EFTA00207677.pdf PDF
…make a sufficient showing on an essential element of her case with respect to which she has the burden of proof. Discussion of Law Showing that EPSTEIN Is Entitled to the Summary Judgment Sought as a Matter of Law. I…
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EFTA01099901.pdf PDF
…his motion, Defendant states: Introduction Defendant, without waiving any affirmative defense or grounds which may entitle him to summary judgment in this action or in any other actions brought by other plaintiffs …
EFTA01100608.pdf PDF
…Epstein vs. Edwards Motion for Summary Judgment EFTA01100608 Case 09-34791-RBR Doc 1603-2 Filed 04/08/11 Page 2 of 30 IN THE CIRCUIT COURT OF THE 15TH …
EFTA00808205.pdf PDF
…is therefore respectfully requested. Preface In its May 19, 2014 order granting Epstein's motion for summary judgment, this Court recounted the following background facts: EFTA00808205 …
EFTA01101060.pdf PDF
…. . any summary judgment evidence on which the adverse party relies."). All referenced exhibits and attachments have previously been filed with the Court and provided to Epstein. Sexual Abuse of Children By Epstein I. Defendant Epstein has a sexual preference for…
EFTA00725968.pdf PDF
…and therefore Edwards is entitled to summary judgment on these grounds as well. The truth is the record is entirely devoid of any evidence to support Epstein's claims and is completely and consistently corroborative of Edwards's sworn assertion…
EFTA00729910.pdf PDF
…P. 1.510(c) ("The adverse party shall identify . . . any summary judgment evidence on which the adverse party relies."). Sexual Abuse of Children By Epstein 1. Defendant Epstein has a sexual preference for young children. Deposition of Jeffrey Epstein, Mar…
EFTA01100963.pdf PDF
…Edwards, Esq. is entitled to summary judgment for all claims brought against him in Plaintiff Jeffrey Epstein's Second Amended Complaint. Not only is there an absence of competent evidence to demonstrate that Edwards participated in any fraud against Epstein…
EFTA00611704.pdf PDF
…find the following: 1. Our Motion for Summary Judgment (w/o attachments) 2. Scarola's Memorandum in Opposition (w/o attachments) 3. Transcript of the hearing on our Motion for Summary Judgment 4. Counter-Plaintiff's two Notices of Supplemental…
EFTA00613501.pdf PDF
…Edwards responded to the Motion, fully addressing both the litigation privilege argument and the probable cause and bona fide termination arguments. At the hearing on the Motion for Summary Judgment, this Court explained that it "would not grant the motion…
EFTA01100638.pdf PDF
…P. 1.510(c) ("The adverse party shall identify . . . any summary judgment evidence on which the adverse party relies."). Sexual Abuse of Children By Epstein 1. Defendant Epstein has a sexual preference for young children. Deposition of Jeffrey Epstein, Mar…
EFTA01100939.pdf PDF
…Edwards, Esq. is entitled to summary judgment for all claims brought against him in Plaintiff Jeffrey Epstein's Second Amended Complaint. Not only is there an absence of competent evidence to demonstrate that Edwards participated in any fraud against Epstein…
EFTA00601682.pdf PDF
…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…
EFTA01112407.pdf PDF
…is obliged to follow Wolfe. This Court is not compelled to follow Wolfe and to grant a summary judgment that would immunize EPSTEIN's blatant attempt at extortion through the malicious misuse of the civil justice system. Fourth DCA precedent …
EFTA00799964.pdf PDF
…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…
EFTA00725998.pdf PDF
…P. 1.510(c) ("The adverse party shall identify . . . any summary judgment evidence on which the adverse party relies."). Sexual Abuse of Children Dv Epstein 1. Defendant Epstein has a sexual preference for young children. Deposition of Jeffrey Epstein, Mar…
EFTA01130733.pdf PDF
…individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, NOTICE OF FILING TRANSCRIPT IN SUPPLEMENTAL SUPPORT OF BRADLEY EDWARDS' MOTION FOR SUMMARY JUDGMENT Defendant/Counterplaintiff, BRADLEY J. EDWARDS, by and through his undersigned attorneys, hereby gives notice of the…
EFTA01190277.pdf PDF
…find the following: 1. Our Motion for Summary Judgment (w/o attachments) 2. Scarola's Memorandum in Opposition (w/o attachments) 3. Transcript of the hearing on our Motion for Summary Judgment 4. Counter-Plaintiff's two Notices of Supplemental…
EFTA00676300.pdf PDF
…will show Mike stole a lot of money. Unfortunately, the bank now has filed for summary judgment--wants the judge to simply find we owe the $ and issue a judgment. I want to slow things down and can do…
EFTA00208576.pdf PDF
…I will work with Dexter tomorrow to meld the two into one. « File: Response to Summary Judgment Motn 4-3-2011.wpd » One thought on the "statement of undisputed facts," I would not respond to it at all in this…
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