722.pdf
EFTA00085225Set 9
2021-07-1234p11,087w
districts. See United
States v. Russo, 801 F.2d 624, 626 (2d Cir. 1986). She alleges that officials in the U.S.
Attorney's Office for the Southern District of Florida sought ... offenses involving the sexual abuse of minors
Maxwell does not dispute that the facts alleged in the SI superseding indictment involve
the sexual abuse of minors. The indictment charges that ... Epstein sexually abused each of the
alleged minor victims and that Maxwell allegedly enticed them to travel or transported them for
that purpose. Instead, Maxwell contends that charged offenses
https://www.justice.gov/epstein/files/DataSet%209/EFTA00085225.pdf
EFTA00029540Set 8
2021-07-1234p11,084w
districts. See United
States v. Russo, 801 F.2d 624, 626 (2d Cir. 1986). She alleges that officials in the U.S.
Attorney's Office for the Southern District of Florida sought ... offenses involving the sexual abuse of minors
Maxwell does not dispute that the facts alleged in the SI superseding indictment involve
the sexual abuse of minors. The indictment charges that ... Epstein sexually abused each of the
alleged minor victims and that Maxwell allegedly enticed them to travel or transported them for
that purpose. Instead, Maxwell contends that charged offenses
https://www.justice.gov/epstein/files/DataSet%208/EFTA00029540.pdf
EFTA00794556Set 9
2017-03-31159p41,795w
what was at issue was the truth or falsity of the plaintiff's
7 allegations concerning sexual abuse and the activities of the
8 defendant. I think that ... statements about the defendant -- to be clear, because one of
16 the allegations is, of course, she was a madam and a
17 coconspirator with Epstein -- do involve Epstein ... your Honor. I think I lost
9 you there. I apologize.
10 So the allegations in the complaint are that when our
11 client came forward and said
https://www.justice.gov/epstein/files/DataSet%209/EFTA00794556.pdf
EFTA00205039Set 9
2011-04-2035p14,311w
Victims' Rights Act
(the "Motion") [DE 48].I In the context of a motion alleging that the U.S. Department of Justice
violated Plaintiff's rights under the Crime Victims Rights ... Justice regulations. Movant should be granted leave to intervene to rebut these false allegations,
and to seek sanctions. Alternatively, the Court on its own initiative should require Plaintiffs and
their ... compliance with Federal Rule of Civil Procedure 11.
Without any attempt to tie the allegations to the asserted violation of the CVRA,
Paragraphs 52 and 53 of the Motion falsely
https://www.justice.gov/epstein/files/DataSet%209/EFTA00205039.pdf
EFTA00292559Set 9
13p3,039w
Defendant/Counter-Plaintiff
Bradley Edwards' ("Edwards") Counterclaim, and states:
1. Epstein admits that the Counterclaim alleges an amout within the jurisdictional
purview of the Court, but denies that Edwards is entitled ... interpreted
any provision thereof in Paragraph 4 of his Counterclaim, Epstein denies the allegations.
EFTA00292559
5. Epstein admits that he was a party to civil actions brought on behalf ... purported
victims. The remaining allegations in Paragraph 5 contain annotations that are wholly
inapposite, unprincipled, needlessly inflammatory, and serve no purpose other than to
bolster Counter-Plaintiff's allegations
https://www.justice.gov/epstein/files/DataSet%209/EFTA00292559.pdf