EFTA01193709Set 9
2008-07-1611p6,425w
provide a synopsis of the release terms and the proposals did not
specifically articulate what, if any, claims were to be resolved if Appellants/Plaintiffs accepted the proposals.
Pursuant to Swartsel ... which was identified in Appellee/Defendant's proposals. Therefore, because the proposals do not
specifically articulate what, if any, claims, were to be resolved if Appellants/Plaintiffs accepted the proposals,
Appellee/Defendant ... Tortious Interference. The counts descnbed in Appellee/Defendant's Counterclaim's were not articulated in his
Proposals for Settlement. The proposals therefore, cannot be deemed clear and unambiguous when the specific
https://www.justice.gov/epstein/files/DataSet%209/EFTA01193709.pdf
EFTA00105779Set 9
2021-04-0974p19,866w
factor in a capital case, nor have I understood you
15 to be even articulating that. I understand it solely to be
16 that he apparently did a good deed ... going to be
23 withholding under FOIA, to be able to articulate what at least
24 you have in mind beyond that, because it can't be that
25 Tartaglione ... L49KNEWM
1 Curtain descends over the Bureau of Prisons' production; you
2 need to articulate what it is, what the factual component is,
3 of the interaction between Tartaglione
https://www.justice.gov/epstein/files/DataSet%209/EFTA00105779.pdf
EFTA00075024Set 9
2006-10-2331p8,486w
serious
to warrant protection."). "[B]road allegations of harm unsubstantiated by specific examples or
articulated reasoning fail to satisfy the test."In re Parmalat Sec. Litig., 258 F.R.D ... specific documents should remain
shielded from the public demonstrates that she cannot articulate such specific reasons and cannot
meet her burden.
Further, the central allegations underlying this case—that Maxwell ... cause substantial
harm." Brown, 929 F.3d at 50. Further, "a court must still articulate specific and substantial
5
EFTA00075032
CasaP.€1.g--16Ata3g4SaineDiggrfieAFiag0414491K034,26a81*403tif 24
reasons for sealing
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075024.pdf
EFTA00606510Set 9
2014-01-2778p19,578w
know,
14 Judge Cope is very well-respected and his opinions
15 are very articulate, but it also ignores a
16 Third DCA's full panel's decision ... litigation privilege.
12 But as I've indicated, the most cogent and
13 well articulated opinion on this subject is
14 Judge Sasser's opinion in Johnson vs. Libow ... KING: But certainly not malicious
5 prosecution for the reasons that are
6 well-articulated by Judge Sasser and others. And
7 with regard to the reasons I've just
https://www.justice.gov/epstein/files/DataSet%209/EFTA00606510.pdf
EFTA00596701Set 9
2017-01-1917p4,739w
newspaper
intervention granted so that it may "articulate the public interest in access to the records at issue").
Movant's intervention is appropriate to protect not only its own interest ... open to the public, and by
extension the news media, absent the most clearly articulated and compelling reason for closing
them in a particular circumstance." Katzman v. Victoria's Secret ... could not, hypothetically even meet a lower "good cause" standard, as none has been articulated.
See, e.g., United States v. Amodeo II, 71 F.3d
https://www.justice.gov/epstein/files/DataSet%209/EFTA00596701.pdf
EFTA00105954Set 9
2021-10-1112p2,803w
requires particularized notice to the defense of the exact evidence to be offered,
an articulated non-propensity purpose for its admission, and the reasoning supporting that
purpose. Despite notice ... trial, so that the defendant has a fair opportunity to meet it;
(B) articulate in the notice the permitted purpose for which the prosecutor intends to offer
the evidence ... identify the evidence that it intends to offer
pursuant to the rule but also articulate a non-propensity purpose for which the
evidence is offered and the basis for concluding
https://www.justice.gov/epstein/files/DataSet%209/EFTA00105954.pdf
EFTA00016206Set 8
2021-10-1112p2,782w
requires particularized notice to the defense of the exact evidence to be offered,
an articulated non-propensity purpose for its admission, and the reasoning supporting that
purpose. Despite notice ... trial, so that the defendant has a fair opportunity to meet it;
(B) articulate in the notice the permitted purpose for which the prosecutor intends to offer
the evidence ... identify the evidence that it intends to offer
pursuant to the rule but also articulate a non-propensity purpose for which the
evidence is offered and the basis for concluding
https://www.justice.gov/epstein/files/DataSet%208/EFTA00016206.pdf
EFTA00285631Set 9
2018-08-0770p17,816w
analysis in Abarca, which basically is that Congress had the
16 ability to articulate that it wished to apply it retroactively,
17 wished to apply it to any action that ... certainly
11 understand, accept and agree with the proposition as you've
12 articulated it as far as it goes, but I think that the case law
13 with respect ... purposes of the
allegations in this complaint.
