…RWS Document 22 Filed 12/15/15 Page 2 of 14 Table of Contents ARGUMENT....................................................................................................................... 2 I. The Motion to Dismiss is Dispositive and Well Founded I…
…X .. ............................................. VIRGINIA L. GIUFFRE, Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. …
…in her Motion to Dismiss, Maxwell claims that in both 2011 and 2015 she anticipated litigation against tabloids. Specifically, she stated that in 2011, “litigation . . . was forthcoming,” and in 2015, she made her press release “’pertinent to’ anticipated good-faith…
…to complete all fact discovery by July 1, 2016. (Doc. #13) On November 30, 2015, contemporaneous with the filing of her Rule 12(b) Motion to Dismiss, Ms. Maxwell also requested of this Court a stay of discovery pursuant to…
…had no role in instigating the investigation of Maxwell, both of these representations to were false. In turn, the government issued a in the . See Motion under the Due Process Clause to Suppress and Dismiss Counts 5 and 6, EX…
…to complete all fact discovery by July 1, 2016. (Doc. #13) On November 30, 2015, contemporaneous with the filing of her Rule 12(b) Motion to Dismiss, Ms. Maxwell also requested of this Court a stay of discovery pursuant to…
…submitted to the Court in Opposition to the Motion to Dismiss, a cease and desist letter issued by Devonshires Solicitors, Mr. Philip Barden’s firm. See McCawley Decl. in Support of Plaintiff’s Opp’n to Motion to Dismiss at…
…Feb. 1, 2001). 5 “It, of course, is black letter law that the mere filing of a motion to dismiss the complaint does not constitute ‘good cause’ for the issuance of a discovery stay.” Barrett v. Forest Labs., Inc., No…
…to complete all fact discovery by July 1, 2016. (Doc. #13) On November 30, 2015, contemporaneous with the filing of her Rule 12(b) Motion to Dismiss, Ms. Maxwell also requested of this Court a stay of discovery pursuant to…
…to complete all fact discovery by July 1, 2016. (Doc. #13) On November 30, 2015, contemporaneous with the filing of her Rule 12(b) Motion to Dismiss, Ms. Maxwell also requested of this Comi a stay of discovery pmsuant to…
…since appealed this Court’s ruling on his motion to intervene to publish select documents filed by Defendant, which is currently pending in the Second Circuit. It is our understanding that Dershowitz will shortly be moving to dismiss his appeal. …
…2003, 4 N.Y.3d 665, 678, 797 N.Y.S.2d 790, 830 N.E.2d 1118 2 In the Motion to Dismiss, Maxwell does not dispute that NY law applies. See D.E. 15, Maxwell MTD at 7…
…(See Opinion & Order re: Defendant’s Motion to Disqualify Counsel for Plaintiff and to Dismiss the Complaint, dated October 16, 2019 [dkt. no. 67].) Ms. Giuffre retained Cooper & Kirk to represent her shortly thereafter. 4 Case 1:15-cv…
… EDWARDS AND CASSELL ARE ENTITLED TO SUMMARY JUDGMENT ON THE COUNTERCLAIM ON THE BASIS OF THEIR AFFIRMATIVE DEFENSE OF LITIGATION PRIVILEGE. As the Court is aware, Edwards and Cassell have pending a motion to dismiss both counts of the First…
…motion.” In re 2TheMart.com, Inc. Sec. Litig., 114 F. Supp. 2d 955, 965 (C.D. Cal. 2000) (emphasis in original). Just as with a motion to dismiss for failure to state a claim, in ruling on a motion to…
…attached that 9 order, because I believe the Court can consider it taking 10 judicial notice, to my declaration here on the motion to 11 dismiss. 12 In the order, just so we're all clear, I'm not 13 …
…attached that 9 order, because I believe the Court can consider it taking 10 judicial notice, to my declaration here on the motion to 11 dismiss . 12 In the order, just so we ' re all clear, I'm not 13 …
…was undertaken by the parties, as demonstrated by the 950 docket entries as of August 27, 2018, including a motion to dismiss the Complaint which was denied by opinion of February 29, 2016 (the "February 29 Opinion"). The primary issue…
…below, '''· ;.:'.'''1'"''.·'.::-· the motion is granted in p~rt and d$nied in p~rt. ·.;. ,:., l. …
…Like all of you, you woke up in the middle 3 of the night thinking about this case. I would like to see if 4 I can clarify my understanding. 5 In the motion to dismiss, I concluded, I think…
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