EFTA00205039Set 9
2011-04-2035p14,311w
INTERVENE
OR IN THE ALTERNATIVE FOR A SUA SPONTE RULE 11 ORDER
Comes now, Movant Bruce E. Reinhart, pursuant to Federal Rule of Civil Procedure
24(b), and seeks leave ... intervene as a party-in-interest in this matter. Movant seeks to
intervene to file a Motion for Sanctions based on unfounded factual and legal accusations made
about Movant ... rights under the Crime Victims Rights Act, Plaintiffs make irrelevant and
gratuitous accusations that Movant violated unspecified Florida Bar rules and Department of
Justice regulations. Movant should be granted leave
https://www.justice.gov/epstein/files/DataSet%209/EFTA00205039.pdf
EFTA01809334Set 10
2009-06-166p1,792w
STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF IOWA
EASTERN DIVISION
RONNIE LEROY SNYDER,
Movant, No. C09-2028-LRR
No. CR04-2008-LRR
vs.
ORDER
UNITED STATES OF AMERICA.
This ... sentence pursuant to 28 U.S.C. § 2255 (civil docket no. 1). Ronnie
Leroy Snyder ("the movant") filed such motion on June 16, 2009. On June 22, 2010, the
court directed ... parties to brief the claims that the movant included in his motion
pursuant to 28 U.S.C. § 2255 (civil docket no. 5). On July 21, 2010, the movant filed a
supplement
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01809334.pdf
EFTA00205074Set 9
2011-03-2131p13,342w
MOTION FOR SANCTIONS
Comes now, Bruce E. Reinhart, intervenor and party in interest (hereinafter
"Movant"), and moves this Honorable Court to impose sanctions under Federal Rule of
Civil Procedure ... intentional or reckless false, bad
faith, vexatious factual and legal assertions made about Movant in Paragraphs 52 and 53
of Plaintiff's Motion for Finding of Violations of the Crime ... asserted violation of the
CVRA, Paragraphs 52 and 53 falsely allege, that Movant violated Florida Bar rules and
Department of Justice regulations by representing Epstein's employees in civil litigation
https://www.justice.gov/epstein/files/DataSet%209/EFTA00205074.pdf
EFTA01098305Set 9
2011-03-2131p13,371w
MOTION FOR SANCTIONS
Comes now, Bruce E. Reinhart, intervenor and party in interest (hereinafter
"Movant"), and moves this Honorable Court to impose sanctions under Federal Rule of
Civil Procedure ... intentional or reckless false, bad
faith, vexatious factual and legal assertions made about Movant in Paragraphs 52 and 53
of Plaintiff's Motion for Finding of Violations of the Crime ... asserted violation of the
CVRA, Paragraphs 52 and 53 falsely allege, that Movant violated Florida Bar rules and
Department of Justice regulations by representing Epstein's employees in civil litigation
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098305.pdf
EFTA00730479Set 9
2010-11-0111p5,330w
aspect of this case, the
Government of the U.S. Virgin Islands (movant) filed a motion to intervene pursuant to Rule 1
(b). Petitioner has no objection to movant's proposed ... period of limitations for assessing tax
was still open. On June 18, 2010, movant filed Its motion to intervene.
I. The Virgin Islands
Although part of the United States ... Thus, petitioner argues, the period of limitations on assessment has
expired.
Movant agrees with petitioner with respect to the expiration of the section 6501(a) period of
limitations
https://www.justice.gov/epstein/files/DataSet%209/EFTA00730479.pdf
EFTA01134776Set 9
2011-03-216p1,710w
INTERVENE OR IN THE ALTERNATIVE FOR A SUA SPONTE RULE 11 ORDER
Comes now, Movant Bruce E. Reinhart, and replies to Plaintiffs' Response to his Motion
To Intervene ... fact sufficient to support permissive intervention.
Plaintiffs do not address, nor oppose, Movant's request that the Court on its own initiative
require Plaintiffs and their counsel to show their ... Rule of Civil
Procedure 11. The Court should hold a sanctions hearing, either through Movant's intervention
or sua sponte.
