EFTA00156400Set 9
2022-04-2945p15,329w
perpetrate sexual abuse.
Following the thirteen-day trial, the Court submitted to the jury the six counts in the
Indictment. The jury deliberated for over five days and returned ... denied. The Rule 29 motion challenging all counts
of conviction is denied because the jury's guilty verdicts were readily supported by the extensive
witness testimony and documentary evidence admitted ... charged in the Indictment, presented by the
Government at trial, and on which the jury was accurately instructed. The Defendant's contrary
claim of a constructive amendment of or variance
https://www.justice.gov/epstein/files/DataSet%209/EFTA00156400.pdf
EFTA00804787Set 9
2017-11-0946p7,314w
individually, and
BRADLEY J. EDWARDS, individually,
Defendants/Counter-Plaintiff.
/
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S
NOTICE OF PROPOSED JURY INSTRUCTIONS AND VERDICT FORM
Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), pursuant to Florida Rule of Civil
Procedure ... files this Notice of Proposed Jury Instructions and Verdict Form. Epstein adopts
Defendant/Counter-Plaintiff Bradley J. Edwards' ("Edwards") November 9, 2017, proposed
Standard (Civil) Jury Instructions ... which Epstein has not
restated here. Epstein objects to Edwards' November 9, 2017, proposed Jury Instructions Nos.
201.1, 201.2, 406.2, 406.4, 406.5, 406.8, 406.12 and Adverse Inference, and Edwards' November
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804787.pdf
EFTA00077249Set 9
2020-07-0213p2,794w
STATEMENT 1
STATEMENT OF FACTS 2
A. Procedural History 2
B. This District's Jury Plan 2
ARGUMENT 4
EFTA00077250
TABLE OF AUTHORITIES
Page(s)
Cases
Duren v. Missouri ... EFTA00077251
PRELIMINARY STATEMENT
When the COVID-19 pandemic temporarily limited the availability of grand juries in the
Manhattan courthouse, the government responded with an extraordinary measure. Rather than
wait ... residents of counties constituting the Manhattan Division of this District
could appear for grand jury service, the government, in its apparent determination to mark the
anniversary of its indictment
https://www.justice.gov/epstein/files/DataSet%209/EFTA00077249.pdf
EFTA01112444Set 9
2010-03-0323p7,116w
compensatory or actual damages, if any,
on Plaintiff's claims. Only if the jury determines at the first stage that Defendant is liable for
punitive damages would the second stage ... evidence not allowable in the first stage would if appropriate
be presented. The same jury would hear and decide both stages.
In the alternative, and should the Court deny Defendant ... liability for actual damages and the amount of actual damages, if any. If the jury finds for
the plaintiff in the first trial phase, the matter would proceed
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112444.pdf
EFTA01297082Set 10
2017-07-1143p15,935w
insolvency, badge, "actual fraud, transferred, new trial,
defraud, actual intent, fraudulent transfers, jury verdict, failed to present, essential element,
post-petition, hinder, proven, deliberations, jewelry, transfers of property, failed ... made from Debtor Jeffrey Prosser to his
wife, Defendant Dawn Prosser. Following trial, the jury returned a verdict in favor of
Trustee Carroll and against Prosser. Thereafter, Prosser moved ... protective" motion for a new trial. The Trustee
moved for judgment on the jury verdict.
1 By agreement of al parties. this case was tried contemporaneously with the parallel Chapter
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01297082.pdf
EFTA00086685Set 9
2016-03-1827p8,445w
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
x C
IN RE GRAND JURY SUBPOENA
19 Misc. 149 (CM)
x
SEALED MEMORANDUM DECISION AND ORDER GRANTING
THE GOVERNMENT ... firm of
Boies Schiller Flexner LLP ("Boies Schiller") to comply with a grand jury subpoena.
The application is granted.
I. Background
A. The Protective Order
In September 2015, Virginia ... Protective Order, or (2) moved to quash the subpoena. See
In re Grand Jury Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d 1221, 1225 (2d Cir.
1991) ("The proper
https://www.justice.gov/epstein/files/DataSet%209/EFTA00086685.pdf
EFTA00727606Set 9
2009-06-2216p3,888w
This matter is before the Court for entry of judgment
following a trial by jury and for a determination of an
appropriate award, if any, of prejudgment interest.
