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Found 730 results for "Lang"
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(15 occurrences)
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...adequate punishment if this was a purely federal case versus what is necessary so that it is not a to put it in petite language a manifest injustice so that it wouldnt have come to the office in the first place And that I think is the importan...
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...oped that tomorrow Friday the 3rd A Right hed have a chance to and whats notable here is that is that the theres strong language that the Office believes that the federal interest would not be vindicated in the absence of a two year term of sta...
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...oncrete that is setting right A Right And lib is the letter as it actually went out the next day A And its got the same language Its identical It has the same language It has one typo corrected This is last day in the office A Yes And hes gone...
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(15 occurrences)
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Page Draft language From Hugh Hurwitz To Date Subject Ray Ormond __ Draft language Attachments TEXT.htm discussed severa options are be...
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...VE i nformation it should be properly delivered labe led stored and disposed of according to po licy Page Page RE Draft language From To Date Subject I OAG Hugh HurwitzRay Ormond RE Draft language Attachments TEXT.htm Mime.822 Page Page Thanks...
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...rom Hugh Hurwitz lt i bop.gov Sent Sunday August PM To lt mt OAG jmd.usdoj.gov Cc Ray Orman it tc bop.gov Subject Draft language Ic as discussed several options are below Please note that we should discuss timing of all this I will need to ensu...
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(10 occurrences)
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...I I I I I I I I I I I I I I I a Call Type O,P,E,N D,O i Entry Day REVIEW P,E,N D,O,O,R i Caller Name Last UNK BM First LANGUAGE BARRIE Mid See Ca ller Addre Dr Mod Ci y/S tat Phone Source L,o a t,i,o Dr EL BRILLO WY Mod C,i t.Y PALM BEACH I.D a...
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...l i sp Addtl Locations Vehicle Persons Page of Call Entry Day/Tm Caller Name Last UNK BM Type E.N i REVIEW E.N i First LANGUAGE BARRIE Mid Se Caller Address Dr City/State L,o,c,a i Dr i,t PALM BEACH issued Phone EL BRILLO B.l o.c A A I cleared...
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...-kind contributions amounted to in aid Jerry Perenchio president of Univision Perenchio founded Univision the Spanish language 1V network that broadcasts throughout the United http abqtrib.com/archives ne news donate.shtml age of28 TERRORIST SI...
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(15 occurrences)
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...she is immune from prosecution for any federal crime during any time period anywhere in the United States based on the language of a document that does not name her and which she did not sign Moreover she seeks to enforce the NPA against a U.S...
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...t at Aside from the reference to United States which as noted above is insufficient the defendant does not point to any language in this provision that purportedly binds other districts Instead she argues that the absence of language specifical...
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...rict in which they are entered absent affirmative indications otherwise Put differently the absence of express limiting language in this provision is not an affirmative indication of a broader application Accordingly under Second Circuit law th...
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(10 occurrences)
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...plication of current law Specifically your action for declaratory relief fails based on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is ordered by a court pursuant to subsection fo...
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...s Ins Co Loftus So 3d Fla 4th DCA As is always the case when a court undertakes a legislative intent analysis the plain language of the statute is the starting and often ending point See Horowitz So 2d at When the statute is clear and unambiguo...
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...ng point See Horowitz So 2d at When the statute is clear and unambiguous courts will not look behind the statutes plain language for legislative intent or resort to rules of statutory construction to ascertain intent Loftus So 3d at Fla 4thDCA2...
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(15 occurrences)
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...re sent by an FBI administrative employee who was not directly involved in the investigation incorporated standard form language used by the FBI when communicating with victims and were not drafted or reviewed by the subjects Moreover the state...
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...e Defense Notifies Acosta That It May Pursue a Department Review of the USAOs Actions Acosta Attempts to Revise the NPA Language concerning Monetary Damages but the Defense Does Not Accept It January Acosta and Sloman Meet with Sanchez Who Make...
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...d the terms of the NP A Villafana was the primary USAO representative negotiating with defense counsel and drafting the language of the NP A under her supervisors direction and guidance and she signed the NPA on behalf of the USAO Thereafter Vi...