MR. MILLER: Well, I think we carefully articulated in
4 our motion papers that the reason we cited to the
5 evidence
https://www.justice.gov/epstein/files/DataSet%209/EFTA00285631.pdf
EFTA00792343Set 9
57p11,385w
form. See A.4 (Order Appealed From, dated Jan.
18, 2011). The Court failed to articulate any findings of fact or
conclusions of law, as required under SORA. See A.4 (Order ... process
safeguards). Courts evaluating that liberty interest under the
procedural due process analysis articulated by the U.S. Supreme Court
in Matthews v. Eldridge, 424 U.S. 319 (1976) (balancing the private ... evidence; and
(7) the right to appeal.
33
EFTA00792381
See id. at 471-72 (articulating the above seven procedures as essential
to satisfy procedural due process when assigning risk levels
https://www.justice.gov/epstein/files/DataSet%209/EFTA00792343.pdf
EFTA00603264Set 9
2010-08-1657p11,344w
Order efAppealed From, dated Jan. 18, 2011). The Court
failed to articulate any findings of fact or conclusions of law, as required
under SORA. See RA.-4 (Order ef4pnealed From ... safe • u :_rd . Courts evaluating
that liberty interest under the procedural due process analysis
articulated by the U.S. Supreme Court in Matthews v. Eldridge, 424 U.S.
319, 96 S.Ct ... convincing
evidence; and
(7) the right to appeal.
See id. at 471-72 (articulating the above seven procedures as essential to
satisfy procedural due process when assigning risk levels under
https://www.justice.gov/epstein/files/DataSet%209/EFTA00603264.pdf
EFTA01077101Set 9
61p12,214w
form. See A.4 (Order Appealed From, dated Jan.
18, 2011). The Court failed to articulate any findings of fact or
conclusions of law, as required under SORA. See A.4 (Order ... process
safeguards). Courts evaluating that liberty interest under the
procedural due process analysis articulated by the U.S. Supreme Court
in Matthews v. Eldridge, 424 U.S. 319 (1976) (balancing the private ... convincing
evidence; and
the right to appeal.
33
EFTA01077140
See id. at 471-72 (articulating the above seven procedures as essential
to satisfy procedural due process when assigning risk levels
https://www.justice.gov/epstein/files/DataSet%209/EFTA01077101.pdf
EFTA00086277Set 9
2020-09-043p1,213w
under COVID-lockdown is "not [a] great"
burden. Both arguments are borderline frivolous.
No articulated harm to Plaintiff's interests: Despite proclaiming a stay will
"harm plaintiff's interests ... Criminal Case
will resolve those issues one way or the other. Plaintiff does not articulate a basis for
her desire to pursue all three avenues simultaneously nor why such multiple ... been indicted." Resp. at 6.
The Second Circuit has a litany of factors, articulated in Louis Vuitton Malletier S.A.
v. LY USA, Inc., 676 F.3d
https://www.justice.gov/epstein/files/DataSet%209/EFTA00086277.pdf
EFTA01166123Set 9
2014-01-2763p13,023w
know,
14 Judge Cope is very well-respected and his opinions
15 are very articulate, but it also ignores a
16 Third DCA's full panel's decision ... litigation privilege.
12 But as I've indicated, the most cogent and
13 well articulated opinion on this subject is
14 Judge Sasser's opinion in Johnson vs. Libow ... KING: But certainly not malicious
5 prosecution for the reasons that are
6 well-articulated by Judge Sasser and others. And
7 with regard to the reasons I've just
https://www.justice.gov/epstein/files/DataSet%209/EFTA01166123.pdf
EFTA00794298Set 9
2018-11-1310p3,063w
truth. Pursuant to long-
established Florida Supreme Court precedent, Epstein is required to articulate his "specific legal
argument" in order to properly preserve it for appeal to the Fourth District ... Edwards' sworn testimony in this lawsuit. Rather,
Epstein complied with Florida law by articulating his specific legal arguments as to why the e-
mails are relevant, never had any attorney ... should be darned if he does, darned if
he does not. Had Epstein not articulated the specific legal bases in his motion, Edwards would
have claimed "lack of preservation
https://www.justice.gov/epstein/files/DataSet%209/EFTA00794298.pdf