EFTA00204922.pdf PDF
…She just denied my motion for continuance, so it looks like the case is going forward. Sent: Thursday, December 08, 2011 4:02 PM Subject: Re: Jane Does I US -- Sealed Response to Motion to Dismiss I'm actually out…
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EFTA00204924.pdf PDF
From: (USAFLS)" ctl To: " Elarlin>(USAFI (USAFLS)" Subject: RE: Jane Does I US -- Sealed Response to Motion to Dismiss Date: Thu, 08 Dec 2011 20:54:57 +0000 I mportance: Normal S I will be out of the office tomorrow…
EFTA00071797.pdf PDF
From: ' (USANYS)" To: ' Subject: RE: separate research project Date: Wed, 26 Jun 2019 14:39:18 +0000 Importance: Normal The government made the claim you are referencing in its Sealed Motion to Dismiss for Lack of Subject Matter Jurisdiction, originally…
EFTA00209798.pdf PDF
From: ' (USAFLS)" To: ' (USAFLS)" Subject: Re: Jane Does I United States - Redacted Pleadings Date: Wed, 03 Jul 2013 15:39:57 +0000 Importance: Normal I was waiting for the order to make the change on the motion to dismiss. Thanks…
EFTA00726672.pdf PDF
…101 from filing a parallel state court claim thus she has not, by affirmative waiver filed before the challenged Motion to Dismiss, committed herself to a litigation strategy that would potentially qualify her for the waiver of liability obligation. …
EFTA00205706.pdf PDF
…litigation and the contemplated motion to dismiss. What do you think? By the way, was the MDFL given a copy of the NPA? I think they should be made aware that they should carefully review it to ensure that they…
EFTA00205177.pdf PDF
…Brad is buried in a three-week jury trial, so I have not been able to consult with him at any length about the pending motion to dismiss and to stay. I also have another brief due on next Wednesday…
EFTA00204929.pdf PDF
…Brad is buried in a three-week jury trial, so I have not been able to consult with him at any length about the pending motion to dismiss and to stay. I also have another brief due on next Wednesday…
EFTA00204876.pdf PDF
…grant or deny the motion to dismiss without requiring additional pleadings from any party, unless the court believes it needs more briefing. Normally, sur-replies are not permitted unless the reply has gone beyond responding to the issues raised in…
EFTA00209347.pdf PDF
…58 AM To: Sanchez, Eduardo (USAFLS); Lee, Dexter (USAFLS) Subject: RE: Jane Does t United States - Redacted Pleadings Hi Ed — I finished reviewing the rest. They all look good. In the Reply in support of the Motion to Dismiss for…
EFTA00880849.pdf PDF
…and we file a non appealable motion to dismiss. even though general contracts are curable where there has been no harm, if the govt intrprets this as a plea agreement , woudl that change the general rgiht to cure. Sent from…
EFTA00206813.pdf PDF
…that I would have to consult with the Executive Division on whether we would permanently forego filing a motion to dismiss for lack of prosecution. As it stands, the victims will file a joint motion to extend the period for…
EFTA00880972.pdf PDF
…a parallel state court claim thus she has not, by affirmative waiver filed before the challenged Motion to Dismiss, committed herself to a litigation strategy that would potentially qualify her for the waiver of liability obligation On Fri, Jun 19…
EFTA00729100.pdf PDF
…alleges that Epstein was in "clear breach of the NPA" by filing a Motion to Dismiss contesting the legality of a lawsuit before Judge Marra, Response, pg 2. The waivers of liability and right to contest jurisdiction were not effectuated…
EFTA00584357.pdf PDF
…be entitled to depositions; of course, he would be entitled to take discovery, and we don't believe that any of that violates the non-prosecution agreement. The issue with the pleading that he filed, the motion to dismiss the…
EFTA00731364.pdf PDF
…alleges that Epstein was in "clear breach of the NPA" by filing a Motion to Dismiss contesting the legality of a lawsuit before Judge Marra, Response, pg 2. The waivers of liability and right to contest jurisdiction were not effectuated…
EFTA00205594.pdf PDF
…could expect if your motion to dismiss is denied. But we have yet to receive anything at all regarding discovery. We would trust that you will carry through on what we understood you had agreed to in the telephone call…
EFTA00205133.pdf PDF
…Yet in your 13 page motion to dismiss, you did not discuss US' Walker or any of the case law that we had previously cited. In our response, we noted that we thought we are about to be "sandbagged" because…
EFTA00205522.pdf PDF
…government filed a motion to dismiss based on lack of standing, arguing that the alleged CVRA violation was not redressable. The victims have responded with a lengthy opposition, including a listing of remedies they claim are available to them (pages…
EFTA00204932.pdf PDF
…123 F.3d 1353 (11 ih Cir. 1997), the Eleventh Circuit observed that "[fJacial challenges to the legal sufficiency of a claim or defense, such as a motion to dismiss based on failure to state a claim for relief, should…
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