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(15 occurrences)
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...gs Davis Bailynson So 3d Fla 4th DCA See Bionetics Corp Kenniasty So 3d Fla Accordingly Fla Stat provides the following language authorizing the award of attorneys fees as sanctions in actions such as the present litigation Upon the courts init...
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...erved in conjunction with a demand In fact regarding motions for attorneys fees the Statute is limited to the following language regarding the safe harbor provision A motion by a party seeking sanctions under this section must be served but may...
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...ument here Plaintiff has failed to provide any supporting authority whatsoever and there is no statutory requirement or language in that supporting record evidence must exist to properly serve a demand and motion for attorneys fees The central...
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(15 occurrences)
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...ils under the Statute Plaintiff has failed to provide any supporting authority and there is no statutory requirement or language in that supporting record evidence must exist to properly serve a demand and motion for attorneys fees See Plaintif...
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...request by a grand jury for use by the grand jury or on order the court pursuant to Florida Statutes Based on the clear language of Fla Stat there can be no good faith reasonable expectation of success for the State Attorney to produce and disc...
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...charged with the more serious crimes of sexual activity with minors and slammed State Attorney Barry Krischer in blunt language seldom used by one law enforcement official with another because of what he perceived as that offices mishandling o...
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(14 occurrences)
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...umstances where fees should be awarded and the purpose is to defer meritless filings The statute provides the following language authorizing the award of attorneys fees such as in the present litigation It says Upon the Court-31.1 initiative or...
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...here under a but that does not apply here in any sense and I ll explain to you why First let me read you the statutory language This is a and it says Notwithstanding subsections and monetary sanctions may not be awarded a Under paragraph if th...
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...it applied to the material facts and with a reasonable expectation of success So here the plaintiff tries to twist the language of that statute in two different ways to suit its argument First they entirely failed to recognize that the a sic d...
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(12 occurrences)
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...reasonable and obvious implications To do so would be an abrogation of legislative power Id Accordingly here the plain language of section is clear and unambiguous and therefore controls See Horowitz Plantation Gen Hosp Ltd 2ship So 2d Fla Aga...
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...s reasonable and obvious implications To do so would be an abrogation oflegislative power Id Accordingly here the plain language of section is clear and unambiguous and therefore controls See Horowitz Plantation Gen Hosp Ltd ship So 2d Fla Agai...
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...mand letter and motion for attorneys fees The course of action taken by the State Attorney actually tracks the specific language set forth in the Statute to wit A motion by a party seeking sanctions under this section must be served but may not...
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(15 occurrences)
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...OSEPH ABRUZZO CLERK PM Epste ttorney Jack Goldberger did not return messages A source close to the case suggested it is languishing pending a decision by the FBI oh whether to refer it to federal prosecutors still have a pending case FBI spokes...
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...OSEPH ABRUZZO CLERK PM Epste.ttorney Jack Goldberger did not return messages A source close to the case suggested it is languishing pending a decision by the FBI on whether to refer it to federal prosecutors We 5till have a pe_IJ,4ing case FBI...
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...I know thats what theyreusing as their basis to get to these But its our position that the clear unambiguous statutory language it shows that this disclosure only applies to a civil or criminal case and that within that civil or criminal Speak...
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(15 occurrences)
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...re sent by an FBI administrative employee who was not directly involved in the investigation incorporated standard form language used by the FBI when communicating with victims and were not drafted or reviewed by the subjects Moreover the state...
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...re sent by an FBI administrative employee who was not directly involved in the investigation incorporated standard form language used by the FBI when communicating with victims and were not drafted or reviewed by the subjects Moreover the state...
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...ense Notifies Acosta That It May Pursue a Department Review of the USAO 2s Actions.99 Acosta Attempts to Revise the NPA Language concerning Monetary Damages but the Defense Does Not Accept January Acosta and Sloman Meet with Sanchez Who Makes A...
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(15 occurrences)
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...rwarded to Fisher CA/Aronberg-0567 FILED PALM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Acosta Attempts to Revise the NPA Language concerning Monetary Damages but the Defense Does Not Accept It Acosta undertook to respond to defense counsel 2s co...
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...defense counsel 2s continuing concern about the provision He sent to Deputy Assistant Attorney General Sigal Mandelker language that he proposed including in a revision to the NPA 2s implementation section Mandelker forwarded the language to h...
