…PROCESS Having already once received this Court's indulgence for Plaintiffs' total disregard of Florida's procedural rules governing proper service of process and a 120-day extension of the time within which to effect service (effectively providing Plaintiffs with…
…involved and the fact that witnesses, plaintiffs and the defendant may only be deposed once. (See Order Consolidating Cases for Purpose of Discovery and Procedural Motions That Relate to Multiple Cases). EFTA00725630 Jane Doe v. Epstein, et al. Page 2 …
…PROCESS Having already once received this Court's indulgence for Plaintiffs' total disregard of Florida's procedural rules governing proper service of process and a 120-day extension of the time within which to effect service (effectively providing Plaintiffs with…
…be a budget overrun as the shower was the only tile in the budget I think part of our procedural problem is in the past we have a posted budget in job cost and Emad had a reference to base…
…MOTION FOR LEAVE TO ASSERT CLAIM FOR PUNITIVE DAMAGES AND MOTION FOR SANCTIONS AGAINST EDWARDS Plaintiff/Counter-Defendant Jeffrey Epstein, by and through his undersigned counsel and pursuant to Rule 1.190(0 of the Florida Rules of Civil Procedure, …
…an Order disqualifying itself from all further proceedings in the above-styled cause, and as grounds therefore states the following: PROCEDURAL REQUISITES Based upon the facts delineated below, Epstein has a well-founded fear that he will not receive a…
…Modify the Protective Order for the reasons set forth below. The Proposed Intervenors are two non-parties, Jeffrey Epstein and Leslie Groff (“Epstein Defendants”). PRELIMINARY STATEMENT PROCEDURAL HISTORY On March 18, 2016, this Court entered a Protective Order (DE 62…
…of 11 The plaintiff, in moving for a clerk's default, implied that service was made in accordance with either federal or Florida procedure. As discussed below, however, service was clearly ineffective under the federal and Florida rules of procedure…
…Apart from pushing down costs, this provides a procedural consistency, meaning we can be confident that our properties are liveable and durable when tenants move in. The level of refurbishment we implement varies from property to property- our refurbishment team…
… INTRODUCTION Confronted with Rule 1.440, a compulsory rule of Florida Civil Procedure, and unequivocal legal precedent interpreting the same clearly against him, Edwards levels false and misleading accusations against Epstein and injects impertinent allegations into his argument in…
…Thousand Dollars ($200,000.00) and with Schneider Regional Medical Center for about Two Thousand Five Hundred Dollars ($2,500.00) per-week for on-call services. PROCEDURAL HISTORY Julito Francis filed a verified Petition for Divorce on November 4…
…advantage. See e.g., Manning v. Cooper, 981 So.2d 688 (Fla. 4th DCA 2009). Disqualification motions should not be used a procedural weapons. Quail Cruise Ship Management, Ltd. v. Agenda De Viagens CVC Limitada, 2010 WL 2926042 S.D…
…to seek reconsideration of the Court's order granting that motion, to which Haddon Morgan was not provided notice or any opportunity to respond. Procedural Background As the Court knows, counsel for Plaintiff in this action were also counsel for…
…LAW Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, hereby requests that this Court enter an Order of Protection from Defendant/Counter…
…dated May 14, 2009 [Document 82], was for common discovery and procedural motions only. There is absolutely nothing in the order that would allow the multiple Plaintiffs in the separately filed actions against EPSTEIN to file multiple and duplicative substantive…
…lenity. We therefore quash the decision below and approve the Second District's decision in Taylor. I. FACTS AND PROCEDURAL HISTORY The facts on which the underlying convictions are based are explained in the district court's opinion. Leg Kasischke…
…that, in May 2009, Judge Kenneth Marra consolidated the related federal court cases for discovery and procedural purposes and directed that witnesses common to the multiple cases would be deposed only once. I further understand from conversations with Messrs. Critton…
…of their improper and ineffective service attempt, Plaintiffs took no action to comply with the Court's service deadline. 2. In complete disregard for Florida's procedural rules and Florida Statutes Section 48.031(1)(a), on March 10, 2015…
…Party, The Post 18 peak at than. I don't see where any of the proper 17 DEANNA SHULLMAN, ESQUIRE 19 procedures to seal the documents was ever followed to 18 Thomas, LoCiero & Bralow, PL 19 101 N.E. 3rd…
…Fla. Stat. The non-admissibility issue is the subject of a separate Motion.' Edwards' Motion Fails to Meet Court Requirements to Reopen Discovery and Seeks Preferential Treatment Second and procedurally, Edwards cannot have it both ways. As the Court made…
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