EFTA00067542Set 9
2008-10-2831p10,960w
filed
by Jane Doe No. 3. (Herman, Jeffrey) (Entered: 05/22/2008)
05/29/2008 5 Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 3.
(Attachments: # 1 Exhibit ... Goldberger on behalf of Jeffrey Epstein (Goldberger,
Jack) (Entered: 06/13/2008)
06/13/2008 7 RESPONSE to Motion re 5 Plaintiff's MOTION for Entry of Default by Clerk Against Defendant Jane
Copyright ... Attachments: # 1 Affidavit of
Richard Barnett)(Goldberger, Jack) (Entered: 06/13/2008)
06/20/2008 8 Defendant's MOTION to Stay by Jeffrey Epstein. Responses due by 7/10/2008 (Goldberger, Jack)
(Entered: 06/20/2008)
06/20/2008
https://www.justice.gov/epstein/files/DataSet%209/EFTA00067542.pdf
EFTA00614086Set 9
2011-09-1621p6,470w
UNITED STATES
JANE DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION FOR "LIMITED"
INTERVENTION OF JEFFREY EPSTEIN
COME NOW Jane Doe #1 and Jane Doe #2 (also referred ... victims"), by and
through undersigned counsel, to oppose the motion of convicted sex offender Jeffrey Epstein for
"limited" intervention in this case under ... motion for "limited" intervention should be denied for three separate and
independent reasons. First, Epstein's motion is not timely. The victims very specifically advised
Epstein more than one year
https://www.justice.gov/epstein/files/DataSet%209/EFTA00614086.pdf
EFTA00791869Set 9
2019-03-1527p6,343w
Thurgood Marshall U.S. Courthouse 40 Foley Square, New York, NY 10007 Telephone: 212-857.8500
MOTION INFORMATION STATEMENT
Docket Ntunber(s): 18-2868 Caption luse short Ski
Motion for. to Reconsider ... from: Hon. Robert W. Sweet, District Judge (S.D.N.Y.)
Please check appropriate boxes: FOR EMERGENCY MOTIONS, MOTIONS FOR STAYS AND
1NJUCTIONS PENDING APPEAL:
Has movant notified posing counsel (required by Local ... sought in this court? Yes MINo
Requested return date and explanation of emergency:
The motion requests that post argument orders be held in abeyance pending resolution
Opposing 1's position
https://www.justice.gov/epstein/files/DataSet%209/EFTA00791869.pdf
EFTA00074964Set 9
2020-06-1740p9,195w
subject to at
least some presumption of public access"); id. at 53 (discovery motion materials "subject to a
lesser — but still substantial — presumption of public access"); see also Securities ... S.D.N.Y.
June 17, 2020) ("The presumption attached to non-dispositive motions... 'is generally somewhat
lower than the presumption applied to material introduced at trial, or in connection with
dispositive motions ... such as motions for dismissal or summary judgment."') (quoting Brown, 929
F.3d at 50).
A. Non-Response from Does 1 and 2 Not Dispositive of Countervailing Interests
Plaintiff argues that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00074964.pdf
EFTA01407189Set 10
2016-10-12100p20,728w
appeal was
an
appropriate sanction for appellant's failure to file its brief.
OUTCOME: Motion to dismiss granted.
CORE TERMS: summary judgment, scheduling, reconsideration, deadline, weigh,
failure
to prosecute, designation ... lack of responsibility for its counsel's dilatory conduct
is not dispositive on
a motion to dismiss for failure to prosecute, because a client cannot always
avoid the
consequences ... Ordinarily, a claim, or defense, will be deemed meritorious when the
allegations of the
motion, if established, would support recovery by plaintiff or would
constitute a complete
defense.
EFTA01407223
Bankruptcy
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01407189.pdf
EFTA00803113Set 9
2017-03-31158p39,273w
would like to see if
4 I can clarify my understanding.
5 In the motion to dismiss, I concluded, I think, that
6 what was at issue was the truth ... opinion.
9 Yesterday, we were discussing the redactions of the
10 intervention motion. I got the sense, perhaps wrongly, that
11 the plaintiff's position was that the defamation ... other
16 things that she sets forth in the Churcher articles, in the
17 motion to intervene, there are a whole series of other things
18 that are -- I mean
https://www.justice.gov/epstein/files/DataSet%209/EFTA00803113.pdf
EFTA00612250Set 9
2017-03-31158p38,362w
would like to see if
4 I can clarify my understanding.
5 In the motion to dismiss, I concluded, I think, that
6 what was at issue was the truth ... opinion.