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...Acosta sent to Sanchez a letter proposing to resolve 223our disagreements over interpretation by replacing the existing language of the NPA relating to with a provision that would read Any person who while a minor was a victim of a violation of...
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(11 occurrences)
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...there was an allegation of an attempted suicide the court made inquiry The court obviously was interested I recall your language You talked about that being one of the several open questions indicating an interest on the court for the others as...
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...there was an allegation of an attempted suicide the court made inquiry The court obviously was interested I recall your language You talked about that being one of the several open questions indicating an interest on the court for the others as...
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...es the Crime Victim Rights Act and the very statute that Mr Epstein is being prosecuted under but it ignores the actual language of those statutes and many other statutes in which Congress has made clear that the purpose of the criminal law is...
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(15 occurrences)
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...aintiffs attempt to multiply the penalties recoverable under a by pleading six separate counts is inconsistent with the language and structure of The law allows for a single action predicated on any and all predicate criminal acts and entitles...
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...law does refer to a minor it changes the laws present-tense references is to past-tense references was And the laws new language now makes clear that unlike the statute those victimized while under the age of may sue after they turn Given that...
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...Mashas Law superfluous it would make Mashas Laws internally redundant because Mashas Law retained the legal disability language from the version of See U.S.C In short the retained legal disability language in of the statute would be entirely r...
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(10 occurrences)
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...al criminal statute U.S.C as the requisite predicate act for a claim pursuant to U.S.C a Plaintiff generally tracks the language of subsection of U.S.C eff Apr which states in relevant part Whoever using the mail or any facility or means of int...
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...ue as to any material fact and that the moving party is entitled to a judgment as a matter of law In our view the plain language of Rule mandates the entry of summary judgment after adequate time for discovery and upon motion against a party wh...
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...of the statutory minimum previously in effect during the time of the alleged acts The statute as amended in contains no language stating that the application is to be retroactive Thus there is no manifest intent that the statute is to apply ret...
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(15 occurrences)
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...ally Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Case No 08-CV-80380-Marra-Johnson Page tracks the language of subsection of U.S.C which states in relevant part Whoever using the mail or any facility or means of interstate...
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...ue as to any material fact and that the moving party is entitled to a judgment as a matter of law In our view the plain language of Rule mandates the entry of summary judgment after adequate time for discovery and upon motion against a party wh...
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...of the statutory minimum previously in effect during the time of the alleged acts The statute as amended in contains no language stating that the application is to be retroactive Thus there is no manifest intent that the statute is to apply ret...
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(10 occurrences)
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...al criminal statute U.S.C as the requisite predicate act for a claim pursuant to U.S.C a Plaintiff generally tracks the language of subsection of U.S.C eff until Apr which states in relevant part Whoever using the mail or any facility or means...
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...sue as to any material fact and that the moving party is entitled to a judgment as a matter oflaw In our view the plain language of Rule mandates the entry of summary judgment after adequate time for discovery and upon motion against a party wh...
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...on FLSD Docket Page of Jane Doe No Epstein Case No 08-CV-80381-Marra-Johnson Page The statute as amended in contains no language stating that the application is to be retroactive Thus there is no manifest intent that the statute is to apply ret...
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(10 occurrences)
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...al criminal statute U.S.C as the requisite predicate act for a claim pursuant to U.S.C a Plaintiff generally tracks the language of subsection of U.S.C eff Apr which states in relevant part Whoever using the mail or any facility or means of int...
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...sue as to any material fact and that the moving party is entitled to a judgment as a matter oflaw In our view the plain language of Rule mandates the entry of summary judgment after adequate time for discovery and upon motion against a party wh...
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...of the statutory minimum previously in effect during the time of the alleged acts The statute as amended in contains no language stating that the application is to be retroactive Thus there is no manifest intent that the statute is to apply ret...
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(13 occurrences)
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...prior counts It is well settled that in interpreting a statute the courts inquiry begins with the plain and unambiguous language of the statutory text CBS Inc Prime Time Venture F.3d th Cir U.S Castroneves WL S.D Fla citing Reeves Astrue F.3d t...
