gov.uscourts.nysd.447706.15.0.pdf PDF
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X ............................................... VIRGINIA L. GIUFFRE, PLAINTIFF, V. …
Found 184 results
for “motion to dismiss”
in 210ms
gov.uscourts.nysd.447706.1332.15.pdf PDF
…Motion to Dismiss stage. See, e.g., In re Giant Interactive Grp., Inc. Sec. Litig., 643 F. Supp. 2d 562, 573 (S.D.N.Y. 2009) (Sweet, J.) (Court not considering evidence outside of complaint in deciding motion to dismiss…
gov.uscourts.nysd.447706.35.0.pdf PDF
…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…
gov.uscourts.nysd.447706.20.0.pdf PDF
…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…
gov.uscourts.nysd.447706.23.0.pdf PDF
…own words, it must be disregarded. 3 Case 1:15-cv-07433-RWS Document 23 Filed 12/17/15 Page 9 of 32 pre-litigation privilege. As part of a motion to dismiss, these arguments must be rejected. First…
gov.uscourts.nysd.447706.29.0.pdf PDF
…GIUFFRE, PLAINTIFF, DEFENDANT’S NOTICE OF V. SUPPLEMENTAL AUTHORITY GHISLAINE MAXWELL, …
gov.uscourts.nysd.447706.29.1.pdf PDF
…causing to be made three very discreet statements: (1) Defendant defamed Plaintiff, (2) Defendant cast Plaintiff in a false light, and (3) Defendant intentionally inflicted emotional distress upon Plaintiff.1 Presently before the Court is a Motion to Dismiss and…
gov.uscourts.nysd.447706.1137.19_2.pdf PDF
…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…
gov.uscourts.nysd.447706.26.0.pdf PDF
…cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAIINTIFF, VIRGINIA L. GIUFFRE’S NOTICE OF SUPPLEMENTAL AUTHORITY In further support of her Opposition to Defendant’s Motion to Dismiss the Complaint, Plaintiff Virginia L. Giuffre, by and through her undersigned counsel…
gov.uscourts.nysd.447706.589.0.pdf PDF
…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. …
gov.uscourts.nysd.447706.16.0.pdf PDF
…for Defendant Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in support of Maxwell’s Motion to Dismiss the Complaint filed in this action by Plaintiff Virginia L. Giuffre. 2. Attached hereto as Exhibit A is a…
gov.uscourts.nysd.447706.562.2.pdf PDF
… 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…
gov.uscourts.nysd.447706.96.0.pdf PDF
…to prejudge that, but I mean that's the issue as I understand it. MR. PAGLIUCA: Well, and the Court narrowed this down in the Court's order on the motion to dismiss, which is that the statements relating to…
gov.uscourts.nysd.447706.1137.15_2.pdf PDF
…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…
gov.uscourts.nysd.447706.31.0_1_1.pdf PDF
…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 …
gov.uscourts.nysd.447706.1325.18.pdf PDF
…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 …
gov.uscourts.nysd.447706.955.0.pdf PDF
…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…
gov.uscourts.nysd.447706.851.0.pdf PDF
…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…
gov.uscourts.nysd.447706.892.0.pdf PDF
…with the motion of defendant Ghislaine Maxwell (" Maxwell " or the "Defendant") for summary judgment to dismiss the complaint of plaintiff Virginia L . Giuffre ("Giuffre" or the "P l aintiff"). Based upon the conclusions set forth below , the motion to intervene…
gov.uscourts.nysd.447706.1325.19.pdf PDF
…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…
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