This memorandum provides an overview of issues related to claims for punitive damages against Jeffrey Epstein. It outlines the legal framework for such claims in both state and federal courts, including pleading requirements, burden of proof, discovery of financial net worth, limitations on damages, and potential affirmative defenses. The memo also discusses jury instructions and mitigating factors that could influence the outcome of punitive damage claims.
documents/EFTA00727535.pdf
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