""LITIGANT"" — Epstein Files Search

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EFTA00210140Set 9

2015-07-0651p13,318w

party may not discover documents and tangible things that are prepared in anticipation of litigation or for trial by or for another party or its representative (including the other party ... opinions, or legal theories of a party's attorney or other representative concerning the litigation." Id. 26(b)(3)(B). Such "opinion work product enjoys a nearly absolute immunity ... work-product privilege extends only to documents that an attorney prepares "in anticipation of litigation." Fed. R. Civ. P. 26(a)(3)(A). Petitioners argue that the work-product privilege

https://www.justice.gov/epstein/files/DataSet%209/EFTA00210140.pdf

EFTA00607688Set 9

2014-01-2778p19,578w

affirmative defenses 21 raised, but one of them that was raised was the 22 litigation privilege. And we are here today to 23 talk with you about the litigation privilege ... pronouncing that correctly, and the Wolfe case. 13 All of them deal with litigation privilege which 14 dates back to 1917. And I think that we are all 15 most ... during the course of a judicial proceeding would 18 be protected by the litigation privilege and no 19 action could be taken on them. 20 Over the years different courts

https://www.justice.gov/epstein/files/DataSet%209/EFTA00607688.pdf

EFTA00595583Set 9

2015-11-3029p8,962w

Self-Defense Privilege Protects Ms. Maxwell's Statements 9 B. The Pre-Litigation Privilege Protects Ms. Maxwell's Statements 14 II. PLAINTIFF FAILED TO PLAUSIBLY PLEAD DEFAMATION 17 A. Viewed ... serious and criminal sexual abuse from 1999-2002. Plaintiff repeated those allegations in litigation pleadings to which Ms. Maxwell was not a party and which since have been stricken ... dismissed. Moreover, because the denials when viewed in context demonstrate that they were pre-litigation demands to the British newspapers to cease and desist, they likewise are entitled

https://www.justice.gov/epstein/files/DataSet%209/EFTA00595583.pdf

EFTA00726092Set 9

2009-11-1233p8,061w

would impact the plaintiff's decision of whether or not to settle the current litigation; are the Plaintiffs motivated to, in essence, commit perjury or shade their testimony to gain ... agents or clients, and any third party regarding a purported settlement of any litigation between Jeffrey Epstein and RRA and/or its clients, or the financing of any litigation between Jeffrey ... Epstein and RRA and/or its clients, including but not limited to: a. Representations that litigation with Jeffrey Epstein has been settled; b. Soliciting or receiving money in return for settlement

https://www.justice.gov/epstein/files/DataSet%209/EFTA00726092.pdf

EFTA01112467Set 9

2010-03-2327p8,263w

including the absolute immunity afforded to Epstein for both causes of action under the litigation privilege, and Edwards's failure to state a cause of action in both abuse ... taken by Epstein for which Edwards is now suing occurred during the pendency of litigation, completely barring his claim under the litigation privilege. Edwards's cause of action for Malicious ... Prosecution, like his claim for Abuse of Process, is barred by the litigation privilege. Moreover, assuming arguendo that somehow Edwards's claims were not barred by the litigation privilege, Edwards

https://www.justice.gov/epstein/files/DataSet%209/EFTA01112467.pdf

EFTA01416838Set 10

2017-06-19122p23,787w

Rule 23." In re Gen. Motors Corp. Pick-Up Truck Fuel Tank Products Liab. Litig. ("GM Truck Prods."), 55 F.3d 768, 797 (3d Cir. 1995). Under Rule ... relevant evidence and arguments presented by the parties." In re Hydrogen Peroxide Antitrust Litig., 552 F.3d 305, 306 (3d Cir. 2008). 1. Numerosity Rule 23(a)(1) requires that ... significant unique or atypical defenses to her claims." In re Schering Plough Corp. ERISA Litig., 589 F.3d 585, 597-98 (3d Cir. 2009). Plaintiffs' claims, "for settlement purposes only

