EFTA00788112Set 9
107p21,462w
would like to do is proceed first with the
8 motion for summary judgment that was filed
9 by Mr. Edwards -- strike that -- by
10 Mr. Epstein -- excuse ... heard on that, at least,
7 prior to you hearing the summary judgment
8 motion.
9 I apologize, Mr. Scarola, for jumping
10 in.
11 THE COURT: Okay, the motion ... lots of reasons to be
20 prepared to argue the motion for summary
21 judgment today.
22 Your Honor will recall at the hearing
23 of September 15th when
https://www.justice.gov/epstein/files/DataSet%209/EFTA00788112.pdf
EFTA01295845Set 10
2016-10-1252p21,251w
failure to file its brief.
OUTCOME: Motion to dismiss granted.
CORE TERMS: summary judgment, scheduling, reconsideration, deadline, weigh, failure
to prosecute, designation, discovery, failure to comply, affirming, bankruptcy proceedings,
extension ... defense.
Bankruptcy Law > Practice 8, Proceedings > Appeals > Procedures
[HN2j An appeal from a judgment, order, or decree of a bankruptcy judge to a district court
or bankruptcy appellate panel shall ... plaintiff or would constitute a complete
defense.
Bankruptcy Law > Practice & Proceedings > Adversary Proceedings > Judgments &
Remedies
Bankruptcy Law > Practice & Proceedings > Appeals > Standards of Review >
General Overview
Civil Procedure > Summary Judgment > Standards
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01295845.pdf
EFTA01100608Set 9
2011-04-0830p8,889w
Filed 04/08/11 Page 1 of 30
EXHIBIT B
Epstein vs. Edwards
Motion for Summary Judgment
EFTA01100608
Case 09-34791-RBR Doc 1603-2 Filed 04/08/11 Page ... BRADLEY J. EDWARDS, individually,
Defendants,
DEFENDANT BRADLEY J. EDWARDS'S MOTION FOR FINAL SUMMARY JUDGMENT
Defendant, Bradley J. Edwards, Esq., by and through his undersigned counsel and pursuant to
Rule ... Florida Rules of Civil Procedure, hereby moves for Final Summary Judgment and in
support thereof states as follows:
I. INTRODUCTION
The pleadings and discovery taken to date show that there
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100608.pdf
EFTA01100963Set 9
2011-11-0924p7,030w
EDWARDS, individually,
Defendants,
DEFENDANT BRADLEY J. EDWARDS'S
RENEWED MOTION FOR FINAL SUMMARY JUDGMENT
Defendant, Bradley J. Edwards, Esq., by and through his undersigned counsel and
i
purkuant to Rule ... matirial facts and that Bradley J. Edwards, Esq. is entitled to summary judgment for all claims
brought against him in Plaintiff Jeffrey Epstein's Second Amended Complaint. Not only ... camera.
B. Summary of the Argument
Bradley J. Edwards, Esq., is entitled to summary judgment on Epstein's frivolous claim
for at least three separate reasons.
First, because Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100963.pdf
EFTA00234871Set 9
2009-06-1941p9,427w
PROPERTY OF EPSTEIN, AND TO POST A $15 MILLION BOND,
TO SECURE POTENTIAL JUDGMENT
COMES NOW Plaintiff Jane Doe, by and through undersigned counsel, and
hereby files this Motion ... Epstein's property, and to post a $15
million bond to secure any potential judgment in this case, for the reasons explained in
the accompanying supporting memorandum.
Plaintiff Jane ... Epstein's property and to post a $15 million bond to secure any potential judgment in
this case.
Epstein is a billionaire who recently has been fraudulently transferring his assets
https://www.justice.gov/epstein/files/DataSet%209/EFTA00234871.pdf
EFTA00616074Set 9
2014-05-075p1,562w
SUMMONS
To the employer.
YOU ARE SUMMONED and required to file answers to the judgment creditor's interrogatories, in the Office of the Clerk of this
Court, 18 North County ... summons and to wages which become due
thereafter until the balance due on the judgment is paid.
IF YOU FAIL TO ANSWER, A CONDITIONAL JUDGMENT BY DEFAULT MAY BE TAKEN ... AGAINST YOU FOR
THE AMOUNT OF THE JUDGMENT UNPAID. .
FEDERAL AGENCY EMPLOYEES: Effective upon service of this summons and pursuant to 5 USC 552(a), you am to
commence
https://www.justice.gov/epstein/files/DataSet%209/EFTA00616074.pdf
EFTA01282752Set 10
2013-10-2843p24,134w
applicable to it, any provision of its constitutional documents, any order or judgment of any court
or
other agency of government applicable to it or any of its assets ... organisation or the jurisdiction of its head or home office, a
proceeding seeking a judgment of insolvency or bankruptcy or any other relief under any
bankruptcy or insolvency ... supervisor or similar official, or
(B) has instituted against it a proceeding seeking a judgment of insolvency or bankruptcy or any
other relief under any bankruptcy or insolvency
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01282752.pdf
EFTA00169707Set 9
2013-10-2843p24,055w
applicable to it, any provision of its constitutional documents, any order or judgment of any court or
other agency of government applicable to it or any of its assets ... organisation or the jurisdiction of its bead or home office, a
proceeding seeking a judgment of insolvency or bankruptcy or any other relief under any
bankruptcy or insolvency ... supervisor or similar official, or
(B) has instituted against it a proceeding seeking a judgment of insolvency or bankruptcy or any
other relief under any bankruptcy or insolvency
https://www.justice.gov/epstein/files/DataSet%209/EFTA00169707.pdf
EFTA00594036Set 9
2009-07-2732p9,748w
FLSD Docket 07/27/2009 Page 43 of 73
564. Wherefore, the plaintiff, L.M., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided ... continue to suffer these
losses in the future.
