DataSet-9
EFTA00234914
8 pg
…appear. The undersigned's supervisor,-, agreed with Mr. Black that
would not have to produce the disputed items if the motion was filed. It is understandable that
this could have been interpreted as an excuse from appearing, as well, and…
DataSet-9
EFTA00211802
4 pg
…Black that Mr. Riley would not have to appear and produce the disputed items if a motion to quash
all aspects of the subpoenas was filed. Neither party's pleading has asserted that the subpoenas should be
quashed as to…
DataSet-9
EFTA00206831
2 pg
…previous e-mails, we stand ready to work with you to try and narrow the range of
disputed facts — and trust that you will be willing to stipulate to all the facts that are correct in our pleadings. (Most of…
DataSet-9
EFTA00214014
2 pg
…filed quickly as well without any delay.
3. You have previously promised to review our statement of facts and tell us which facts are being disputed — and to
work with us to narrow the range of disputes. As you know…
DataSet-9
EFTA00206833
2 pg
…previous e-mails, we stand ready to work with you to try and narrow the range of
disputed facts — and trust that you will be willing to stipulate to all the facts that are correct in our pleadings. (Most of…
DataSet-9
EFTA00206714
2 pg
…agree to a factual assertion if we believe it is correct.
Insofar as your proposal to resolve the case, if there are disputed facts, the government does not agree to an evidentiary
hearing on the facts disputed by the government…
DataSet-9
EFTA00206762
2 pg
…previous e-mails, we stand ready to work with you to try and narrow the range of
disputed facts — and trust that you will be willing to stipulate to all the facts that are correct in our pleadings. (Most of…
DataSet-9
EFTA01139610
11 pg
…seal.
Second, Epstein misunderstands the compelling need that the victims have for those
materials. The materials all relate directly to important and disputed issues in this case.
Third, at a minimum, Epstein's motion should not be granted at this…
DataSet-9
EFTA00214003
2 pg
…agree to a factual assertion if we believe it is correct.
Insofar as your proposal to resolve the case, if there are disputed facts, the government does not agree to an evidentiary
hearing on the facts disputed by the government…
DataSet-9
EFTA01190883
12 pg
…GOVERNMENT'S PRIVILEGE LOG IS GROSSLY INADEQUATE.
In their opening pleading, the victims explained that the Government has substantially
violated the Court's order to provide an appropriately detailed privilege log for the disputed
documents. DE 265 at 1-2…
DataSet-9
EFTA00805389
18 pg
…FILED UNDER SEAL
EFTA00805389
TABLE OF CONTENTS
PRELIMINARY STATEMENT 1
BACKGROUND 3
A. The Jane D…
DataSet-9
EFTA00718009
3 pg
…is not a binding commitment, or even an offer, to
settle any dispute on the terms listed herein. Further advice as to ethical and other considerations would
be secured before proceeding with a possible settlement. It is understood that this…
DataSet-9
EFTA00857996
2 pg
…none of which were able to be disputed at a
hearing — and now an affidavit she is afraid of Alan — and when its time for someone to question her they move to
quash
I think Kendall might have the relationships…
DataSet-9
EFTA00206864
7 pg
…stand ready to promptly provide whatever pleading or
motion the Court believes is appropriate to resolve this case quickly. The victims' motion also
asks for an evidentiary hearing if the facts are disputed by the U.S. Attorney's Office…
DataSet-9
EFTA00845556
4 pg
…It is not a binding commitment, or even an
offer, to settle any dispute on the terms listed herein. Further advice as to ethical and other
considerations would be secured before proceeding with a possible settlement. It is understood that
…
DataSet-9
EFTA00210743
4 pg
…public record. The relief we seek is temporary, to maintain the status
quo until the Court has determined that the balance weighs in favor of unsealing a letter relating
to an issue being disputed in good faith. FTC, Abbvie Prod…
DataSet-9
EFTA01157357
9 pg
…nature of summary judgment motion (with a proposed set of undisputed facts), although
the exact procedures for CVRA cases are unclear.
In an effort to narrow and resolve disputes in this case, the victims had previously
notified the U.S…
DataSet-9
EFTA00211160
2 pg
…2016.
6. In the event the Court finds that a disputed issue of fact precludes the granting of
EFTA00211160
summary judgment, the Court will schedule an evidentiary hearing at a later date.
DONE AND ORDERED in chamb…
DataSet-9
EFTA00585747
8 pg
…Fifth Amendment privileges; instead, they had actual substantive
EFTA00585747
testimony to give regarding the disputed issues in the case. There is absolutely nothing to be
gained by either party from the jury's
ability to observe Mr.…
DataSet-9
EFTA00618173
2 pg
…5. In the event the Court finds that a disputed issue of fact precludes the granting of summary
EFTA00618173
Case 9:08-cv-80736-KAM Document 346 Entered on FLSD Docket 12/23/2015 Page 2 of 2
judgment, the…