DataSet-9
EFTA00728644
2 pg
…FOR JUDGMENT ON TIFF. PLEADINGS OR
ALTERNATIVE MOTION FOR SUMMARY JUDGMENT ON EDWARDS'
COUNTERCLAIM FOR ABUSE OF PROCESS
THIS CAUSE having come to be considered upon EPSTEIN'S MOTION FOR
JUDGMENT ON THE PLEADINGS OR ALTERNATIVE MOTION FOR SUMMARY
JUDGMENT…
DataSet-9
EFTA00600007
3 pg
…up to and
including May 2. The victims also request that they receive 50% of the number of pages that the
Government used to respond to their summary judgment motion, a total of 27 pages.
For the convenience of the…
DataSet-9
EFTA00619909
3 pg
…Counter-Defendant, JEFFREY EPSTEIN (EPSTEIN), moved for summary
judgment on the claims asserted against him and the Court expressed its intention to grant
Epstein's Motion.
2. Counter-plaintiff EDWARDS filed an extensive Motion for Reconsideration on
February 6, 2014…
DataSet-9
EFTA01186127
2 pg
…JANE DOE #2, by though undersigned counsel hereby file
the attached additional exhibits to their Consolidated Statement of Undisputed Material Facts and
Motion for Partial Summary Judgment with Incorporated Memorandum of Law filed on February
10, 2016 as DE 361…
DataSet-9
EFTA00207876
3 pg
…Dear
1. Thank you for the information sent today.
2. What is the Government's position on the page limits applicable to our "summary judgment" pleading —
do you believe we are under the civil rules? Or under the criminal rules?…
DataSet-9
EFTA00207923
4 pg
…the extra time. What about extra pages? We anticipate that we will need 27 pages to
reply to your 53 page response to our "summary judgment" motion — thanks for lettings us know your position. Paul
Paul G. Cassell
Ronald N…
DataSet-9
EFTA00710841
3 pg
…West Palm Beach, FL 33401
ROOM #: 9-C
SP C1FIC MATTERS TO BE HEARD:
MOTION FOR A STAY OF SUBPOENA PENDING RULING ON PREVI USLY-FILED
MOTION FOR SUMMARY JUDGMENT, FOR A PROTECTIVE ORDER AND FOR
SCHEDULING ORDER ON CREATING…
DataSet-9
EFTA00210525
4 pg
…2015 to May 28, for the government to respond to the
supplemental request for production and request for admissions. I have a summary judgment due on May 15, which is
consuming much of my time. I understand from Ed that…
DataSet-9
EFTA00212695
3 pg
…Dear
1. Thank you for the information sent today.
2. What is the Government's position on the page limits applicable to our "summary judgment" pleading —
do you believe we are under the civil rules? Or under the criminal rules?…
DataSet-9
EFTA00211140
5 pg
…however, the Court has ordered discovery to develop the
factual record concerning the summary judgment motion (DE 99 at 11). The Court reserved
ruling on the victims' motion for an order directing the Government not to suppress relevant
evidence (DE…
DataSet-9
EFTA00607331
4 pg
…EPSTEIN
Case No.: 502009CA040800XXXXMBAG
Page 2 of 4
Motion to Strike Epstein's Motion for Summary Judgment
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
to all Counsel on the attached…
DataSet-9
EFTA00799857
5 pg
…Rights Act. Because of the complexity
of the case, the Court granted the victims leave to file a single, sixty-page motion for summary
judgment, which included 157 separate assertions of material fact. DE 361 at 8-47. In response…
DataSet-9
EFTA00724355
3 pg
…Counter-defendant,
JEFFREY EPSTEIN, and in support thereof would show that the record evidence presented to
the Court in support of Edwards' Motion for Summary Judgment satisfies the statutory
pre uisites for the assertion of a punitive damage claim. Specifically…
DataSet-9
EFTA00607083
4 pg
…80743
Dear Jeffrey:
Enclosed please find the Order on Status Conference held March 6, 2012 regarding
Counter-Plaintiff/Defendanfs Motion for Summary Judgment The hearing on same has been re-
scheduled for July 27, 2012 at 8:30 a.m.…
DataSet-9
EFTA00610172
4 pg
…
EFTA00610172
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Order Setting Hearing on Epstein's Motion for Summary Judgment
4) Any materials submitted arc due at least 7 days prior to the hearing; and 5) The
moving party is required to bring…
DataSet-9
EFTA01179433
5 pg
…filed
a Counterclaim against Mr. EPSTEIN. After many months of litigation and on the eve of a
heating on Mr. Edwards' Motion for Summary Judgment, Mr. EPSTEIN dismissed his Complaint
without prejudice. The Counterclaim proceeded and went through several amendments…
DataSet-9
EFTA01112638
6 pg
…through his undersigned counsel,
moves this Honorable Court to permit the filing of the accompanying Amendment to the Third
Amended Counterclaim and in support thereof would show that on the eve of the summary
judgment hearing scheduled to address Plaintiff…
DataSet-9
EFTA01205212
3 pg
…in support would show:
1. Epstein claims fees pursuant to the rejection by Edwards of Epstein's proposal for
settlement and the subsequent entry of Summary Judgment in favor of Epstein.
2. The Court has ordered mediation in this matter…
DataSet-9
EFTA00592978
5 pg
…the foregoing Notice of Filing Exhibits in
Support of Opposition to Petitioners' Motion for Partial Summary Judgment, and Respondent's
Cross-Motion for Summary Judgment was filed with the Clerk of the Court and served on counsel
on the attached…
DataSet-9
EFTA00589816
6 pg
…through his undersigned counsel,
moves this Honorable Court to permit the filing of the accompanying Amendment to the Third
Amended Counterclaim and in support thereof would show that on the eve of the summary
judgment hearing scheduled to address Plaintiff…