EFTA00285631Set 9
2018-08-0770p17,816w
Jeffery
16 Epstein, and
17 Your Honor, we respectfully submit that the amended
18 complaint before you is legally deficient and should be
19 dismissed for several reasons, the first ... timely. Our belief is that the statute of
21 limitations has lapsed.
22 The amended complaint also fails, your Honor, to
23 properly allege fraud, coercion or force, which ... timely fashion.
21 In late 2008, effective early 2009, Section 1591 was
22 amended to permit a ten year statute of limitations. And I
23 think the preliminary, the threshold
https://www.justice.gov/epstein/files/DataSet%209/EFTA00285631.pdf
EFTA00073205Set 9
2020-09-0155p15,254w
POPLAR, INC., SOUTHERN TRUST
COMPANY, INC.; JOHN AND JANE DOES
DEFENDANTS,
FIRST AMENDED COMPLAINT
COMES NOW, the Government of the United States Virgin Islands ("Government") and
files this First Amended ... 09/01/20 Page 3 of 55
GVI v. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 2 of 55
2. This Court has subject matter jurisdiction over this civil ... 09/01/20 Page 4 of 55
GVI v. Estate of Jeffrey Epstein
GVI's First Amended Complaint
Page 3 of 55
Petition for Probate and Letters Testamentary which included Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00073205.pdf
EFTA01440323Set 10
2018-04-11132p33,160w
GLDUS138 Ian Slome
Execution Version
Proprietary and Confidential
AMENDED AND RESTATED LIMITED PARTNERSHIP AGREEMENT
OF
GLENDOWER ACCESS SECONDARY OPPORTUNITIES IV (U.S.), L.P.
(A Delaware Limited Partnership)
Dated as of April ... INTERESTS") OF GLENDOWER ACCESS
SECONDARY OPPORTUNITIES IV (U.S.), L.P. (THE "PARTNERSHIP") REPRESENTED BY
THIS
AMENDED AND RESTATED LIMITED PARTNERSHIP AGREEMENT HAVE NOT BEEN
REGISTERED UNDER THE SECURITIES ... AMENDED (THE "SECURITIES
ACT"),
THE SECURITIES LAWS OF ANY STATE OR ANY OTHER APPLICABLE SECURITIES LAWS, IN
RELIANCE UPON EXEMPTIONS FROM THE REGISTRATION REQUIREMENTS OF THE
SECURITIES ACT AND SUCH
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01440323.pdf
EFTA01445643Set 10
2018-04-11132p33,159w
GLDUS140 Lawrence Hirsch
Execution Version
Proprietary and Confidential
AMENDED AND RESTATED LIMITED PARTNERSHIP AGREEMENT
OF
GLENDOWER ACCESS SECONDARY OPPORTUNITIES IV (U.S.), L.P.
(A Delaware Limited Partnership)
Dated as of April ... INTERESTS") OF GLENDOWER ACCESS
SECONDARY OPPORTUNITIES IV (U.S.), L.P. (THE "PARTNERSHIP") REPRESENTED BY
THIS
AMENDED AND RESTATED LIMITED PARTNERSHIP AGREEMENT HAVE NOT BEEN
REGISTERED UNDER THE SECURITIES ... AMENDED (THE "SECURITIES
ACT"),
THE SECURITIES LAWS OF ANY STATE OR ANY OTHER APPLICABLE SECURITIES LAWS, IN
RELIANCE UPON EXEMPTIONS FROM THE REGISTRATION REQUIREMENTS OF THE
SECURITIES ACT AND SUCH
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01445643.pdf
EFTA01103222Set 9
2013-04-2239p9,054w
motion to overrule all
9 claims of privilege other than claims of Fifth
10 Amendment privilege and to impose sanctions.
11 We also served I believe at that same time ... than privilege and
13 required a privilege log, except as to the
14 Fifth Amendment privilege assertions, within
15 15 days.
16 On March 20, 2013 we filed a notice ... that basis alone all of
12 these objections, other than the Fifth
13 Amendment privilege objections, can be
14 overruled. However, we are prepared today to
15 deal with those
https://www.justice.gov/epstein/files/DataSet%209/EFTA01103222.pdf
EFTA01103207Set 9
2013-04-2215p9,025w
claims of privilege other than claims of Fifth
West Palm Beach. Florida 33401 0 Amendment privilege and to impose sanctions.
