EFTA00808026Set 9
2009-12-0728p8,180w
matter of law, Edwards cannot secure
summary judgment on the basis of the sword and shield doctrine or the litigation privilege.
STATEMENT OF THE CASE
A. Delay in Discovery Pending ... even remotely relevant to Edwards' summary judgment
arguments based upon the litigation privilege, the sword and shield doctrine, and the Ponzi
scheme. The following examples will vividly illustrate this point ... Attorney's Office must be stricken for the reasons set
forth herein.
THE SWORD AND SHIELD DOCTRINE DOES NOT
SUPPORT SUMMARY JUDGMENT FOR EDWARDS
Edwards contends that Plaintiff must
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808026.pdf
EFTA00947019Set 9
2012-10-312p282w
From: Jeffrey Epstein <jeffreyepsteinorg®gmail.com>
To: Jeffrey Epstein <jeevacation@grnail.com>
Subject: Fwd: Colonial era swords for Zorro Ranch (private message)
Date: Wed, 31 Oct 2012 17:00:42 +0000
Attachments: Sword_l.doc ... message
From:
Date: Mon, Oct 29, 2012 at 3:29 PM
Subject: Colonial era swords for Zorro Ranch (private message)
To: jeffreyeparg®gmail.com
Jeffrey Epstein
Zorro Ranch
49 Zorro Ranch ... come to my attention that you might be interested in three rare
antique colonial swords that I wish to sell, on behalf of a collector
friend.
Two apparently mutual acquaintances
https://www.justice.gov/epstein/files/DataSet%209/EFTA00947019.pdf
EFTA01081110Set 9
2009-12-0718p5,749w
received the
documents subpoenaed and discovery related to those documents has concluded.
IV. THE SWORD AND SHIELD DOCTRINE DOES
NOT SUPPORT SUMMARY JUDGMENT
Edwards contends that Plaintiff must be denied ... Epstein's M/Strike
First, Edwards misapprehends the nature and application of the "sword and shield"
doctrine, which "embraces the rule `that a plaintiff may not seek affirmative relief ... authorities, Plaintiff's claims may not be dismissed on summary
judgment pursuant to the "sword and shield" doctrine because the information Edwards sought to
elicit from Plaintiff at his deposition
https://www.justice.gov/epstein/files/DataSet%209/EFTA01081110.pdf
EFTA01103302Set 9
2009-12-0719p5,830w
received the
documents subpoenaed and discovery related to those documents has concluded.
IV. THE SWORD AND SHIELD DOCTRINE DOES
NOT SUPPORT SUMMARY JUDGMENT
Edwards contends that Epstein must be denied ... Edwards' arguments are wrong.
First, Edwards misapprehends the nature and application of the "sword and shield"
doctrine, which "embraces the rule 'that a plaintiff may not seek affirmative relief ... authorities, Epstein's claims may not be dismissed on summary
judgment pursuant to the "sword and shield" doctrine because the information Edwards sought to
elicit from Epstein at his deposition
https://www.justice.gov/epstein/files/DataSet%209/EFTA01103302.pdf
EFTA01100999Set 9
39p13,881w
claims, he is barred from prosecuting this case against Edwards.
