EFTA00069276Set 9
2012-08-0134p14,214w
others.
Carl baby, I'm afraid this means your first "investigation" of my complaints to you wasn't exactly "thorough" as
I've been saying for years.
Shall I point ... Oleg related entities/people: Money laundering shells. Is the grossly corrupt SEC regretting their Jaclin
complaint which was a cover up for much larger criminal activity: MY CLAIMS?
But there ... more.
The SEC also brought "more coverup than complaint" In Frost,Honig,Alpha,Stetson et al. The SEC Knows who
else was involved in the Jaclin money laundering shell PRComplete/YESDtc
https://www.justice.gov/epstein/files/DataSet%209/EFTA00069276.pdf
EFTA00083492Set 9
2020-11-3051p18,796w
Michael Farkas: ilncubator and
Skyway: money laundering shells. Farkas conspicuously absent from SEC complaints. Controlled both.
Governor Richardson. Drexel Alum. Jonathan New: NETE CFO also BLNK. Prolific Bag Man JMJ/Keener ... Kamensky case. I have never met Kamensky. When I saw the joint SEC/SDNY
complaint I became physically ill. I am an SEC whistleblower. The SEC/SDNY have actively and continuously
obstructed ... Hanover/Magna, JMJ,Keener,
Hicks, Fife,UBSS, and FINRA's NITE Nov 2016 Rule 204 complaint. ALL my information. In addition: FINRA
EFTA00083512
brought a complaint against Brown Brothers Harriman AFTER
https://www.justice.gov/epstein/files/DataSet%209/EFTA00083492.pdf
EFTA00104216Set 9
2019-08-1049p12,907w
NAUTILUS, INC.; HYPERION AIR, LLC;
POPLAR, INC., JOHN AND JANE DOES
DEFENDANTS,
COMPLAINT
COMES NOW, the Government of the United States Virgin Islands ("Government") and
files this Complaint against ... V.I.C. § 4903.
EFTA00104216
GVI v. Estate of Jeffrey E. Epstein
GVI's Complaint
Page 2 of 48
4. The Virgin Islands is an unincorporated territory of the United States ... million in cash;
EFTA00104217
GVI v. Estate of Jeffrey E. Epstein
GVI's Complaint
Page 3 of 48
b. $127 million in fixed income and equity investments;
c. $195 million
https://www.justice.gov/epstein/files/DataSet%209/EFTA00104216.pdf
EFTA01112644Set 9
2010-06-0461p16,854w
filed a Motion for Default due to
Rothstein's failure to respond to the Complaint.
3. A default was entered by the Clerk on January 21, 2010.
4. Rothstein filed ... December 09, 2009, Rothstein was personally served with the
summons and Complaint in this action. See Verified Return of Service attached as
IEWilbit A and Affidavit of Carlos Aguirre, process ... came forward. See
Exhibit B 115. Mr. Aguirre then -personally placed the Complaint and Amended
Summons in Mr. Rothstein's hands and advised him that he was being served with
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112644.pdf
EFTA00726708Set 9
2010-01-27167p47,179w
Rothstein, et aL
Complex Litigation Division - Case No.: 09-062943 (19)
Third Amended Complaint
ABS CAPITAL FUNDING, LLC, ALEXA
FUNDING, LLC, BERENFELD SPRITZER
SHECHTER SHEER, LLP, TRACY
WEINTRAUB, GARY BERKOWITZ ... Defendants.
PAM
CLERK OF CIRCUIT COURT
f
BROWARO COUN Y. FL
THIRD AMENDED COMPLAINT
Plaintiffs, RAZORBACK FUNDING, LLC, D3 CAPITAL CLUB, LLC, BFMC
INVESTMENT, LLC, LINDA VON ALLMEN as Trustee ... Rothstein, et at
Complex Litigation Division - Case No.: 09-062943 (19)
Third Amended Complaint
STRICTLY KOSHER MEATS, INC., (collectively referred to herein as "Plaintiffs") hereby sue
Defendants, SCOTT W. ROTHSTEIN
https://www.justice.gov/epstein/files/DataSet%209/EFTA00726708.pdf
EFTA01082923Set 9
2011-07-13194p59,682w
motion to dismiss on the, I guess, it's the second amended
2 complaint.
