EFTA01120533Set 9
2010-06-3029p8,593w
individually,
BRADLEY J. EDWARDS, individually, and
M, individually,
Defendant(s).
=tOUNTER-PLAINTIFF, EDWARDS' SECOND RENEWED MOTION FOR LEAVE TO
ASSERT CLAIM FOR PUNITIVE DAMAGES
Counter-plaintiff, BRADLEY J. EDWARDS, moves ... provide
relevant and material discovery;
EFTA01120533
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Second Renewed Motion for Leave to Assert Claim for Punitive Damages
4. was filed for the sole purpose ... assert punitive damages claim).
2
EFTA01120534
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Second Renewed Motion for Leave to Assert Claim for Punitive Damages
Section 768.72 provides for the amendment
https://www.justice.gov/epstein/files/DataSet%209/EFTA01120533.pdf
EFTA00089154Set 9
2020-12-0834p11,257w
GHISLAINE MAXWELL,
Defendant.
x
THE GOVERNMENT'S MEMORANDUM IN OPPOSITION
TO THE DEFENDANT'S RENEWED MOTION FOR RELEASE
AUDREY STRAUSS
Acting United States Attorney
Southern District of New York
Attorney ... GHISLAINE MAXWELL,
Defendant.
x
THE GOVERNMENT'S MEMORANDUM IN OPPOSITION
TO THE DEFENDANT'S RENEWED MOTION FOR RELEASE
The Government respectfully submits this memorandum in opposition to the defendant ... renewed motion for release on bail, dated December 8, 2020 (the "Renewed Bail Motion"). Five
months ago, after thorough briefing and a nearly two-hour hearing, this Court concluded that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00089154.pdf
EFTA00086915Set 9
2020-07-1422p6,908w
would
ensure her appearance. Bail was therefore denied.
The Defendant has now filed a renewed motion for release on bail pending trial, which
the Government opposes. In her renewed motion ... first motion for release on July 14, 2020, the Court DENIES the
Defendant's renewed motion for release on bail.'
I. Background
On June 29, 2020, a grand jury ... decision to detain the defendant until trial).
III. Discussion
The Defendant bases her renewed motion for bail on both 18 U.S.C. § 3142(0 and the
Court's inherent powers
https://www.justice.gov/epstein/files/DataSet%209/EFTA00086915.pdf
EFTA00096519Set 9
2021-05-1734p6,320w
INFORMATION STATEMENT
Docket Number(s): 21-770/21-58 Caption [use short Ski
Motion for: Renewed Motion for Pretrial Release
Set forth below precise. complete statement of relief sought:
Ghislaine Maxwell ... Southern District of New York, 20-CR-330 (AJN)
Appellant Ghislaine Maxwell's Renewed
Motion for Pretrial Release
Leah S. Saffian David Oscar Markus
LAW OFFICES OF LEAH SAFFIAN *Counsel ... Document 89-1, 05/17/2021, 3102450, Page3 of 14
Appellant Ghislaine Maxwell's Renewed Motion for Bond
Although this Court denied Ghislaine Maxwell's motion for bond
(see Ex. A, Order
https://www.justice.gov/epstein/files/DataSet%209/EFTA00096519.pdf
EFTA00089451Set 9
2021-04-2714p2,551w
INFORMATION STATEMENT
Docket Number(s): 21-770/21-58 Caption luse short Mk].
Motion for. Renewed Motion for Pretrial Release
Set forth below precise. complete statement of relef sought:
Ghislaine Maxwell ... Southern District of New York, 20-CR-330 (AJN)
Appellant Ghislaine Maxwell's Renewed
Motion for Pretrial Release
Leah S. Saffian David Oscar Markus
LAW OFFICES OF LEAH SAFFIAN *Counsel ... Record
ME- markuslaw.com
EFTA00089452
Appellant Ghislaine Maxwell's Renewed Motion for Bond
Although this Court denied Ghislaine Maxwell's motion for bond
(see Ex. A, Order, April
https://www.justice.gov/epstein/files/DataSet%209/EFTA00089451.pdf
EFTA01147824Set 9
2010-04-128p1,819w
this Motion as Exhibit 1.
10. On November 11, 2011, Edwards filed his Renewed Motion for Summary
Judgment and a lengthy Statement of Undisputed Facts in which he purported ... Edwards relying on communications with the government and
reporters as part of his Renewed Motion for Summary Judgment and to support his contention
that Epstein has waived his Fifth Amendment ... burdensome. The request is relevant and necessary in order for Epstein to defend Edwards'
Renewed Motion for Summary Judgment, including Edwards' contention that Epstein has
waived his Fifth Amendment rights
https://www.justice.gov/epstein/files/DataSet%209/EFTA01147824.pdf
EFTA01147724Set 9
2010-04-128p1,829w
this Motion as Exhibit 1.
10. On November 11, 2011, Edwards filed his Renewed Motion for Summary
Judgment and a lengthy Statement of Undisputed Facts in which he purported ... Edwards relying on communications with the government and
reporters as part of his Renewed Motion for Summary Judgment and to support his contention
that Epstein has waived his Fifth Amendment ... burdensome. The request is relevant and necessary in order for Epstein to defend Edwards'
Renewed Motion for Summary Judgment, including Edwards' contention that Epstein has
waived his Fifth Amendment rights
https://www.justice.gov/epstein/files/DataSet%209/EFTA01147724.pdf
EFTA00619553Set 9
2015-07-074p993w
SCOTT ISRAEL,
Defendants.
ORDER STAYING CASE
THIS CAUSE is before the Court upon Defendants' Renewed Motion to Stay
Proceedings [DE 46] ("Motion"). The Court has reviewed the Motion, Plaintiff ... death of Jermaine McBean. See DE 46-1. Subsequently, Defendants
filed their Renewed Motion to Stay Proceedings, asserting that "special circumstances"
now exist to warrant a stay of the instant ... criminal proceeding.
It is accordingly
ORDERED AND ADJUDGED as follows:
1. Defendants' Renewed Motion to Stay Proceedings [DE 46] is GRANTED.
3
EFTA00619555
Case 0:15-cv-60968-JIC Document
https://www.justice.gov/epstein/files/DataSet%209/EFTA00619553.pdf
EFTA01734801Set 10
2016-09-068p2,140w
GIUFFRE,
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
X
DEFENDANT'S RENEWED MOTION TO COMPEL SETTLEMENT AGREEMENT
Laura A. Menninger
Jeffrey S. Pagliuca
HADDON, MORGAN, AND FOREMAN ... Ghislaine Maxwell ("Ms. Maxwell"), pursuant to Fed. R. Civ. P. 37(aX3),
files this Renewed Motion to Compel Settlement Agreement regarding the confidential
settlement agreement between Plaintiff and Jeffery Epstein ... SERVICE
I certify that on September 6, 2016, I electronically served this Defendant's Renewed
Motion to Compel Settlement Agreement via ECF on the following:
Sigrid S. McCawley Paul
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01734801.pdf
EFTA00030910Set 8
2020-11-252p520w
filed a letter request
seeking an in camera conference for the presentation of a renewed motion for release on bail and
a request to seal the November 25, 2020 letter ... confer and to jointly prepare a briefing
schedule for the Defendant's forthcoming renewed motion for release on bail.
SO ORDERED.
Dated: December 3, 2020
Asts.gek
New York, New York
https://www.justice.gov/epstein/files/DataSet%208/EFTA00030910.pdf