…Eleven months into this case, and after the close of fact discovery, Defendant continues to refuse to abide by her most basic and fundamental discovery obligations. A summary of this ongoing and willful non-compliance, as well as a supplement…
…Eleven months into this case, and after the close of fact discovery, Defendant continues to refuse to abide by her most basic and fundamental discovery obligations. A summary of this ongoing and willful non-compliance, as well as a supplement…
…Eleven months into this case, and after the close of fact discovery, Defendant continues to refuse to abide by her most basic and fundamental discovery obligations. A summary of this ongoing and willful non-compliance, as well as a supplement…
…Case 1:15-cv-07433-LAP Document 1137-16 Filed 10/22/20 Page 2 of 15 TABLE OF CONTENTS Page I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL CLAIMS AND DEFEN…
…E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 TABLE OF CONTENTS Page I. THE PROPOSED DEPOSI…
…Case 1:15-cv-07433-LAP Document 1320-21 Filed 01/03/24 Page 2 of 15 TABLE OF CONTENTS Page I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL CLAIMS AND DEFEN…
… Case 1:15-cv-07433-RWS Document 203 Filed 06/13/16 Page 2 of 15 TABLE OF CONTENTS Page I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL CLAIMS AND DEFENS…
… Case 1:15-cv-07433-LAP Document 211 Filed 06/14/16 Page 3 of 16 TABLE OF CONTENTS Page I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL CLAIMS AND DEFE…
…to “identify[] the most current address available for [a non-party] in a public records database or other readily available source.” This will ensure that the notice to non- parties is “the best practicable under the circumstances.” Guevoura Fund Ltd…
…S. Currency in the Amount of $119,984.00, 304 F.3d 165, 176-77 (2d Cir. 2002)); N.Y. Dist. Council of Carpenters Pension Fund v. Perimeter Interiors, Inc., 657 F. Supp. 2d 410, 415 (S.D.N.Y…
…many if not all of the Complaints against Epstein pursuant to his plea agreement to fund such lawsuits against him were styled as “Jane Doe” to protect the privacy of his underage victims. 1 Case 1:15-cv-07433-LAP…
…8 Brink’s Inc. v. City of New York, 717 F.2d 700 (2d Cir. 1983)........................................................................................................ 8 Cerro Gordo Charity v. Fireman’s Fund Am. Life Ins. Co., 819 F.2d 1471 (8th Cir. 1987) .........................................................................…
…Case 1:15-cv-07433-LAP Document 1256-8 Filed 05/03/22 Page 3 of 16 TABLE OF CONTENTS Page I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL CLAIMS AND DEFENSES I…
…United States Constitution guarantees an accused the right to an impartial jury. This fundamental guarantee is part of a criminal defendant’s basic right to a fair trial, which requires that a defendant must be judged by a jury of…
…Case 1:15-cv-07433-LAP Document 1256-11 Filed 05/03/22 Page 3 of 15 TABLE OF CONTENTS Page I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL CLAIMS AND DEFEN…
…undue burden (“Privacy Interests”). CI-4 - Preserving the fundamental rights of suspects or others under criminal investigation – including due process right to a fair trial and impartial jury unimpaired by excessive publicity, release of potentially inadmissible evidence for the Criminal…
…that there is an error in the redactions on DE 173-6, page 63. As to the remainder of the letter, we fundamentally disagree with Ms. Menninger’s objections to our redactions (DE 173-6 at pages 59-63, 104…
…that which has already been sealed for far too long. She further fundamentally mischaracterizes the role of the media in seeking access to court records: The media are not distinguishable from the public; they are the surrogates for the public…
…Case 1:15-cv-07433-LAP Document 1320-24 Filed 01/03/24 Page 3 of 16 TABLE OF CONTENTS Page I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL CLAIMS AND DEFEN…
…Case 1:15-cv-07433-LAP Document 1137-17 Filed 10/22/20 Page 3 of 16 TABLE OF CONTENTS Page I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL CLAIMS AND DEFEN…