9 Yesterday, we were discussing the redactions of the
10 intervention motion. I got the sense, perhaps wrongly, that
11 the plaintiff's position was that the defamation ... other
16 things that she sets forth in the Churcher articles, in the
17 motion to intervene, there are a whole series of other things
18 that are -- I mean
https://www.justice.gov/epstein/files/DataSet%209/EFTA00612250.pdf
EFTA00085098Set 9
2019-03-0618p7,254w
Westlaw citation is currently 2017 WL 1787934, 325 F.Supp.3d 428,
available. granted motions to intervene, but denied
United States Court of Appeals, Second requests to unseal. Intervenors appealed.
Circuit ... Cernovich Media,
Intervenors-Appellants, [21 district court abused its discretion in
v. denying motion to unseal filings related to
Plaintiff-Appellee, discovery motions.
v.
Ghislaine Maxwell,
Defendant-Appellee: Pooler, Circuit ... circumstances, preserving
consideration in summary judgment accused's right to fundamental
motion are—as matter of fairness in jury selection process,
law—judicial documents to which protection of attorney-client
https://www.justice.gov/epstein/files/DataSet%209/EFTA00085098.pdf
EFTA01191873Set 9
2015-01-2140p13,998w
JANE DOE #2,
Petitioners,
vs.
UNITED STATES OF AMERICA,
Respondent.
PLAINTIFFS RESPONSE TO MOTION FOR
LIMITED INTERVENTION BY ALAN M. DERS HON rrz
COME NOW petitioners Jane ... Jane Doe No. 4 ("the victims"), to respond in opposition to Mr. Dershowitz's motion
for limited intervention (DE 282). Dershowitz moves to intervene to strike a proffer made ... Jane Doe No. 3 of facts that support her pending motion to join this action. The Court should
deny the motion. Dershowitz has not established any direct interest in this
https://www.justice.gov/epstein/files/DataSet%209/EFTA01191873.pdf
EFTA00186748Set 9
2006-08-1820p9,233w
from the United States District Court compelling the production, then you must file a motion
to quash the grand July subpoena before the United States District Judge who empaneled ... order, and I can proceed before the United States District Judge by filing a motion to
'I do not know whether the grand jury proceedings have yet been transcribed ... United States District Judge to sign. If you prefer to file your
own motion, I can assist in notifying the Court of the motion, which should be filed ex parte
https://www.justice.gov/epstein/files/DataSet%209/EFTA00186748.pdf
EFTA00074599Set 9
2021-04-1569p52,989w
provisions are particularly relevant here.
First, and most obviously given its title—"Motion for relief include, among other information, "Mlle district court case
number" and "[t]he name ... gives victims
Id. § 45.10(c)(2Xiii)-(iv). Upon receipt of a complaint,
a "motion" remedy in the district court and a mandamus
remedy in the court of appeals. With respect ... take up
"report the results of the investigation to" the Ombudsman,
and decide any motion asserting a victim's right forthwith."
Id. § 3771(d)(3). And with respect
https://www.justice.gov/epstein/files/DataSet%209/EFTA00074599.pdf
EFTA00792252Set 9
2019-03-2024p4,929w
Clerk's Office> , FILED. Service
date 03/19/2019 by CM/ECF. [2521592] [18-2868]
03/19/2019 15.1. Motion for Leave for Non—Party 3 MOTION FOR LEAVE TO INTERVENE, on behalf of
Limited ... Intervenor to File Unredacted Non—Party Filer(s), FILED. Service date03/19/2019 by
Motions Ex CM/ECF.[2521598] [18-2868]
03/19/2019 152 Motion for Limited Intervention 4 MOTION FOR LEAVE TO INTERVENE ... Party Filer(s), FILED. Service date03/19/2019 by
CM/ECF. 2521599 18-2868
03/19/2019 153 MOTION TO FILE AMICUS CURIAE BRIEF, on behalf
.151Motion for Leave to File
https://www.justice.gov/epstein/files/DataSet%209/EFTA00792252.pdf
EFTA01112229Set 9
2010-02-0133p10,480w
Dixie Highway, Room 4A, West
Palm Beach, FL. 33401
SPECIFIC MATTERS TO BE HEARD: Motion for Final Summary Judgment of
Foreclosure
KINDLY GOVERN YOURSELVES ACCORDINGLY. Please arrive 15 minutes
before ... good faith attempt has been made to
resolve the matters raised in the motion.
I HEREBY CERTIFY that a true and correct copy of the foregoing was mailed to
Christy ... STEPHEN R. ALEXANDER, MICHAEL
T. HARDMAN, JULIE C. HARDMAN,
VILLAGE OF PALM SPRINGS,
Defendants.