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01416838.pdf

EFTA01193956Set 9

2014-09-197p3,448w

CASE iv SUMMARY OF ARGUMENT vii STANDARD OF REVIEW 1 ARGUMENT 2 I. THE LITIGATION PRIVILEGE SHOULD NOT ACT TO BAR A CLAIM FOR MALICIOUS 2 PROSECUTION CONCLUSION CERTIFICATE ... malicious prosecution against Richard DeBrincat and Jason DeBrincat through the application of the litigation privilege. (R.179). In the motion Richard DeBrincat and Jason DeBrincat did not dispute ... malicious prosecution. The trial court improperly granted summary judgment based solely upon the litigation privilege. The litigation privilege should not bar a cause of action for malicious prosecution because

https://www.justice.gov/epstein/files/DataSet%209/EFTA01193956.pdf

EFTA00190026Set 9

2009-11-2036p8,414w

FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. I Plaintiff, 50 2009 UV 0 3 MCCUE SCOTT ... serious obstructions of justice, actionable frauds, and the orchestration and conducting of egregious civil litigation abuses that resulted in profoundly serious injury to Jeffrey Epstein one of several targets ... sanctioning of a series of depositions that were unrelated to any principled litigation purpose but instead designed to discover extraneous private information about Epstein or his personal and business associates

https://www.justice.gov/epstein/files/DataSet%209/EFTA00190026.pdf

EFTA01099134Set 9

2015-03-0226p11,196w

filed in federal court on behalf of their client are absolutely protected under the litigation privilege. With regard to Count II, the limited statements are not EFTA01099134 Edwards, Bradley ... event, are protected under both the fair report privilege and the litigation privilege. BACKGROUND The events underlying this defamation case arise from a lawsuit filed by attorneys Edwards and Cassell ... relief, since it rests on statements that are reasonably related to the CVRA litigation, are not defamatory and that are, in any event, protected by the fair report privilege

https://www.justice.gov/epstein/files/DataSet%209/EFTA01099134.pdf

EFTA00607531Set 9

2009-11-2036p8,599w

FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff ... serious obstructions of Justice, actionable frauds, and the orchestration and conducting of egregious civil litigation abuses that resulted in profoundly serious injury to Jeffrey Epstein one of several targets ... sanctioning of a series of depositions that er extraneous private information about litigation purpose but instead designed to discov (including well-known public figures) In .Epstein or his personal

https://www.justice.gov/epstein/files/DataSet%209/EFTA00607531.pdf

EFTA00726202Set 9

2010-05-1745p12,174w

four decades, the Podhurst firm has concentrated its practice exclusively in trial and appellate litigation in both federal and state COUR. 2. Defendant, Jeffrey Epstein ("Epstein" or "Defendant', is fifty ... provision, however, shall not obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, if after consideration of potential settlements, an attorney representative elects ... suggests that you consider the following criteria:" 1. Experience doing both plaintiffs' and defense litigation. 2. Experience with state and federal statutory and common law tort claims. 3. The ability

https://www.justice.gov/epstein/files/DataSet%209/EFTA00726202.pdf

EFTA01191873Set 9

2015-01-2140p13,998w

discretionary intervention for four reasons: First, Dershowitz has another forum in which to litigate and defend his reputational interests — a pending defamation action regarding this very case; second, Dershowitz ... adversarial to victims of known sexual abuse on every point in this litigation. Now that many of those issues we discussed have been resolved in our favor, it seems ... long as we can stipulate to her being added. Without a stipulation, we foresee litigation over this point, which will produce nothing but additional delay — and further question about your

https://www.justice.gov/epstein/files/DataSet%209/EFTA01191873.pdf

EFTA00223211Set 9

this Office's choice of representative was intended to influence the outcome of civil litigation. Second, your co-counsel expressed concerns similar to those raised in your letter regarding ... select the representative. These criteria were: (1) Experience doing both plaintiffs' and defense litigation; (2) Experience with state and federal statutory and common law tort claims; (3) Ability to communicate ... effectively with young women; (4) Experience litigating against large law firms and high profile attorneys who may test the veracity of the victims' claims; (5) Sensitivity to the nature

