""Renewed Motion"" — Epstein Files Search

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Corpus: 1990-03-17 – 2025-12-01

December 2012

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EFTA01187485Set 9

2012-12-0526p7,790w

Epstein's Memorandum of Law in of Opposition to Mr. Edwards's Second Renewed Motion for Leave to Assert a Claim for Punitive Damages, and all accompanying exhibits. This Motion ... JEFFREY EPSTEIN'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S SECOND RENEWED MOTION FOR LEAVE TO ASSERT A CLAIM FOR PUNITIVE DAMAGES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein ... files this Memorandum of Law in Opposition to Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") Second Renewed Motion for Leave to Assert Claim for Punitive Damages. In support thereof, Epstein states: PROCEDURAL

https://www.justice.gov/epstein/files/DataSet%209/EFTA01187485.pdf

EFTA00296751Set 9

2012-08-0363p10,500w

Order dated March 20, 2012; • Motion for Entry of Default as to Nick Lambros & Renewed Motion for Entry of Default as to AVLC, LLC d/b/a Sound X and proposed Order ... DEMANDED Defendants. PUNITIVE DAMAGES SOUGHT MOTION FOR ENTRY OF DEFAULT AS TO NICK LAMBROS & RENEWED MOTION FOR ENTRY OF DEFAULT AS TO AVLC _LLC d/b/a SOUND X COME NOW Plaintiffs ... EXHIBIT A] EFTA00296755 Epstein v. Lambros Civil No. 2012-cv-21 Motion & Renewed Motion for Entry of Default Page 2 5. Service on Ron Goldstein was accomplished on February

https://www.justice.gov/epstein/files/DataSet%209/EFTA00296751.pdf

EFTA01102306Set 9

2011-12-076p2,252w

revise draft Interrogatories CEK 0.50 11/03/11 Revise Motion for Clarification Regarding Discovery; review Renewed Motion for JLA 3.50 Summary Judgment; e-mail to Client regarding Motion for Clarification; telephone call ... with Darren Indyke regarding Motion for Clarification (2). 11/04/11 Receipt and review ofBradley Edwards' Renewed Motion for Final Summary CEK 1.00 Judgment; review of draft of Motion for Clarification Regarding ... Epstein regarding same (6); correspondence to J. Scarola regarding same; review Statement ofFacts and Renewed Motion for Summary Judgment; review Privilege Log; e-mails with attachments from Jackie Perczek regarding

https://www.justice.gov/epstein/files/DataSet%209/EFTA01102306.pdf

EFTA00023895Set 8

2021-04-1614p4,594w

superseding indictment. The Court understands the primary purpose of Maxwell's renewed motion to be to preserve these arguments for appellate review, and the Court denies the 2 EFTA00023896 Case ... Document 317 Filed 08/13/21 Page 3 of 14 renewed motion for substantially the same reasons set forth in its April 16 opinion. The Court will proceed to briefly explain ... arguments for why the Court should depart from this reasoning—the first in her renewed motion and the second in a letter of supplemental authority

https://www.justice.gov/epstein/files/DataSet%208/EFTA00023895.pdf

EFTA01082320Set 9

2010-04-128p1,800w

this Motion as Exhibit I. 10. On November 11, 2011, Edwards filed his Renewed Motion for Summary Judgment and a lengthy Statement of Undisputed Facts in which he purported ... Edwards relying on communications with the government and reporters as part of his Renewed Motion for Summary Judgment and to support his contention that Epstein has waived his Fifth Amendment ... burdensome. The request is relevant and necessary in order for Epstein to defend Edwards' Renewed Motion for Summary Judgment, including Edwards' contention that Epstein has waived his Fifth Amendment rights

https://www.justice.gov/epstein/files/DataSet%209/EFTA01082320.pdf

EFTA00603152Set 9

2010-04-128p1,809w

this Motion as Exhibit I. 10. On November 11, 2011, Edwards filed his Renewed Motion for Summary Judgment and a lengthy Statement of Undisputed Facts in which he purported ... Edwards relying on communications with the government and reporters as part of his Renewed Motion for Summary Judgment and to support his contention that Epstein has waived his Fifth Amendment ... burdensome. The request is relevant and necessary in order for Epstein to defend Edwards' Renewed Motion for Summary Judgment, including Edwards' contention that Epstein has waived his Fifth Amendment rights

https://www.justice.gov/epstein/files/DataSet%209/EFTA00603152.pdf

EFTA01111318Set 9

2010-04-128p1,826w

this Motion as Exhibit 1. 10. On November 11, 2011, Edwards filed his Renewed Motion for Summary Judgment and a lengthy Statement of Undisputed Facts in which he purported ... Edwards relying on communications with the government and reporters as part of his Renewed Motion for Summary Judgment and to support his contention that Epstein has waived his Fifth Amendment ... burdensome. The request is relevant and necessary in order for Epstein to defend Edwards' Renewed Motion for Summary Judgment, including Edwards' contention that Epstein has waived his Fifth Amendment rights

