…damages to make such an evidentiary proffer, the standard of proof is rather minimal, and it is inappropriate for this Court to weigh the evidence. As such, the standard closely resembles a Motion to Dismiss. The Court is required to…
…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 Divniks was…
…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 Dicirliks was…
…INC., and JEFFREY E. EPSTEIN, Defendants. X DEFENDANTS THE FINANCIAL TRUST COMPANY AND JEFFREY E. EPSTEIN'S NOTICE OF MOTION TO DISMISS PLAINTIFFS' COMPLAINT WITH PREJUDICE PLEASE TAKE NOTICE that, upon declaration of Benn…
…AMENDED COUNTERCLAIM AS TO PUNITIVE DAMAGES THIS CAUSE, having come before the Court on February 4, 2013, upon Plaintiff/Counter-Defendant Jeffrey Epstein's Motion to Dismiss Defendant/Counter- Plaintiff Bradley Edwards's Fourth Amended Counterclaim as to Punitive Damages…
…Bradley J. Edwards' Motion to Dismiss Plaintiff/Counter-Defendant, Jeffrey Epstein's Amended Complaint served April 15, 2011, in the above-styled cause. The Court having reviewed the Motion, hearing argument of counsel and being otherwise fully advised in the…
…Florida 33409 Phone: Fax: Attorney for BRADLEY J. EDWARDS 2 …
…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 attempted to serve Defendant…
…Defendants. MOTION OF COUNTER-DEFENDANT, JEFFREY EPSTEIN, FOR A MORE DEFINITE STATEMENT AND MOTION TO DISMISS Counter-Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, pursuant to Rule 1.140(b)(6) and Rule 1.140(e…
…for a More Definite Statement and Motion to Dismiss, promises, it Is hereby heard argument of counsel and being fully advised In those hereby graMMT ORDERED and…
…ROOM 9C SPECIFIC MATTERS TO BE HEARD: (1) Defendant/Counter-Claimant, Bradley J. Edwards' Motion for Leave to Amend to Assert a Claim for Punitive Damages; and (2) Defendant/Counter-Claimant, Bradley J. Edwards' Motion to Dismiss Second Amended Cmiriplaint …
…Fisher, No. 20 Civ. 1818, 2020 WL 2765107, at *2 (S.D.N.Y. May 28, 2020), a motion for voluntary dismissal with prejudice is generally subject "to far less scrutiny," HOV Servs., Inc. v. ASG Techs. Gip., Inc., No…
…2012 Trial Calendar; and it is now further hereby ORDERED that all discovery is STAYED pending the determination of J.P. Molyneux Studio, Ltd.'s Motion to Dismiss. SO ORDERED this day of August 2012. HON. JAMES S. CARROU, III…
…Ltd. and Juan Pablo Molyneux, Plaintiffs, ) AFFIDAVIT OF ROSH D. ALGER IN OPPOSITION TO -against- DEFENDANTS' …
…Motion for a Severance of and Separate Trial on Counts Five and Six of the Superseding Indictment 6. Motion to Strike Surplusage from the Superseding Indictment 7. Motion to Dismiss Counts One Through Six of the Superseding Indictment for Pre…
…By this appeal, the appel- complaint at defendant's place of business lant challenges the correctness of the trial was insufficient where summons and com- court's denial of the motion to dismiss. We plaint were merely left with defendant…
…the matter would be dismissed without further order of this Court. Although Mr. Epstein's affidavit confirming the location of his residence in the U.S. Virgin Islands was filed as part of Mr. Epstein's original motion to quash…
…628 F.2d at 1376). Third, Ms. Maxwell's Motion to Dismiss the claims against her is strong and warrants a stay of discovery pending its resolution. The claims against Ms. Maxwell are barred by the applicable statute of limitations…
…discovery will not be postponed until Edwards' Counterclaim withstands a Motion to Dismiss. 5. The Defendant/Counter-Plaintiff will not sustain any prejudice as a result of a short extension being granted to Plaintiff to respond to these discovery requests. …
…33401: MOTION OF COUNTER-DEFENDANT, JEFFREY EPSTEIN, FOR A MORE DEFINITE STATEMENT AND MOTION TO DISMISS Pursuant to Local Rule No. 4, a good faith attempt was made prior to the hearing on this motion to resolve this matter with…
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