Under the well-established "sword and shield" doctrine, Epstein cannot seek damages from
Edwards while at the same time asserting ... included those
allegations in a lawsuit that was and is barred by both the sword-shield doctrine and the
absolute litigation privilege. His lawsuit was merely a desperate measure ... Epstein has hidden behind the Fifth Amendment. As a
result, under the "sword and shield doctrine" widely recognized in Florida caselaw, his suit must be
dismissed
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100999.pdf
EFTA01100608Set 9
2011-04-0830p8,889w
claims, he is barred from prosecuting this case against Edwards. Under the well-
established "sword and shield" doctrine, Epstein cannot seek damages from Edwards while at the same
time asserting ... Epstein has hidden behind the Fifth Amendment. As a
result, under the "sword and shield doctrine" widely recognized in Florida caselaw, his suit must be
dismissed ... fifth amendment to avoid giving discovery, using the fifth amendment as both a `sword
and a shield.'" DePalma v. DePalma, 538 So.2d 1290, 1290 (Fla. 4th Dist
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100608.pdf
EFTA00725968Set 9
30p8,528w
claims, he is barred from prosecuting this case against Edwards. Under the well-
established "sword and shield" doctrine, Epstein cannot seek damages from Edwards while at the same
time asserting ... Epstein has hidden behind the Fifth Amendment. As a
result, under the "sword and shield doctrine" widely recognized in Florida caselaw, his suit must be
dismissed ... fifth amendment to avoid giving discovery, using the fifth amendment as both a `sword
and a shield.' DePalma v. DePalma, 538 So.2d 1290, 1290 (Fla. 4th Dist
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725968.pdf
EFTA00729953Set 9
29p8,607w
claims, he is barred from prosecuting this case against Edwards. Under the well-
established "sword and shield" doctrine, Epstein cannot seek damages from Edwards while at the same
time asserting ... Epstein has hidden behind the Fifth Amendment. As a
result, under the "sword and shield doctrine" widely recognized in Florida caselaw, his suit must be
dismissed ... fifth amendment to avoid giving discovery, using the fifth amendment as both a `sword
and a shield.' DePalma v. DePalma, 538 So.2d 1290, 1290 (Fla. 4th Dist
https://www.justice.gov/epstein/files/DataSet%209/EFTA00729953.pdf
EFTA01655731Set 10
2024-01-0516p9,056w
Thefts
• Missouri Cold Case: FBI Offers $10,000 Reward for Information on Stolen Truman Swords
• FBI Offers $2,000 Reward For 'Pink Backpack Bandit' in New Mexico
FINANCIAL CRIME & CORPORATE ... face.
Missouri Cold Case: FBI Offers $10,000 Reward for Information on Stolen Truman Swords
EFTA01655738
KTVI (FOX-2) (01/04, Dowell) reported that the FBI is still searching for Harry ... Truman's swords, which were stolen
over 37 years ago from Independence, Missouri. According to the article, in 1987, the Truman Presidential Library
was broken into, and several items were
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01655731.pdf
EFTA01120533Set 9
2010-06-3029p8,593w
claims, he was barred from prosecuting his case against Edwards. Under the
well-established "sword and shield" doctrine, Epstein could not legitimately seek damages from
Edwards while at the same ... claim at all, Epstein hid behind the Fifth Amendment. As a
result, under the "sword and shield doctrine" widely recognized in Florida case law, his suit
could not have been ... Fifth Amendment to avoid giving discovery, using the
fifth amendment as both a `sword and a shield." DePaltna v. DePalma, 538 So.2d 1290, 1290
(Fla. 4th Dist
https://www.justice.gov/epstein/files/DataSet%209/EFTA01120533.pdf
EFTA00792811Set 9
187p36,662w
that my client can't
DRAFT ONLY !!!! NOT PROOFREAD
EFTA00792866
57
1 use it sword and shield. My client is not
2 using Fifth Amendment as sword and shield ... whatsoever.
4 In the example I gave Your Honor, that
5 would be a sword and shield if my client
6 refused to answer the question ... instituted that action, Fifth Amendment,
10 that would be a sword and shield, and they
11 could get an adverse inference.
12 So part of my omnibus -- revised
13 omnibus
https://www.justice.gov/epstein/files/DataSet%209/EFTA00792811.pdf
EFTA01100939Set 9
2011-11-0924p7,029w
claims, he is barred from prosecuting this case against Edwards. Under the
well-established "sword and shield" doctrine, Epstein cannot seek damages from Edwards while
at the same time asserting ... EFTA01100954
11/03/2011 15:57 FAX SEARCY DENNEY 2017
Amendment. As a result, under the "sword and shield doctrine" widely recognized in Florida
caselaw, his suit must be dismissed ... fifth amendment to avoid giving discovery, using the
fifth amendment as both a 'sword and a shield.'" DePalma v. DePalma, 538 So.2d 1290, 1290
(F1j. 4th Dist
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100939.pdf
EFTA01178512Set 9
2012-06-283p307w
JUNE 28, 2012
This week's projects are pretty spooky! We've got a sword fighting video game, a bi-
coastal dance piece, and a nifty gadget to help ... CLANG i En garde
Legendary sci-fi author Neal Stephenson
wants to revolutionize the sword fighting game.
