…original memorandum in support of motion to dismiss; (ii) reply memorandum in support of motion to dismiss for lack of subject mater jurisdiction and (iii) motion to stay discovery pending resolution ofmotion to dismiss was appropriately made in conformity with…
…court below. They have nothing whatsoever to do with the federal government. In the August 21, 2008 order, Judge Marra granted the Jane Does' ore tenus motion seeking production of the NPA directly from the U.S. Attorney, but with…
…5 Entered on FLSD Docket 07/05/2013 Page 3 of 4 WHEREFORE, the United States respectfully requests that its Reply in Support of Its Motion to Dismiss for Lack of Subject Matter Jurisdiction be sealed. DATED: January 26, 2012 …
…STATE OF FLORIDA, Respondent. REPLY TO RESPONSES TO EMERGENCY PETITION FOR WRIT OF CERTIORARI AND RESPONSE TO E.W.'S MOTION TO DISIMISS PETITION FOR LACK OF JURISDICTION Petitioner, JEFFREY EPSTEIN, replies to the three separate responses filed by respondents…
…if you cannot get them to agree, we will charge you with fed crime with mandatory minimums. After the state jail sentence is complete, if one of our names brings litigation, should you file a motion to dismiss the litigation…
…agreed that on any action brought in the 2255, he 3 will admit to liability. 4 And I received on May 26 a motion to dismiss, which 5 we're prepared to respond to and disagree with, but totally 6 …
…to hold Mr. Epstein in breach of the Agreement in order to exact litigation concessions from Mr. Epstein that were never contemplated by the Agreement. =ln still another case, Mr. Epstein was forced to retract a legitimate motion to dismiss…
…trial court denied the motion for stay and imposed daily fines until the documents were U produced. a The First District Court of Appeals affirmed the trial court's order and noted Mariner has failed to explain bow the production…
…In Court File entered July 2, 2008 (Exhibit "B".) 3. The sealing of these documents was done without written motion required by Rule 2.420(d)(1) or notice to the public, the media, the record newspaper and the victims…
…non-prosecution agreement! Having now reviewed the non-prosecution agreement, the Government's response to the victims' motion and the accompanying sworn declaration are simply untrue. The above- quoted provision simply does not appear In the agreement anywhere. It is…
…Applicant stands to either gain or lose by the court's direct legal operation and effect ofjudgment in the pending matter. 3. Applicant is not injecting a new issue into the pending matter. 4. Applicant's motion to intervene is…
…J. Epstein Pages: 6 Urgent For review Please coTment U Please reffiltl Please =vale ❑ ❑ Please see attached Motion to Intervene and Petition for Amass …
…2009, at 9:00 a.m., at which time the Court will hear "Epstein's Motion to Stay Disclosure of Non-Prosecution Agreement and Addendum Pending Review". DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida this SIGNED…
…advising of the Petitioner's position on this motion. WHEREFORE, Respondent B.B. respectfully requests the Court supplement the record before the Court on Petitioner Epstein's petition for writ of certiorari with the attached letter to Respondent B.B…
…statute involved. N/A Please state in short form the anticioated issues raised. For example, on criminal issues: denial of motion for judgment of acquittal, denial of motion to suppress evidence, error In sentence; on civil issues, award of alimony…
…party making the request that the motion is being made in good faith and is supported by a sound factual and legal basis. 2. The records that are the subject of a Motion to Make Court Records Confidential will be…
…documents must be unsealed. As grounds for this Motion, the Post states: 1. The Post is a daily newspaper that has covered this matter and related proceedings. In an effort to inform its readers concerning these matters, the Post relies…
…ordered Mr. Epstein's attorney to file the documents under seal during his plea conference on June 30, 2008. 4. On June 25, 2009, Judge Colbath granted non-parties' motions to vacate the order sealing records and ordered them disclosed…
…16). CONCLUSION This Court should grant certiorari and quash the June 25, 2009 order granting non-parties' motions to unseal the confidential non-prosecution agreement and addendum between Mr. Epstein and the United States Attorney's Office. CERTIFICATION OF EXISTENCE…
…The court denied the motion, but stayed disclosure until noon on Thursday, July 2, so Mr. Epstein could seek emergency review of the denial in this Court (A-17). ARGUMENT Whether to grant a stay is discretionary with the trial…
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