EFTA00768962.pdf PDF
From: ' To: Jeffrey Epstein Subject: Re: FW: RE: Mike Hardman Date: Fri, 20 Nov 2009 16:35:54 +0000 Inline-Images: mime_part_l.png; mime_part_2.png trent got the first forclosure motion dismissed. They…
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EFTA00209891.pdf PDF
…July 18, 2013 2:03 AM RIPSIMAar 11.1.1.11ian Subject: RE: Correcting False Representation in Epstein's Response to our Motion to Dismiss What is the Government doing to correct the false impression? We contacted you on Monday…
EFTA00768960.pdf PDF
…I wasn't surprised the judge denied the motion to dismiss this time around. My argument is better suited for a summary judgment motion at this point. Mike Kranz did tell me that the bank was discussing settlement w/ Hardman…
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…
EFTA00205149.pdf PDF
…Mr. We will shortly be filing a motion to compel Government responses to our discovery requests -- discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay…
EFTA00718248.pdf PDF
…and that were the basis for several disclosures in his 6-19 Order denying the Motion to Dismiss (eg that there were 2 Grand Juries and that there was some form of recusal of SD Fla in favor of the…
EFTA00206689.pdf PDF
…will not agree to an evidentiary hearing for disputed facts. I will tell him the government intends to file a motion to dismiss for lack of prosecution and failure to state a claim, insofar as the right to consultation claim…
EFTA00712223.pdf PDF
…loves scarola , maybe we should somehow give him the choice of spending may hours reviewing logs or getting rid of both cases.. as they survived the motion to dismiss, i think we stress that they have no damages.. and this…
EFTA00792998.pdf PDF
…2008 WL 591869, at *9 (S.D.N.Y. Mar. 4, 2008)). Indeed, a district court has authority to allow "jurisdictional discovery" to proceed even while a motion to dismiss is pending. See, e.g., Daventree Ltd. v. Republic of…
EFTA00623124.pdf PDF
…Count Should Be Merged Into A Single Count) of the EFTA00623127 Case 9:09-cv-80591-KAM Document 53 Entered on FLSD Docket 06/12/2009 Page 2 of 2 Defendant's Motion to Dismiss the First Amended Complaint Or…
EFTA01126142.pdf PDF
…to his files, it is clear that despite counsel's efforts in the past, discovery has proceeded slowly, depositions and IMEs have been subjected to extensive motion practice, and their remain pending discovery disputes and an outstanding Motion to Dismiss…
EFTA01114351.pdf PDF
…the Plaintiffs Motion to Dismiss the Counterclaim of the Defendant, BRADLEY J. EDWARDS. The Court heard argument of counsel and has reviewed the authorities they have cited, and is otherwise fully advised in the premises. First, as to Count I…
EFTA00222018.pdf PDF
…psychological and emotional damages. Am. Compl. ¶ 31. Defendant argues in his motion that Counts I and III of the Amended Complaint must be dismissed for failure to state a claim upon which relief can be granted. Fed. R. Civ. P…
EFTA00725500.pdf PDF
…for filing a responsive Motion to Dismiss and thereafter an Answer to claims brought by Jane Doe 103 pursuant to 18 USC 2255 that were referenced in our earlier letter to you dated March 5, 2010 to which there has…
EFTA00222482.pdf PDF
…psychological and emotional damages. Am. Compl. ¶ 31. Defendant argues in his motion that Counts I and III of the Amended Complaint must be dismissed for failure to state a claim upon which relief can be granted. Fed. R. Civ. P…
EFTA00731326.pdf PDF
…this case, "D]ssues regarding the minimum amount of damages available to Plaintiff under 18 U.S.C. § 2255 do not affect whether Plaintiff has stated a claim and are not appropriate for a motion to dismiss. These damages issues…
EFTA00209461.pdf PDF
…in Epstein's Response to our Motion to Dismiss Date: Thu, 18 Jul 2013 06:02:56 +0000 Importance: Normal Attachments: Epstein-response-mtd.pdf Inline-Images: image001.jpg Hi What is the Government doing to correct the false impression…
EFTA00607658.pdf PDF
…etc., et al., Defendant(s). ORDER ON PLAINTIFF/COUNTER-DEFENDANT EPSTEIN'S MOTION TO DISMISS AMENDED COUNTERCLAIM THIS CAUSE having come before the Court upon the Plaintiff/Counter- Defendant, JEFFREY EPSTEIN's Motion to Dismiss Amended Counterclaim, and the Court…
EFTA01114353.pdf PDF
…ROTHSTEIN, etc., et al., Defendant(s). ORDER ON MOTION TO DISMISS PLAINTIFF'S SECOND AMENDED COMPLAINT THIS CAUSE came before the Court upon the Defendant, BRADLEY EDWARDS' Motion to Dismiss the Plaintiff's Second Amended Complaint served August 23, 2011…
EFTA01093420.pdf PDF
…Plaintiff's Motion to Dismiss the Counterclaim of the Defendant, BRADLEY J. EDWARDS. The Court heard argument of counsel and has reviewed the authorities they have cited, and is otherwise fully advised in the premises. First, as to Count I…
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