…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…
…For example, Defendant avoided her 2009 deposition in a case concerning Epstein by falsely claiming to be out of the country (she was, instead, photographed at Chelsey Clinton’s New York wedding). Additionally, in her Motion to Dismiss, Defendant claimed…
…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 …
…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…
…privilege as it applies to Mr. Gow’s January 2, 2015 communication to members of the British press are spelled out in detail in the Memorandum of Law In Support of Defendant’s Motion to Dismiss at page 8-13…
…the “laptop records” until Dr. Olson’s deposition, and Dr. Olson provided them at that time, a fact Defendant admits in a footnote in her Motion to Reopen Ms. Giuffre’s Deposition. In that brief, Defendant complains that they were…
…the “laptop records” until Dr. Olson’s deposition, and Dr. Olson provided them at that time, a fact Defendant admits in a footnote in her Motion to Reopen Ms. Giuffre’s Deposition. In that brief, Defendant complains that they were…
…that, as things stand today, all of this testimony is under 3 Id. Ms. Giuffre will be filing an opposition to Dershowitz’s motion to intervene shortly. 4 See McCawley Decl. at Composite Exhibit 1, Figueroa June 24, 2016 Dep…
…in filings submitted in connection with discovery disputes or motions in limine is generally somewhat lower than the presumption applied to material introduced at trial, or in connection with dispositive motions such as motions for dismissal or summary judgment.” Id…
…2 Now, with those preliminary thoughts in mind I am 3 going to deny the motion at this time because I know that there 4 is a statement, some kind of a statement from the mediator in 5 the Florida…
…2 Now, with those preliminary thoughts in mind I am 3 going to deny the motion at this time because I know that there 4 is a statement, some kind of a statement from the mediator in 5 the Florida…
…appropriately. 2 Now, with those preliminary thoughts in mind I am 3 going to deny the motion at this time because I know that there 4 is a statement, some kind of a statement from the mediator in 5 the…
…appropriately. 2 Now, with those preliminary thoughts in mind I am 3 going to deny the motion at this time because I know that there 4 is a statement, some kind of a statement from the mediator in 5 the…
…the charges and accused her two lawyers of acting improperly.) Last Friday, Edwards and Cassell issued a notice of withdrawal of the motion for partial summary judgement, and the litigation came to an end. The notice is short and sweet…
…conspiring” with Epstein to keep them “in the dark’’ so the plea arrangement could be done without the victims “raising any objection.” In February 2016, Edwards and co-counsel Paul Cassell filed a still-pending motion for summary judgment that…
…York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S CORRECTED1 REPLY IN SUPPORT OF MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT …
…Accordingly, her efforts to depose Epstein, Marcinkova, and Kellen seek important information that will be admissible at trial. III. MS. GIUFFRE’S REQUEST IS TIMELY. Defendant also argues that this motion is somehow “premature.” Defendant’s Resp. at 2-3…
… Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S NON-REDACTED MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT IN FEDERAL RULE CIVIL PROCEDURE 30(A)(2)(a)(ii) Sigrid Mc…
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