EFTA01045410.pdf PDF
…after a fierce Court battle. Cooperman fought his SEC Insider trading case in Court, and got part of It thrown out on a motion to dismiss.[1] He leveraged that victory Into a settlement approved on May 22, 2017, which …
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EFTA00209450.pdf PDF
…Court has not yet ruled on your motion to dismiss, and has said that it will not rule on your motion for expedited decision until it does so, so we believe that another motion for expedited decision should be similarly…
EFTA00206813.pdf PDF
…that I would have to consult with the Executive Division on whether we would permanently forego filing a motion to dismiss for lack of prosecution. As it stands, the victims will file a joint motion to extend the period for…
EFTA00214003.pdf PDF
…The government will be filing a motion to dismiss under Rule 12(b)(6) on the claim under 18 U.S.C. 3771(a)(5). We will also be seeking dismissal on the grounds of failure to prosecute. If plaintiffs…
EFTA00206689.pdf PDF
…will not agree to an evidentiary hearing for disputed facts. I will tell him the government intends to file a motion to dismiss for lack of prosecution and failure to state a claim, insofar as the right to consultation claim…
EFTA00206692.pdf PDF
…obligation to consult with plaintiffs. The government will be filing a motion to dismiss under Rule 12(b)(6) on the claim under 18 =. 3771(a)(5). We will also be seeking dismissal on the grounds of failure to…
EFTA00095957.pdf PDF
…off a scheduled April date — and teed up a motion schedule to last into late May for defendant whose counsel Montell Figgins said he plans to ask for dismissal on the basis that his client is being unlawfully singled out…
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…
EFTA00661568.pdf PDF
…and May 21, 2012, respectively (after each successful Motion to Dismiss). > At this point of the litigation, your Counterclaim has been dismissed three (3) times for its deficiencies. If you are conceding that Mr. Edwards' Counterclaim has no merit…
EFTA00204932.pdf PDF
…123 F.3d 1353 (11 ih Cir. 1997), the Eleventh Circuit observed that "[fJacial challenges to the legal sufficiency of a claim or defense, such as a motion to dismiss based on failure to state a claim for relief, should…
EFTA00222018.pdf PDF
…psychological and emotional damages. Am. Compl. ¶ 31. Defendant argues in his motion that Counts I and III of the Amended Complaint must be dismissed for failure to state a claim upon which relief can be granted. Fed. R. Civ. P…
EFTA00591577.pdf PDF
…Page 1 of 13
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
Plaintiff,
Case No.: I5-cv-07433-RWS
Ghislaine Maxwell,
Defendant.
REPLY MEMORANDUM OF LAW IN SUPPORT OF
DEFENDANT'S
EFTA00077571.pdf PDF
…2016) iv EFTA00077575 Ghislaine Maxwell submits this reply in support of her Motion to suppress all evidence the government obtained from a grand jury subpoena it issued <…
EFTA00222482.pdf PDF
…psychological and emotional damages. Am. Compl. ¶ 31. Defendant argues in his motion that Counts I and III of the Amended Complaint must be dismissed for failure to state a claim upon which relief can be granted. Fed. R. Civ. P…
EFTA00221460.pdf PDF
…80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPS…
EFTA00212960.pdf PDF
…80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPS…
EFTA00212245.pdf PDF
…that I would have to consult with the Executive Division on whether we would permanently forego filing a motion to dismiss for lack of prosecution. As it stands, the victims will file a joint motion to extend the period for…
EFTA00189749.pdf PDF
…80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPS…
EFTA00221985.pdf PDF
…and battery. Accordingly, even if the Complaint had not been amended, it sufficiently alleges facts establishing an assault and battery. Based on the foregoing, Defendant's Motion to Dismiss is moot, and, in any event, not well founded, and therefore…