While buttons and triggers have always felt
inadequate for simulating real sword combat ... Clang utilizes advances in motion controllers
so you can swing, slash, and wield your sword
to victory.
EXPLORE THIS PROJECT
CLANG
by Subutai Corporation
PACategory Video Games
R_ocation Seattle
https://www.justice.gov/epstein/files/DataSet%209/EFTA01178512.pdf
EFTA01100963Set 9
2011-11-0924p7,030w
claims, he is barred from prosecuting this case against Edwards. Under the
well-established "sword and shield" doctrine, Epstein cannot seek damages from Edwards while
at the same time asserting ... EFTA01100978
11/03/2011 15:57 FAX SEARCY DENNEY 2017
Amendment. As a result, under the "sword and shield doctrine" widely recognized in Florida
caselaw, his suit must be dismissed ... fifth amendment to avoid giving discovery, using the
fifth amendment as both a 'sword and a shield.'" DePalma v. DePalma, 538 So.2d 1290, 1290
(F1j. 4th Dist
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100963.pdf
EFTA00621816Set 9
2011-03-3122p5,969w
ACKERMAN: Your Honor, in regard to
21 Mr. Scarola's argument on sword and shield, okay. With
22 regard to the Fifth Amendment, Mr. Scarola has this
23 argument that ... believes that the Fifth -- the sword and
24 shield doctrine, which we argued previously in the motion
25 for summary judgment, Mr. Epstein has not taken the Fifth
ORANGE REPORTING ... that counterclaim. So to be involved at this point with
7 the sword and shield doctrine would not be appropriate.
8 So what I would ask the Court
https://www.justice.gov/epstein/files/DataSet%209/EFTA00621816.pdf
EFTA01070055Set 9
2011-07-13158p39,441w
issues. Mr. Ackerman to talk about various issues that may
24 come up, including sword and shield. Get to those so that
25 we don't constantly have ... decisions on all of these other
3 issues you guys are talking about, including sword and
4 shield, including privilege, including whether or not, you
5 know, Mr. Edwards
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070055.pdf
EFTA01924516Set 10
2014-05-0634p8,338w
look beyond the explosions
and manoeuvres at the political intent. Last week's "Abdullah
Sword" military exercises in the north-east of Saudi Arabia
brought together 130,000 troops ... extent, but, gradually, piece by piece, it is being
undermined.
That is what Abdullah Sword was about, establishing a credible
alternative deterrent. In time, the signals are that Saudi Arabia ... leadership role for the region. By staging
such a forceful display with Abdullah Sword, the kingdom is
showing the region that it has the allies and the weapons to
defend
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01924516.pdf
EFTA01069861Set 9
2011-07-13194p59,835w
issues. Mr. Ackerman to talk about various issues that may
24 come up, including sword and shield. Get to those so that
25 we don't constantly have ... decisions on all of these other
3 issues you guys are talking about, including sword and
4 shield, including privilege, including whether or not, you
5 know, Mr. Edwards
https://www.justice.gov/epstein/files/DataSet%209/EFTA01069861.pdf
EFTA01187574Set 9
2012-12-139p3,573w
hero [Hamas'] Ahmed
Al-Ja'abari"
Jibril Rajoub: "We will not return the sword to its sheath until there
is a state"
Mahmoud Al-Aloul: Hopefully Arab Spring will create ... land... Out of loyalty to your blood, Yasser Arafat...
we will not return the sword to its sheath until there is a state, until your
aspirations are realized, until ... blood,
Yasser Arafat, you who died during this month, we will not return the
sword to its sheath until there is a state, until your aspirations are
realized, until
https://www.justice.gov/epstein/files/DataSet%209/EFTA01187574.pdf
EFTA01732064Set 10
2015-12-097p2,092w
death come for them in a flash
Children of Zion, tell of the swords that were openly plunged=in you
Your necks and =eads, your buses and soldiers have tasted ... being humiliated<=span>
For your men love the r=nging sound of their swords
=span>And competed among themselves for Allah, how good is Heaven
Make volcanoes of war erupt ... death come for them in a flash
Children of Zion, tell of=the swords that were openly plunged in you
Your necks and heads, your buses and soldiers have
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01732064.pdf