Epstein Files Search

EFTA00808752Set 9

2011-02-2512p3,153w

raised relevance. We raised probative value substantially outweighed by the danger or unfair prejudice, confusion, misleading the jury, as well as hearsay and authenticity. This is a very good example ... bearing on the issues at bar, and which can only result in unfair prejudice to Epstein, confusion of the jury, and unfortunately, a second trial of this case. ARGUMENT Edwards ... argues that Exhibit #132 is relevant, not unfairly prejudicial, and not barred by the hearsay rule. His main contention is that the article is relevant to the punitive damages claim

https://www.justice.gov/epstein/files/DataSet%209/EFTA00808752.pdf

EFTA00311151Set 9

2012-04-1074p23,416w

homeowner dispute with title insura nce company, business ownership dispute, commercial disputes, personal injury, unfair trade or busine ss practice, trade secrets, bad faith, fraud. Handled contractual disputes involving healthcare ... disputes, legal malpractice, attorney fee disputes, insurance coverage, commercial disputes, employment disputes, personal injury, unfair trade or business practice, trade secrets, bad faith, fraud. . As a neutral arbitrator and mediator ... Appointed discovery referee by the Los Angeles Superior Court in disputes involving insurance, unfair competition, real property and business disputes. Mediation: since July 1998, has conducted 100's of mediations

https://www.justice.gov/epstein/files/DataSet%209/EFTA00311151.pdf

EFTA01112075Set 9

2009-11-0157p27,919w

that right is not unlimited. Disqualification is appropriate where a party (Epstein) obtains an unfair informational advantage by virtue of their counsel (Haddad) having access to privileged or confidential information ... confidential communications between Frye and his former lawyer. The Court held that an unfair informational advantage accruing to law firm through its representation of Frye's former lawyer ... confidential information from Frye, thereby giving the law firm now representing that lawyer an unfair informational advantage against Frye in the deficiency action in which it also represented the adversary

https://www.justice.gov/epstein/files/DataSet%209/EFTA01112075.pdf

EFTA00801498Set 9

2017-11-109p2,492w

Florida Statutes, because any probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues, and misleading the jury. "[E]ven if relevant, a trial court ... because any remote or minimal probative value is clearly outweighed by the danger of unfair prejudice, confusion of issues, and the risks of misleading the jury. See Fla. Stat ... weighing the probative value against the unfair prejudice, it is proper for the court to consider the need for the evidence; the tendency of the evidence to suggest an improper

https://www.justice.gov/epstein/files/DataSet%209/EFTA00801498.pdf

EFTA00103308Set 9

2021-07-1234p11,087w

that the Government brought the charges within the statute of limitations and did not unfairly delay in bringing them. • Maxwell moves to dismiss the Mann Act counts because they ... deprive her of any vested rights. Maxwell contends that it is unfair to allow the Government to prosecute her now for conduct that occurred more than twenty years ... agreed to disclose their names in advance of trial. There is thus no unfairness here. See Stringer, 730 F.3d at 126. As discussed below, the Court will require the parties

https://www.justice.gov/epstein/files/DataSet%209/EFTA00103308.pdf

EFTA00785729Set 9

2018-08-0218p3,382w

Sender: Self ( jeeitunes®gmail.com Participants: Lawrence Krauss ( ), Self ( jeeitunes@gmail.com ) Your arguments re unfair , are tricky. As you were given plenty of rope EFTA00785729 ... Sender: Self ( e:jeeitunes®gmail.com Participants: Lawrence Krauss ( ), Self ( e: ) Your arguments re unfair , are tricky. As you were given plenty of rope iMessage ... jeeitunes@gmail.com ) It sounds like a eulogy, the great honor is not outweighed by the unfairness SMS 2018-08-02 17:07:11 (UTC) [1] Sender: Self ( e:jeeitunes®gmail.com Participants

https://www.justice.gov/epstein/files/DataSet%209/EFTA00785729.pdf

EFTA00103343Set 9

2021-07-1234p11,087w

that the Government brought the charges within the statute of limitations and did not unfairly delay in bringing them. • Maxwell moves to dismiss the Mann Act counts because they ... deprive her of any vested rights. Maxwell contends that it is unfair to allow the Government to prosecute her now for conduct that occurred more than twenty years ... agreed to disclose their names in advance of trial. There is thus no unfairness here. See Stringer, 730 F.3d at 126. As discussed below, the Court will require the parties

