…Plaintiff, JEFFREY EPSTEIN, submits his response in opposition to Defendant, SCOTT ROTHSTEIN'S ("Rothstein") Motion to Set Aside Default, and states: Background and Procedural Posture 1. Epstein filed the instant action against Rothstein and others on December 9, 2009. 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…
…foo). the application may be returned to you. Complete the Procedural Checklist on page 7 of the instructions. Part I Identification of Applicant 18 Full name of organization (as shown in organizing document) 2 Employe…
…his undersigned counsel, and files this Motion to Dismiss, and as good grounds therefore states as follows: I. In complete disregard for Florida's procedural rules and Florida Statutes Section 48.031(1)(a), on March 10, 2015, Plaintiffs improperly…
…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…
…Document 1328-41 Filed 01/05/24 Page 2 of 31 TABLE OF CONTENTS Page TABLE OF AUTHORITIES ........................................................................…
…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…
…INSTRUCTION Ms. Giuffre hereby files a Renewed Motion to Compel Data from Defendant’s Undisclosed Email Accounts and for an Adverse Inference Jury Instruction, and states as follows. I. SIGNIFICANT PROCEDURAL HISTORY On October 14, 2016, Ms. Giuffre filed a…
…Document 1218-22 Filed 07/15/21 Page 2 of 31 TABLE OF CONTENTS Page TABLE OF AUTHORITIES ........................................................................…
…flight, Lawrence Visoski ("Visoski"), pre-cleared United States Customs in St. Thomas and complied with the same pre-arrival reporting procedures he had observed for the numerous flights he previously made to Teterboro from St. Thomas, on March I, 2016…
…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…
…Edwards' inaccurate and misleading factual and procedural recitation is typical of the smoke- and-mirrors strategy he steadfastly has adhered to throughout the course of this litigation to justify a malicious prosecution counterclaim against Epstein for which Edwards has no…
…defective because the Plaintiff did not timely file the Affidavit of Service. However, a delay in filing proof of service under CPLR 308 is merely a procedural irregularity, not jurisdictional, and may be corrected nunc pro tunc by the court…
…provisions of SORNA, except for 18 USCS § 2250, were devoted to procedural issues; although SORNA required sex offenders to provide detailed personal information and appear in person so that jurisdiction could take current photograph and verify their information, 42 USCS §…