EFTA01363297Dataset 10
1995-08-171p633w
…b) claim against Chase, and denied Chase's motion to dismiss the state law claims against it. The district court also denied the Plaintiffs' motion for leave to amend the first amended complaint. The court found that the claims of the Additional Plaintiffs did not relate back to the date of the original complaint under Rule 15(c). Because the claims of the Additional Plaintiffs, without relation-back, were time- barred under the applicable statutes of limitations, the district court…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01363297.pdf
EFTA01363296Dataset 10
1990-04-271p517w
…the Plaintiffs moved for leave to amend the first amended complaint, pursuant to Fed. R. Civ. P. 15(a), to add Laurence LoScalzo, Constance LoScalzo, Kenneth Boklan, Dix Hills Equities Group, Inc., and Dix Hills Air (together, the "Additional Plaintiffs") as parties. The proposed second amended complaint alleged that Black and the other Defendants defrauded the Additional Plaintiffs by For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0053246 CONFIDENTIAL SDNY_GM_00199430 EFTA01363296
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01363296.pdf
EFTA01093254Dataset 9
2015-10-0938p15,352w
…2014, Tamara Green filed a complaint alleging that William H. Cosby, Jr. ("Defendant') publicly defamed her in statements made by individuals operating at his direction and/or within the scope of their employment. (Dkt. No. 1, Compl.) The complaint was subsequently amended to include similar daims by two additional plaintiffs, Therese Serignese and Linda Traitz (collectively, the three are referred to as "Plaintiffs"). (Dkt. No. 13, Am. Compl.) Defendant filed motions to dismiss Plaintiffs' amended complaint in its entirety (Dkt…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01093254.pdf
EFTA01249094Dataset 9
2015-01-142p333w
…Australian Ave, Suite 400 West Palm Beach, FL 33401 From: Sent 201512:04 PM To: Subject Questions Hi - Sorry to trouble you about this case a air but is preparing the government's response to a motion to add two additional plaintiffs, one of whom is Three inquiries have come up. The first relates toM telephone interview of early in the case where stated that she did not want to provide infommaion. Is there a 302 or EC orany other…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01249094.pdf
EFTA01626115Dataset 10
2008-07-0721p7,154w
…Sys., 165 F.3d 419, 425 (6th Cir. 1999). This already-liberal policy is applied even more generously when the proposed amendment simply adds new plaintiffs, because prejudice to the other party is less likely to result from adding additional plaintiffs than from adding new 4 The proposed amended petition contains nine words in it referring to Jane Doe No. 3 and Jane Doe No. 4. As argued in the next section of this pleading, Jane Doe No. 1 and…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01626115.pdf
EFTA02729648Dataset 11
2019-09-1253p10,708w
…Taking the Deposition of. for September 16, 2009. Exhibit 'I" EXHIBIT 2. 09/11/2019 Agency to Agency Requet 19411 CONFIDENTIAL SDNY_GM00331966 EFTA 0020469? EFTA02729676 Page 2 of 11 Page 2 of 33 Page 2 2. Additionally, notices were sent out in other cases in connection with deposing additional Plaintiffs. 3. No objection(s) was/were received for . which was the only deposition set relative to theMMIlaintiffs. 4. On August 27, 2009, the undersigned counsel sent a letter to…
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02729648.pdf
EFTA00298999Dataset 9
10p2,150w
…Weissing, Edwards, Fistos, & Lehrman to disparage Epstein, to seek new clients on whose behalf he can sue Epstein, to attract additional plaintiffs for whom he can file suit, and to achieve notoriety with the press. See Composite Exhibit A attached hereto. FOURTH AFFIRMATIVE DEFENSE For his Fourth Affirmative Defense, Epstein asserts that he is afforded absolute immunity pursuant to the "Litigation Privilege" because at all times his actions were connected with, relevant to, and material to. the cause at hand…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00298999.pdf
EFTA00210695Dataset 9
2008-07-0721p7,074w
…Sys., 165 F.3d 419, 425 (6h Cir. 1999). This already-liberal policy is applied even more generously when the proposed amendment simply adds new plaintiffs, because prejudice to the other party is less likely to result from adding additional plaintiffs than from adding new 4 The proposed amended petition contains nine words in it referring to Jane Doe No. 3 and Jane Doe No. 4. As argued in the next section of this pleading, Jane Doe No. 1 and…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00210695.pdf
EFTA00613644Dataset 9
2008-07-0721p7,141w
…Sys., 165 F.3d 419, 425 (6h Cir. 1999). This already-liberal policy is applied even more generously when the proposed amendment simply adds new plaintiffs, because prejudice to the other party is less likely to result from adding additional plaintiffs than from adding new 4 The proposed amended petition contains nine words in it referring to Jane Doe No. 3 and Jane Doe No. 4. As argued in the next section of this pleading, Jane Doe No. 1 and…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00613644.pdf
EFTA01084920Dataset 9
2013-02-1410p2,387w
…Fistos, & Lehrman, both on its firm website and firm Facebook page, to disparage Epstein, to seek new clients on whose behalf he can sue Epstein, to attract additional plaintiffs for whom he can file suit, and to achieve notoriety with the press. See Composite Exhibit A attached hereto. FOURTH AFFIRMATIVE DEFENSE For his Fourth Affirmative Defense, Epstein asserts that he is afforded absolute immunity pursuant to the "Litigation Privilege" because his actions were connected with, relevant to, and material to…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01084920.pdf