EFTA00285477Set 9
2017-05-1514p6,372w
permits knowledge to be averred generally, we have
repeatedly required plaintiffs to plead the factual basis which gives rise to
a strong inference of fraudulent intent. Essentially, while Rule ... license to base claims of fraud on speculation and conclusory
allegations. An ample factual basis must be supplied to support the
charges.
Wood v. Research Applied Associates, 328 Fed.Appx ... performance of a party's representations").
Finally, the Complaint fails to provide a factual basis, let alone an "ample factual basis,"
that would give rise to a "strong inference
https://www.justice.gov/epstein/files/DataSet%209/EFTA00285477.pdf
EFTA00801426Set 9
2011-04-1434p9,651w
permits knowledge to be averred generally, we have
repeatedly required plaintiffs to plead the factual basis which gives rise to
9
EFTA00801438
FILED UNDER SEAL
a strong inference of fraudulent ... license to base claims of fraud on speculation and conclusory
allegations. An ample factual basis must be supplied to support the
charges.
Wood y. Research Applied Associates ... grounds for a fraud action").
Finally, the FAC fails to provide any factual basis, let alone an "ample factual basis," that
would give rise to the "strong inference of fraudulent
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801426.pdf
EFTA00039227Set 9
2009-12-0455p17,333w
hearing report, their finding
as to the reliability of each confidential informant and the factual basis for that finding. If
the report would reveal the confidential informant's identity, this ... report, their finding as to the reliability of each informant and its factual basis. The
report must identify specific information relied on and the factual basis for that reliance.
When ... prepares a separate report documenting the findings of the reliability of each informant, their
factual basis, the information relied on, and the factual basis for that reliance. This separate
report
https://www.justice.gov/epstein/files/DataSet%209/EFTA00039227.pdf
EFTA00298455Set 9
2017-04-0610p4,709w
permits knowledge to be averred generally, we have
repeatedly required plaintiffs to plead the factual basis which gives rise to
a strong inference of fraudulent intent. Essentially, while Rule ... license to base claims of fraud on speculation and conclusory
allegations. An ample factual basis must be supplied to support the
charges.
Wood v. Research Applied Associates, 328 Fed.Appx ... performance of a party's representations").
Finally, the Complaint fails to provide a factual basis, let alone a "ample factual basis,"
that would give rise to a "strong inference
https://www.justice.gov/epstein/files/DataSet%209/EFTA00298455.pdf
EFTA00307096Set 9
2017-01-2625p7,457w
permits knowledge to be averred generally, we have
repeatedly required plaintiffs to plead the factual basis which gives rise to
a strong inference of fraudulent intent. Essentially, while Rule ... license to base claims of fraud on speculation and conclusory
allegations. An ample factual basis must be supplied to support the
charges.
4
EFTA00307101
Wood v. Research Applied Associates ... performance of a party's representations").
Finally, the FAC fails to provide a factual basis, let alone an "ample factual basis," that
would give rise to the "strong inference
https://www.justice.gov/epstein/files/DataSet%209/EFTA00307096.pdf
Admission #1 is anything other than an unqualified
admission, please state in detail the factual basis for your denial.
2. If your answer to Request for Admission #2 is anything ... other than an unqualified
admission, please state in detail the factual basis for your denial.
3, If your answer to Request for Admission #3 is anything other than an unqualified ... admission, please state in detail the factual basis for your denial.
Page 2 of 4
EFTA00723779
4. If your answer to Request for Admission #4 is anything other than
https://www.justice.gov/epstein/files/DataSet%209/EFTA00723778.pdf
EFTA00224742Set 9
2007-12-0617p1,018w
Thursday, December 06, 2007 3:05 PM
Subject: Epstein
Could you please outline what factual basis you think fits the procuring statute
for the plea conference. I am trying ... Thursday, December 06, 2007 3:05 PM
Subject: Epstein
Could you please outline what factual basis you think fits the procuring statute
for the plea conference. I am trying ... Sent: Thursday. December 06 7007105 PM
• Sulfect: Epstein
Could you please outline what factual basis you think fits the procuring statute for the plea
conference. I am trying to
finalize
https://www.justice.gov/epstein/files/DataSet%209/EFTA00224742.pdf
EFTA00724269Set 9
5p3,674w
however, there is no 14 Counter-Defendant relies upon and has cited to
15 factual basis and no legal basis for the filing 15 the Court.
