EFTA00582880Set 9
2009-12-2111p3,299w
Edwards' M/Dismiss Amended Complaint
process claim against Epstein -- was done "with malice, moral turpitude, wantonness,
willfulness, or reckless indifference to the rights of others." Edwards has not done ... irrelevant to the
recovery of punitive damages because they do not establish "willful and wanton misconduct [by
Epstein] of a character no less culpable than what is necessary to convict ... process claim against him evinces a "reckless disregard of human
life . . . or which shows wantonness or recklessness . ." Am. Cyanamid
https://www.justice.gov/epstein/files/DataSet%209/EFTA00582880.pdf
EFTA01108155Set 9
2013-02-1127p6,394w
requirement when
7 pleading such.
8 You must plead ultimate facts demonstrating
9 wantonness, oppression, or outrage. And the law is
10 very clear; that the mere use of adjectives ... themselves insufficient to support a claim of
12 wantonness, recklessness, or maliciousness. And the
13 case for which that proposition stands is Leuare
14 versus Music & Worth Construction Incorporated ... Edwards fails to allege any additional facts
12 that support willful and wanton misconduct or gross
13 and flagrant reckless indifference for acts committed
14 by Mr. Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA01108155.pdf
EFTA00608623Set 9
2013-02-1127p6,223w
requirement when
7 pleading such.
8 You must plead ultimate facts demonstrating
9 wantonness, oppression, or outrage. And the law is
10 very clear; that the mere use of adjectives ... themselves insufficient to support a claim of
12 wantonness, recklessness, or maliciousness. And the
13 case for which that proposition stands is Leuare
14 versus Music & Worth Construction Incorporated ... Edwards fails to allege any additional facts
12 that support willful and wanton misconduct or gross
13 and flagrant reckless indifference for acts committed
14 by Mr. Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00608623.pdf
EFTA01108182Set 9
11p6,410w
must plead ultimate facts demonstrating
7
On behalf of Bradley J. Edwards: 9 wantonness, oppression. or outrage. And the law is
a SEARCY DENNEY SCAROLA. ET AL 10 very clear ... themselves insufficient to support a claim of
West Palm Beach. Florida 33409
12 wantonness, recklessness, or maliciousness. And the
L0 13 case for which that proposition stands is Leuare ... Fourth DCA case from 2010. and Marty versus Gresh.
12 that support willful and wanton misconduct or gross 12 501 So. 2d 87 Florida First DCA, 1987. which states
https://www.justice.gov/epstein/files/DataSet%209/EFTA01108182.pdf
EFTA01188267Set 9
2013-02-1127p6,394w
requirement when
7 pleading such.
8 You must plead ultimate facts demonstrating
9 wantonness, oppression, or outrage. And the law is
10 very clear; that the mere use of adjectives ... themselves insufficient to support a claim of
12 wantonness, recklessness, or maliciousness. And the
13 case for which that proposition stands is Leuare
14 versus Music & Worth Construction Incorporated ... Edwards fails to allege any additional facts
12 that support willful and wanton misconduct or gross
13 and flagrant reckless indifference for acts committed
14 by Mr. Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA01188267.pdf
EFTA01188256Set 9
11p6,411w
must plead ultimate facts demonstrating
7
On behalf of Bradley J. Edwards: 9 wantonness, oppression. or outrage. And the law is
a SEARCY DENNEY SCAROLA. ET AL 10 very clear ... themselves insufficient to support a claim of
West Palm Beach. Florida 33409
12 wantonness, recklessness, or maliciousness. And the
10 IIIIIIIII 13 case for which that proposition stands is Leuare ... Fourth DCA case from 2010. and Marty versus Gresh.
12 that support willful and wanton misconduct or gross 12 501 So. 2d 87 Florida First DCA, 1987. which states
https://www.justice.gov/epstein/files/DataSet%209/EFTA01188256.pdf
EFTA01092815Set 9
38p7,692w
created, and/or unsubstantiated.
55. As a direct result of this intentional, knowing, willful and wanton
misrepresentation by ATTORNEY LEWIS and ATTORNEY TEIN and LEWIS
TEIN and other former employees ... through and including November 2009, ATTORNEYS
LEWIS and ATORNEY TEIN and LEWIS TEIN knowingly, wantonly, improperly
and illicitly charged the MICCOSUKEE TRIBE millions of dollars in legal fees for
legal ... through and including November 2009, ATTORNEY
LEWIS and ATTORNEY TEIN and LEWIS TEIN knowingly, wantonly, improperly
and illicitly obtained and used the monetary property of the MICCOSUKEE TRIBE
https://www.justice.gov/epstein/files/DataSet%209/EFTA01092815.pdf
EFTA01188294Set 9
2013-02-1110p4,355w
requirement when
7 pleading such.
8 You must plead ultimate facts demonstrating
9 wantonness, oppression, or outrage. And the law is
10 very clear; that the mere use of adjectives ... themselves insufficient to support a claim of
12 wantonness, recklessness, or maliciousness. And the
13 case for which that proposition stands is Leuare
14 versus Music & Worth Construction Incorporated ... Edwards fails to allege any additional facts
12 that support willful and wanton misconduct or gross
13 and flagrant reckless indifference for acts committed
14 by Mr. Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA01188294.pdf
EFTA01188304Set 9
2013-02-1123p4,392w
requirement when
7 pleading such.
