EFTA00793920Set 9
2018-04-1127p8,166w
denied. As an initial matter, there is no power to make a finding
of criminal contempt. Moreover, the Motions must be denied on the merits because the order
which Movants ... compensatory damages. DE 6323, p. 12. All Movants also seek either a finding of criminal
contempt and "monetary sanctions" (id. at p. 17) or a finding of criminal contempt ... Link.
Movants' Motions must be denied.
MEMORANDUM OF LAW
I. No Ability to Find Criminal Contempt
The Court does not have the ability to make a finding of criminal contempt
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793920.pdf
EFTA00728793Set 9
2008-06-3018p4,681w
FORBIDDING
HARASSMENT AND INDIRECT CONTACT, FOR APPROPRIATE SANCTIONS AND
ADDITIONAL REMEDIES INCLUDING REFERRAL FOR CRIMINAL CONTEMPT
Plaintiff, Jane Doe, through undersigned counsel, hereby files this emergency
motion for a hearing ... state court), including a referral to the U.S. Attorney's Office
for prosecution of criminal contempt.
To put the matter bluntly, defendant Epstein is intimidating Jane Doe in violation ... conference on
Tuesday or after any other court hearing;
Seventh, this Court should initiate criminal contempt sanctions against Epstein
for the violations of its two orders under Fed. R. Crim
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728793.pdf
EFTA01079679Set 9
2010-12-2726p6,194w
orders (and an order of the state court), including a referral
for prosecution of criminal contempt.
Jane Doe In violation
To put the matter bluntly, defendant Epstein is intimidating ... after any other court hearing;
ions against Epstein
Seventh, this Court should initiate criminal contempt sanct
by referring a criminal
for the violations of its two orders under ... Court ultimately proceeds first by way
the Fifth Amendment only in
by way of criminal contempt, Epstein would be entitled to invoke
Co., Inc., 480 F.3d 1234.
the later criminal
https://www.justice.gov/epstein/files/DataSet%209/EFTA01079679.pdf
EFTA00787717Set 9
2018-04-1350p11,164w
response.
18 The movants are asking for a finding of
19 civil contempt, criminal contempt, and extensive
20 discovery.
21 Civil concept -- as your Honor probably
22 knows, there ... motion, that Bankruptcy Courts don't have the inherent
4 power to find criminal contempt.
5 Now based on the facts that I just laid ... definition
OUELLETTE & MAULDIN COURT REPORTERS, INC.
EFTA00787745
Page 30
1 punitive, and that's criminal contempt. Civil contempt,
2 it only deals with future conduct, not anything that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00787717.pdf
EFTA00787704Set 9
2018-04-1313p10,979w
only way we could ever determine this would be to 19 civil contempt, criminal contempt, and extensive
20 get access to the CD and have it evaluated ... motion, that Bankruptcy Courts don't have the inherent 3 cases, that's seeking criminal contempt sanctions, which
4 power to find criminal contempt. 4 I've already discussed ... necessary, and have the Court
Page 30 Page 32
1 punitive, and that's criminal contempt. Civil contempt, 1 rule on objections. There shouldn't just be a carte
https://www.justice.gov/epstein/files/DataSet%209/EFTA00787704.pdf
EFTA01196969Set 9
2015-09-096p2,132w
circuit court found that the
county court's order constituted a finding of indirect criminal contempt
because it did not impose a purgeable sanction. As such, the circuit court
found ... Rule of
Criminal Procedure 3.840(a), which requires orders to show cause
regarding indirect criminal contempt be based "on the judge's own motion
or on affidavit of any person ... Rule 3.840(a) and filed an affidavit
from the tenant with his motion for criminal contempt. In the affidavit,
the tenant specifically alleged that he "received a telephone message from
https://www.justice.gov/epstein/files/DataSet%209/EFTA01196969.pdf
EFTA00736311Set 9
2010-07-026p831w
FORBIDDING HARASSMENT AND INDIRECT CONTACT,
FOR APPROPRIATE SANCTIONS AND ADDITIONAL REMEDIES INCLUDING
REFERRAL FOR CRIMINAL CONTEMPT UNDER SEAL
Plaintiff, Jane Doe, hereby moves this Court for an Order permitting Plaintiff ... Forbidding Harassment and Indirect Contact for Appropriate
Sanctions and Additional Remedies Including Referral for Criminal Contempt to be filed
under seal and would state:
Jane Doe requests this Emergency Motion ... Forbidding Harassment and Indirect Contact for Appropriate Sanctions and
Additional Remedies Including Referral for Criminal Contempt Under Seal.
