…!* 9) virginia* 10) jenna* 11) jena* 12) genna* 22) massage* 23) masseur* 24) therapist* 26) mindspring* 42) *copter* 43) chopper* 44) pilot* 45) manifest* 46) log* 47) flight* 48) passport* 52) state* /3 attorney* 1 57) al!n* 58) all…
…showing of: (1) an intervening change in controlling law; (2) the availability of new evidence; or (3) a need to correct a clear error or prevent manifest injustice.” Id. at 696. “Reconsideration should not be granted where the moving party…
…or manifest injury, 23 and it's our position that that hasn't been 24 shown in the requested relief. 25 THE COURT: You don't think confidential Case 1:15-cv-07433-LAP Document 1218-35 Filed 07/15…
…same case absent cogent and compelling reasons such as an intervening change of controlling law, the availability of new evidence, or the need to correct a clear error or prevent manifest injustice.” United States v. Thorn, 446 F.3d 378…
…to be shown irreparable harm, death, or manifest injury, and it's our position that that hasn't been shown in the requested relief. THE COURT: You don't think confidential settlement agreements should be sealed? I know you don…
…it is based on information already known to the Court. Moreover, there is no clear error or manifest injustice that warrants reconsideration of the Court’s ruling. Defendant’s request should be denied. Sincerely, /s/ Sigrid S. McCawley …
…properly granted only if there is a showing of: (1) an intervening change in controlling law; (2) the availability of new evidence; or (3) a need to correct a clear error or prevent manifest injustice.” Drapkin v. Mafco Consol. Grp.…
…of the transcript of her deposition, and there is a need to correct clear error or prevent manifest injustice relating to the unsealing of the transcript. We respectfully request that the Court keep sealed Ms. Maxwell’s and Doe 1…
…it. A motion for reconsideration may only be granted where there is “an intervening change of controlling law, the availability of new evidence, or the need to correct a clear error or prevent manifest injustice.” Cunningham v. Cornell Univ., No…
…January 13, 2020. ARGUMENT I. Legal Standard Reconsideration is appropriate “where there is an intervening change of controlling law, newly available evidence, or the need to correct a clear error or prevent manifest injustice.” Perez v. Progenics Pharm., Inc., 46…
…win the day, yes, T do believe that you can create a mighty manifesto on prostitution as it exists in the U.S.A. in the years leading up to 2014- one that has real literary possibilities. If you win…
…at p. 84. Yet, according to flight manifests, in that same general time period, Defendant was listed as a passenger at least eleven times either landing in or departing from West Palm Beach, Florida on Jeffrey Epstein’s private plane…
…at p. 84. Yet, according to flight manifests, in that same general time period, Defendant was listed as a passenger at least eleven times either landing in or departing from West Palm Beach, Florida on Jeffrey Epstein’s private plane…
…at p. 84. Yet, according to flight manifests, in that same general time period, Defendant was listed as a passenger at least eleven times either landing in or departing from West Palm Beach, Florida on Jeffrey Epstein’s private plane…
…of an address book containing Dershowitz's name and contact information which an Epstein associate characterized as "the Holy Grail;" and (7) Numerous demonstrably incomplete flight manifests showing that Jane Doe No. 3 was transported on Epstein's private plane…
…Castillo, 692 F.3d 108, 118 (2d Cir. 2012) (noting that “passing reference” to issue insufficient to avoid forfeiture). Although we may excuse Doe 171’s forfeiture to avoid a “manifest injustice,” In re Nortel Networks Corp. Sec. Litig., 539…
…2016 Page 4 of 12 41) marcinko* 42) *copter* 43) chopper* 44) pilot* 45) manifest* 46) log* 47) flight* 48) passport* 49) terramar* 50) southern* w/3 district* 51) palm* w/3 beach* 52) state* /3 attorney* 53) ross* 54…
…witness. And I instruct the witness 23 Q. Ma'am, isn't it true that you've seen the 24 not to answer based on her Fifth Amendment 24 passenger manifest for Jeffrey Epstein's plane? 25 privilege. 25 MR…
…motion to stay pending appeal on an emergency basis, and to prevent a manifestly unjust cat-out-of-the-bag disclosure that could potentially occur while an otherwise meritorious motion to stay pending appeal remains pending. See generally Drapkin v…
…unsealing on an ex parte basis, resulting in a need for correction to avoid a manifest injustice which presents an imminent risk of causing grave trauma and imminent physical harm to Doe 171. Second, Doe 171 requires this Court’s…
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