https://www.justice.gov/epstein/files/DataSet%209/EFTA00103343.pdf

EFTA00020261Set 8

2021-07-1234p11,082w

that the Government brought the charges within the statute of limitations and did not unfairly delay in bringing them. • Maxwell moves to dismiss the Mann Act counts because they ... deprive her of any vested rights. Maxwell contends that it is unfair to allow the Government to prosecute her now for conduct that occurred more than twenty years ... agreed to disclose their names in advance of trial. There is thus no unfairness here. See Stringer, 730 F.3d at 126. As discussed below, the Court will require the parties

https://www.justice.gov/epstein/files/DataSet%208/EFTA00020261.pdf

EFTA00103238Set 9

2021-07-1234p11,087w

that the Government brought the charges within the statute of limitations and did not unfairly delay in bringing them. • Maxwell moves to dismiss the Mann Act counts because they ... deprive her of any vested rights. Maxwell contends that it is unfair to allow the Government to prosecute her now for conduct that occurred more than twenty years ... agreed to disclose their names in advance of trial. There is thus no unfairness here. See Stringer, 730 F.3d at 126. As discussed below, the Court will require the parties

https://www.justice.gov/epstein/files/DataSet%209/EFTA00103238.pdf

EFTA00090494Set 9

2021-07-1234p11,087w

that the Government brought the charges within the statute of limitations and did not unfairly delay in bringing them. • Maxwell moves to dismiss the Mann Act counts because they ... deprive her of any vested rights. Maxwell contends that it is unfair to allow the Government to prosecute her now for conduct that occurred more than twenty years ... agreed to disclose their names in advance of trial. There is thus no unfairness here. See Stringer, 730 F.3d at 126. As discussed below, the Court will require the parties

https://www.justice.gov/epstein/files/DataSet%209/EFTA00090494.pdf

EFTA01122490Set 9

13p4,054w

litigant might have invoked the privilege primarily to abuse, manipulate or gain an unfair strategic advantage over opposing parties. If it appears that a litigant has sought ... stressing that courts must be "free to fashion whatever remedy is required to prevent unfairness"). In such circumstances, particularly if the litigant's request to waive comes only ... this litigation," "put[] the SEC to enormous and unnecessary expense," and "provide him an unfair strategic advantage in this litigation, allowing him to effectively ambush the SEC with evidence, defenses

https://www.justice.gov/epstein/files/DataSet%209/EFTA01122490.pdf

EFTA00029540Set 8

2021-07-1234p11,084w

that the Government brought the charges within the statute of limitations and did not unfairly delay in bringing them. • Maxwell moves to dismiss the Mann Act counts because they ... deprive her of any vested rights. Maxwell contends that it is unfair to allow the Government to prosecute her now for conduct that occurred more than twenty years ... agreed to disclose their names in advance of trial. There is thus no unfairness here. See Stringer, 730 F.3d at 126. As discussed below, the Court will require the parties

https://www.justice.gov/epstein/files/DataSet%208/EFTA00029540.pdf

EFTA00087774Set 9

2007-05-0121p5,654w

propensity, despite the alleged conduct being entirely legal, and would mislead the jury and unfairly prejudice Ms. Maxwell. Accordingly, the Court should exclude evidence related to Accuser-3. BACKGROUND ... surplusage on the grounds that they could not support the charged conspiracies and were unfairly prejudicial to Ms. Maxwell. See Def.'s Mem. in Supp. of Mot. to Strike Surplusage ... probative value of the evidence cannot be substantially outweighed by its potential for unfair 2 For the same reasons, Ms. Maxwell also renews her motion to strike the allegations related

