Epstein Files Search

EFTA01070407Set 9

2009-02-1344p15,146w

dant is entitled to the documents objection is required to be overruled, and Defen requested. Production Request No. 2 , psychologists, 2. All bills/expenses from any medical doctor, chiropractor members ... required to immediately dant realleges and documents. In support of ordering immediate production, Defen To Discovery" to request no. 5 incorporates his "Legal Argument Supporting Entitlement above herein. EFTA01070414 Document ... party involved in the privileged, which is relevant to the claims or defen pending action." Id. ding Plaintiffs sexual In accordance with Rule 26, the discovery sought regar whether

https://www.justice.gov/epstein/files/DataSet%209/EFTA01070407.pdf

EFTA00731015Set 9

2010-02-0427p10,511w

dants in civil actions. — "... a specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defen ded from asserting the privilege civil defendant who raises an affirmative defense is not preclu ... dants in civil actions. — "... a specific denial."). See also 24 yla.Jur,2d Evidence §592. Defen precluded from asserting the privilege civil defendant who raises an affirmative defense ... constitute the kind of voluntary [against self-incrimination], because affirmative defen plaintiff bringing a claim seeking application for affirmative relief' which would prevent a affirmative relief from asserting the privilege

https://www.justice.gov/epstein/files/DataSet%209/EFTA00731015.pdf

EFTA01126028Set 9

2010-02-0428p10,848w

dants in civil actions. — "... a specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defen ded from asserting the privilege civil defendant who raises an affirmative defense is not preclu ... dants in civil actions. — "... a specific denial."). See also 24 yla.Jur,2d Evidence §592. Defen precluded from asserting the privilege civil defendant who raises an affirmative defense ... constitute the kind of voluntary [against self-incrimination], because affirmative defen plaintiff bringing a claim seeking application for affirmative relief' which would prevent a affirmative relief from asserting the privilege

https://www.justice.gov/epstein/files/DataSet%209/EFTA01126028.pdf

EFTA00178938Set 9

19p8,463w

counsel and the Epstein 1 write to follow up on the Decemberl4th meeting between defen al Agent in Charge and myself.' I prosecutors. as well as our First Assistant ... provide for the OSI: objections to the appointment proem; die USA() propos of defens e cownµ l matter. before I had any knowledge an independent third Irony selector ... District has agreed to defer •—• • e counsel. hundred pages of arguments and exhibits from defens ' Over the past two weeks. we have received several be interpr et as agreem

https://www.justice.gov/epstein/files/DataSet%209/EFTA00178938.pdf

EFTA01070533Set 9

2009-07-2041p13,997w

PLAIN NDANT'S EXPENSES,: PLAINTIFFS OBJECTIONS. & FOR DEFE INCLUDING ATTORNEYS' FEES the Court on Defen dant Epstein's Motion To THIS CAUSE came before •.. ce To Plaintiff And To 0Yerrule ... entitled °Sexual Batter dant, ." "Conspiracy to Commit Tortlous Assault only against Defen seek Information about In her answers to Interrogatory nos. 9 and 10, which C.MA.'s damages claims, Plaintiff ... component dant is entitled to the documents objection is required to be overruled, and Defen requested. Production Request No. 2 ractor, psychologists, 2. All bills/expenses from any medical doctor, chirop

https://www.justice.gov/epstein/files/DataSet%209/EFTA01070533.pdf

EFTA01076581Set 9

2009-12-2130p7,583w

knowledge to either admit or 39. Defen ct agr aph 39 and the reb y den ies these allegations and demands stri anions contained in Par proof thereof ... dant, r in RR A) all atte nde d Ep stein's deposition, otherwise Defen Adler (another named partne agraph 42 (c). Defendant ... Julies the allegations contained 73, Defen pre viously set forth herein. 1-53, 55-59, 61-68 and 70-72 as EFTA01076597 Q012 I SEARCY DERRY FAX 3618845818 (: 12/21/200

https://www.justice.gov/epstein/files/DataSet%209/EFTA01076581.pdf

EFTA00724098Set 9

2010-04-1616p3,535w

million in Scott Rothstein's Penal schem added a number of bigh•prothe defene dants Thesday to a lawsuit 'getting racer-- . The latest version of the suit names Private Bank ... more red flags his dealings with pensa victi Rothstein. "Wete havems.added deep-pocket defen• The complaint also listed as defen- dents." he seat I believe there will be dants Seismal ... hoodwink are "bona? ed a lot lie said he doubted if any of the defen of people. Ha was good.. He was real dants would be surprised

https://www.justice.gov/epstein/files/DataSet%209/EFTA00724098.pdf

EFTA00286283Set 9

2009-11-2036p8,598w

certain dant in the Civil Actions. scheme directly impacted EPSTEIN as a named defen quoted in a November 2009 19. Miami attorney and developer, Alan Sakowitz, was a potential investor ... dants could be in essence evidence to use with investors to show how potential defen the value of any legitimate blackmailed into paying settlement that far exceeded damage claim ... causing EPSTEIN to spend tens ding of dollars in unnecessary attorneys' fees and costs defen but was what appeared to be discovery related to the Civil Actions entirely related

https://www.justice.gov/epstein/files/DataSet%209/EFTA00286283.pdf

EFTA01070451Set 9

2009-07-2050p15,294w

Entitlement to Discovery produce the requested Once again, Plaintiff should be required to immediately Defen dant rea)leges and documents. In support of ordering Immediate production, To Discovery" to request ... then. minor encou another female in EPSTEIN's presence, and comm itted numerous ; Defen dant Plaintiff to become involved In prostitution iff includ ing, but not then minor Plaint criminal ... Judici dant's motion to compel therein directed County, State of Florida, which granted Defen multicount complaint Including claims for 3 In Batas v. Ruzzo supra, the Plaintiffs alleged

