DataSet-9
EFTA00307096
25 pg
…coercion.
First, the allegations of coercion are unspecific and wholly conclusory, as exemplified by
the allegations in paragraph 48 that "Defendants Epstein and Maxwell intimidated, threatened,
humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance. These…
DataSet-9
EFTA01111399
14 pg
…alleges inter alia that Epstein invoked his Fifth Amendment right against self-
incrimination (¶6); notwithstanding Epstein's "intimidation" tactics, Edwards' clients have
continued to prosecute their claims (97); Edwards has not engaged in any unethical or improper
conduct (9 8)…
DataSet-9
EFTA01111344
13 pg
…Count I alleges inter alia that Epstein invoked his Fifth Amendment right against self-
incrimination (¶6); notwithstanding Epstein's "intimidation" tactics, Edwards' clients have
continued to prosecute their claims (97); Edwards has not engaged in any unethical or improper
conduct (…
DataSet-9
EFTA01111385
14 pg
…alleges inter alia that Epstein invoked his Fifth Amendment right against self-
incrimination (¶6); notwithstanding Epstein's "intimidation" tactics, Edwards' clients have
continued to prosecute their claims (97); Edwards has not engaged in any unethical or improper
conduct (9 8)…
DataSet-9
EFTA01111357
14 pg
…Count I alleges inter alia that Epstein invoked his Fifth Amendment right against self-
incrimination (¶6); notwithstanding Epstein's "intimidation" tactics, Edwards' clients have
continued to prosecute their claims (97); Edwards has not engaged in any unethical or improper
conduct (…
DataSet-9
EFTA01112592
14 pg
…Count I) and a claim for malicious prosecution (Count II).
Count 1 alleges inter alia that Epstein invoked his Fifth Amendment right against self-
incrimination (¶6); notwithstanding Epstein's "intimidation" tactics, Edwards' clients have
continued to prosecute their claims (¶7)…
DataSet-9
EFTA00158752
19 pg
…scheme involved recruiting young women and girls by making false
promises and using his wealth, power and threats to intimidate the females into submission to his
demands. This same pattern was repeated numerous times with numerous young women and
girls.…
DataSet-9
EFTA01108461
14 pg
…Count I alleges inter alia that Epstein invoked his Fifth Amendment right against self-
incrimination (¶6); notwithstanding Epstein's "intimidation" tactics, Edwards' clients have
continued to prosecute their claims (97); Edwards has not engaged in any unethical or improper
conduct (…
DataSet-9
EFTA00801525
19 pg
…the rest of the allegations in the
FAC. For example, Plaintiff asserts without any specific factual basis that there was a
"continued cover-up" involving attempts to "intimidate witnesses" and the "destruction of
documents and evidence." Opp. at 8. However…
DataSet-9
EFTA00583806
6 pg
…are relevant to this litigation or not. The
witness has no direct knowledge and will likely be intimidated or even feel obliged to search for
answers he cannot know if required to give testimony at this time.
18. This type…
DataSet-9
EFTA00145606
37 pg
…I was then
harassed and intimidated to repeatedly give the address where I was in hiding,
including my loved one contact details.
This made me very uncomfortable and even more frightened as Ghislaine appeared
by telephone for the deposition duration…
DataSet-9
EFTA00086375
143 pg
…truth about what happened at Epstein's house, the police
"; "I had been greatly intimidated, which is why I could not be truthful initially
and I wanted to end the threat of the possibility of "; and "I wanted to assist…
DataSet-9
EFTA00285477
14 pg
…coercion.
First, the allegations of coercion are unspecific and wholly conclusory, as exemplified by
the allegations in paragraph 45 that "Defendants Epstein and Maxwell intimidated, threatened,
humiliated and verbally abused Plaintiff in order to coerce her into sexual compliance. These…
DataSet-9
EFTA01111371
14 pg
…alleges inter alia that Epstein invoked his Fifth Amendment right against self-
incrimination (¶6); notwithstanding Epstein's "intimidation" tactics, Edwards' clients have
continued to prosecute their claims (97); Edwards has not engaged in any unethical or improper
conduct (9 8)…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…Litigation.” ...................14
2. Defendant’s Statements Are Outside The Scope Of The
“Pre-Litigation” Qualified Privilege Because They Were Made
To Bully, Harass, And Intimidate...................................................…
DataSet-9
EFTA01199129
2 pg
PalmBeachDailyNpm,c9rn Print this page Close
Claim: Epstein filed lawsuit to 'intimidate' attorney Edwards prosecuting sex abuse cases
By MICHELE DARGAN
DAILY NEWS STAFF WRITER
Updated: 8:21 p.m. Friday, Oct. 15. 2010
Posted: 8:04 p.m. Friday…
DataSet-10
EFTA01480957
1 pg
…A.5
LENGTH: 823 words
HEADLINE: Claim: Epstein filed lawsuit to 'intimidate' victims' attorney
BYLINE: MICHELE DARGAN Daily News Staff Writer
BODY:
Billionaire sex offender Jeffrey Epstein filed his 2009 lawsuit against attorney Brad Edwards in an effort to get…
DataSet-9
EFTA00808515
34 pg
…CASE AND FACTS 4-11
Background Facts 4
Epstein Attempts to Intimidate His Victims by Filing Suit Against and 5-11
Retaliates Against their Lawyer
ARGUMENT 12-26
…
DataSet-9
EFTA00294244
47 pg
…liability and to deter cooperation in the ongoing criminal investigation by employing the
extraordinary financial resources at his disposal to intimidate his victims and their legal counsel
into abandoning their legitimate claims or resolving those claims for substantially less than…
DataSet-9
EFTA01111289
6 pg
…had had engaged in any unethical or improper conduct
(1 8) and seeks damages for abuse of process based on allegations that Epstein "has filed the
claims herein against EDWARDS . . .for the sole purpose of further attempting to intimidate
EDWARDS . . …