16 of a cause ... says more
2 than that. He says there is no, absolutely no
3 factual basis for it therefore there can be no
4 legitimate purpose for it.
5 MR. CRITTON ... circumstances, every case would be is
10 there is really no factual basis for it under
11 those circumstances.
12 THE COURT: I'm not sure. I will go back
https://www.justice.gov/epstein/files/DataSet%209/EFTA00724269.pdf
EFTA00614554Set 9
5p3,653w
however, there is no 14 Counter-Defendant relies upon and has cited to
15 factual basis and no legal basis for the filing 15 the Court.
16 of a cause ... says more
2 than that. He says there is no, absolutely no
3 factual basis for it therefore there can be no
4 legitimate purpose for it.
5 MR. CRITTON ... circumstances, every case would be is
10 there is really no factual basis for it under
11 those circumstances.
12 THE COURT: I'm not sure. I will go back
https://www.justice.gov/epstein/files/DataSet%209/EFTA00614554.pdf
EFTA00613391Set 9
2016-02-0150p13,597w
signed and filed the Joinder Motion, Edwards and
Cassell knew that there was no factual basis for alleging that Dershowitz abused
Alternatively, at the time they drafted, signed and filed ... signed and filed the Joinder Motion, Edwards and
Cassell knew that there was no factual basis for the allegations that Dershowitz abused "other
minors" or witnessed the abuse of "other ... effectively conceded — by
way of deposition testimony showing the total lack of any reasonable factual basis for the
allegations — that the attorneys had no reasonable evidentiary basis to support
https://www.justice.gov/epstein/files/DataSet%209/EFTA00613391.pdf
EFTA00095871Set 9
2019-07-1146p15,250w
being activity on an airplane, I just wanted to make sure that there is factual
basis for the plea that the agents can confirm"), Dkt. 361-9 (prosecutor stating ... know the
factual basis for the alleged [redacted] because we have no independent evidence of that"). In
short, these were suggested hypotheses not facts, and the government itself ultimately ... there was factual support for the allegations. They do not provide a sufficiently reliable
factual basis for any finding by clear and convincing evidence. As to the suggestion
https://www.justice.gov/epstein/files/DataSet%209/EFTA00095871.pdf
EFTA00058429Set 9
2019-07-1116p7,359w
being activity on an airplane, I just wanted to make sure that there is factual
basis for the plea that the agents can confirm"), Dkt. 361-9 (prosecutor stating ... know the
factual basis for the alleged [redacted] because we have no independent evidence of that"). In
short, these were suggested hypotheses not facts, and the government itself ultimately ... there was factual support for the allegations. They do not provide a sufficiently reliable
factual basis for any finding by clear and convincing evidence. As to the suggestion
https://www.justice.gov/epstein/files/DataSet%209/EFTA00058429.pdf
EFTA00097460Set 9
2019-07-1116p7,359w
being activity on an airplane, I just wanted to make sure that there is factual
basis for the plea that the agents can confirm"), Dkt. 361-9 (prosecutor stating ... know the
factual basis for the alleged [redacted] because we have no independent evidence of that"). In
short, these were suggested hypotheses not facts, and the government itself ultimately ... there was factual support for the allegations. They do not provide a sufficiently reliable
factual basis for any finding by clear and convincing evidence. As to the suggestion
https://www.justice.gov/epstein/files/DataSet%209/EFTA00097460.pdf
EFTA00233059Set 9
2007-09-14118p32,226w
being
activity on an airplane, I just want to make sure that there is factual basis for the plea
that the agents can confirm.
I'm not sure exactly where ... address the crimes that we were addressing, and
still doesn't like the factual basis. In his opinion, the plea should only
we were not investigating Mr. Epstein abusing ... being
activity on an airplane, I just want to make sure that there is factual basis for the plea
that the agents can confirm.
I'm not sure exactly where
https://www.justice.gov/epstein/files/DataSet%209/EFTA00233059.pdf