MOTION FOR FINAL SUMMARY JUDGMENT OF FORECLOSURE
Plaintiff, National City Bank, as successor by merger
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112229.pdf
EFTA00612483Set 9
2015-10-2035p8,537w
FOURTH DISTRICT
CASE NO. 4D14-2282
BRADLEY J. EDWARDS,
Appellant,
v.
JEFFREY EPSTEIN,
Appellee.
MOTION FOR LEAVE TO FILE SUPPLEMENTAL ARGUMENT
The appellee, Jeffrey Epstein, respectfully moves for leave ... Shortly thereafter, oral argument was set for October 20, 2015.
4. Edwards filed a motion to cancel the oral argument, arguing that based upon
Fischer, this Court should summarily reverse ... additional brief extension of time for
filing Epstein's response to the motion to cancel oral argument, indicating that
Edwards' motion would be opposed based in part upon the tipsy
https://www.justice.gov/epstein/files/DataSet%209/EFTA00612483.pdf
EFTA00592369Set 9
2017-03-3194p24,655w
treat these matters, but one count I have is that we have 45
6 motions before me. That may not be entirely accurate ... want lunch, that's okay. I can endure.
13 By the way, the Epstein motion will go over to
14 tomorrow because we were told, if I understand it correctly ... today
19 ends, for our joint effort, at 3:30 -- the defendant's motion
20 with respect to the supplemental reports of Jansen and Kliman;
21 the 302 motion
https://www.justice.gov/epstein/files/DataSet%209/EFTA00592369.pdf
EFTA00092308Set 9
2019-03-0626p5,904w
Southern
District of New York (Robert W. Sweet, Judge) denying their respective
motions to unseal filings in a defamation suit. We conclude that the
' The Clerk of Court is directed ... Southern District of
New York (Robert W. Sweet, Judge) denying their respective motions
to unseal filings in a defamation suit. We conclude that the District
Court failed to conduct ... additional parties from
the pleadings, including those against Dershowitz, and therefore
denied Dershowitz's motion as moot.5
The stricken allegations, however, quickly found their way into
the press, and several
https://www.justice.gov/epstein/files/DataSet%209/EFTA00092308.pdf
EFTA00294291Set 9
2012-02-0115p4,446w
individually,
Defendant,
1
DEFENDANT/COUNTER-PLAINTIFF, BRADLEY J. EDWARDS, RESPONSE IN
dPPOSITION TO JEFFERY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER
RBLATING TO HIS DEPOSITION AND IN SUPPORT OF EDWARDS' MOTINO ... undersigned attomeys, respectfully responds in opposition to
Plan tiff/Counterdefendant, Jeffrey Epstein's (hereinafter EPSTELN) motion for a protective
orde[ and to terminate his deposition. The motion is ffivolous and should ... 2002/015
Ed rds adv. Epstein
Casa No.: 502009CA040800XXXXMBAG
Resrlonse in Opposition to Epstein's Motion for Protective Order Rotating to his Deposition and in
Sumfort of Edwards' Motion to Compel
https://www.justice.gov/epstein/files/DataSet%209/EFTA00294291.pdf
EFTA00808590Set 9
2017-12-0519p5,443w
EDWARDS, individually, and
•I., individually,
Defendants.
RESPONSE IN OPPOSITION TO DEFENDANT JEFFREY EPSTEIN'S MOTION TO
ALLOW AMENDMENT TO EXHIBIT LIST AND SUPPLEMENT TO MOTION TO
ALLOW AMENDMENT TO EXHIBIT ... through undersigned counsel, hereby files this
Response in Opposition to Defendant Jeffrey Epstein's Motion to Allow Amendment to Exhibit
List and Supplement thereto, and as grounds therefor states ... Exhibits.
EFTA00808590
Edwards adv. Epstein
Case No. 502009CA040800XXXXMBAG
Response in Opposition to Epstein's Motion to Amend Exhibit List.
On November 6, 2017, Epstein filed his Motion to Continue
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808590.pdf
EFTA01098037Set 9
2011-10-1421p6,534w
UNITED STATES OF AMERICA,
Defendant.
JEFFREY EPSTEIN'S OMNIBUS REPLY IN SUPPORT
OF HIS MOTION FOR LIMITED INTERVENTION
We clarify at the outset the plaintiffs' claim that they have ... plaintiffs
[DE 96] in response to Mr. Epstein's motion for limited intervention. Mr. Epstein's intervention is
timely, as of right and as a matter of discretion, and properly ... evidentiary use of letters and emails reflecting plea negotiations. The Court should
grant his motion for limited intervention.
I.
INTRODUCTION
For a number of years, Jeffrey Epstein endured intensive investigation
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098037.pdf