…Epstein to file a motion seeking limited intervention so that there are no procedural issues regarding whether the protections and policies relating to Federal Rules of Evidence 410 and 408 should be fully considered by the Court in determining whether…
…for Summary Judgment on the Fourth Amended Counterclaim and Supporting Memorandum of Law, based on the law of the case doctrine. RELEVANT PROCEDURAL BACKGROUND In the Fourth Amended Counterclaim, Edwards raised two claims against Epstein: 1) abuse of process and…
…E. Salt Lake City, UT 84112 Telephone: Facsimile: E-Mail: casse p aw.utah.edu Counsel for Real Party in Interest Jane Doe …
…9014. Procedural History and Findings of Fact This proceeding arises from an agreed order canceling a hearing on a motion to shift costs and setting forth a procedure for the printing of certain documents under a subpoena issued from the…
…Intervenor. I INTERVENOR JEFFREY EPSTEIN'S BRIEF IN OPPOSITION TO JUDICIAL REFORMATION OF THE NON-PROSECUTION AGREEMENT 1 EFTA00299022 TABLE OF CONTENTS …
…6. Motion of BE to exceed page limitations - in general for multiple 9/19/17 motions and supporting memoranda because of the need to address complex factual circumstances and the lengthy and unique procedural history of this case 7. BE…
…Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, files this Motion for Summary Judgment on Defendant/Counter-Plaintiff Bradley Edwards's Fourth Amended Counterclaim, and in support…
…Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, hereby files this Renewed Motion for Summary Judgment on the sole remaining count of Defendant/Counter- Plaintiff Bradley…
…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 Employer…
…Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, files this Motion for Summary Judgment on Defendant/Counter-Plaintiff Bradley Edwards's Fourth Amended Counterclaim, and in support…
…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…
…11 Defendant Ghislaine Maxwell, through counsel, submits this Response to plaintiff’s “Motion to Compel All Work Product and Attorney Client [sic] Communications with Philip Barden” (Doc.637). PROCEDURAL BACKGROUND On February 24, 2016, we served on plaintiff’s counsel…
…as Jeffrey Epstein and Leslie Groff, cannot challenge this Court’s Protective Order. Therefore, the Court should summarily deny this motion. PROCEDURAL HISTORY On March 18, 2016, this Court entered a Protective Order (DE 62) for the privacy of the…
…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…
…5000 TABLE OF CONTENTS PAGE NO. TABLE OF AUTHORITIES ...................................................................................................... iii-v PRELIMINA…
… TABLE OF CONTENTS Page TABLE OF AUTHORITIES .......................................................................................................... ii I. …
…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…
…Defendant. West Headnotes (37) Civil Action No. 14–30211–MGM | Signed October 9, 2015 [1] Federal Courts Substance or procedur
…INTRODUCTION ................................................................................................................. 1 I. PRELIMINARY STATEMENT ..................................................................................... 1 II. CERTIFICATE OF CONFERRAL .................................................................…
…Ghislaine Maxwell, through counsel, submits this Surreply in opposition to plaintiff’s “Motion to Compel All Work Product and Attorney Client [sic] Communications with Philip Barden” (Doc.637). INTRODUCTION Procedurally, plaintiff’s Motion to Compel is a mess. The motion…
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