…Filer: Sarah Kellen Document Number: 56 Docket Text: Defendant's MOTION to Adopt/Join [31] Reply to Response to Motion, [13] Defendant's MOTION to Dismiss [1] ComplaintDefendant's MOTION to Dismiss [1] Complaint by Sarah Kellen. (Attachments: # (1) Text…
…Mr. We will shortly be filing a motion to compel Government responses to our discovery requests — discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay…
…So, I beefed up the facts about the LM complaint using the quote from the motion to dismiss it. We will need an affidavit for JE today as well. If you have the prior version and want to tweak it…
…Filer: Jeffrey Epstein Document Number: 104 Docket Text: RESPONSE/REPLY to [92] Response to Motion to Dismiss by Jeffrey Epstein. (Pike, Michael) 9:08-o-80893 Notice has been electronically mailed to: Bradley James Edwards Jack Alan Goldberger Michael James…
…you asked the government not to file a motion to dismiss for lack of prosecution, maintaining that such a motion would be ill-founded. When I asked why the petitioners were concerned about the government filing an ill-founded motion…
…Mr. We will shortly be filing a motion to compel Government responses to our discovery requests -- discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay…
…Dear We will shortly be filing a motion to compel Government responses to our discovery requests -- discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay…
…a parallel state court claim thus she has not, by affirmative waiver filed before the challenged Motion to Dismiss, committed herself to a litigation strategy that would potentially qualify her for the waiver of liability obligation On Fri, Jun 19…
…eenehre We will shortly be filing a motion to compel Government responses to our discovery requests — discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay…
…the position that the pre-2006 Amendments version of the law applies. See Defendant Epstein's Motion to Dismiss, for More Definite Statement and To Strike Directed to Plaintiff Jane Doe's Complaint at 9, Jane Doe v. Jeffrey Epstein…
…2008 WL 591869, at *9 (S.D.N.Y. Mar. 4, 2008)). Indeed, a district court has authority to allow "jurisdictional discovery" to proceed even while a motion to dismiss is pending. See, e.g., Daventree Ltd. v. Republic of…
…you asked the government not to file a motion to dismiss for lack of prosecution, maintaining that such a motion would be ill-founded. When I asked why the petitioners were concerned about the government filing an ill-founded motion…
…to his files, it is clear that despite counsel's efforts in the past, discovery has proceeded slowly, depositions and IMEs have been subjected to extensive motion practice, and their remain pending discovery disputes and an outstanding Motion to Dismiss…
…and May 21, 2012, respectively (after each successful Motion to Dismiss). > At this point of the litigation, your Counterclaim has been dismissed three (3) times for its deficiencies. If you are conceding that Mr. Edwards' Counterclaim has no merit…
… By this Motion, Ms. seeks to file a responsive pleading in this action by adopting as if set forth legally and factually by Ms. M, co-defendant Jeffrey Epstein's Motion to Dismiss Plaintiff's Complaint and Supporting Memorandum and…
…Page 1 of 13
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
Plaintiff,
Case No.: I5-cv-07433-RWS
Ghislaine Maxwell,
Defendant.
REPLY MEMORANDUM OF LAW IN SUPPORT OF
DEFENDANT'S
…to dismiss Plaintiff's original Complaint in this action. 9 EFTA_R1_00012694 …
…and battery. Accordingly, even if the Complaint had not been amended, it sufficiently alleges facts establishing an assault and battery. Based on the foregoing, Defendant's Motion to Dismiss is moot, and, in any event, not well founded, and therefore…
…to dismiss Plaintiff's original Complaint in this action. 9 EFTA_R1_02213302 …
…the allegations in the complaint are true (even if doubtful in fact)." Id. On a motion to dismiss, the well pleaded allegations of plaintiff's complaint are taken as true and construed in the light most favorable to the plaintiff…
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