EFTA00282045Set 9
43p23,231w
EVENT, SHALL THE AUTHORIS OR
COPYRIGHT HOLDERS BE LIABLE FOR ANY CLAIM, DAMAGES OR OTHER LIABILITY, WHETHER IN AN
ACTION OF CONTRACT, TORT OR OTHERWISE, ARISING FROM ... LEFFLER OR SILICON GRAPHICS BE LIABLE FOR ANY SPECIAL INCIDENTAL
INDIRECT OR CONSEQUENTIAL DAMAGES OF ANY KIND, OR ANY DAMAGES WHATSOEVER
RESULTING FROM LOSS OF USE, DATA OR PROFITS, WHETHER ... ADVISED OF THE
POSSIBILITY OF DAMAGE, AND ON ANY THEORY OF LIABILITY, ARISING OUT OF OR IN CONNECTION
WITH THE USE OR PERFORMANCE OF THIS SOFTWARE.
Portions of this product
https://www.justice.gov/epstein/files/DataSet%209/EFTA00282045.pdf
EFTA00805442Set 9
2011-10-0416p4,481w
BRADLEY J. EDWARDS, individually,
Defendants/Counter-Plaintiff.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S
MOTION TO STRIKE DEFENDANT/COUNTER-PLAINTIFF'S DAMAGES
EXPERT WITNESS, DR. BERNARD JANSEN. AND TO EXCLUDE HIS TESTIMONY
Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), moves ... assist the trier of fact, and states:
INTRODUCTION
Edwards is Attempting to Recover Damages Based on a Defamation Action
Despite protestations to the contrary and this Court's rulings, Edwards ... plans to seek
damages based on a defamation action. Edwards' expert confirms this and Edwards has
illustrated this in both statements made to the Court and in discovery:
• March
https://www.justice.gov/epstein/files/DataSet%209/EFTA00805442.pdf
EFTA01120533Set 9
2010-06-3029p8,593w
tOUNTER-PLAINTIFF, EDWARDS' SECOND RENEWED MOTION FOR LEAVE TO
ASSERT CLAIM FOR PUNITIVE DAMAGES
Counter-plaintiff, BRADLEY J. EDWARDS, moves this Honorable Court for entry of an
Order granting ... leave to assert a claim for punitive damages against the Counter-defendant,
'JEFFREY EPSTEIN, and in support thereof would show that the evidente summarized herein
satisfies the statutory prerequisites ... assertion of a punitive damage claim. Specifically, the
evidence establishes that EPSTEIN's Complaint against EDWARDS;
1. was filed in the total absence of evidence to support any allegation
https://www.justice.gov/epstein/files/DataSet%209/EFTA01120533.pdf
EFTA00807900Set 9
2018-01-1757p21,391w
abatement of
the Purchase Price or to any lost profits or other damages, deductions, offsets or credits. In the
event Purchaser fails to notify Seller of its election within such ... shall not, in any respect, be reduced,
nor shall Purchaser be entitled to any damages by reason thereof. Purchaser agrees that upon
settlement at Closing, it shall be deemed ... enter into this Agreement. Purchaser assumes the full risk of
any loss or damage occasioned by any fact, circumstance, condition or defect pertaining to the
Property caused or arising
https://www.justice.gov/epstein/files/DataSet%209/EFTA00807900.pdf
EFTA00348327Set 9
2015-04-29121p66,382w
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%209/EFTA00348327.pdf
EFTA00810602Set 9
2018-08-1712p2,815w
Epstein.
In these contempt proceedings, the three Victims all successfully sought intervention to
seek damages from Epstein and his attorneys. This Court then requested that the Victims file a
summary ... their damages. DE 6427. Pursuant to that directive, the Victims then filed what they
believed to be adequate extension and summary of their damages request, suggesting that a
presumptive minimum ... amount might be an appropriate way of assessing their damages in this case
due to Epstein's improper retention of confidential materials. DE 6384. Epstein then contested
the presumptive approach
https://www.justice.gov/epstein/files/DataSet%209/EFTA00810602.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
EFTA00798407Set 9
2018-09-049p4,976w
License Agreement For Dockage, "[t]he owner shall be
liable for all damages to the Boat Slip and other facilities owned by [CBM] and other
boats or vessels or person ... landfall at St. Thomas.
11. As a direct and proximate result, CBM sustained heavy damage caused by Defendant
vessel to the concrete finger piers, pilings, wooden waters, cleats and other ... presently estimated allocated amount of $160,473 necessary to
repair and restore the damaged Marina and over $70,000 in allocated expenses to
implement temporary repairs to minimize any loss
https://www.justice.gov/epstein/files/DataSet%209/EFTA00798407.pdf
LL.M.. and Lisa A. Zakolski. M.A., J.D.