3 MR. ACKERMAN: It's the amended complaint, be the
4 second complaint.
5 THE COURT ... case
20 started out with a thirty page, seventy-nine paragraph,
21 five count complaint that read more like a press release
22 than a legal pleading ... knew, which he didn't,
4 but we must take the allegations of the complaint as true,
5 if all he knew was, because there were a lot of people
https://www.justice.gov/epstein/files/DataSet%209/EFTA01082923.pdf
EFTA01100909Set 9
16p3,889w
BRADLEY J. EDWARDS, individually, and
L.M., individually,
Defendant(s).
MOTION TO DISMISS SECOND AMENDED COMPLAINT
Defendant/Counter-plaintiff, BRADLEY J. EDWARDS, moves this Honorable Court to
dismiss the Second Amended Complaint against ... action and in
support thereof would show:
1. the "Introduction" to the Second Amended Complaint is nothing more than
conclusory surplusage apparently intended to defame Mr. Edwards under the protection ... litigation privilege;
2. Except for the filing of a federal complaint that did not name Epstein and was
apparently never served on him,* the Amenclid:Complaint fails to identify
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100909.pdf
EFTA01198664Set 9
2013-07-1752p11,855w
DANIELS,
individually; JOSEPH TITPNB, individually,
Defendants.
PLAINTIFFS' MOTION FOR LEAVE TO FILE AMENDED COMPLAINT
COME NOW the Plaintiffs, KENNETH MANFREDI, SR., KENNETH MANFREDI,
JR., and ALEXANDER LIEBSTER, as trustee ... undersigned counsel, and hereby move this Court for leave to file their Amended Complaint,
a true and cowed copy of which is attached hereto and matted as Exhibit ... Estate of Ernesto Litter
(hereinafter collectively referred to as "Plaintiffs") filed the subject Complaint.
2. Plaintiffs have not attempted to amend the Complaint prior to this motion.
3. This amended
https://www.justice.gov/epstein/files/DataSet%209/EFTA01198664.pdf
EFTA00268792Set 9
2017-03-2320p3,944w
AdelaiSe SA b001:
23 March 2017
Our ref
Ms Jacqueline Pearce
Dear Ms Pearce
Complaints against practitioners eidi Salvemini, chlan McAuliffe, Bill Otham, Michael
Wood, Eugenia Matthews, Davi eather Mack ... your letter with annexure dated 1 March 2017, directed to the Society
regarding your complaint against the above mentioned practitioners.
Complaints against legal practitioners in South Australia fall within ... that you forward
it to the
Commissioner directly.
Please note that with regard to complaints against Magistrates I would suggest
that you
contact the Courts Administration Authority to establish
https://www.justice.gov/epstein/files/DataSet%209/EFTA00268792.pdf
EFTA01108155Set 9
2013-02-1127p6,394w
response that we provided,
10 Your Honor, was a highlighted copy of the complaint..
11 THE COURT: Then I got it. Okay. Yes, ma'am.
12 MS. COLEMAN: Judge ... Florida First DCA, 1986.
16 Allegations that are in an amended complaint
17 without supporting ultimate facts are insufficient as
18 a matter of law to stay a cause ... reusing the word
2 malice to support a claim in punitive damages.
3 This complaint fails to do so, and because of
4 that, the punitive damages allegations should
https://www.justice.gov/epstein/files/DataSet%209/EFTA01108155.pdf
EFTA00582880Set 9
2009-12-2111p3,299w
ignoring the applicable legal standards. It is premature
because it attacks a non-existent complaint and no operative complaint was pending. Second,
there is no basis for imposing punitive damages ... proceed with certain claims against Edwards that had been included in the initial complaint.