Plaintiffs also prematurely ask that, if the Court permits intervention
https://www.justice.gov/epstein/files/DataSet%209/EFTA01134776.pdf
EFTA01081814Set 9
2011-03-216p1,688w
INTERVENE OR IN THE ALTERNATIVE FOR A SUA SPONTE RULE 11 ORDER
Comes now, Movant Bruce E. Reinhart, and replies to Plaintiffs' Response to his Motion
To Intervene ... fact sufficient to support permissive intervention.
Plaintiffs do not address, nor oppose, Movant's request that the Court on its own initiative
require Plaintiffs and their counsel to show their ... Rule of Civil
Procedure 11. The Court should hold a sanctions hearing, either through Movant's intervention
or sua sponte.
Plaintiffs also prematurely ask that, if the Court permits intervention
https://www.justice.gov/epstein/files/DataSet%209/EFTA01081814.pdf
EFTA00793920Set 9
2018-04-1127p8,166w
contempt. Moreover, the Motions must be denied on the merits because the order
which Movants claim was violated is an order cancelling a hearing which does not provide any
detail ... Jaffe, Bradley Edwards, L.M.,
E.W., and Jane Doe are collectively referred to herein as "Movants." DE 6323, DE 6325, DE 6326 and DE
6345 are collectively referred ... EFTA00793920
Case 09-34791-RBR Doc 6355 Filed 04/11/18 Page 2 of 17
Movants seek the extraordinary remedy of sanctions, and discovery in support of
sanctions, based on the purported
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793920.pdf
EFTA00807546Set 9
2018-03-136p809w
through its undersigned counsel, hereby moves this Honorable
Court to allow Paul G. Cassell ("Movant") to appear as counsel for the victims in
this Epstein v. Edwards case and represents ... following:
1. Movant resides in Salt Lake City, Utah.
2. Movant is an attorney and employed as a professor of law at the S.J.
Quinney College ... University of Utah. As permitted by University of
EFTA00807546
Utah regulations, Movant undertakes some private representations as well as pro
bono representations.
3. Movant has been retained personally
https://www.justice.gov/epstein/files/DataSet%209/EFTA00807546.pdf
EFTA00805432Set 9
2018-03-0710p2,201w
EMERGENCY VERIFIED MOTION TO APPEAR PRO HAC VICE
COMES NOW Paul G. Cassell, Movant herein files this Verified Motion to Appear Pro
Hac Vice on behalf of.., M., and Jane ... respectfully represents the following:
1. Movant resides at Salt Lake City, Utah.
2. Movant is an attorney and a professor of law at the S.J. Quinney College ... University of Utah. As permitted by University of Utah regulations, Movant undertakes
some private representations as well as pro bono representations.
3. Movant has been retained personally to, in conjunction
https://www.justice.gov/epstein/files/DataSet%209/EFTA00805432.pdf
EFTA00596701Set 9
2017-01-1917p4,739w
Compelling Reason" nor "Good Cause"
to Seal the Summary Judgment Documents 8
2.2.3 Movant's Motion is Distinct from Prof. Dershowitz's 9
3.0 CONCLUSION 10
ii
EFTA00596702
Case ... 01/19/17 Page 6 of 17
MEMORANDUM OF LAW
Michael Cernovich ("Cernovich") d/b/a Cernovich Media ("Movant" or "Intervenor") is a
lawyer, author, documentary filmmaker, author, and host of the Mike Cernovich ... Motion
for Summary Judgment and the press is here to show it to them.
Movant takes no position with respect to the relative merits of the Parties' arguments in
this
https://www.justice.gov/epstein/files/DataSet%209/EFTA00596701.pdf
EFTA01098301Set 9
2011-04-204p984w
INTERVENE
OR IN THE ALTERNATIVE FOR A SUA SPONTE RULE 11 ORDER
Comes now, Movant Bruce E. Reinhart, pursuant to Federal Rule of Civil Procedure
24(b), and seeks leave ... intervene as a party-in-interest in this matter. Movant seeks to
intervene to file a Motion for Sanctions based on unfounded factual and legal accusations made
about Movant ... rights under the Crime Victims Rights Act, Plaintiffs make irrelevant and
gratuitous accusations that Movant violated unspecified Florida Bar rules and Department of
Justice regulations. Movant should be granted leave
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098301.pdf
EFTA01083955Set 9
2011-09-255p1,418w
Attorney, hereby files this Response to the Motion for Limited Intervention of Jeffrey Epstein
("Movant") [DE93].
