EFTA00804696Dataset 9
2018-04-042p372w
…we must respond by way of this letter. The letter states that you were being provided with a Motion for Ruling on Service of Process on Defendant Jeffrey Epstein with attached exhibits, filed with the clerk of March 29, 2018. In fact, the motion that is attached to the letter was Plaintiffs' Motion for Special Set Hearing/Status Conference. We have strenuously objected to Plaintiffs' Motion for Ruling on Service of Process which may have been filed on March 29…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804696.pdf
EFTA00799428Dataset 9
2018-04-043p972w
…Mr. Titone appears to be attempting, again, to engage in ex parte communication with the Court. Because of this ex parte communication we must respond by way of this letter. We note as a preliminary matter that Mr. Titone's letter states that you were being provided with a Motion for Ruling on Service of Process on Defendant Jeffrey Epstein with attached exhibits, filed with the clerk on March 29, 2018. In fact, the motion that is attached to Mr…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799428.pdf
EFTA00788364Dataset 9
2017-10-1919p6,183w
…Luc Brunel, individually and MCI Model & Talent Miami, LLC vs. Jeffrey Epstein, Tyler McDonald, Tyler McDonald D/B/A/ YLORG Case No.: 14-21348 CA 01 Dear Judge Smith: Please find enclosed a courtesy copy of Defendant, Jeffrey Epstein's, Response to Motion for Ruling on Service of Process on Defendant, Jeffrey Epstein without a Hearing. Because the Plaintiffs attorney, Mr. Titone, is asking by way of his motion that you rule on his motion without a hearing, we are…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00788364.pdf
EFTA00585817Dataset 9
2015-02-094p1,666w
…LLC. Plaintiffs, VS. JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A/ YI.ORG Defendants. MEMORANDUM IN OPPOSITION TO MOTION FOR RULING ON SERVICE OF PROCESS Having already once received this Court's indulgence for Plaintiffs' total disregard of Florida's procedural rules governing proper service of process and a 120-day extension of the time within which to effect service (effectively providing Plaintiffs with a 2-year service window), Plaintiffs again ignore Florida's jurisdictional prerequisites with their improper…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00585817.pdf
EFTA00800147Dataset 9
2017-10-1618p5,835w
…of this Memorandum is attached as Exhibit A. In the seven months that have passed since Mr. Epstein filed his Memorandum in Opposition, Plaintiff has never even attempted to set his motion for hearing. 6. Also in response to Plaintiffs prior Motion for Ruling on Service of Process and because the Plaintiff had failed to comply with this court's order of October 5, 2016, Defendant, Jeffrey Epstein, filed a Motion to Dismiss. As grounds for the Motion to Dismiss…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00800147.pdf
EFTA00610043Dataset 9
2015-02-096p2,835w
…LLC. Plaintiffs, vs. JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/13/A/ YI.ORO Defendants. MEMORANDUM IN OPPOSITION TO MOTION FOR RULING ON SERVICE OF PROCESS Having already once received this Court's indulgence for Plaintiffs' total disregard of Florida's procedural rules governing proper service of process and a 120-day extension of the time within which to effect service (effectively providing Plaintiffs with a 2-year service window), Plaintiffs again ignore Florida's jurisdictional prerequisites with their improper…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00610043.pdf
EFTA00797675Dataset 9
2018-09-1413p3,780w
…Likely to Succeed on the Merits There is indeed a substantial likelihood of success on the merits of Epstein's appeal. In support, Epstein incorporates his March 30, 2017 Motion to Dismiss, his March 30, 2017 Memorandum in Opposition to Plaintiffs' Motion for Ruling on Service of Process, and his July 24, 2018 Supplemental Motion to Dismiss. Without belaboring his arguments previously 6 LINK & ROCKENBACH, PA CIVIL TRIAL & APPELLATE LAW 1555 Palm Beath Lakes Blod . Suite 930 - West Par Beach…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00797675.pdf
EFTA00585821Dataset 9
2015-03-104p921w
…Mr. Epstein in this case (which was Plaintiffs' one and only service attempt during the period of extension granted by this Court) by leaving the summons and amended complaint with a non-party at an office address, which was clearly not Mr. Epstein's personal residence. 7. For the numerous reasons cited in Mr. Epstein's Opposition to Motion for Ruling on Service of Process, Plaintiffs' November 17, 2016 service attempt was improper and ineffective. 8. On December 7, 2016…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00585821.pdf
EFTA00610037Dataset 9
2016-10-056p1,511w
…Epstein in this case (which was Plaintiffs' one and only service attempt during the period of extension granted by this Court) by leaving the summons and amended complaint with a non-party at an office address, which was clearly not Mr. Epstein's personal residence. EFTA00610038 8. For the numerous reasons cited in Mr. Epstein's Opposition to Motion for Ruling on Service of Process, Plaintiffs' November 17, 2016 service attempt was improper and ineffective. 9. On December 7, 2016…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00610037.pdf
EFTA00792289Dataset 9
2018-11-0513p1,908w
…Defendant's App. H, p.106), Brunel then filed a Motion for Ruling on Service of Process on March 16, 2017 (Defendant's App. G). Epstein then filed a motion to quash the service or dismiss until March 30, 2017 (Defendant's App. H,I,J). s EFTA00792293 Finally, on October 16, 2017, Plaintiffs filed a follow-up Motion for Ruling on Service of Process on Epstein (Defendant's App. K). Epstein then filed a Motion in Opposition. (Defendant's…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00792289.pdf