EFTA01199686Set 9
51p10,988w
country, that the
litigation privilege does not apply to the malicious initiation of meritless litigation.
The litigation privilege is designed to protect statements and actions during
litigation, which are pertinent ... stifled. However,
allowing the litigation privilege to immunize parties who maliciously file meritless
litigation is unjustified by the relevant policy considerations, and will eliminate a
significant deterrent to unnecessary litigation ... pertain to the filing of a lawsuit, much less a meritless one
brought with malicious motives.
The first significant clarification of the litigation privilege in Florida after
Myers occurred
https://www.justice.gov/epstein/files/DataSet%209/EFTA01199686.pdf
EFTA01104267Set 9
51p10,994w
country, that the
litigation privilege does not apply to the malicious initiation of meritless litigation.
The litigation privilege is designed to protect statements and actions during
litigation, which are pertinent ... stifled. However,
allowing the litigation privilege to immunize parties who maliciously file meritless
litigation is unjustified by the relevant policy considerations, and will eliminate a
significant deterrent to unnecessary litigation ... pertain to the filing of a lawsuit, much less a meritless one
brought with malicious motives.
The first significant clarification of the litigation privilege in Florida after
Myers occurred
https://www.justice.gov/epstein/files/DataSet%209/EFTA01104267.pdf
EFTA01106989Set 9
51p11,008w
country, that the
litigation privilege does not apply to the malicious initiation of meritless litigation.
The litigation privilege is designed to protect statements and actions during
litigation, which are pertinent ... stifled. However,
allowing the litigation privilege to immunize parties who maliciously file meritless
litigation is unjustified by the relevant policy considerations, and will eliminate a
significant deterrent to unnecessary litigation ... pertain to the filing of a lawsuit, much less a meritless one
brought with malicious motives.
The first significant clarification of the litigation privilege in Florida after
Myers occurred
https://www.justice.gov/epstein/files/DataSet%209/EFTA01106989.pdf
EFTA00102999Set 9
2019-03-26239p78,398w
Sitting in White Plains 198
2. The Defendant's Fair Cross-Section Claim Is Meritless 205
a. The Defendant Has Not Established that Blacks or Hispanics Are Unfairly
Represented ... defendant's motions
to suppress evidence obtained through a judicially approved subpoena are meritless, and her
allegations of Government misconduct are baseless. Fifth, Counts Five and Six—which charge ... negotiate the NPA and is not bound by it.
The defendant's arguments are meritless, and the Court should reject them. As a threshold
matter, under the well-settled
https://www.justice.gov/epstein/files/DataSet%209/EFTA00102999.pdf
EFTA00075024Set 9
2006-10-2331p8,486w
they
have a First Amendment right of access, for years. And if Maxwell's meritless objections prevail,
the public will never have access to those documents.
Recognizing Plaintiff's concern ... reasons to seal the first five motions in their entirety, Maxwell's
objections are meritless. Accordingly, as a general approach, the Court should unseal the first five
motions with only ... were
improperly submitted or constituted an "abuse of court records and files" is meritless. Maxwell
Mem. at 4. Each document at issue was submitted to assist the Court in rendering
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075024.pdf
EFTA01082675Set 9
2013-07-177p1,992w
fully below, neither cause
of action can stand against Epstein; Edwards's Complaint is meritless, and sanctions are
warranted.
MEMORANDUM OF LAW
Epstein is entitled to his attorneys' fees ... costs as sanctions, as Edwards has
filed, and failed to withdraw, a meritless Complaint. Section 57.105 of the Florida
Statutes provides as follows:
(I) Upon the court's initiative ... fully explained
below, Edwards's claims against Epstein are meritless and in direct contravention with
the law, and sanctions are therefore warranted.
LITIGATION PRIVILEGE MANDATES DISMISSAL OF THIS CASE
Florida
https://www.justice.gov/epstein/files/DataSet%209/EFTA01082675.pdf
EFTA00612150Set 9
2013-07-177p2,007w
fully below, neither cause
of action can stand against Epstein; Edwards's Complaint is meritless, and sanctions are
warranted.
MEMORANDUM OF LAW
Epstein is entitled to his attorneys' fees ... costs as sanctions, as Edwards has
filed, and failed to withdraw, a meritless Complaint. Section 57.105 of the Florida
Statutes provides as follows:
(I) Upon the court's initiative ... fully explained
below, Edwards's claims against Epstein are meritless and in direct contravention with
the law, and sanctions are therefore warranted.
LITIGATION PRIVILEGE MANDATES DISMISSAL OF THIS CASE
Florida
https://www.justice.gov/epstein/files/DataSet%209/EFTA00612150.pdf
EFTA00808803Set 9
2018-04-1310p2,526w
Procedure 12(f). Moreover, the Court
should also deny the motion because it is meritless.
Epstein's Motion to Strike Is Untimely.
First, the Court should simply deny Epstein ... denied for that reason as well.
Epstein's Motion Is, in Any Event, Meritless.
Fourth, Epstein's motion simply fails on its merits. A motion to strike "is a drastic
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808803.pdf
EFTA01202952Set 9
2014-10-2017p4,679w
First Request for Production to the Government (DE 260). The Government's objection is
meritless for four reasons.
First, the Government cannot object to discovery on "relevance" grounds, but only ... victims can determine
which documents the Government deems "irrelevant," the Government's arguments are
meritless. The requested documents go to the central issues in this case, such as whether
https://www.justice.gov/epstein/files/DataSet%209/EFTA01202952.pdf
EFTA01114250Set 9
2016-01-2611p2,814w
Motion") has no support in the law or
the facts. It is entirely meritless and should be denied.
INTRODUCTION AND EXECUTIVE SUMMARY
Roberts's counsel, David Boies ("Boies"), does ... they were not), the current motion to strike and for sanctions would be patently meritless.
Settlement communications are admissible at trial for some purposes but are not admissible for
other
https://www.justice.gov/epstein/files/DataSet%209/EFTA01114250.pdf
EFTA00808816Set 9
2009-12-0738p7,270w
result of the severance in this
case, as demonstrated by Epstein's meritless attempt in the Petition to imagine one
possible inconsistency. Specifically, Epstein contends that "one possibility ... proximately caused by Rothstein's illegal conduct ..." (Pet., p.18). That contention
16
EFTA00808836
is meritless, as the jury will not be asked any such question in the trial of Edwards
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808816.pdf
EFTA00596449Set 9
2008-08-0836p11,867w
obtainable from any alternative source").
In short, it is legally meritless for Edwards to rely on the vacated result in the Jane Doe
Action. Instead, he must independently establish that ... traditional sense of the word." Edwards
Aft 1 24. This assertion is meritless. During the course of the sexual abuse litigation, Edwards regularly spoke with
Rush about the litigation
https://www.justice.gov/epstein/files/DataSet%209/EFTA00596449.pdf