DataSet-9
EFTA00209798
1 pg
From: ' (USAFLS)"
To: ' (USAFLS)"
Subject: Re: Jane Does I United States - Redacted Pleadings
Date: Wed, 03 Jul 2013 15:39:57 +0000
Importance: Normal
I was waiting for the order to make the change on the motion to dismiss. Thanks…
DataSet-9
EFTA00209347
2 pg
…58 AM
To: Sanchez, Eduardo (USAFLS); Lee, Dexter (USAFLS)
Subject: RE: Jane Does t United States - Redacted Pleadings
Hi Ed — I finished reviewing the rest. They all look good. In the Reply in support of the Motion to Dismiss for…
DataSet-9
EFTA00207944
2 pg
…s Office there.
I am writing to request that the Government file new, redacted copies of its currently pending motion to dismiss and motion for stay. As
you may know, the Government has filed these two motions entirely under seal…
DataSet-9
EFTA00208787
3 pg
…Ruling Upon Respondent's Motion to Dismiss
Motion to Seal United States' Reply in Support of Its
E 146 01/26/2012 Motion to Dismiss for Lack of Subject Matter
…
DataSet-9
EFTA01098110
4 pg
…original
memorandum in support of motion to dismiss; (ii) reply memorandum in support of motion to
dismiss for lack of subject mater jurisdiction and (iii) motion to stay discovery pending resolution
of motion to dismiss was appropriately made in conformity…
DataSet-9
EFTA00609955
4 pg
…original
memorandum in support of motion to dismiss; (ii) reply memorandum in support of motion to
dismiss for lack of subject mater jurisdiction and (iii) motion to stay discovery pending resolution
of motion to dismiss was appropriately made in conformity…
DataSet-9
EFTA01081810
4 pg
…original
memorandum in support of motion to dismiss; (ii) reply memorandum in support of motion to
dismiss for lack of subject mater jurisdiction and (iii) motion to stay discovery pending resolution
of motion to dismiss was appropriately made in conformity…
DataSet-9
EFTA00095654
2 pg
…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…
DataSet-9
EFTA00097329
2 pg
…Reply Memorandum in Support of Motion to Dismiss Counts Five and Six of the
Superseding Indictment Because the Alleged Misstatements Are Not Perjurious as a
Matter of Law
5. Reply Memorandum in Support of Motion for a Severance of and…
DataSet-9
EFTA00600054
15 pg
…original
memorandum in support of motion to dismiss; (ii) reply memorandum in support of motion to
dismiss for lack of subject mater jurisdiction and (iii) motion to stay discovery pending resolution
of motion to dismiss was appropriately made in conformity…
DataSet-9
EFTA01081647
10 pg
…emphasis added). On the same day, the Court denied the Government's motion to dismiss the
case and directed that discovery proceed. DE 189.
Epstein and his attorneys quickly sought a stay of the ruling from this Court. DE 193…
DataSet-9
EFTA00079608
4 pg
…submitted in
connection with discovery and evidentiary motions than to summary judgment filings). Thus, a
lower presumption of public access attaches the parties' pretrial bail submissions than to exhibits
introduced at trial or in connection with a motion to dismiss.
…
DataSet-9
EFTA00079612
4 pg
…submitted in
connection with discovery and evidentiary motions than to summary judgment filings). Thus, a
lower presumption of public access attaches the parties' pretrial bail submissions than to exhibits
introduced at trial or in connection with a motion to dismiss.
…
DataSet-9
EFTA00211570
6 pg
…MARRA (S.D. Fla.) itself.
Petitioners further agree to execute the Joint Stipulation of Dismissal with Prejudice that is
attached hereto as Appendix B and which Petitioners herein agree that Respondent may file
in Case No. 08-80736-CIV-MARRA…
DataSet-9
EFTA00211469
6 pg
…MARRA (S.D. Fla.) itself.
Petitioners further agree to execute the Joint Stipulation of Dismissal with Prejudice that is
attached hereto as Appendix B and which Petitioners herein agree that Respondent may file
in Case No. 08-80736-CIV-MARRA…
DataSet-9
EFTA00082136
2 pg
…to the public; and records of such proceedings have
been kept from the public eye. The rule of grand jury secrecy . . . is an integral part
of our criminal justice system.").
• The proposed redactions to the defendant's motion to dismiss…
DataSet-9
EFTA00207838
25 pg
…to comply with Request for Production No. 10.
The Court singled out Epstein's argument about settlement confidentiality as specifically
Docket entry 54 is this Court's Opinion and order granting and denying in part Motion
to Dismiss and Motion…
DataSet-9
EFTA00205152
2 pg
…s Office there.
I am writing to request that the Government file new, redacted copies of its currently pending motion to dismiss
and motion for stay. As you may know, the Government has filed these two motions entirely under seal…
DataSet-9
EFTA00211310
6 pg
…D.
Fla.) itself. Petitioners further agree to execute the Joint Stipulation of Dismissal with
Prejudice that is attached hereto as Appendix B and which Petitioners herein agree that
Respondent may file in Case No. 08-80736-CIV-MARRA (S.D…
giuffre-maxwell
gov.uscourts.nysd.447706.1049.0
91 pg
…in support of 12.1.15
Defendant's Motion to Dismiss
16‐1 Exhibit A‐E 12.1.15
Plaintiff's Memorandum of
23 Law in Opposition of 12.17.15
Defendant's Motion to Dismiss
Declaration of Sigrid McCawley
…
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