10
1 We also served I believe at that same ... than the Fifth
13 to see any of the motions or the orders. 13 Amendment privilege objections, can be
14 THE COURT: No, I don't need to see them ... other than the Fifth
25 On March 4, 2013 a response to that ,.5 Amendment privilege and we filed our Rule
6 8
1 motion to strike was filed
https://www.justice.gov/epstein/files/DataSet%209/EFTA01103207.pdf
EFTA00292075Set 9
2012-09-1710p2,114w
RESOLUTIONS APPROVED BY
THE BOARD OF DIRECTORS OF
ALIPHCOM
SEPTEMBER 17, 2012
APPROVAL OF AMENDMENT TO SIXTH AMENDED AND RESTATED INVESTOR RIGHTS AGREEMENT
AND WAIVER OF NOTICE AND PARTICIPATION RIGHTS ... WHEREAS, the Company and certain Investors entered into the Sixth Amended
and Restated Investor Rights Agreement, dated June 16, 2011 (the "IRA") in connection
with the initial closing ... WHEREAS, the Board believes it is in the best interests of the Company to amend
the IRA to (i) include the Common Stock purchased and expected to be purchased
https://www.justice.gov/epstein/files/DataSet%209/EFTA00292075.pdf
EFTA01204470Set 9
2014-03-0530p10,376w
EXECUTION VERSION
SECOND AMENDED AND RESTATED EXCHANGE AGREEMENT
SECOND AMENDED AND RESTATED EXCHANGE AGREEMENT (the
"Agreement"), dated as of March 5, 2014, among Apollo Global Management, LLC, a Delaware
limited ... Apollo Principal Holdings IX, L.P. and AMH
Holdings (Cayman), L.P. entered into that certain Amended and Restated Exchange Agreement
dated as of May 6, 2013 (the "Amended & Restated Exchange Agreement ... desire to
enter into this Agreement to amend and restate the Amended & Restated Exchange Agreement in
its entirety as more fully set forth below;
NOW, THEREFORE, in consideration
https://www.justice.gov/epstein/files/DataSet%209/EFTA01204470.pdf
EFTA01107917Set 9
2009-10-1618p5,322w
provide the requested
information, because it is not properly subject to a Fifth Amendment invocation.
SPECIFIC REQUESTS FOR PRODUCTION
Request No. 5.
Jane Doe withdraws this request.
Requests ... this lawsuit and I must
accept this advice or risk losing my Sixth Amendment right to effective
representation. Accordingly, I assert my federal constitutional rights under
the Fifth, Sixth ... Fourteenth Amendments as guaranteed by the United
States Constitution. Drawing an adverse inference under these
circumstances would unconstitutionally burden my exercise of my
constitutional rights, would be unreasonable, and would
https://www.justice.gov/epstein/files/DataSet%209/EFTA01107917.pdf
EFTA00317211Set 9
2010-02-0437p13,297w
support, Epstein states:
L Introduction
The Fifth Amendment serves as a guarantee against testimonial compulsion and provides,
in relevant part, that "[n]o person...shall be compelled in any Criminal ... Page No. 3
Moreover, in addition to the testimonial privilege discussed herein, the Fifth Amendment
includes an act of production which encompasses circumstances highly relevant to certain of
the discovery ... producing responsive documents is considered testimonial
and is protected by the Fifth Amendment. See In re Grand Jury Subpoena, 1 F.3d 87, 93 (2nd
Cir. 1993); Rudy-Glanzer v. Glanzer
https://www.justice.gov/epstein/files/DataSet%209/EFTA00317211.pdf
EFTA01099943Set 9
2006-07-2632p10,791w
claim brought pursuant to §2255 in Count III of the Second Amended Complaint
[D.E. 50]; (2) Plaintiff has failed to and cannot establish a predicate act — under 18 U.S.C ... U.S.C. §2255, which she attempts to assert in Count III of her Second
Amended Complaint [D.E. 50). In particular, the undisputed material facts show that
Plaintiff has failed ... Loc.Gen.Rule 73
Statement of the Case
1. Plaintiff JANE DOE NO. 3's Second Amended Complaint [D.E. 50), dated
February 27, 2009, attempts to assert three causes of action. Count
https://www.justice.gov/epstein/files/DataSet%209/EFTA01099943.pdf
EFTA01100005Set 9
2006-07-2643p14,726w
claim brought pursuant to §2255 in Count III of the Amended Complaint [D.E. 19];
