EFTA01102447Set 9
2011-07-138p1,896w
AGAINST EDWARDS
Plaintiff/Counter-Defendant Jeffrey Epstein, by and through his undersigned
counsel and pursuant to Rule 1.190(0 of the Florida Rules of Civil Procedure, §768.72 of
the Florida Statues ... This Court, in denying the Motion, explained to Edwards what is required
under Rule 1.190(f) to pass muster procedurally. This Court avowed:
[Rule] 1.190, which is the rule ... repeatedly disagreed with this Court's assessment that his Motion did
not comply with Rule 1.190(0 of the Florida Rules of Civil Procedure and §768.72 of the
Florida Statutes
https://www.justice.gov/epstein/files/DataSet%209/EFTA01102447.pdf
EFTA01112386Set 9
2013-09-114p791w
COUNTERCLAIM
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his
undersigned counsel and pursuant to Rule 1.190 of the Florida Rules of Civil Procedure,
hereby moves this Honorable Court to permit ... Amended
Counterclaim to conform with the evidence. In support of this Motion, Epstein states:
Rule 1.190(a) of the Florida Rides of Civil Procedure governs amendments to
pleadings, and provides ... cause no
prejudice to Edwards because Edwards has already sought discovery on this defense.
Rule 1.190(b) of the Florida Rules of Civil Procedure provides that "[w]hen issues
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112386.pdf
EFTA01187485Set 9
2012-12-0526p7,790w
DAMAGES
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his
undersigned counsel and pursuant to Rule 1.190(0 of the Florida Rules of Civil
Procedure and §768.72 of the Florida Statues ... complaint." Globe Newspaper
Company v. King, 658 So. 2d 518, 520 (Fla. 1995). Additionally, Rule 1.190(1) of the
Florida Rules of Civil Procedure governs amendments to pleadings to assert ... Edwards's First
Motion for Leave to Assert a Claim for Punitive Damages declared:
[Rule] 1.190, which is the rule on amended and supplemental pleadings,
was amended in two thousand
https://www.justice.gov/epstein/files/DataSet%209/EFTA01187485.pdf
EFTA01112383Set 9
2013-09-093p416w
COUNTERCLAIM
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his
undersigned counsel and pursuant to Rule 1.190 of the Florida Rules of Civil Procedure,
hereby moves this Honorable Court to permit ... Affirmative Defenses to Edwards's Fourth Amended
Counterclaim to conform with the evidence.
Rule 1.190(a) of the Florida Rules of Civil Procedure governs amendments to
pleadings, and provides
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112383.pdf
EFTA00724170Set 9
2010-04-1310p2,005w
Strike Directed To
Plaintiff's Second Amended Complaint, dated April 13, 2010. pursuant to Rule 1.190,
Fla.R.Civ.Proc. (2010). In support of granting his motion, EPSTEIN states:
1. On April ... also seeking to strike ¶4. There are no
other changes.
4. Pursuant to Rule 1.190(a), leave to amend shall be freely given when
justice so requires. The proposed amendment ... original answer. Justice requires that the
amendment be allowed.
5. Also pursuant to Rule 1.190(a), a party is allowed to amend a pleading "by
written consent of the adverse
https://www.justice.gov/epstein/files/DataSet%209/EFTA00724170.pdf
EFTA01100999Set 9
39p13,881w
Defendant, Bradley J. Edwards, Esq., by and through his undersigned counsel and
pursuant to Rule 1.190(f), Florida Rules of Civil Procedure, hereby moves for leave to amend
to assert
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100999.pdf