https://www.justice.gov/epstein/files/DataSet%209/EFTA00087774.pdf

EFTA00074479Set 9

2007-05-0121p5,698w

propensity, despite the alleged conduct being entirely legal, and would mislead the jury and unfairly prejudice Ms. Maxwell. Accordingly, the Court should exclude evidence related to Accuser-3. BACKGROUND ... surplusage on the grounds that they could not support the charged conspiracies and were unfairly prejudicial to Ms. Maxwell. See Def.'s Mem. in Supp. of Mot. to Strike Surplusage ... probative value of the evidence cannot be substantially outweighed by its potential for unfair 2 For the same reasons, Ms. Maxwell also renews her motion to strike the allegations related

https://www.justice.gov/epstein/files/DataSet%209/EFTA00074479.pdf

EFTA00088802Set 9

2021-10-1184p23,883w

probative value of the evidence is "substantially outweighed" by the danger of unfair prejudice. Id. at 1182; see Fed. R. Evid. 403. Until December I, 2020, the Government was required ... trial; and (3) has probative value which is not substantially outweighed by any unfair prejudicial effect. See Zackson, 12 F.3d at 1182. If requested, such evidence must be admitted with ... sexual conduct with" putative victim). The defense argues that this testimony will be unfairly prejudicial to the defendant. See Fed. R. Evid. 403. According to the defense, if Minor Victim

https://www.justice.gov/epstein/files/DataSet%209/EFTA00088802.pdf

EFTA00156400Set 9

2022-04-2945p15,329w

notice of the Government's theory at trial, she cannot claim that she was unfairly or substantially prejudiced. See United States v. Kaplan, 490 F.3d ... allegations that Was sexually abused in New Mexico. She therefore claims she was unfairly surprised by its introduction. For purposes of this motion, the Court will assume that.. testimony ... request a continuance when evidence is introduced suggests that a defendant was not unfairly surprised or prejudiced. See Kaplan, 490 F.3d at 130. Here, the Defendant had sufficient notice

https://www.justice.gov/epstein/files/DataSet%209/EFTA00156400.pdf

EFTA00805158Set 9

2018-01-0531p6,526w

amounts attributed to each of those individual's settlement is solely being sought to unfairly prejudice Epstein and to make public the names of the women who deserve and settled ... raised the following objections: (3) relevance; (4) probative value substantially outweighed by danger of unfair prejudice, confusion of issues, misleading the jury, or needless presentation of cumulative evidence; (7) hearsay ... argue remote relevance, 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

https://www.justice.gov/epstein/files/DataSet%209/EFTA00805158.pdf

EFTA00799975Set 9

2007-04-2433p10,181w

faulted for petitioners' decision. V. THE GOVERNMENT DID NOT TREAT THE VICTIMS UNFAIRLY In their summary judgment motion, petitioners' allegation of unfair treatment was based upon alleged deception ... their motion, petitioners provided sixteen (16) examples of what they claimed was unfair treatment. D.E. 361 at 52-53. All of the examples dealt with the government allegedly engaging ... entered pleas of guilty in Florida state court. The victims were not treated unfairly by the government. With the fate of the NPA in question due to Epstein's attorneys

https://www.justice.gov/epstein/files/DataSet%209/EFTA00799975.pdf

EFTA00211718Set 9

2007-04-2432p10,140w

attorney for the Government or any Government agent, felt that she was treated unfairly, or that she failed to receive reasonable or accurate notice. Jane ... petitioners was reasonable, timely, and accurate. VI. THE GOVERNMENT DID NOT TREAT THE VICTIMS UNFAIRLY Petitioners next claim the Government did not treat them with fairness, in violation of section ... resolving the federal investigation as it did through the NPA simply do not constitute unfair treatment of the victims and did not fail to respect the dignity and privacy

https://www.justice.gov/epstein/files/DataSet%209/EFTA00211718.pdf

EFTA00728161Set 9

2009-09-3019p6,423w

probative value substantially outweighs the danger of harm to any victim and of unfair prejudice to any party." 5. "The determination under such a balancing test is necessarily highly fact ... court suggested the probative value of such evidence outweighs the danger of damage or unfair prejudice. Id. Finally, the court observed that to allow plaintiff "to use these alleged experiences ... probative for the reasons stated above and there is no danger of harm or unfair prejudice to Jane Doe as the issue merely concerns her first sexual partner. The evidence

https://www.justice.gov/epstein/files/DataSet%209/EFTA00728161.pdf