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"R. Civ"
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EFTA00030080
Dataset 8
2021-03-12
3p
505w
Subject:
FW: Jeffrey Epstein/Ghislaine Maxwell/FOIA
From:
' r <
From: '
r
< To:' "< >, ' Subject: FW: Jeffrey Epstein/Ghislaine Maxwell/FOIA Date: Fri. 12 Mar 2021 16:08:21 +0000 You're welcome to join, and I'm adding you to the calendar invitation, but certainly no need, I can deal with this one. From: Sent: Friday, March 12, 2021 11:05 AM To: Cc: >; > Subject: RE: Jeffrey Epstein/Ghislaine Maxwell/FOIA Yes, so far I'm free Monday a.m. pick a time and send…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00030080.pdf
EFTA01372132
Dataset 10
1p
573w
…70 at 21, "the claims of the Class Representatives and the Settlement Class are predicated on the core common issue as to whether Defendants are liable for the damages suffered" by Class members as a result of the defective part. Id. 3. Typicality Under Rule 23(a)(3), the Named Plaintiffs' claims must be "typical of the claims or defenses of the class." Fed.
R
.
Civ
. P. 23(a)(3). 'The typical inquiry is intended to assess . . . whether the named…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01372132.pdf
EFTA00803855
Dataset 9
2018-11-15
3p
1,665w
To:
Igor Zlnoviev
…or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material: The following provisions of Fed.
R
.
Civ
. P. 45 are attached — Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to respond to this subpoena and…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00803855.pdf
EFTA01125871
Dataset 9
2016-05-17
10p
3,255w
To:
LUCIANO FONTANILLA (a/k/a JO JO FONTANILLA)
…or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material: See Schedule A attached. The following provisions of Fed.
R
.
Civ
. P. 45 are attached — Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to respond…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01125871.pdf
EFTA01119772
Dataset 9
2012-06-06
3p
1,461w
…so that the requesting party may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it. Place: Date and Time: The provisions of Fed.
R
.
Civ
. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are attached. Date: CLERK OF COURT Signature ofClerk or Deputy…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01119772.pdf
EFTA01130781
Dataset 9
2015-09-21
8p
1,447w
…breadth that good cause for a stay exists. Any objections to individual discovery requests can be dealt with accordingly, and are not proper grounds for a Rule 26 protective order. See Fed.
R
.
Civ
. P. 34. Finally, with respect to unfair prejudice, Defendant submits that the requested stay is for the limited period of time necessary for the Court to rule on the motion to dismiss, and thus Plaintiff would not be unfairly prejudiced. Def.'s Mot. to Stay at…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01130781.pdf
EFTA00128680
Dataset 9
2010-03-12
70p
13,765w
…set forth below, so that the requesting party may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it. Place: Date and Time: The provisions of Fed.
R
.
Civ
. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are attached. Date: 1, 10 CLERK OF…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00128680.pdf
EFTA00092337
Dataset 9
2017-06-13
1p
84w
From:
r aMIIM>
To:
t' aNIMIIM>, I, r
From:
r
aMIIM> To: t' aNIMIIM>, I,
r
Subject Date: Mon, 24 Feb 2020 17:38:32 +0000 I noticed in the DB presentation mat rial that there is a 6/13/17 transfer from Epstein to with note "Reference Doe 43 v. Epstein et al." as a defendant in that lawsuit (it's docket 17
Civ
. 616 (JGK), so I guess not particularly surprising, but worth being aware of I guess. I added the complaint t itness folder. Assistant…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00092337.pdf
EFTA01371359
Dataset 10
1p
485w
Page 12 2016 U.S. Dist. LEXIS 97188, * and (vii) the binding effect of a class judgment on members under Rule 23(c)(3)." Fed.
R
.
Civ
. P. 23(c)(2)(B). The notice provided to N14 Class members met those requirements. It described the proposed settlement, its terms, and the nature of the claim filed on behalf [*23] of the Class. See 92-4 Ex. A. It also described Class members' right to be excluded from the settlement, to…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01371359.pdf
EFTA00622770
Dataset 9
2016-05-25
13p
4,139w
To:
JEFFREY EPSTEIN
…or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and mast permit inspection, copying, testing, or sampling of the material: PLEASE SEE ATTACHED EXHIBIT A The following provisions of Fed.
R
.
Civ
. P. 45 are attached — Rule 45(c), relating to the place of compliance; Rule .15(d), relating to your protection as a person subject to a subpoena; and Rub 45(e) and (g), relating to your duty to…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00622770.pdf
EFTA00222188
Dataset 9
2008-01-31
11p
2,519w
…herself or himself), but that statute gives the defendant more time to respond than do the federal or Florida rules. See id. (acknowledging that Fed.
R
.