8 You must plead ultimate facts demonstrating
9 wantonness, oppression, or outrage. And the law is
10 very clear; that the mere use of adjectives ... themselves insufficient to support a claim of
12 wantonness, recklessness, or maliciousness. And the
13 case for which that proposition stands is Leuare
14 versus Music & Worth Construction Incorporated ... Edwards fails to allege any additional facts
12 that support willful and wanton misconduct or gross
13 and flagrant reckless indifference for acts committed
14 by Mr. Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA01188304.pdf
EFTA00613391Set 9
2016-02-0150p13,597w
irrelevant, defamatory and false
allegations that Dershowitz abused =, Edwards and Cassell acted willfully, wantonly and
recklessly and intentionally disregarded Dershowitz's rights, warranting the imposition of
punitive damages.
COUNT ... participated in and witnessed the abuse of "other minors," Edwards
and Cassell acted willfully, wantonly and recklessly and intentionally disregarded Dershowitz's
rights, warranting the imposition of punitive damages ... Motion's false, irrelevant and defamatory allegations
about Dershowitz, Edwards and Cassell acted willfully, wantonly and recklessly and
intentionally disregarded Dershowitz's rights, warranting the imposition of punitive damages.
COUNT
https://www.justice.gov/epstein/files/DataSet%209/EFTA00613391.pdf
EFTA01721823Set 10
2019-09-0622p6,769w
and/or abuse on African Soil.
At all times material hereto, Defendants' actions were willful, wanton, malicious,
reckless, and/or outrageous in their disregard for the rights and safety of the
Plaintiffs ... Defendants, both prior to
and/or subsequent to the misconduct committed herein.
Defendant(s) willful, wanton, gross negligent and /or negligent act(s) of
commission and/or omission, resulted directly ... United States Government.
At all times material hereto, defendant(s) actions were willful, wanton,
malicious, reckless, and outrageous in their disregard for the rights and safety of
the Plaintiff
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01721823.pdf
EFTA00152219Set 9
2019-09-0624p7,463w
and/or abuse on African Soil.
At all times material hereto, Defendants' actions were willful, wanton, malicious,
reckless, and/or outrageous in their disregard for the rights and safety of the
Plaintiffs ... Defendants, both prior to
and/or subsequent to the misconduct committed herein.
Defendant(s) willful, wanton, gross negligent and /or negligent act(s) of
commission and/or omission, resulted directly ... United States Government.
At all times material hereto, defendant(s) actions were willful, wanton,
malicious, reckless, and outrageous in their disregard for the rights and safety of
the Plaintiff
https://www.justice.gov/epstein/files/DataSet%209/EFTA00152219.pdf
EFTA00594193Set 9
2015-09-2118p3,677w
reading descriptions of truthful facts to disbelieve her entirely.
Maxwell made her false statements wantonly and with the specific intent to maliciously damage
good name and reputation ... sexually abuse and then, in order to avoid having these crimes discovered, Maxwell
wantonly and maliciously set out to falsely accuse, defame, and discredit . In so doing,
Maxwell's efforts ... exemplary damages are necessary in this case to deter Maxwell and
others from wantonly and maliciously using a campaign of lies to discredit and other
victims of sex trafficking.
PRAYER
https://www.justice.gov/epstein/files/DataSet%209/EFTA00594193.pdf
EFTA00585800Set 9
2002-04-2914p4,259w
Jeepers also
seeks an award of punitive damages as a result of Defendants' malicious, wanton, and oppressive
conduct.
THE PARTIES
4. Plaintiff Jeepers is a U.S. Virgin Islands corporation. Jeepers ... EFTA00585810
48. The conduct of Defendants toward Plaintiff was malicious, wanton, and
oppressive.
49. As a direct and proximate result of Defendants' misrepresentations, Plaintiff has
been injured.
SECOND CAUSE ... management fee charged to Jeepers.
54. The conduct of Defendants toward Plaintiff was malicious, wanton and
oppressive.
55. As a direct and proximate result of Defendants' breaches, Plaintiff has been
https://www.justice.gov/epstein/files/DataSet%209/EFTA00585800.pdf
EFTA00085709Set 9
2019-06-2435p9,342w
termination from employment, for employees of the
Department of Justice who willfully or wantonly fail to comply with provisions
of Federal law pertaining to the treatment of crime victims ... employee violated a crime victim's rights, but not in a willful or wanton manner,
the Ombudsman shall require the employee "to undergo training on victims'
rights." 28 C.F.R ... however, the Ombudsman finds that the DOJ
employee willfully or wantonly violated a crime victim's rights, the Ombudsman
shall recommend "a range of disciplinary sanctions
https://www.justice.gov/epstein/files/DataSet%209/EFTA00085709.pdf
EFTA00676990Set 9
2015-09-2112p2,669w
reading descriptions of truthful facts to disbelieve her entirely.
Maxwell made her false statements wantonly and with the specific intent to maliciously damage
good name and reputation ... sexually abuse and then, in order to avoid having these crimes discovered, Maxwell
wantonly and maliciously set out to falsely accuse, defame, and discredit . In so doing,
Maxwell's efforts ... exemplary damages are necessary in this case to deter Maxwell and
others from wantonly and maliciously using a campaign of lies to discredit and other
victims of sex trafficking.
PRAYER
https://www.justice.gov/epstein/files/DataSet%209/EFTA00676990.pdf