EFTA00728201Set 9
2009-03-0253p14,628w
every interrogatory and document request propounded by Plaintiff:
Drawing an adverse inference under these circumstances would
unconstitutionally burden my exercise of my constitutional rights,
would be unreasonable, and would therefore ... Reasons for Motion
Plaintiff's request for insurance documents is reasonable under the circumstances of this
case, and well within the scope of Fed.R.Civ.P. 26. Requests for such insurance ... Document Request no. 6. The
breadth of this definition is reasonable under the circumstances of this case. Upon information and
belief, Defendant Epstein conducted his business and personal affairs through
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728201.pdf
EFTA00598276Set 9
40p16,756w
permitted the release of restrictions
on the use or management of funds under certain circumstances. The changes UMIFA made to
the law permitted charitable organizations to use modern investment techniques ... part of an overall investment strategy,
6. Diversify investments unless due to special circumstances, the purposes of the
fund are better served without diversification,
7. Dispose of unsuitable assets ... also includes writings that do not have a donative purpose. For example,
under some circumstances the bylaws of the institution, minutes of the board of directors, or
canceled checks could
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598276.pdf
EFTA00221909Set 9
2009-07-1020p5,672w
Fourteenth Amendments as guaranteed
by United States Constitution. Drawing an adverse inference under these
circumstances would unconstitutionally burden my exercise of my
constitutional rights, would be unreasonable, and would therefore ... Fourteenth Amendments as guaranteed
by United States Constitution. Drawing an adverse inference under these
circumstances would unconstitutionally burden my exercise of my
constitutional rights, would be unreasonable, and would therefore ... Fourteenth Amendments as guaranteed
by United States Constitution. Drawing an adverse inference under these
circumstances would unconstitutionally burden my exercise of my
constitutional rights, would be unreasonable, and would therefore
https://www.justice.gov/epstein/files/DataSet%209/EFTA00221909.pdf
EFTA00205039Set 9
2011-04-2035p14,311w
person's knowledge, information, and belief, formed
after an inquiry reasonable under the circumstances:
(I) it is not being presented for any improper purpose, such as to harass,
cause unnecessary ... 11th Cir. 2003). The analysis is whether "a reasonable
attorney in like circumstances could believe that his actions were factually and legally
justified." Id (citing Riccard v. Prudential ... false. They were made in bad faith, without a factual inquiry reasonable under the
circumstances, or elementary research into the legal basis for the allegations.
Paragraphs 52 and 53 omit
https://www.justice.gov/epstein/files/DataSet%209/EFTA00205039.pdf
EFTA00230437Set 9
2010-12-1051p6,704w
attorney or law enforcement personnel or there are present other
extraordinary circumstances. Based on our review of Professor Cassell's correspondence, and the
pleadings filed in the Doe case ... EFTA00230437
• • •
court has made a fmding of misconduct and there are no extraordinary circumstances.
We have, therefore, determined that these allegations do not warrant further inquiry and we
consider this ... attorney or law enforcement personnel or there are present other
extraordinary circumstances. Based on our review of Professor Cassell's correspondence, and the
pleadings filed in the Doe case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00230437.pdf
EFTA00015219Set 8
2020-05-2658p17,292w
relating to any juvenile delinquency proceeding, unless the
release is necessary to meet certain circumstances described within the statute. This statute was
enacted before the Open FOIA ... criminal history of third party
juveniles. Plaintiffs' request does not meet the specific circumstances set forth in the statute for
disclosure; therefore, the records are properly withheld pursuant to Exemption ... time of the creation of the
document, and not the present.
