EFTA00209450.pdf PDF
…Court has not yet ruled on your motion to dismiss, and has said that it will not rule on your motion for expedited decision until it does so, so we believe that another motion for expedited decision should be similarly…
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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…
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…
EFTA01377741.pdf PDF
…PTAB. We moved to consolidate the 2014 Complaint with the 2010 Complaint (the Complaints), and the District Court granted our motion on July 16, 2014. We moved to dismiss certain claims as time barred under California and Delaware law, and…
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…
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…
EFTA00221460.pdf PDF
…80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPS…
EFTA00212960.pdf PDF
…80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPS…
EFTA00189749.pdf PDF
…80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPS…
EFTA00212893.pdf PDF
…80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPS…
EFTA00065989.pdf PDF
…OF NEW YORK x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) v. GHISLAINE MAXWELL, Defendant. X MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO …
EFTA00605542.pdf PDF
…EPSTEIN'S MOTION TO DISMISS.COUNT VI & FOR MORE DEFINITE STATEMENT & TO STRIKE DIRECTED TO PLAINTIFF JANE DOE NO. 103'S COMPLAINT (dated 2/23/20101 Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, moves to dismiss Count…
EFTA00605537.pdf PDF
…EPSTEIN'S MOTION TO DISMISS.COUNT VI & FOR MORE DEFINITE STATEMENT & TO STRIKE DIRECTED TO PLAINTIFF JANE DOE NO. 103'S COMPLAINT (dated 2/23/20101 Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, moves to dismiss Count…
EFTA00801525.pdf PDF
…Estate of Leven, 116 F.supp.3d 314 (S.N.N.Y. 2015) ("in deciding a motion to dismiss a complaint for want of personal jurisdiction, the district court may consider materials outside of the complaint"). For the same reasons…
EFTA00728487.pdf PDF
…that the Motion to Dismiss that is referenced therein did not constitute a willful breach of Mr. Epstein's obligations under the non-prosecution agreement. Mr. Epstein's counsel unanimously determined that the filing of this motion to dismiss was…
EFTA00099352.pdf PDF
…330 (AJN) v. GHISLAINE MAXWELL, Defendant. X MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NON-PROSECUTION AGREEMENT …
EFTA00222813.pdf PDF
…F.Supp.2d 742, 754 (M.D. Pa. 2007); and the recent cases in front of this court on Defendant's Motions to Dismiss and For More Definite Statement — Doe No. 2 v. Epstein 2009 WL 383332 (S.D. Fla…
EFTA00605538.pdf PDF
…EPSTEIN'S MOTION TO DISMISS.COUNT VI & FOR MORE DEFINITE STATEMENT & TO STRIKE DIRECTED TO PLAINTIFF JANE DOE NO. 103'S COMPLAINT (dated 2/23/20101 Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, moves to dismiss Count…
EFTA00605540.pdf PDF
…EPSTEIN'S MOTION TO DISMISS.COUNT VI & FOR MORE DEFINITE STATEMENT & TO STRIKE DIRECTED TO PLAINTIFF JANE DOE NO. 103'S COMPLAINT (dated 2/23/20101 Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, moves to dismiss Count…
EFTA00221363.pdf PDF
…80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPS…
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