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...ts inquiry begins with the text The Court must first look to the plain meaning of the words and scrutinize the statutes language structure and purpose Id In addition in construing a statute a court is to presume that the legislature said what i...
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...n construing a statute a court is to presume that the legislature said what it means and means what it said and not add language or give some absurd or strained interpretation As stated in CBS Inc supra at Those who ask courts to give effect to...
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(14 occurrences)
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...of the case and must be admiss ible or reasonably calculated to lead to admissible evidence See Allstate llisu.rance Co Langston So.2d Amente Newma11 So.2d Ru.mill Stardu:,t Crufs ers Inc So.2d Fla 5th DCA The concept of relevancy ls broader in...
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...prior counts It is well settled that in interpreting a statute the courts inquiry begins with the plain and unambiguous language of the statutory text CBS Inc Prime Time Venture F.3d th Cir U.S Castroneves WL S.D Fla citing Reeves Astrue F.3d t...
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...ts inquiry begins with the text The Court must first look to the plain meaning of the words and scrutinize the statutes language structure and purpose Id In addition in construing a statute a court is to presume that the legislature said what i...
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(13 occurrences)
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...prior counts It is well settled that in interpreting a statute the courts inquiry begins with the plain and unambiguous language of the statutory text CBS Inc Prime Time Venture F.3d th Cir U.S Castroneves WL S.D Fla citing Reeves Astrue F.3d t...
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...ts inquiry begins with the text The Court must first look to the plain meaning of the words and scrutinize the statutes language structure and purpose Id In addition in construing a statute a court is to presume that the legislature said what i...
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...n construing a statute a court is to presume that the legislature said what it means and means what it said and not add language or give some absurd or strained interpretation As stated in CBS Inc supra at Those who ask courts to give effect to...
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Content Matches:
(10 occurrences)
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...al criminal statute U.S.C as the requisite predicate act for a claim pursuant to U.S.C a Plaintiff generally tracks the language of subsection of U.S.C which states in relevant part Whoever using the mail or any facility or means of interstate...
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...ue as to any material fact and that the moving party is entitled to a judgment as a matter of law In our view the plain language of Rule mandates the entry of summary judgment after adequate time for discovery and upon motion against a party wh...
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...of the statutory minimum previously in effect during the time of the alleged acts The statute as amended in contains no language stating that the application is to be retroactive Thus there is no manifest intent that the statute is to apply ret...
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(14 occurrences)
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...he jurisdiction of the federal court over claims is exclusive However unlike other Congressional enactments there is no language in the statute which expressly states that jurisdiction of such cause of action lies exclusively with the federal c...
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...he specified criminal acts occurring prior to the statutes effective date of July The statute as amended in contains no language stating that the application is to be retroactive Thus there is no manifest intent that the statute is to apply ret...
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...gly this Court is required to apply the statute in effect at the time of the alleged criminal acts Not only is there no language in the statute stating that it is to apply retroactively but further such application of the version of U.S.C to ac...
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(10 occurrences)
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...those who deliberately knowingly and intentionally target and exploit children through the internet Though the literal language may superficially apply to a wider variety of behaviors we submit that the statute cannot properly be used to prose...
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...ch as a man traveling with his paramour which we submit never implicated a legitimate federal concern See generally D.J Langum Crossing the Lines Legislating Morality Under the Mann Act Even where there is broad agreement that certain conduct s...
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...e or attempts to do so shall be fined under this title and imprisoned not less than ten years or for life The statutory language and reported decisions confirm the statutes important but nan-ow focus the luring of children over the internet Unl...
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(10 occurrences)
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...data shall remain or be made visible presenter notes shall remain or be made visible and to the extent ESI in a foreign language is produced processing of such ESI shall be unicode-compliant Document Unitization If a Native Format file that is...
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...data shall remain or be made visible presenter notes shall remain or be made visible and to the extent ESI in a foreign language is produced processing of such ESI shall be unicode-compliant Document Unitization If a Native Format file that is...
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...data shall remain or be made visible presenter notes shall remain or be made visible and to the extent ESI in a foreign language is produced processing of such ESI shall be unicode-compliant Document Unitization If a Native Format file that is...