https://www.justice.gov/epstein/files/DataSet%209/EFTA00223211.pdf

EFTA00066433Set 9

2019-02-286p2,879w

with the matter v. Ghislaine Maxwell, et al. ("M"), 15 Civ. 7433 (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application ... Schiller") requiring the production of copies of discovery and related materials related to the Litigation. The Subpoena was validly issued pursuant to an ongoing investigation into Jeffrey Epstein and others ... Government has been advised that Boies Schiller, which is counsel for plaintiffs in the Litigation, does not intend to contest the Subpoena. However, the Government is advised that although Boies

https://www.justice.gov/epstein/files/DataSet%209/EFTA00066433.pdf

EFTA00088205Set 9

2020-08-246p2,973w

Court of Appeals and a separate district court in this same court (the "Civil Litigation") the fact that her adversary in the civil case pending in those two fora already ... dark about the fact and method of the disclosure. They claim the civil litigation is "unrelated," that issuance of the subpoena was "standard practice," and that disclosure will jeopardize ... vast swath of materials." Each of the government's arguments lack merit. The Civil Litigation is Not "Unrelated": First, the government claims the civil action is "unrelated." Resp

https://www.justice.gov/epstein/files/DataSet%209/EFTA00088205.pdf

EFTA00212253Set 9

2008-10-0150p18,079w

where the allegations relate to the exercise of the attorney's authority to investigate, litigate, or provide legal advice. This includes allegations relating to the actions of the Department ... during the course of the investigation in order to better assess 2 EFTA00212256 the litigation impact of the alleged misconduct and to permit the Attorney General and Deputy Attorney General ... matters outside the jurisdiction of OPR; sought review of issues that were being litigated or that had already been considered and rejected by a court; were frivolous, vague, or unsupported

https://www.justice.gov/epstein/files/DataSet%209/EFTA00212253.pdf

EFTA01128707Set 9

2013-07-0228p5,886w

clear that someone (like Epstein) who is litigating in a case cannot take an immediate, interlocutory appeal of an alleged privilege issue, but must instead wait to the conclusion ... Epstein argues that "questions of privilege and confidentiality asserted by non-parties to the litigation are paradigmatic examples of circumstances in which interlocutory appeals are allowed ... take an interlocutory appeal of a district court decision denying an attorney-client litigation." Presumably the reasons that Epstein does not rely on this provision is that he does

https://www.justice.gov/epstein/files/DataSet%209/EFTA01128707.pdf

EFTA00729092Set 9

2007-09-248p1,923w

nature of the fee dispute that is at the core of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the United States Attorney ... fees of the attorney representative prior to his electing to file and/or filing "contested litigation" or "any other contested remedy" against Epstein and was to "cease" and not obligate Epstein ... fees and costs of contested litigation filed against him" (Addendum to Agreement, Par. 7C). The fee obligation required that Epstein "pay such attorney representative his or her regular customary hourly

https://www.justice.gov/epstein/files/DataSet%209/EFTA00729092.pdf

EFTA01089193Set 9

2009-06-12174p43,641w

assure all parties that there will be no delay and no need for adversarial litigation regarding fees. More generally, I want to assure you that Mr. Epstein has directed ... issues that we believe fall at the intersection of Section 2255 and the civil litigation. We reserve our right, if you believe a proposed filing to conflict with ... twelve hours a day at his attorney's office working on nothing but the litigation pending against him, this excuse will not be accepted. This letter is being provided

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

EFTA00618182Set 9

2017-10-1016p4,323w

Proceedings, and as grounds therefor states as follows: 5un ana Jeffrey Epstein initiated this litigation in 2009. For three years, he carried the burden of proof to establish that Bradley ... became Mr. Edwards' counterclaim for malicious prosecution. For the next five years, the parties litigated Mr. Edwards' claims in both the trial and appellate courts and continued to take substantial ... matter. For the next five (5) years, the parties engaged in vigorous litigation at both the trial and appellate levels concerning Mr. Edwards' claim for malicious prosecution. Substantial discovery

https://www.justice.gov/epstein/files/DataSet%209/EFTA00618182.pdf

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Corpus: 1990-03-17 – 2025-12-01

July 2015

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