(2) Plaintiff has failed to and cannot establish a predicate act — under 18 U.S.C ... under 18 U.S.C. §2255, which she attempts to assert in Count III of her
Amended Complaint [D.E. 19]. In particular, the undisputed material facts show that
Plaintiff has failed ... Marra-Johnson
Page 3
1. Plaintiff JANE DOE NO, 7's Amended Complaint [D.E. 19), dated February 27,
2009, attempts to assert three causes of action. Count I and Count
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100005.pdf
EFTA01269548Set 10
50p16,341w
Company duly organized and existing under the laws of the United States Virgin Islands
amended its Articles of Organization to reflect a change of name from LSJ Employees ... CONFIDENTIAL FirstBankPR000915
EFTA_00124395
EFTA01269562
Superseding-Current-Reason
ItCS5 t43°
Date: Initial'
CERTIFICATE OF AMENDMENT
TO ARTICLES OF ORGANIZATION
OF
LSJ EMPLOYEES, LLC
LSJ EMPLOYEES, LLC, a limited liability company ... United States Virgin Islands (the "Company'),
DOES HEREBY CERTIFY that the following Amendment to the Company's Articles of
Organization has been duly adopted in accordance with the provisions
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01269548.pdf
EFTA00621816Set 9
2011-03-3122p5,969w
COURT: Let me ask one question right there.
12 Has there been an amended complaint filed as of yet or not
13 because there was discussion about that ... ACKERMAN: Your Honor, I have amended and
15 taken out all the allegations --
16 THE COURT: I just want to know, has there been
17 an amended complaint filed ... ACKERMAN: No, but I have amended the present
19 complaint.
20 MR. SCAROLA: There has been an amendment to the
21 complaint filed.
22 THE COURT: I really
https://www.justice.gov/epstein/files/DataSet%209/EFTA00621816.pdf
EFTA00221256Set 9
2009-06-094p706w
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
DEFENDANT EPSTEIN'S UNOPPOSED FIRST MOTION TO AMEND
AFFIRMATIVE DEFENSES TO PLAINTIFF'S SECOND AMENDED COMPLAINT
Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through ... undersigned attorneys, moves to amend his affirmative defenses as set forth in the
attached Defendant EPSTEIN's First Amended Answer & Affirmative Defenses to
Plaintiffs Second Amended Complaint, attached hereto ... Pursuant to Rule 15(a)(2), Fed.R.Civ.P., a party may amend his pleading "only
with the opposing party's written consent or the court's leave. The court should
https://www.justice.gov/epstein/files/DataSet%209/EFTA00221256.pdf
EFTA00080555Set 9
20p5,370w
YORK
In re: Second Warrant and Order For
Prospective and Historical Location AMENDED APPLICATION
Information and Pen Register
Information for the Cell hone Assigned Mag.
Call Number , USAO
Reference ... 2018R01618
Amended Application for Second Warrant and Order
for Cellphone Location and Pen Register Information
The United States of America, by its attorney, Audrey Strauss, Acting United States
Attorney ... historical location information and pen register information
for a cellphone. As grounds for this Amended Application the Government relies on the following
facts and authorities.
I. Introduction
https://www.justice.gov/epstein/files/DataSet%209/EFTA00080555.pdf
EFTA00091719Set 9
20p5,345w
YORK
In re: Second Warrant and Order For
Prospective and Historical Location AMENDED APPLICATION
Information and Pen Register
Information for the Cellphone Assigned Mag.
Call Number 978-525-8484, USAO ... Reference No. 2018R01618
Amended Application for Second Warrant and Order
for Cellphone Location and Pen Register Information
The United States of America, by its attorney, Audrey Strauss, Acting United States ... historical location information and pen register information
for a cellphone. As grounds for this Amended Application the Government relies on the following
facts and authorities.
I. Introduction
https://www.justice.gov/epstein/files/DataSet%209/EFTA00091719.pdf