EFTA00727606
Addie ... factual and procedural background is required.
This matter was tried to a jury in two stages from June 22,
2009 to July 2, 2009. The first stage dealt with liability ... their conversion claim
against D'Amour.
During the first stage of trial, the jury found the Sellers
liable on the Buyers' breach of contract and unjust enrichment
claims. The jury
https://www.justice.gov/epstein/files/DataSet%209/EFTA00727606.pdf
EFTA00011096Set 8
17p4,725w
Court's order, the parties recently submitted, under seal, a joint proposed jury
questionnaire. The Court has scheduled three days for prospective jurors to complete the final
Court-approved questionnaire ... July 2020, has
significantly increased the likelihood that prospective jurors will report to jury selection with
preconceptions, impressions, and opinions about the conduct at issue in the trial and those ... insufficient for this case and
will be redundant to questions posed in the proposed jury questionnaire. A written questionnaire
coupled with sequestered voir dire of individual prospective jurors and limited
https://www.justice.gov/epstein/files/DataSet%208/EFTA00011096.pdf
EFTA00085225Set 9
2021-07-1234p11,087w
Maxwell,
OPINION & ORDER
Defendant.
ALISON J. NATHAN, District Judge:
In June 2020, a grand jury returned a six-count indictment charging Ghislaine Maxwell
with facilitating the late financier Jeffrey Epstein ... suppress evidence, and compel discovery. After the parties fully briefed those
motions, a grand jury returned a second (S2) superseding indictment adding a sex trafficking
count and another related conspiracy ... material. The Court concludes that
these issues are best left for the jury.
• Maxwell moves to sever the perjury counts from the Mann Act counts so that they can
proceed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00085225.pdf
EFTA00029540Set 8
2021-07-1234p11,084w
Maxwell,
OPINION & ORDER
Defendant.
ALISON J. NATHAN, District Judge:
In June 2020, a grand jury returned a six-count indictment charging Ghislaine Maxwell
with facilitating the late financier Jeffrey Epstein ... suppress evidence, and compel discovery. After the parties fully briefed those
motions, a grand jury returned a second (S2) superseding indictment adding a sex trafficking
count and another related conspiracy ... material. The Court concludes that
these issues are best left for the jury.
• Maxwell moves to sever the perjury counts from the Mann Act counts so that they can
proceed
https://www.justice.gov/epstein/files/DataSet%208/EFTA00029540.pdf
EFTA00154640Set 9
2021-07-1234p11,087w
Maxwell,
OPINION & ORDER
Defendant.
ALISON J. NATHAN, District Judge:
In June 2020, a grand jury returned a six-count indictment charging Ghislaine Maxwell
with facilitating the late financier Jeffrey Epstein ... suppress evidence, and compel discovery. After the parties fully briefed those
motions, a grand jury returned a second (S2) superseding indictment adding a sex trafficking
count and another related conspiracy ... material. The Court concludes that
these issues are best left for the jury.
• Maxwell moves to sever the perjury counts from the Mann Act counts so that they can
proceed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00154640.pdf
EFTA00104652Set 9
2021-07-1234p11,087w
Maxwell,
OPINION & ORDER
Defendant.
ALISON J. NATHAN, District Judge:
In June 2020, a grand jury returned a six-count indictment charging Ghislaine Maxwell
with facilitating the late financier Jeffrey Epstein ... suppress evidence, and compel discovery. After the parties fully briefed those
motions, a grand jury returned a second (S2) superseding indictment adding a sex trafficking
count and another related conspiracy ... material. The Court concludes that
these issues are best left for the jury.
• Maxwell moves to sever the perjury counts from the Mann Act counts so that they can
proceed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00104652.pdf
EFTA00105663Set 9
2021-07-1234p11,087w
Maxwell,
OPINION & ORDER
Defendant.
ALISON J. NATHAN, District Judge:
In June 2020, a grand jury returned a six-count indictment charging Ghislaine Maxwell
with facilitating the late financier Jeffrey Epstein ... suppress evidence, and compel discovery. After the parties fully briefed those
motions, a grand jury returned a second (S2) superseding indictment adding a sex trafficking
count and another related conspiracy ... material. The Court concludes that
these issues are best left for the jury.
• Maxwell moves to sever the perjury counts from the Mann Act counts so that they can
proceed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00105663.pdf