EFTA00599160Set 9
2010-01-0817p3,349w
Supplement to his Motion for Sanctions
and Alternative Motion to Identify B.B. (the "Initial Motion"). In support, Epstein
states as follows:
1. As stated in Epstein's Initial Motion ... because B.B. wishes to travel under a pseudonym after
6. As stated in the Initial Motion, courts have reasoned that there is no
express or implied right to bring ... requests the Court
enter an order granting the relief requested herein and in the Initial Motion, and for
any additional relief the Court deems just and proper.
Certificate of Service
https://www.justice.gov/epstein/files/DataSet%209/EFTA00599160.pdf
EFTA00723572Set 9
2010-01-0817p2,571w
Supplement to his Motion for Sanctions
and Alternative Motion to Identify M. (the "Initial Motion"). In support, Epstein
states as follows:
EFTA00723573
I v. Epstein
e No. 2008CA037319X)CO0MMI
Page ... because a wishes to travel under a pseudonym after
6. As stated in the Initial Motion, courts have reasoned that there is no
express or implied right to bring ... requests the Court
enter an order granting the relief requested herein and in the Initial Motion, and for
any additional relief the Court deems just and proper.
Certificate of Service
https://www.justice.gov/epstein/files/DataSet%209/EFTA00723572.pdf
EFTA00074599Set 9
2021-04-1569p52,989w
commonly understood to denote a vehicle
an idiosyncratic meaning to the word - motion," and we are
for initiating a new and freestanding lawsuit. As one legal
doubly loathe to ascribe ... different meanings to the very
encyclopedia summarizes matters: "The function of a motion
is not to initiate new litigation, but to bring before the court same word. 15
for ruling ... hours." Id. Importantly here, the provision continues by
the word "motion" to signify an instrument for initiating
stating that "[i]n no event shall proceedings be stayed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00074599.pdf
EFTA00206003Set 9
2011-11-22163p26,539w
explicit filing requirement was deleted from the rule.
As to "initial discovery," my recollection is that, notwithstanding the motion to stay discovery, we expressed a
willingness to look ... explicit filing requirement was deleted from the rule.
As to "initial discovery," my recollection is that, notwithstanding the motion to stay discovery, we expressed a
willingness to look ... explicit filing requirement was deleted from the rule.
As to "initial discovery," my recollection is that, notwithstanding the motion to stay discovery, we expressed a
willingness to look
https://www.justice.gov/epstein/files/DataSet%209/EFTA00206003.pdf
EFTA00726318Set 9
2010-01-2083p25,091w
Filed Prior to the Initial Pre-hearing Conference
If a party files a motion before the Initial Pre-hearing Conference, FINRA Dispute
Resolution will transmit the motion and any responses ... Code of Arbitration Procedure 12503 and 13503. If the motion is not
forwarded to the Panel before the initial pre-hearing conference, the moving party
may raise the issue with ... Asked
Questions document we published on our Web site, www.finra.org.
Is For questions about motion practice under the Old Code, please contact your case administrator.
EFTA00726323
Please contact our office
https://www.justice.gov/epstein/files/DataSet%209/EFTA00726318.pdf
EFTA01158909Set 9
2015-03-1912p3,575w
that the
Government claims is applicable.
As noted in their initial pleading (DE 311 at 1-2), this motion is "protective" because it
may be unnecessary. The victims' currently-filed ... U.S.C. § 2401. Neither
claim has merit and, in any event, the motion to amend relates back to the initial complaint.
3
EFTA01158911
Case 9:08-cv-80736-KAM Document ... that exist in this case. The
victims explained at length in their opening motion that the initial complaint specifically
recounted that the Government had violated the rights of "other victims
https://www.justice.gov/epstein/files/DataSet%209/EFTA01158909.pdf
EFTA01134802Set 9
2013-05-0137p14,486w
Fund will co-
finance the next 100 motion pictures produced or acquired by Universal without
any exclusions.) The Fund may initiate a few additional Fund Pictures by the
Managing Member ... Universal"), to be produced or
acquired and distributed by Universal ("Universal Initiated Pictures"), and possibly a
few additional motion pictures originated by the Company (which will be subject ... applicable motion picture shall be payable thirty (30) days
prior to the initial theatrical release of such motion picture.
