EFTA00582880Set 9
2009-12-2111p3,299w
DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'
MOTION FOR LEAVE TO AMEND TO ASSERT CLAIM FOR PUNITIVE DAMAGES
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his
undersigned counsel, hereby offers the following response ... Defendant/Counter-
Plaintiff EDWARDS' ("Edwards") Motion for Leave to Assert a Claim for Punitive Damages
("motion")" and states:
SUMMARY OF ARGUMENT
Edwards' latest kitchen-sink motion for leave to add punitive ... damages is utterly frivolous,
obscuring the relevant issues and flatly ignoring the applicable legal standards. It is premature
because it attacks a non-existent complaint and no operative complaint
https://www.justice.gov/epstein/files/DataSet%209/EFTA00582880.pdf
EFTA01735094Set 10
2009-07-2450p14,401w
action and the claims set forth herein
pursuant to 18 U.S.C. § 2255. L.M. seeks damages in excess of 1 million dollars.
7. This Court has venue of this action pursuant ... admitting liability for all counts
enumerated in this Complaint. Plaintiff L.M. is entitled to damages, as further alleged
below, including damages as provided in 18 U.S.C. § 2255, as amended ... embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01735094.pdf
EFTA01279893Set 10
2002-04-1531p13,198w
resulting from
any action of his pet, and shall repair at his expense any damage to the Common Elements caused
by his pet. If any Owner violates these rules more ... contractor designated by the
Executive Board. The Owner shall also be responsible for any damage caused by the removal of
the antenna or satellite dish, including the sealing of conduits ... shall indemnify, defend and
hold the Association harmless from and against any loss, damage, claim or other liability resulting
from the installation, maintenance, repair, use and/or removal of the antenna
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01279893.pdf
EFTA01413064Set 10
55p17,363w
encouraged to use this access restriction
capability to help reduce losses or damages
that may arise out of improper or unauthorized use of an Internet Banking
EFTA01413076
Service ... liable
or have any responsibility of any kind for
any loss or damage incurred by you as a result, directly or indirectly, of
any unauthorized person gaining
access ... other things, this means that
you will be solely liable for any
losses or damages resulting from your breach of this Agreement or to which
your negligence contributed, or
which
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01413064.pdf
EFTA02073776Set 10
2015-07-2940p14,444w
and/or American
Express. Concierge Company and/or American Express shall not be liable for loss, damage, or
other claim with respect to any services or products provided to Card Member ... and/or American
Express. Concierge Company and/or American Express shall not be liable for loss, damage, or
other claim with respect to any services or products provided to Card Member ... and/or American
Express. Concierge Company and/or American Express shall not be liable for loss, damage, or
other claim with respect to any services or products provided to Card Member
https://www.justice.gov/epstein/files/DataSet%2010/EFTA02073776.pdf
EFTA01433867Set 10
2018-08-2029p7,744w
Corp., and ABC, Inc., as follows:
INTRODUCTION
1
This is an action to recover damages on behalf of Plaintiffs and members of
the
proposed class, defined below (the "Class ... Federal Rules of Civil Procedure for money damages.
68.
This suit is a class action brought on behalf of a Class consisting of and
defined as
all investors, Noteholders, and/or ... Class
reasonably
relied to their detriment;
B. whether Plaintiffs and the Class suffered monetary damages as a result of
the
Defendants' deceptive, unlawful and unfair actions
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01433867.pdf
EFTA01308056Set 10
2008-07-1122p4,693w
resident of the State
of New York.
6. This is an action for damages in excess of $50 million.
7. This Court has jurisdiction of this action and the claims ... continue to suffer severe and permanent traumatic injurie
s, including mental, psychological and
emotional damages.
WHEREFORE, PlaintiffJane Doe, by and through her
Father, as parent and natural guardian,
demands judgment ... against Defendant Jeffrey Epstein for compe
nsatory damages, punitive damages,
costs, and such other and further relief as this Court deems
just and proper.
HERMAN & MERMELSTEIN. P. A.
wkwi.nermanlaw.com
SDNY
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01308056.pdf
EFTA02074500Set 10
2015-08-2649p19,007w
and/or American Express.
Concierge Company and/or American Express shall not be liable for loss, damage,
or other claim with respect to any services or products provided to Card Member ... and/or American Express.
Concierge Company and/or American Express shall not be liable for loss, damage,
or other claim with respect to any services or products provided to Card Member ... and/or American Express.
Concierge Company and/or American Express shall not be liable for loss, damage,
or other claim with respect to any services or products provided to Card Member
https://www.justice.gov/epstein/files/DataSet%2010/EFTA02074500.pdf
EFTA01416838Set 10
2017-06-19122p23,787w
Settlement, vehicles deemed a total loss (other than
vehicles whose engines failed or were damaged
due to timing-chain tensioner and/or timing chain failure), vehicles whose
true mileage is unknown ... their vehicle at a loss before the effective
settlement date due
to an unrepaired damaged or failed engine caused by timing-chain tensioner
and/or timing
chain failure, again subject ... predicated on the core common issue as to whether
Defendants are
liable for the damages suffered" by Class members as a result of the
defective part. Id.