Civ
. P. 4(e)(2) has a "'resided therein' requirement," unlike "New York's substituted service statute," NY CPLR 308); NY CPLR 308 (providing that service is not deemed effected until 10 days after the process-server's affidavit is filed with the Court). This is not a motion to quash, or a motion…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00222188.pdf
EFTA00309164
Dataset 9
6p
1,380w
…motions to reconsider pending. When the Defendant does file an Answer to the First Amended Complaint, the Defendant may assert defenses which may expand the scope of this litigation and thus impact the scope of discovery. Accordingly, this Initial Disclosure Statement is subject to amendment, and the Plaintiffs reserve the right to supplement this disclosure. II. Fed.
R
.
Civ
. P. 26(a)(1)(A)(l1). The following are documents, information and/or things in Plaintiffs' possession, custody or control that…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00309164.pdf
EFTA00205039
Dataset 9
2011-04-20
35p
14,311w
…with a copy of the pleading. Movant first saw the pleading on April 20, 2011. 2 EFTA00205045 Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 4 of 31 (3) the factual contentions have evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable opportunity for further investigation or discovery. Fed.
R
.
Civ
. P. 11(b). Rule 11 uses an objective standard. Kaplan v. DaimlerChrysler, A.G.…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00205039.pdf
EFTA01098979
Dataset 9
2011-03-10
5p
722w
… ) ) Defendant. ) (CARROLL, J.) ) DEFENDANT'S MOTION FOR LEAVE TO FILE AN AMENDED REPLY WITH POINTS AND AUTHORITIES COMES NOW Defendant, FANCELLI PANELING, INC. ("Fanelli"), by and through its undersigned counsel, to move this Honorable Court for its Ordergranting Defendant in this action leave to file an Amended Reply, pursuant to Fed.
R
.
Civ
. P. 7, 12 & IS, LRCI 7.1(d), Super. Ct. Rules 7, 48 U.S.C. §1561 and the Constitutional considerations embodied therein. In support of its…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098979.pdf
EFTA00221158
Dataset 9
2008-06-13
6p
1,859w
…The 1 EFTA00221158 Case 9:08-cv-80380-KAM Document 28 Entered on FLSD Docket 07/16/2008 Page 2 of 6 envelope was marked "personal and confidential" and did not indicate that the envelope was from an attorney or related to a legal action. (DE 6.) Standard of Review Rule 55(c) of the Federal Rules of Civil Procedure states that a "court may set aside an entry of default for good cause." Fed.
R
.
Civ
. P. 55(c)…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00221158.pdf
EFTA00725099
Dataset 9
2010-04-26
9p
2,818w
To:
The C.O.U.Q. Foundation, Inc., by and through its Registered Agent, CT Corporation System, 1200 S. Pine Island
…so that the requesting party may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it. Place: Date and Time: The provisions of Fed.
R
.
Civ
. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are attached. Date: CLERK OF COURT OR Signature ofClerk or…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725099.pdf
EFTA00725262
Dataset 9
1p
71w
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACII COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Fla.
R
.
Civ
. Pro.1201 Plaintiff, Case No. 50 2009CA040800XXXXMB AG v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. CONSENT I, Jeffrey Epstein, hereby consent to the substitution of Fowler White Burnett as my attorneys and the withdrawal of Burman, Critton, Luttier & Coleman. By: Jeffrey Epstein EFTA00725262
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725262.pdf
EFTA00088120
Dataset 9
2020-08-04
9p
3,452w
Subject:
RE: Jeffrey Epstein-Related Touhy Requests
From:
r
To:
c= 2
From:
r
To:' r< Cc: ' „cl [=. Subject: RE: Jeffrey Epstein-Related Touhy Requests Date: Tue, 04 Aug 2020 20:28:04 +0000 Is the 3500 folder just the Witnesses & Cooperators folders, or is there another spot? Sorry if I'm missing / forgetting something. From: Sent: Sunday, August 02, 2020 14:49 To: c= 2 Subject: Fwd: Jeffrey Epstein-Related Touhy Requests With this in mind, could you please save the Touhy correspondence in the 3500 folder? Thanks. Sent from…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00088120.pdf
EFTA00075650
Dataset 9
2021-08-30
13p
5,523w
Subject:
RE: US v. Maxwell - [conferral re photo and other discovery deficiencies]
From:
r
To:
Laura Menriii (USANYS)"
From:
r
To: Laura Menriii (USANYS)" Cc: S) [Contractor]" (USANYS) [Contractor]" alMES> Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Date: Mon, 30 Aug 2021 23:42:05 +0000 Laura, With respect to your questions about the HC materials, as I noted in my earlier email, we do not know how the miscommunication about the number of images happened. Somehow that number was relayed incorrectly to me from the FBI during my verbal conversations with them…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075650.pdf
EFTA00787645
Dataset 9
2017-10-26
11p
2,606w
…Exh. B.) and Order of October 18, 2017 (EFC #67). The decisions of the Jane Doe Matter Court to suspend the filing of the motion to dismiss until a decision on the Motion to Modify in this case is entirely consistent with New York law. It is well-settled that a court may consider evidence outside of the complaint on a motion to dismiss based on personal jurisdiction pursuant to Fed.
R
.
Civ
. P. 12(b)(2). See Pearson Educ.…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00787645.pdf
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