1.3 Powers. The Manager shall have the right, at its sole
https://www.justice.gov/epstein/files/DataSet%209/EFTA01134802.pdf
EFTA01728788Set 10
2007-07-2522p3,288w
United States does not contend that intentionally disobeyed the subpoena, but notes that
the Motion to Quash does not address all aspects of the subpoenas and, therefore, the subpoena ... before the grand jury on September 18, 2007. However,
'Witness did not file an initial motion to quash the grand jury subpoenas, but
did file a Reply to the United ... investigation and the matters occurring befiere the grand
jury to Epstein.
Prior to its initial Motion to File Ex Parte Affidavits, Rules, the undersigned conferred
with counsel for Intervenor Epstein
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01728788.pdf
EFTA00723045Set 9
2009-07-295p901w
August 14, 2009, Plaintiffs filed their Reply Memorandum in Support of
Motion for Protective Order (DE 266), and attached and cited newly filed
declarations for which Defendant does not have ... under the rules. Therefore, the declarations delineated below are outside the
scope of Plaintiffs' initial Motion for Protective Order and the Defendants'
Response in Opposition. Moreover, the declarations are untimely ... Jane Doe 4
dated July 17, 2009 because that declaration is attached to Plaintiffs' initial
motion.
EFTA00723046
Memorandum of Law
7. Ivory v. Hoime
https://www.justice.gov/epstein/files/DataSet%209/EFTA00723045.pdf
EFTA00582761Set 9
2012-01-2510p3,117w
pursuant
to Rule 1.530(a) of the Florida Rules of Civil Procedure. Accordingly, this Motion for
Reconsideration is proper so that this Court may consider the burden of proof ... with which Epstein was served, which was
attached as Exhibit B to Epstein's initial Motion to Quash, states thereon that it is "to be served at
an alternate location ... reasons delineated in the case law cited above and in Epstein's initial
Motion to Quash, courts will also quash the service of a nonresident party when that party
https://www.justice.gov/epstein/files/DataSet%209/EFTA00582761.pdf
EFTA00090721Set 9
2021-09-0352p13,922w
complete the story" of the charged
offenses. Id. at 48-49. In its Motion, the defense cited numerous cases in this Circuit holding
that evidence of other conduct involving alleged ... also be excluded under Rule 404(b) and Rule 403.
As argued in our initial Motion, evidence that Ms. Maxwell allegedly encouraged an adult to
engage in legal sexual activity ... misleading
the jury. Fed. R. Evid. 403. As we previously argued in our initial Motion, rape is highly
emotional and inflammatory, much more so than the "sexualized massages" alleged
https://www.justice.gov/epstein/files/DataSet%209/EFTA00090721.pdf
EFTA01325008Set 10
1998-04-0112p6,480w
argument, I resolved several of the issues pertaining to
these motions on the record. As an initial matter, I denied Epstein's motion to remand
and granted Fishers motion ... respect to Soffer only.
DISCUSSION
A. Standards for Summary Judgment
The standards applicable to motions for summary judgment are well-settled. A
court may grant summary judgment only where there ... SDNY_GM_02742798
EFTA_00229447
EFTA01325013
Once the moving party meets its initial burden of production, the burden shifts to
the nonmoving party to demonstrate that there exist genuine issues
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01325008.pdf
EFTA00223050Set 9
1997-12-1711p6,447w
argument, I resolved several of the issues pertaining to these motions on the
record. As an initial matter, I denied Epstein's motion to remand and granted Fisher's motion ... Safer
only.
DISCUSSION
EFTA00223054
A. Standards for Summary Judgment
The standards applicable to motions for summary judgment are well-settled. A court may grant summary
judgment only where there ... nonmoving party."
Anderson, 477 U.S. at 248.
Once the moving party meets its initial burden of production, the burden shifts to the nonmoving party to
demonstrate that there exist genuine
https://www.justice.gov/epstein/files/DataSet%209/EFTA00223050.pdf
EFTA00204759Set 9
1997-12-178p6,452w
argument, I resolved several of the issues pertaining to these motions on the
record. As an initial matter, I denied Epstein's motion to remand and granted Fisher's motion ... respect to Soffer
only.
DISCUSSION
A. Standards for Summary Judgment
The standards applicable to motions for summary judgment are well-settled. A court may grant summary
judgment only where there ... nonmoving party."
Anderson, 477 U.S. at 248.
Once the moving party meets its initial burden of production, the burden shifts to the nonmoving party to
demonstrate that there exist genuine
https://www.justice.gov/epstein/files/DataSet%209/EFTA00204759.pdf