3. Typicality
Under
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01416838.pdf
EFTA02326346Set 11
2015-12-1081p13,640w
prior =o shipment. Upon receipt, please inspect
your purchase and notify us of =ny damage; we will arrange for a prompt replacement. If, within 7 days =or Quick Ship
upholstery ... value.
We cannot accept returns on monogrammed, =ersonalized, special-order items, or on items damaged through normal
=ear and tear. We also cannot accept returns of final-sale items which ... prior =o shipment. Upon receipt, please inspect
your purchase and notify us of =ny damage; we will arrange for a prompt replacement. If, within 7 days =or Quick Ship
upholstery
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02326346.pdf
EFTA01704493Set 10
2006-02-10100p58,178w
anywhere
at www.americanexpress.com/paybill.
For automatic replacement of a lost, stolen, non-received or damaged card, call 1-800-992-3404. For automatic
balance information, please call ... coiled the funds electronically we may issue a draft against your bank or asset Damage Insurance
account for the amount of the check Authorization for Electronic Payments: By using ... anywhere
at www.americanexpress.com/paybill.
For automatic replacement of a lost, stolen, non-received or damaged card, call 1-800-992-3404. For automatic
balance information, please call
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01704493.pdf
EFTA01327387Set 10
2021-01-111060p189,510w
Requirements
Section 4.3 No Right to Self Insure
Section 4.4 Mete of Loss or Damage. Application of Proceeds
Section 4.5 Reports. Policies. Certificates
Section 4.8 -• -. . . . -- Attorney-in-Fact
ARTICLE ... which may from time to time become worn out, lost, stolen, destroyed, seized. confiscated.
damaged beyond repair or permanently rendered unfit for use for any reason whatsoever. In addition ... testing
of any Parts, whether or not worn out, lost, stolen, destroyed. seized, confiscated damaged beyond repair or permanently
rendered unfit for use; provided, however, that the Grantor
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01327387.pdf
EFTA01704293Set 10
2006-03-04100p47,912w
oral agreement."
Other Important Information About Your Account
Regarding The Car Rental Loss and Damage Insurance Plan
We are adding coverage for Loss of Use as an additional benefit ... Rental Loss and Damage Insurance Plan. This coverage wil be
in effect for any Loss of Use incurred on or after May 1, 2006. Also, additional changes to the Plan ... been noted below. Accordingly, the
Description of Coverage for the Car Rental Loss end Damage Insurance Plan is revised as follows, effective May 1, 2006.
The following definition is added
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01704293.pdf
EFTA01962678Set 10
2013-08-1921p9,692w
which are collectively referred to as "Released
Parties"), any and all claims, damages, causes of action or disputes, whether known or
unknown, based upon acts or omissions occurring or that ... limited to, any and all claims for wages, employment benefits, and damages of any kind
whatsoever arising out of any contracts, expressed or implied (including without limitation
the Employment Agreement ... agrees that he will not seek and hereby waives any claim for
personal damages and/or other personal relief. Dr. Nikolic agrees to cause the withdrawal or
dismissal with prejudice
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01962678.pdf
EFTA00012111Set 8
2021-01-111060p170,897w
which may from time to time become worn out, lost, stolen. destroyed, seized, confiscated.
damaged beyond repair or permanently rendered unfit for use for any reason whatsoever. in addition ... testing
of any Parts, whether or not worn out, lost, stolen, destroyed, seized, confiscated, damaged beyond repair or permanently
rendered unfit for use; provided, however, that the Grantor ... such Part can be removed from such item of Equipment without causing any material damage thereto. Upon the removal
of any Part as above provided, such Part will be released
https://www.justice.gov/epstein/files/DataSet%208/EFTA00012111.pdf
EFTA01331565Set 10
2021-01-111060p191,110w
Requirements
Section 4.3 • • ---- - • - .. No Right to Self insure
Section 4.4 ... . Notice of Loss or Damage. Appticaton of Proceeds
Section 4.5 • • • -- - • • • • •. - Reports. Policies. Certificates
Section 4.6 -• -•• •• - . • ..• Attorney-in-Fact
ARTICLE ... from time to time become worn out, lost, stolen, destroyed,
Grantor, at its
damaged beyond repair or permanently rendered unfit for use for any reason whatsoever. In addition, the
cost ... permanently
of any Parts, whether or not worn out, lost. stolen, destroyed, seized, confacated, damaged beyond
to be
rendered unfit for use; provided, however, that the Grantor
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01331565.pdf
EFTA01704093Set 10
2004-01-08100p48,503w
upon receipt of statement.
For automatic replacement of a lost, stolen, non-received or damaged card, call 1-800-992-3404. For automatic
balance information, please call ... Your maximum liabhity is $50 should you fail to report its loss or theft. Damage Insurance
Charge Card and Statement Information: The annual fee is $395.00 for the Basic Platinum ... Renewal Cards are issued every three years. If the Card you carry is damaged, you may have it replaced sooner Hearing impaired
by calling Customer Service. The $5 amual subscription
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01704093.pdf