https://www.justice.gov/epstein/files/DataSet%209/EFTA01111318.pdf

EFTA00208562Set 9

2013-09-191p213w

JPerczek®myblack.com> Cc: " USAFLS " ,' (USAFLS)" , "Brad Edwards (brad@pathtojustice.com)" <brad®pathtojustice.com> Subject: RE: Position on Renewed Motion for Expedited Ruling Date: Thu, 19 Sep 2013 00:25:53 +0000 Importance: Normal ... Jackie, Brad and I are preparing a renewed motion for an expedited ruling on the Epstein motion for a stay before the CAll. Friday we are going to file

https://www.justice.gov/epstein/files/DataSet%209/EFTA00208562.pdf

EFTA00808421Set 9

2017-07-205p1,148w

SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RENEWED MOTION FOR LEAVE TO DISCLOSE EXPERT WITNESS Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), respectfully renews his request ... CONCLUSION Accordingly, Epstein respectfully requests that the Court grant this renewed Motion and allow his disclosure of Mr. Smith as an expert witness. CERTIFICATE OF SERVICE I certify that

https://www.justice.gov/epstein/files/DataSet%209/EFTA00808421.pdf

EFTA01106989Set 9

motion on October 4, 2011 (R2:360). After extensive filings in support of the renewed Motion for Summary Judgment, a hearing date was set (R4:607). On August

https://www.justice.gov/epstein/files/DataSet%209/EFTA01106989.pdf

EFTA01104267Set 9

motion on October 4, 2011 (R2:360). After extensive filings in support of the renewed Motion for Summary Judgment, a hearing date was set (R4:607). On August

https://www.justice.gov/epstein/files/DataSet%209/EFTA01104267.pdf

EFTA00083712Set 9

2003-05-219p2,542w

unprecedented. They profoundly 2 See Dkt. 97 at 34 (case-comparison chart in the Renewed Motion for Bail); cf. People v. Dominique Strauss-Kahn, 02526/201 I(S.Ct. N.Y. County). Strauss ... Court judge—enhance the already extraordinarily restrictive bail conditions proposed in Ms. Maxwell's Renewed Motion for Bail. In combination, these conditions satisfy the Bail Reform Act and reasonably assure

https://www.justice.gov/epstein/files/DataSet%209/EFTA00083712.pdf

EFTA00065631Set 9

2020-12-081p225w

under seal two versions of the Memorandum of Ghislaine Maxwell in Support of Her Renewed Motion for Bail (the "Motion") and accompanying exhibits: an unredacted original to be kept under

https://www.justice.gov/epstein/files/DataSet%209/EFTA00065631.pdf

EFTA00079608Set 9

2020-11-254p1,415w

Judge Nathan: On behalf of our client, Ghislaine Maxwell, we plan to file a Renewed Motion for Release on Bail (the "Motion") and respectfully request an in camera conference, with

https://www.justice.gov/epstein/files/DataSet%209/EFTA00079608.pdf

EFTA00584796Set 9

2014-05-197p1,489w

SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RENEWED MOTION TO STAY PROCEEDINGS OR ALTERNATIVE MOTION TO CONTINUE THE TRIAL DATE SET IN THIS MATTER

https://www.justice.gov/epstein/files/DataSet%209/EFTA00584796.pdf

EFTA00801238Set 9

COURT: Mr. Scarola, any thoughts? 3 MR. SCAROLA: Your Honor, this is a 4 renewed motion for summary judgment. 5 Your Honor may recall a motion for 6 summary judgment

https://www.justice.gov/epstein/files/DataSet%209/EFTA00801238.pdf

EFTA02175894Set 10

2012-01-251p103w

more details s Remind D: Fowler has received notice that our renewed motion to depose Rothstein will be heard on Feb 1 When Wed Jan 25 4pm - 5pm Eastern Time

https://www.justice.gov/epstein/files/DataSet%2010/EFTA02175894.pdf

EFTA02175632Set 10

2012-01-271p102w

more details s Remind D: Fowler has received notice that our renewed motion to depose Rothstein will be heard on Feb 1 When Fri Jan 27 5am - 6am Calendar

https://www.justice.gov/epstein/files/DataSet%2010/EFTA02175632.pdf

EFTA02175510Set 10

2012-01-301p104w

30am more details A Remind D: has received notice that our renewed motion to depose Rothstein will be heard on Feb 1 When Mon Jan 30 6:30am — 7:30am

https://www.justice.gov/epstein/files/DataSet%2010/EFTA02175510.pdf

EFTA01145698Set 9

SCOTT ROTFIS LIN, etc., et al., Defendant(s). ORDER ON COUNTER-PLAINTIFF EDWARDS' RENEWED MOTION FOR LEAVE TO ASSERT CLAIM FOR PUNITIVE DAMAGES THIS CAUSE came before the Court upon

https://www.justice.gov/epstein/files/DataSet%209/EFTA01145698.pdf

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Results by Dataset25 total

Set 8

2

Set 9

21

Set 10

2