Movant seeks to intervene as of right, pursuant ... intervenor to assert attorney-client and work product privileges.
In this circuit, a movant must establish the following requirements to intervene as of
right under Federal Rule of Civil Procedure ... existing parties to the suit.
'As will be explained, the main difficulty with Movant Epstein's motion to intervene as of
right is its untimeliness. In order to intervene permissively
https://www.justice.gov/epstein/files/DataSet%209/EFTA01083955.pdf
EFTA00794256Set 9
2018-10-2413p3,254w
Lehrman, P.L. ("Farmer Jaffe"), Bradley J.
Edwards ("Edwards") and Intervenor L.M. ("L.M.") (collectively, the "Movants") to pay Epstein's
attorneys' fees for the excessive time spent at the deposition ... Appropriate Relief. (D.E. 6326.)
Edwards and L.M. joined that request. (D.E. 6325; D.E. 6345.) Movants allege that Fowler White
EFTA00794256
and Epstein violated this Court's November 2010 Agreed Order ... regard to pre-hearing discovery." (Apr. Tr. 15:14-18; 16:13-14.) Although
Movants asked for document discovery in their written papers
https://www.justice.gov/epstein/files/DataSet%209/EFTA00794256.pdf
EFTA00286350Set 9
2011-03-2814p3,957w
Massachusetts and
has been a member of.the Massachusetts Bar-since April 24, 1972.
2. Movant is also admitted to practice before the United States Supreme Court, First
Circuit, Second Circuit ... Third Circuit; Fourth Circuit, Fifth Circuit, Sixth Circuit, Ninth Circuit,
and Eleventh Circuit.
3. Movant designates RONALD G. NE1W1RT14, ESQ., of FOWLER WHITE
BURNETT, P.A., who is qualified to practice ... this Court and who consents to designation as
local counsel.
4. Movant certifies that he hasenev.er been disbarred and is not currently suspended
from the practice
https://www.justice.gov/epstein/files/DataSet%209/EFTA00286350.pdf
EFTA00286364Set 9
2011-03-2814p3,957w
Massachusetts and
has been a member of.the Massachusetts Bar-since April 24, 1972.
2. Movant is also admitted to practice before the United States Supreme Court, First
Circuit, Second Circuit ... Third Circuit; Fourth Circuit, Fifth Circuit, Sixth Circuit, Ninth Circuit,
and Eleventh Circuit.
3. Movant designates RONALD G. NE1W1RT14, ESQ., of FOWLER WHITE
BURNETT, P.A., who is qualified to practice ... this Court and who consents to designation as
local counsel.
4. Movant certifies that he hasenev.er been disbarred and is not currently suspended
from the practice
https://www.justice.gov/epstein/files/DataSet%209/EFTA00286364.pdf
EFTA00724496Set 9
2010-11-0211p2,718w
EPSTEIN TO PAY FOR THE
PRODUCTION OF ALL DOCUMENTS IN RESPONSE TO HIS REOUEST
Movants, LM and Bradley J. Edwards, move this Court for relief from Amended Order ... files produced by Trustee was a corrupt and unworkable
file; on October 25, 2010 Movants requested that this corrupted file be resent to their office. In
addition, Movants requested that ... that a better record
for the privilege log can be created. To date Movants still have not received the new disc(s).
8. Once Movants receive all files
https://www.justice.gov/epstein/files/DataSet%209/EFTA00724496.pdf
EFTA00780307Set 9
2010-07-1910p2,646w
EXCLUDE THE PRODUCTION FROM
TRUSTEE STETTIN OF PRIVILEGED DOCUMENTS AND TESTIMONY TO
JEFFREY EPSTEIN
Movant, L.M., moves this Court pursuant to 11 U.S.C. §105(a), Federal Rules of
Bankruptcy Procedure ... state court in connection with an action
pending before the state court.
2. Movant, L.M., respectfully requests that this honorable Court enter a protective order,
consistent with the document production ... Filed 07/19/10 Page 2 of 10
privilege and/or attorney work product.
II. Background
3. Movant, L.M. is a party plaintiff in a civil lawsuit' against party defendant Jeffrey
Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00780307.pdf