EFTA00808816Set 9
2009-12-0738p7,270w
Waste the Resources of the Parties or Court
Denial of Bifurcation Will Prejudice Edwards 28-29
ii
EFTA00808817
CONCLUSION 30
CERTIFICATE OF TYPE SIZE & STYLE 31
CERTIFICATE OF SERVICE ... Thus, Edwards recognized in the Joint Pretrial Stipulation that
there was a possibility of prejudice to Edwards or confusion of the jury resulting
4 Epstein included the Joint Pretrial Stipulation ... trial (without Rothstein's opposition) which would be inadmissible
against Edwards, would prejudice Edwards, and would further confuse the jury
(App.14, pp.146-48). Edwards later supplemented his motion for separate trials
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808816.pdf
EFTA00156400Set 9
2022-04-2945p15,329w
violation of the grand jury clause, while a defendant must show
prejudice in order to prevail on a variance claim." Id. (quoting Frank, 156 F.3d at 337 n.5); see
also ... Rigas, 490 F.3d at 226 ("[A] defendant alleging variance must show `substantial prejudice'
to warrant reversal."). "A defendant cannot demonstrate that [s]he has been prejudiced by a
variance where ... case, and of
Jane's testimony regarding New Mexico specifically, to avoid substantial prejudice. The
Indictment charged a scheme to sexually abuse underage girls in New York. In service
https://www.justice.gov/epstein/files/DataSet%209/EFTA00156400.pdf
EFTA00585420Set 9
2017-09-1525p7,884w
exclude any irrelevant and immaterial evidence when its probative
value is outweighed by prejudice. Devoe v. Western Auto Supply ... relevant, any alleged "probative value is substantially outweighed by the
danger of unfair prejudice, confusion of issues, misleading the jury, or needless presentation of
cumulative evidence." § 90.403 FLA. STAT ... Fort Lauderdale, FL 33301
EFTA00585421
So. 2d 1106, 1107 (Fla. 4th DCA 1982). 'Unfair prejudice' has been described as 'an undue
tendency to suggest decision on an improper basis, commonly
https://www.justice.gov/epstein/files/DataSet%209/EFTA00585420.pdf
EFTA00802160Set 9
2017-09-1525p7,925w
exclude any irrelevant and immaterial evidence when its probative
value is outweighed by prejudice. Devoe v. Western Auto Supply ... relevant, any alleged "probative value is substantially outweighed by the
danger of unfair prejudice, confusion of issues, misleading the jury, or needless presentation of
cumulative evidence." § 90.403 FLA. STAT ... Fort Lauderdale, FL 33301
EFTA00802161
So. 2d 1106, 1107 (Fla. 4th DCA 1982). 'Unfair prejudice' has been described as 'an undue
tendency to suggest decision on an improper basis, commonly
https://www.justice.gov/epstein/files/DataSet%209/EFTA00802160.pdf
EFTA01122490Set 9
13p4,054w
Evidence at Trial
Page 3 of 13
for believing that opposing parties suffered undue prejudice from a litigant's later-
regretted decision to invoke the Fifth Amendment.
This does ... Fifth Amendment to abuse or obstruct the discovery process, trial
courts, to prevent prejudice to opposing parties, may adopt remedial procedures or
impose sanctions. [S]ee Wehling [v. Columbia Broadcasting ... privilege.
As courts and commentators have noted, opposing parties will frequently suffer
prejudice (at the very least from increased costs and delays) when a litigant relies
on the Fifth Amendment
https://www.justice.gov/epstein/files/DataSet%209/EFTA01122490.pdf
EFTA01112444Set 9
2010-03-0323p7,116w
U.S.C. §2255 was stricken. Count IV — Florida
RICO claim has been dismissed with prejudice.
EFTA01112444
Jane Doe v. Epstein, et al.