II. Malicious Prosecution
D. Damages
§ 47. Compensatory, generally
Topic Summary Correlation Table References
West's Key Number Digest
• West's Key Number ... Digest, Malicious Prosecution Om.65 to 67
A.L.Ft. Library
• Attorneys' fees as element of damages in action for false imprisonment or arrest, or for malicious prosecution. 21
A.L.R.3d 1068
Trial Strategy ... essential element of a malicious prosecution claim is that the plaintiff must suffer damages as a result of the original
proceeding.' In a malicious prosecution case, the general rule
https://www.justice.gov/epstein/files/DataSet%209/EFTA00795506.pdf
EFTA01143024Set 9
2011-12-0924p4,729w
forth in your Second
Amended Counterclaim, by providing:
a. a detailed description of the damages you allege you have suffered, including, but
not limited to, those you claim have resulted ... interference in your professional relationships; and
b. a detailed description of the special damages you allege that you have suffered,
including, but not limited to:
(1) the loss ... privilege. Subject to and without waiving that privilege, Bradley
Edwards has described the special damages he has sustained and will continue to sustain in the
future in his currently pending
https://www.justice.gov/epstein/files/DataSet%209/EFTA01143024.pdf
EFTA02052736Set 10
2016-05-0352p13,421w
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/EFTA02052736.pdf
EFTA00175470Set 9
2008-07-2151p10,530w
relief.2 It is clear, however, that
the plaintiff seeks more than $75,000 in damages. This case seeks damages in
connection with alleged sexual misconduct. (Compl. ¶¶ 6-7,) The Complaint ... 11th Cir. 2001) ("When
[a] complaint does not claim a specific amount of damages, removal from state
court is proper if it is facially apparent from the complaint that ... amount in
controversy exceeds the jurisdictional requirement.").
2
The Complaint seeks damages for "[more than] . . . $15,000." (Compl. ¶ I.) This
boilerplate is routinely used in Florida pleading practice to trigger
https://www.justice.gov/epstein/files/DataSet%209/EFTA00175470.pdf
EFTA00724170Set 9
2010-04-1310p2,005w
willing participant in the acts
alleged, and therefore hei claims are barred, or her damages are required to be reduce
accordingly.
EFTA00724176
B.B. v. Epstein, et al.
Page ... with other persons which were the sole or
contributing cause of Plaintiff's alleged damages.
3. As to all counts, Plaintiff impliedly consented to the acts alleged by not objecting ... therefore, her claims are barred, or her damages are required to be reduced
accordingly.
4. As to all counts, Defendant reasonably believed or was told that the Plaintiff had
attained
https://www.justice.gov/epstein/files/DataSet%209/EFTA00724170.pdf
EFTA00586942Set 9
2015-03-2728p10,596w
modifications to the normal life
limitations, overhaul and/or inspection intervals for the Aircraft;
"Material Damage" means any damage to the Aircraft which (a) in accordance with the
Manufacturer's maintenance ... under this Agreement as promptly as practicable after
such cause is terminated.
5.3 Material Damage or Casualty Occurrence prior to Delivery
If, prior to Delivery:
(a) the Aircraft suffers Material ... Damage, the Buyer or the Seller shall promptly notify
the other and the Escrow Agent upon becoming aware of the same and either party
may by notice to the other
https://www.justice.gov/epstein/files/DataSet%209/EFTA00586942.pdf
EFTA00299022Set 9
2006-07-1953p14,386w
their legal positions, the
risk of litigation, and the government's desire to minimize damaging impeachment
evidence of its witnesses. As summarized by AUSA Villafana, the USAO-SDFL made ... Epstein agreed
to waive his right to contest liability and damages as to an unidentified and unknown
number of individuals, whom the government would identify only after Mr. Epstein ... Davis, Oct. 25, 2007 (attached as
Exhibit ).
Mr. Epstein settled civil claims for damages with all claimants including those who
brought actions against him under §2255 as well as those
https://www.justice.gov/epstein/files/DataSet%209/EFTA00299022.pdf
EFTA00040739Set 9
2019-02-2133p11,275w
suit under
18 U.S.C. § 2255, they must agree to waive any other claim for damages. As part of the NPA,
Epstein would not contest the jurisdiction of the United States ... District Court and waived his right
to contest liability and damages. (NPA, DE 361-62.)
Among other provisions, the NPA expanded immunity to any "potential coconspirator"
of Epstein ... offender for life, and he had made certain concessions related
to the payment of damages. (DE 407 at ¶ 70.) According to Jane Doe 1, the Agents did not explain
that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00040739.pdf
EFTA00287399Set 9
2011-05-1819p8,301w
case of such cure, Company shall nevertheless be
responsible for any costs, expenses, or damages actually incurred by Contractor arising out of said
Company's Default.
14. jl ntenti onal ... employees and hold them harmless from and against any and all
claims, liability, losses, damages, costs, expenses (including reasonable attorneys' fees) judgments
and penalties ("Damages and Expenses") arising ... negligence or
willful misconduct on Contractor's part, Company shall indemnify Contractor against any Damages
and Expenses but not including any Damages and Expenses relating to any settlement entered into
https://www.justice.gov/epstein/files/DataSet%209/EFTA00287399.pdf