DATED: July 2, 2010
Respectfully Submitted,
Bradley J. Edwards
FARMER, JAFFE, WEISSING
https://www.justice.gov/epstein/files/DataSet%209/EFTA00736311.pdf
EFTA00728811Set 9
2010-07-026p827w
FORBIDDING HARASSMENT AND INDIRECT CONTACT,
FOR APPROPRIATE SANCTIONS AND ADDITIONAL REMEDIES INCLUDING
REFERRAL FOR CRIMINAL CONTEMPT UNDER SEAL
Plaintiff, Jane Doe, hereby moves this Court for an Order permitting Plaintiff ... Forbidding Harassment and Indirect Contact for Appropriate
Sanctions and Additional Remedies Including Referral for Criminal Contempt to be filed
under seal and would state:
Jane Doe requests this Emergency Motion ... Forbidding Harassment and Indirect Contact for Appropriate Sanctions and
Additional Remedies Including Referral for Criminal Contempt Under Seal.
DATED: July 2, 2010
Respectfully Submitted,
Bradley J. Edwards
FARMER, JAFFE, WEISSING
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728811.pdf
EFTA00160901Set 9
2021-11-2923p15,532w
charge Mark Meadows, Donald Trump's final White House chief of staff, with criminal
contempt of Congress, a key panel member said. "I think we will probably make a decision ... days after a District of Columbia grand jury indicted him on
two counts of criminal contempt of Congress after he defied a subpoena commanding him to give evidence before
https://www.justice.gov/epstein/files/DataSet%209/EFTA00160901.pdf
EFTA00730286Set 9
2010-07-024p724w
Forbidding
Harassment And Indirect Contact, For Appropriate Sanctions, And Additional Remedies
Including Referral For Criminal Contempt
Plaintiff, JANE DOE and Defendant, JEFFREY EPSTEIN ("Epstein"), hereby file their
Joint Stipulation ... Forbidding Harassment And Indirect
Contact, For Appropriate Sanctions, And Additional Remedies Including Referral for Criminal
Contempt (the "Motion for Contempt"), and each state:
I. On July 2, 2010, Plaintiff filed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00730286.pdf
FORBIDDING HARASSMENT AND INDIRECT CONTACT. FOR
APPROPRIATE SANCTIONS, AND ADDITIONAL REMEDIES INCLUDING
REFERRAL FOR CRIMINAL CONTEMPT
STATE OF FLORIDA ) SS
COUNTY OF PALM BEACH )
BEFORE ME, the undersigned authority, personally ... Forbidding Harassment And Indirect Contact, For
Appropriate Sanctions, And Additional Remedies Including Referral For Criminal Contempt (the
EFTA00724321
"Motion for Contempt"). I have personal knowledge of the matters set forth
https://www.justice.gov/epstein/files/DataSet%209/EFTA00724321.pdf
EFTA00727603Set 9
2010-07-023p406w
Forbidding Harassment And Indirect Contact, For Appropriate Sanctions, And
Additional Remedies Including Referral For Criminal Contempt
Plaintiff, JANE DOE and Defendant, JEFFREY EPSTEIN ("Epstein"), hereby file their
Joint Stipulation ... Forbidding Harassment
And Indirect Contact, For Appropriate Sanctions, And Additional Remedies Including Referral
for Criminal Contempt (Des 194 and 195)(the "Motion for Contempt"), and each state:
1. On July
https://www.justice.gov/epstein/files/DataSet%209/EFTA00727603.pdf
EFTA00799314Set 9
2018-03-1923p6,803w
maliciously in disregarding
the injunction, then the court may cite the defendant for criminal contempt." Mercer v.
Mitchell, 908 F.2d 763, 769 (11th Cir. 1990) (citing 18 U.S.C ... notice be provided in open court in an
order to show cause before indirect criminal contempt can be imposed.
17
EFTA00799330
Case 09-34791-RBR Doc 6323 Filed 03/19/18 Page
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799314.pdf