568. Wherefore, the plaintiff, M., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided ... will continue to suffer these
losses in the future.
572. Wherefore, the plaintiff,.., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
https://www.justice.gov/epstein/files/DataSet%209/EFTA00594036.pdf
EFTA01070055Set 9
2011-07-13158p39,441w
arguments through the incorporation of all of the arguments
14 in the summary judgment.
15 THE COURT: You must be some kind of psychic.
16 MR. SCAROLA: I anticipated that ... Your Honor,
18 expressly incorporates the arguments that were made during
19 the summary judgment hearing. And, clearly, one of the
20 principal arguments that was made in the summary ... judgment
21 hearing was an argument with regard to the sword/shield
22 doctrine. I apologize for having intruded upon your
23 thoughts.
24 THE COURT: Go ahead.
25 MR. KNIGHT
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070055.pdf
EFTA01111295Set 9
2009-12-217p2,134w
ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually,
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION
FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY
EDWARDS' COUNTERCLAIM AND SUPPORTING MEMORANDUM OF LAW
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein ... Rule 1.510 of the Florida Rules of Civil Procedure, files
this Motion for Summary Judgment on Defendant/Counter-Plaintiff Bradley Edwards'
Counterclaim, and states as follows :
I. SUMMARY OF ARGUMENT
Summary judgment ... Statements, et al.
the filing of an action. Accordingly, Epstein is entitled to summary judgment on Edwards'
Counterclaim for abuse of process.
Finally, and in the alternative, partial summary judgment
https://www.justice.gov/epstein/files/DataSet%209/EFTA01111295.pdf
EFTA00211718Set 9
2007-04-2432p10,140w
UNITED STATES,
Respondent.
GOVERNMENT'S RESPONSE AND OPPOSITION TO PETITIONERS' MOTION FOR
PARTIAL SUMMARY JUDGMENT AND CROSS-MOTION FOR SUMMARY JUDGMENT
Respondent United States of America, by and through ... undersigned counsel, files its
Response and Opposition to Petitioners' Motion for Partial Summary Judgment and Cross-
Motion for Summary Judgment, and states:
I. INTRODUCTION
Petitioners contend the government violated their ... argument
of petitioners' counsel. The undisputed facts establish that the Government is entitled to
judgment as a matter of law, because it did not violate the CVRA rights of either
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211718.pdf
EFTA01070213Set 9
2011-07-1341p38,837w
incorporation of all of the arguments
RICCO claim. So what. In the summary Judgment.
14 14
15 And Paragraph 32 says that ho tried to frooso 15 THE COURT ... litigation on behalf of his child victim of Mr. Epstoin'a 19 the summary judgment hearing. And, clearly, one of the
20 repeated extensive criminal activity, it is covered ... principal arguments that was made in the summary Judgment
litigation privilege. hearing was an argument with regard co the sword/shield
21 21
22 There aro throe elements of danage that
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070213.pdf
EFTA01900688Set 10
2013-03-0964p17,991w
Dupuy & James M LeBlanc &
resetting 32 MOTION to Certify Class & 33 MOTION for Summary Judgment filed by Bayard
Doe, Ruth Doe, Brenda Doe & Emma Doe. Signed by Judge Martin ... plaintiffs' motion for class certification; and (3) the plaintiffs' motion for
summary judgment. For the reasons that follow, the defendants' motion to dismiss is DENIED
and the plaintiffs' motions ... class certification and summary judgment are continued, to be
reset because of inadequate briefing. Background This putative class action lawsuit follows this
EFTA_R1_00329767
EFTA01900739
Court's March
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01900688.pdf
EFTA00075477Set 9
2020-08-2074p15,469w
material is lower than the
presumption of access this Court ascribed to the summary judgment
material 21
a. Ms. Maxwell's reliance interests, and those of Doe 1, outweigh ... Page12 of 74
After the district court denied Ms. Maxwell's motion for summary
judgment, the parties agreed to a settlement of the defamation claim, and the case
was dismissed ... majority concluded that the district court erred in sealing the summary
judgment materials. Id. at 47-48. Upon the issuance of the mandate, this Court
unsealed the summary judgment materials
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075477.pdf
EFTA00584338Set 9
2009-12-218p2,209w
ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually,
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION
FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY
EDWARDS' COUNTERCLAIM AND SUPPORTING MEMORANDUM OF LAW
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein ... Rule 1.510 of the Florida Rules of Civil Procedure, files
this Motion for Summary Judgment on Defendant/Counter-Plaintiff Bradley Edwards'
Counterclaim, and states as follows :
I. SUMMARY OF ARGUMENT
Summary judgment ... addition, Edwards' claim against
Epstein is barred by the litigation privilege. Partial summary judgment should be entered in
FOWLER WHITE BURNETT P.A. • ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14•• FLOOR
https://www.justice.gov/epstein/files/DataSet%209/EFTA00584338.pdf
EFTA00178057Set 9
2011-05-0290p23,378w
Document 77 Entered on FLSD Docket 05/02/2011 Page 3 of 29
Judgment Motion' at 26. Yet the Government's 53-page response does not even cite -- much
less discuss -- this ... Request for a Hearing on Appropriate Remedies (doe. #48) as their
"summary judgment" motion.
3
EFTA00178059
Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05/02/2011 Page ... CVRA, including the right to confer with prosecutors about
their "case." See Victims' Summary Judgment Motion, Exhibits C & D. The notices also
concluded: "At this time, your case is under
https://www.justice.gov/epstein/files/DataSet%209/EFTA00178057.pdf