DataSet-9
EFTA00872959
2 pg
…best pretrial motion that this relates to; too many risks going anywhere else with it. Once filed, its available in
other cases.
From: jeffrey E.
Sent: Monday, February 26, 2018 8:14 PM
To: Martin G. Weinberg
Subject: Re: ATTORNEY…
DataSet-9
EFTA00761061
3 pg
…from
others is also at risk. Once there is such a subpoena a privilege log would be prepared to exempt all a/c emails. I
would not use the case to subpoena others - instead the case conflicts with other cases…
DataSet-9
EFTA00610239
22 pg
…the discretion of the chief justice,
either set for oral argument and processed as described in section III(B) of this
manual or assigned to a justice and processed in the same manner as other cases
assigned without oral argument…
DataSet-9
EFTA00708293
23 pg
…2010, Epstein propounded a very broad subpoena to the Trustee for
RRA, requesting tens of thousands of e-mails and other records connected with civil cases filed
against him. The subpoena was directed to the Trustee in this case, who…
DataSet-9
EFTA00591687
4 pg
…issues pertain to legislative history
associated with the Crime Victims' Rights Act and related subjects that require extensive
research. Counsel for the victims also have several other cases that have recently required their
attention. As a result of these facts…
DataSet-9
EFTA01114359
17 pg
… 6
1 Mr. Edwards has of using documents or discovery
2 found in one case involving these two parties
3 in other cases. We've also provided that
4 information to the court both in our motion and
5…
DataSet-9
EFTA00100685
16 pg
…of limitations." Id. been directed at most of the universe of probable
interlocutors' and there is as a matter of law no new
ITIFirth and other cases applying the rule in the Internet audience to reach, and no new cause…
DataSet-9
EFTA01194446
9 pg
…Individually, attached hereto as "Exhibit A." There are no other
cases, no other parties to this action, and other potential claims to which the settlement could
possibly allude, rendering the comparison to these cases cited by Edwards misguided.
Accordingly, Edwards…
DataSet-9
EFTA00600760
10 pg
…5.50 1.237.50
corr re settlement negotiations, tolling agmt
re use of SM; review of federal dockets in
other cases/at; research re motion to
preserve evidence, proper protection of
electronic evidence
04/03/09 Draft motion to…
DataSet-9
EFTA00221738
4 pg
…parties in the other six above-styled causes (08-80381, 08-80994,
08-80811, 08-80893 09-80469, 09-80591) are hereby ORDERED TO SHOW CAUSE on or
before May 5, 2009 why all of the cases should not be…
DataSet-9
EFTA00618089
5 pg
…issues pertain to legislative history
associated with the Crime Victims' Rights Act and related subjects that require extensive
research. Counsel for the victims also have several other cases that have recently required their
attention. As a result of these facts…
DataSet-9
EFTA00722655
33 pg
…Epstein has other avenues for
contesting a summary judgment motion, then 'substantial and irreparable prejudice"
does not exist and the Court should not exercise discretion to grant the stay.2
A good illustration of judicial reluctance to stay cases such…
DataSet-9
EFTA00808590
19 pg
…party's possible intentional, or bad faith,
noncompliance with the pretrial order; and (iii) the possible disruption of the
orderly and efficient trial of the case (or other cases).
718 So. 2d at 396 (emphasis added).
Obviously, had Edwards known…
DataSet-9
EFTA00073260
14 pg
…2003) ("Allowing the fruits of one litigation to facilitate preparation in other cases
advances the interests of judicial economy by avoiding wasteful duplication of discovery.").
Since the USVI seeks access to the sealed documents for use in its own related…
DataSet-9
EFTA00812512
25 pg
…the agreement was an accident, here the
illegal agreement was a deliberate plan. In such circumstances, any equitable claim Epstein has
for specific performance of the non-prosecution agreement disappears.
Other cases reach similar conclusions. See, e.g., Craig v…
DataSet-9
EFTA01193667
12 pg
…court has recently and repeatedly said that the rule
and statute must be strictly construed.
In Ward the First District also cited numerous other cases where courts invalidated other
proposals for failing to strictly comply with the rule and statute…
DataSet-9
EFTA00807038
20 pg
…The Lenders understand that other cases allowing discovery
on bad faith at this stage, which the Lenders submit the Court should not adopt, do so on equitable
grounds. Specifically, these cases find that while bad faith is not a defense…
DataSet-9
EFTA00615316
9 pg
…during the pendency
of a state court action subsequently dismissed for improper venue.
Neither Burnett nor other Supreme Court cases present the issue of
whether federal tolling law would apply to a case raising a federal question
but controlled by…
DataSet-9
EFTA00614065
21 pg
…lawsuit. No doubt many other civil claimants have received similar
correspondence in other cases. If criminal defense attorneys are somehow going to dispense
with plea negotiations merely because in a few cases plea discussions might become "later
discoverable" (id.), we…
DataSet-9
EFTA00619558
29 pg
…corresponding
8 In another glaring omission from Plaintiff's submissions to the Court on the topic of the service of Mr. Epstein,
Plaintiff's own counsel have strenuously litigated in other cases that Mr. Epstein is a resident of Florida…
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