EFTA00204922.pdf PDF
…She just denied my motion for continuance, so it looks like the case is going forward. Sent: Thursday, December 08, 2011 4:02 PM Subject: Re: Jane Does I US -- Sealed Response to Motion to Dismiss I'm actually out…
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EFTA00204924.pdf PDF
From: (USAFLS)" ctl To: " Elarlin>(USAFI (USAFLS)" Subject: RE: Jane Does I US -- Sealed Response to Motion to Dismiss Date: Thu, 08 Dec 2011 20:54:57 +0000 I mportance: Normal S I will be out of the office tomorrow…
EFTA00071797.pdf PDF
From: ' (USANYS)" To: ' Subject: RE: separate research project Date: Wed, 26 Jun 2019 14:39:18 +0000 Importance: Normal The government made the claim you are referencing in its Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction, originally…
EFTA00209798.pdf PDF
From: ' (USAFLS)" To: ' (USAFLS)" Subject: Re: Jane Does I United States - Redacted Pleadings Date: Wed, 03 Jul 2013 15:39:57 +0000 Importance: Normal I was waiting for the order to make the change on the motion to dismiss. Thanks…
EFTA00209322.pdf PDF
…August 06, 2013 8:03 AM To: Paul Cassell Cc: Brad Edwards ([email protected]) Subject: Re: Position on Motion for Expedited Ruling on Motion to Dismiss He actually takes very good care of me! The truth is that you…
EFTA00726672.pdf PDF
…101 from filing a parallel state court claim thus she has not, by affirmative waiver filed before the challenged Motion to Dismiss, committed herself to a litigation strategy that would potentially qualify her for the waiver of liability obligation. …
EFTA00205177.pdf PDF
…Brad is buried in a three-week jury trial, so I have not been able to consult with him at any length about the pending motion to dismiss and to stay. I also have another brief due on next Wednesday…
EFTA00204929.pdf PDF
…Brad is buried in a three-week jury trial, so I have not been able to consult with him at any length about the pending motion to dismiss and to stay. I also have another brief due on next Wednesday…
EFTA00204876.pdf PDF
…grant or deny the motion to dismiss without requiring additional pleadings from any party, unless the court believes it needs more briefing. Normally, sur-replies are not permitted unless the reply has gone beyond responding to the issues raised in…
EFTA00209347.pdf PDF
…58 AM To: Sanchez, Eduardo (USAFLS); Lee, Dexter (USAFLS) Subject: RE: Jane Does t United States - Redacted Pleadings Hi Ed — I finished reviewing the rest. They all look good. In the Reply in support of the Motion to Dismiss for…
EFTA00208578.pdf PDF
…August 06, 2013 8:03 AM To: Paul Cassell Cc: Brad Edwards ([email protected]) Subject: Re: Position on Motion for Expedited Ruling on Motion to Dismiss He actually takes very good care of me! The truth is that you…
EFTA00208564.pdf PDF
…August 06, 2013 8:03 AM To: Paul Cassell Cc: (USAFLS); (USAFLS); Brad Edwards ( Subject: Re: Position on Motion for Expedited Ruling on Motion to Dismiss He actually takes very good care of me! The truth is that you've…
EFTA00880972.pdf PDF
…a parallel state court claim thus she has not, by affirmative waiver filed before the challenged Motion to Dismiss, committed herself to a litigation strategy that would potentially qualify her for the waiver of liability obligation On Fri, Jun 19…
EFTA00207929.pdf PDF
…eenehre We will shortly be filing a motion to compel Government responses to our discovery requests — discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay…
EFTA00205507.pdf PDF
…could expect if your motion to dismiss is denied. But we have yet to receive anything at all regarding discovery. We would trust that you will carry through on what we understood you had agreed to in the telephone call…
EFTA00729100.pdf PDF
…alleges that Epstein was in "clear breach of the NPA" by filing a Motion to Dismiss contesting the legality of a lawsuit before Judge Marra, Response, pg 2. The waivers of liability and right to contest jurisdiction were not effectuated…
EFTA00792998.pdf PDF
…2008 WL 591869, at *9 (S.D.N.Y. Mar. 4, 2008)). Indeed, a district court has authority to allow "jurisdictional discovery" to proceed even while a motion to dismiss is pending. See, e.g., Daventree Ltd. v. Republic of…
EFTA00584357.pdf PDF
…be entitled to depositions; of course, he would be entitled to take discovery, and we don't believe that any of that violates the non-prosecution agreement. The issue with the pleading that he filed, the motion to dismiss the…
EFTA00623124.pdf PDF
…Count Should Be Merged Into A Single Count) of the EFTA00623127 Case 9:09-cv-80591-KAM Document 53 Entered on FLSD Docket 06/12/2009 Page 2 of 2 Defendant's Motion to Dismiss the First Amended Complaint Or…
EFTA00731364.pdf PDF
…alleges that Epstein was in "clear breach of the NPA" by filing a Motion to Dismiss contesting the legality of a lawsuit before Judge Marra, Response, pg 2. The waivers of liability and right to contest jurisdiction were not effectuated…