Page 2
1993). No punitive damages are specifically plead ... alternative, if somehow found relevant, introduction of such
evidence would result in undue prejudice to EPSTEIN in both the liability and damages portions
of the trial on all ofPlaintiff ... allowing for separate trial provides in relevant part that —
For convenience, to avoid prejudice, or to expedite and economize, the court may
order a separate trial of one or more
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112444.pdf
EFTA00310529Set 9
2010-07-2010p1,613w
MARRA-JOHNSON
JANE DOE,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
FINAL ORDER OF DISMISSAL WITH PREJUDICE
THIS CAUSE is before the Court upon the parties' Stipulation of Dismissal with
Prejudice ... ORDERED AND ADJUDGED as follows:
1. The above-styled action is hereby DISMISSED WITH PREJUDICE.
2. All pending motions are DENIED AS MOOT.
3. The Court shall retain jurisdiction ... MARRA-JOHNSON
JANE DOE,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
STIPULATION OF DISMISSAL WITH PREJUDICE
Plaintiff, JANE DOE and Defendant, JEFFREY EPSTEIN, (collectively,
'Parties"), by and through their undersigned counsel
https://www.justice.gov/epstein/files/DataSet%209/EFTA00310529.pdf
EFTA00023488Set 8
2019-11-126p1,819w
Judge:
On January 21, 2021, Plaintiff filed I motion to dismiss this action with
prejudice, pursuant to Federal Rule of Civil Procedure 411)(2). In connection with her motion,
Plaintiff ... claims (the "General
Release"). To receive her compensation, Plaintiff must dismiss with prejudice any existing
lawsuits against the Estate and related entities and individuals -- including this lawsuit.
To conclude ... Program, Plaintiff now moves for Rule 411)(2)
dismissal of all claims with prejudice. In connection with her motion, Plaintiff filed the
Proposed Order, to which the Co-Executors
https://www.justice.gov/epstein/files/DataSet%208/EFTA00023488.pdf
EFTA00804571Set 9
125p25,245w
these supplemental exhibits
3 should be allowed because there is, in fact, no
4 prejudice to the plaintiff in this case in
5 letting them come in.
6 THE COURT ... this Court well knows, just requires
17 you, mandates that you do the prejudice
18 analysis.
19 I'm suggesting as the first basis, and I
20 will ... privileged log, and which
16 they can have no prejudice to because they were
17 written or received by Mr. Edwards. There is
18 no need to redepose Mr. Edwards
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804571.pdf
EFTA00095371Set 9
2019-11-126p1,840w
Judge:
On January 21, 2021, Plaintiff iled a motion to dismiss this action with
prejudice, pursuant to Federal Rule of Civil Procedure 41(a)(2). In connection with her motion ... claims (the "General
Release"). To receive her compensation, Plaintiff must dismiss with prejudice any existing
lawsuits against the Estate and related entities and individuals -- including this lawsuit.
To conclude ... Program, Plaintiff now moves for Rule 41(a)(2)
dismissal of all claims with prejudice. In connection with her motion, Plaintiff filed the
Proposed Order, to which the Co-Executors
https://www.justice.gov/epstein/files/DataSet%209/EFTA00095371.pdf
EFTA01188221Set 9
2013-02-077p4,958w
will not receive a fair trial or hearing because of specifically described prejudice or bias of
the judge;
2. that the judge before whom the case is pending, or some ... party untimely files the motion,3
when the motion fails to specifically describe any prejudice or bias on the part of the trial judge,4 when the motion omits ... Initial and Successive Disqualification Motions
If an initial disqualification motion alleges a fear of prejudice or bias under rule 2.160(dX1), the trial judge is required to
determine only
https://www.justice.gov/epstein/files/DataSet%209/EFTA01188221.pdf
EFTA01098037Set 9
2011-10-1421p6,534w
FLSD Docket 10/14/2011 Page 5 of 21
unnecessary, and the result will be needless prejudice to the existing parties and the would-be
intervenor if his motion is granted ... letters on March 21,2011. [DE 50,
51]. The government does not articulate any prejudice from this passage of time. The plaintiffs
complain that they will be prejudiced ... whether an application for intervention is timely, the
relevant issue is not how much prejudice would result from allowing intervention, but rather how
much prejudice would result from the would
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098037.pdf