https://www.justice.gov/epstein/files/DataSet%209/EFTA01070451.pdf

EFTA00729404Set 9

2009-11-20103p24,512w

dant ROTHSTEIN and other coconspirators fraudulently cau in the RRA trust account Defen t controlled tely $57 million ove r several years to a trust accoun the clients to wire ... large charitable dan t RO TH ST EIN and other co-conspirators ma 35. Defen ate rita ble ins titu tion s, inc lud ing hospitals and other legitim vate

https://www.justice.gov/epstein/files/DataSet%209/EFTA00729404.pdf

EFTA01085328Set 9

2012-04-0422p4,448w

them in their individual capacities. Twelfth Affirmative As and for its twelfth affirmative defense, Defen that Plaintiffs claims are barred in whole or in part by lack of contract and/or ... part of their con Fifteenth Affirmative D As and for its fifteenth affirmative defense, Defen sessert that Plaintiffs' claims are a se barred in whole or in part ... orders to De for the fabrication of work to the specifications as outlined therein. Defen performed the work, fully expecting payment upon itk completion. The o purchase order issued

https://www.justice.gov/epstein/files/DataSet%209/EFTA01085328.pdf

EFTA01764521Set 10

2012-10-2622p10,920w

just a down payment on a larger bill to follow. Further, the defens= budget faces its own internal budget issues: for example, Tricare, the mi=itary's health program, costs ... range of poten=ial adversaries."15 These challenges are exacerbated by a crisis of defen=e procurement; America's leading-edge military systems are becoming less affordable and reliable. Aircraft ... Davis and Pe=er A. Wilson, Looming Discontinuities in U.S. Military Strategy and Defens= Planning (Washington, D.C.: The RAND Corporation, 2012), summary.<=p> 16. Christopher Cavas, '=U.S. Carrier Costs Will

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01764521.pdf

EFTA00187391Set 9

1998-03-3193p40,205w

effect in lease, and under those circum- of seq. 0FM leased the building to defen- stances consent could be withheld for any dant Jeffrey E. Epstein in 1992. Epstein reason ... motion for summary judg- as plaintiff Stroll is a citizen of Florida. defen- ment. See Fcd.R.Civ.P. 12(b). dant Epstein is a citizen of New York

https://www.justice.gov/epstein/files/DataSet%209/EFTA00187391.pdf

EFTA01128846Set 9

1996-12-268p6,939w

client privilege in the event that continuedfrom page 2 "perhaps appropriate" that co-defen- the codefendant decides to testify joint-defense meetings. The govern- dants be allowed to exchange infor ... cross-examination? answers to these questions are far waiver provision covers "any defen- from clear, no matter what the joint- OTHER CONCERNS dant who testifies at any proceeding, defense agreement ... care benefit care professions and that they did not Second Circuit found that the defen- program" under 5 24(b). Because the defraud a "health care benefit pro- dants' argument

https://www.justice.gov/epstein/files/DataSet%209/EFTA01128846.pdf

EFTA01089193Set 9

2009-06-12174p43,641w

undersigned counsel, hereby withdraws arguments I through VII as set forth in the Defen dant's Motion to Dismiss the Plaintiffs First Amended Complaint (FAC) [DE 29], dated

https://www.justice.gov/epstein/files/DataSet%209/EFTA01089193.pdf

EFTA01769065Set 10

2012-06-0518p10,570w

minister in the mid-1960s, he moved to the cabinet, becoming the defen=e minister. 6 EFTA_R1_00079419 EFTA01769070 Rabin knew that the=German government in Bonn had introduced ... especially for the meeting and RUcliger Wolf, a state secretary in the Federal Defen=e Ministry, signed on behalf of the German government. Since the Israeli g=vernment had financial

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01769065.pdf

EFTA01796841Set 10

2013-02-0717p9,679w

many observers,=however, and for Iran, too, the nomination of Hagel for secretary of defen=e may be a sign that the White House is beginning to realize that sanction ... President has made clear that is the policy of our government. As Secretary of Defen=e, I will make sure the Department is prepared for any contingency." Satloff's views

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01796841.pdf

EFTA01702869Set 10

2005-02-2570p10,581w

appropriate recipient alibis write to you because I am not certain who among the defen se team, and would thus ask that you letter. I address issues raised by several ... members of the defen team members. please provide a Copy of this letter to all appropriate defense slated in nit Deer:mixt ,1". tenet, First, I would like ro address

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01702869.pdf

EFTA01100849Set 9

2009-08-3156p13,903w

increase If the defendant comm arily a three-leve l decrea se if the defen dant volunt Second, § 2A3.5(b)(2) provides nted er but was preve corrected the failure ... register or voluntarily attempted to regist bute to and the defen dant did nut contri from registering by uncontrollable circumstances, stance s. The reduc tion covers cases in which

https://www.justice.gov/epstein/files/DataSet%209/EFTA01100849.pdf

EFTA01125659Set 9

5p2,760w

public at large." But the court noted that the civil plaintiffs suing the defen- dant were those members of the public at large *direct ' and proximately harmed as a result ... process, much less to disrupt or interfere with the scope or acceptance of a defen- dant's criminal plea. The pending civil litigation is specifically intended to be the means

https://www.justice.gov/epstein/files/DataSet%209/EFTA01125659.pdf