19 In some circumstances, surviving relatives of a deceased individual retain privacy interests in
their information, even after
https://www.justice.gov/epstein/files/DataSet%208/EFTA00015219.pdf
EFTA00018515Set 8
2020-07-1026p8,001w
Characteristics
Demonstrate That She Is Not a Flight Risk 12
2. The Nature and Circumstances of the Charges and the Weight of
the Evidence Militate in Favor of Bail ... through counsel, since Epstein's arrest. Finally, the government
argues that the nature and circumstances of the offense and the weight of the evidence warrant
2
EFTA00018520
Case ... significantly impair a defendant's ability to prepare her defense. Simply put,
under these circumstances, if Ms. Maxwell continues to be detained, her health will be at serious
risk
https://www.justice.gov/epstein/files/DataSet%208/EFTA00018515.pdf
EFTA00310618Set 9
1999-01-0458p26,346w
security, basket of securities or index. The Partnership may pursue these
investments in several circumstances including: (i) to hedge public market securities which a
company owns (holding company structure ... selecting attractive short sale positions
including companies which: under a reasonable set of circumstances appear unlikely to grow into
their valuations, are earning seemingly unsustainably high returns on capital ... capital where
appropriate. The use of leverage has attendant risks and
can, in certain circumstances, substantially increase the
adverse impact to which the Partnership's investment
portfolio may be subject
https://www.justice.gov/epstein/files/DataSet%209/EFTA00310618.pdf
EFTA01197165Set 9
57p27,425w
entities or accounts in a manner that it deems fair and
equitable under the circumstances existing at such time. (See "Other
Activities of the General Partner, Investment Manager; Conflicts ... techniques are employed, they seldom hedge the risks of positions entirely, and in some
circumstances losses may be incurred on both the underlying position and the hedge position
simultaneously ... EMPLOY FROM TIME TO TIME ON
BEHALF OF THE PARTNERSHIP CAN, IN CERTAIN CIRCUMSTANCES, INCREASE
THE ADVERSE IMPACT TO WHICH THE PARTNERSHIP'S PORTFOLIO MAY BE
SUBJECT. (SEE "CERTAIN RISK
https://www.justice.gov/epstein/files/DataSet%209/EFTA01197165.pdf
EFTA02713615Set 11
2012-11-2957p27,450w
entities or accounts in a manner that it deems fair and
equitable under the circumstances existing at such time. (See "Other
Activities of the General Partner, Investment Manager; Conflicts ... techniques are employed, they seldom hedge the risks of positions entirely, and in some
circumstances losses may be incurred on both the underlying position and the hedge position
simultaneously ... EMPLOY FROM TIME TO TIME ON
BEHALF OF THE PARTNERSHIP CAN, IN CERTAIN CIRCUMSTANCES, INCREASE
THE ADVERSE IMPACT TO WHICH THE PARTNERSHIP'S PORTFOLIO MAY BE
SUBJECT. (SEE "CERTAINRISK FACTORS
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02713615.pdf
EFTA00621488Set 9
2011-03-15117p29,066w
relates
8 to the attorney's mental thoughts and
9 impressions. Under almost all circumstances,
10 the thoughts and impressions of a lawyer are
11 completely privileged as work-product ... Under certain circumstances, upon the
13 demonstration of need and upon the demonstration
14 of inability to obtain facts from other sources,
15 fact work-product can be obtained from ... relating to conversations with U.S. Attorneys
14 and FBI Agents which under no circumstances
15 have any privity with the joint defense. So
16 passing it on, particularly coming from
https://www.justice.gov/epstein/files/DataSet%209/EFTA00621488.pdf
EFTA00087251Set 9
2016-02-2921p6,032w
only if the order had
been improvidently granted or upon a showing of extraordinary circumstances or compelling
need.
Judge McMahon held a second ex parte hearing on April ... protective order because it
was subject to modification. Second, the Government had shown extraordinary circumstances
supporting modification of the protective order because it could not otherwise obtain information
about ... case, applying the same
standard but concluding that the Government had not shown extraordinary circumstances or
compelling need.
Following Judge McMahon's order, BSF turned over its records from
https://www.justice.gov/epstein/files/DataSet%209/EFTA00087251.pdf