DataSet-9
EFTA00718009
3 pg
…jeffrey E.
Subject: Re: CONFIDENTIAL - FOR SETTLEMENT PURPOSES ONLY
Date: Mon, 21 Sep 2015 13:08:57 +0000
CONFIDENTIAL - FOR SETTLEMENT PURPOSES ONLY
While these proposals are being conveyed simultaneously, each is independent of the others, and…
DataSet-9
EFTA00845556
4 pg
…September 21, 2015, Brad Edwards > wrote:
CONFIDENTIAL - FOR SETTLEMENT PURPOSES ONLY
While these proposals are being conveyed simultaneously, each is independent of the others, and the
resolution of any one case is not in any way contingent on the…
DataSet-9
EFTA00845548
4 pg
…September 21, 2015, Brad Edwards > wrote:
CONFIDENTIAL - FOR SETTLEMENT PURPOSES ONLY
While these proposals are being conveyed simultaneously, each is independent of the others, and the
resolution of any one case is not in any way contingent on the…
DataSet-9
EFTA00206725
7 pg
…Court ordered the
Government to produce a copy of the Non-Prosecution Agreement between the United States Attorney and
Jeffrey Epstein, and simultaneously entered a protective order prohibiting petitioners from disseminating the
Non-Prosecution Agreement beyond designated individuals. (D.E…
DataSet-9
EFTA00206822
7 pg
…Court ordered the
Government to produce a copy of the Non-Prosecution Agreement between the United States Attorney and
Jeffrey Epstein, and simultaneously entered a protective order prohibiting petitioners from disseminating the
Non-Prosecution Agreement beyond designated individuals. (D.E…
DataSet-9
EFTA00206755
7 pg
…Court ordered the
Government to produce a copy of the Non-Prosecution Agreement between the United States Attorney and
Jeffrey Epstein, and simultaneously entered a protective order prohibiting petitioners from disseminating the
Non-Prosecution Agreement beyond designated individuals. (D.E…
DataSet-9
EFTA00799862
12 pg
…2017). The Government cannot simultaneously assert work
product protection over relevant documents concerning its internal deliberations while making
representations regarding those deliberations to obtain summary judgment. Because the
…
DataSet-9
EFTA00601682
11 pg
…The main thrust of petitioners' waiver argument is that, "(t]he Government cannot
simultaneously assert work product protection over relevant documents concerning its internal
deliberations while making representations regarding those deliberations to obtain summary
judgment." D.E. 414 at 1…
DataSet-9
EFTA00799964
11 pg
…The main thrust of petitioners' waiver argument is that, "(t]he Government cannot
simultaneously assert work product protection over relevant documents concerning its internal
deliberations while making representations regarding those deliberations to obtain summary
judgment." D.E. 414 at 1…
DataSet-9
EFTA00793749
13 pg
…Rulings, a
copy of which is attached as Exhibit A. Simultaneously with the filing of this Motion, Epstein is
filing the disc and stricken trial exhibits under seal in compliance with the Court's rulings at the
March 8, 2018…
DataSet-9
EFTA00088205
6 pg
…Court. This reply describes and discusses
sealed materials and materials subject to the Protective Order in this case. Ms. Maxwell also
simultaneously files under separate cover her proposed redactions to her Request to Modify Protective
Order (Aug. 17, 2020), and…
DataSet-9
EFTA00235792
7 pg
…Court ordered the
Government to produce a copy of the Non-Prosecution Agreement between the United States Attorney and
Jeffrey Epstein, and simultaneously entered a protective order prohibiting petitioners from disseminating the
Non-Prosecution Agreement beyond designated individuals. (D.E…
DataSet-9
EFTA00289808
53 pg
…victims. Should you give me
the go-ahead on Podhurst and Josephsberg selection by COB
tomorrow, I will simultaneously send you a draft of the letter. I
intend to notify the victims by letter after COB Thursday,
November 296. Thanks…
DataSet-9
EFTA00081116
64 pg
…likely fall into an "irrelevant" category of documents, they have simultaneously refused
production of hundreds of other documents that are responsive to our requests on the basis of
relevance.
24. The victims have tried to obtain information on all relevant…
DataSet-9
EFTA00226107
289 pg
…the victims. Should you give me the go-ahead on Podhurst and Josephsberg selection by COB
tomorrow, I will simultaneously send you a draft of the letter. I intend to notify the
victims by letter after COB Thursday, November 29th…
DataSet-9
EFTA00098414
33 pg
…go-head on [victim representative] . . . selection by COB
tomorrow, I will simultaneously send you a draft of the letter. I intend to notify the
victims by letter after COB Thursday, November 29th.
(DE 407 at ¶ 79.)
On November 28, 2007…
DataSet-9
EFTA00193954
651 pg
…the victims. Should you give me the go-ahead on Podhurst and Josephsberg selection by COB
tomorrow, I will simultaneously send you a draft of the letter. I intend to notify the
victims by letter after COB Thursday, November 29th…
DataSet-9
EFTA01081829
101 pg
…Green Tree Servicing LLC, 400 F.3d 1308, 1312
(11th Cir. 2005) ("Equitable estoppel precludes a party from claiming the benefits of a contract
while simultaneously attempting to avoid the burdens that contract imposes."); Rood Co. v. Bd.
of Public…
DataSet-9
EFTA00211273
5 pg
…was able to successfully conclude her case by obtaining
money damages from Epstein. "Equitable estoppel precludes a party from claiming the benefits
of a contract while simultaneously attempting to avoid the burdens that contract imposes."
Blinco v. Green Tree Servicing…
DataSet-9
EFTA00040739
33 pg
…go-head on [victim representative] . . . selection by COB
tomorrow, I will simultaneously send you a draft of the letter. I intend to notify the
victims by letter after COB Thursday, November 29th.
(DE 407 at ¶ 79.)
On November 28, 2007…
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