Third, claims against him were dropped does not provide a basis for asserting punitive damages ... XXXXMB AG
Epstein's Response in Opposition to Edwards' M/Dismiss Amended Complaint
process claim against Epstein -- was done "with malice, moral turpitude, wantonness,
willfulness, or reckless indifference to the rights
https://www.justice.gov/epstein/files/DataSet%209/EFTA00582880.pdf
EFTA00722862Set 9
2009-07-0818p4,771w
motion to dismiss in Jane Doe #8, along with a copy of her complaint.
While I know you expressed to Mr. Lefkowitz that you (USAO) were not inclined
to review ... Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
DEFENDANT EPSTEIN'S MOTION TO DISMISS PLAINTIFF'S COMPLAINT
Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his attorneys, moves
to dismiss Counts ... Plaintiff's Complaint as the causes of action are barred by
the applicable statute of limitations.' Rule 12(b)(6); Local Gen. Rule 7.1 (S.D. Fla.
2009). In support
https://www.justice.gov/epstein/files/DataSet%209/EFTA00722862.pdf
EFTA01079777Set 9
2009-10-1316p4,267w
ROTHSTEIN, individually and
BRADLEY J. EDWARDS, individually,
Defendants.
CORRECTED SECOND AMENDED COMPLAINT
The Plaintiff, Jeffrey Epstein, ("Epstein"), by and through his undersigned attorneys, files
this action against the Defendants, Scott ... fictitious structured settlements,
EFTA01079777
Epstein v Rothstein, Edwards
Case No.: 502009CA040800XXLIMBAG
Corrected Second Amended Complaint
including those falsely claimed to have been reached by RRA for Edwards' clients with claims ... improper use of the
judicial system and civil process by inter alio filing a complaint in federal court, although a state
court complaint had been pending on behalf
https://www.justice.gov/epstein/files/DataSet%209/EFTA01079777.pdf
EFTA00607688Set 9
2014-01-2778p19,578w
abuse
9 of process along with some other counts.
10 In response to that complaint, Mr. Scarola
11 on behalf of Mr. Edwards filed a counterclaim.
12 That counterclaim went ... case, we have exactly the same
14 issue. We've got a complaint that was filed that
15 is alleged in the counterclaim to be malicious
16 prosecution. We also ... from the
22 Edwards side, they have said that the filing of
23 the complaint was in itself it was untrue, the
24 information that was there was untrue; Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00607688.pdf
EFTA00606510Set 9
2014-01-2778p19,578w
abuse
9 of process along with some other counts.
10 In response to that complaint, Mr. Scarola
11 on behalf of Mr. Edwards filed a counterclaim.
12 That counterclaim went ... case, we have exactly the same
14 issue. We've got a complaint that was filed that
15 is alleged in the counterclaim to be malicious
16 prosecution. We also ... from the
22 Edwards side, they have said that the filing of
23 the complaint was in itself it was untrue, the
24 information that was there was untrue; Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00606510.pdf
EFTA01178092Set 9
2012-06-1454p27,105w
cases that were going on in 2009, the deposition
19 costs, the filing of complaints, and things of that
20 nature? Where did that money come from from your ... listed himself as lead counsel.
20 Q. Do you know if any additional complaints
21 were filed while the case was at RRA?
22 A. I have no idea ... Ponzi scheme, Mr. Edwards or anyone in that
25 litigation group to file additional complaints?
0054
1 A. No.
2 Q. Who is Cara Holmes
https://www.justice.gov/epstein/files/DataSet%209/EFTA01178092.pdf
EFTA00600803Set 9
2009-08-143p841w
Conference with RCJ and JDE.
01/21/09 EBS Review case file in preparation for drafting complaint 2.25 506.25
01/23/09 KWE Travel to and from Wachula; Collateral interviews with ... emails; status report; emalls. 0.25 106.25
02/26/09 EBS Review and analyze comments to draft. complaint; 0.25 56.25
conference with AE, SB, re:* settlement negotiations
and drafting of complaint
02/26/09 ... Conference with Amy Josefsberg Eden; EBS; 3.00 1,275.00
Reviewing other complaints; Looking torn
complaint Editing draft; Telephone call with Amy
Josefsberg Eden and RCJ.
02/27/09 EBS Review comments
https://www.justice.gov/epstein/files/DataSet%209/EFTA00600803.pdf