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(15 occurrences)
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...ends to rely upon it But this was an authored decision by Judge Melanie May from the Fourth DCA And that case has great language to guide this Court PALM BEACH REPORTING SERVICE INC on In that case Judge May wrote We do not quarrel with those c...
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...es that not sound inequitable Does that not sound inappropriate Does that not sound specifically contrary to the quoted language that I have just indicated here MS ROCKENBACH The quoted language as you indicated Your Honor I made knowing that t...
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...e Plaintiff and his trial counsel will not seek another continuance and be will be ready to try the case in days quoted language pledging to this Court that otherwise this case is ready to go and now we are faced with this defect after all of t...
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(12 occurrences)
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...IRE PODHURST ORSECK P.A West Flagler Street Suite Miami Florida Phone rjosefsberg podhurst.com kezell podhurst.com ADAM LANGINO ESQUIRE LEOPOLD KUVIN PGA Boulevard Suite Palm Beach Gardens Florida Phone skuvin leopoldkuvin.com PROSE COURT REPOR...
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...arge in the above cause Continued from Volume I VIDEOGRAPHER Were going back on the record at I CROSS EXAMINATION BY MR LANGINO Hello My name is Adam Langino and I represent B.B Ill have fewer questions than the rest of everybody since Im going...
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...ronically signed by Sandra Townsend bcae87 de Case Document Filed Page of Page answers in response to your questions MR LANGINO Thank you BY MR LANGINO One thing I wasnt sure about was the date of your employment When did you start with Mr Epst...
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(11 occurrences)
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...Y KATHERINE EZELL West Flagler Street Suite Miami Florida Attorney for Jane Doe and Page APPEARANCES LEOPOLD-KUVIN ADAM LANGINO ESQ PGA Boulevard Suite Palm Beach Gardens Florida Attorney for B.B RICHARD WILLITS ESQ 10th Avenue North Suite Lake...
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...P BY ROBERT CRITTON ESQ North Flagler Drive Suite West Palm Beach Florida Attorney for Jeffrey Epstein ALSO PRESENT JOE LANGSAM VIDEOGRAPHER Case Document Filed Page of Rue Notre Dame Miami Beach FL Kress Court Reporting Inc Pages to Page INDEX...
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...ing Inc Pages to Page INDEX OF EXAMINATION WITNESS DIRECT CROSS ALFREDO RODRIGUEZ By Mr Mermelstein By Mr Edwards By Mr Langino INDEX OF EXHIBITS 11-18.8EXHIBITS PAGE Message pad Documents Page 1-1235.4Deposition taken before MICHELLE PAYNE Cou...
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(15 occurrences)
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...Filed Page of ALL VR FLIGHTS Sorted by Date 784.5F0light GIUFFRE BATES Jeffrey Epstein JE AP Albert Pinto or Adam Perry Lang Virginia Roberts VR Unidentified Female US Virgin Islands West Palm Beach Jeffrey Epstein JE Ghislaine Ma-3.1xwell GM E...
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...ll GM Sarah Kellen London England White Plains NY Jeffrey Epstein JE Ghislaine Maxwell GM AP Albert Pinto or Adam Perry Lang Unidentified Female West Palm Beach US Virgin Islands Jeffrey Epstein JE Ghislaine Maxwell GM Sarah Kellen AP Albert Pi...
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...le West Palm Beach US Virgin Islands Jeffrey Epstein JE Ghislaine Maxwell GM Sarah Kellen AP Albert Pinto or Adam Perry Lang Emmy Taylor Case Document Filed Page of GHISLAINE MAXWELL FLIGHTS SORTED BY AIRCRAFT/FLIGHT DATE Count 957.5Flight GIUF...
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(15 occurrences)
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EXH-4 BI-3 LED UN-5 DER EA-5 Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN...
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...aintiff JAMES EDWARD STALEY Third Party Defendant CONFIDENTIAL ATTORNEYS EYES ONLY May Videotaped deposition of WILLIAM LANGFORD taken pursuant to notice was held at the law offices of Boies Schiller Flexner LLP Hudson Yards New York New York a...
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...d Realtime Reporter and Notary Public GOLKOW LITIGATION SERVICES ph deps golkow.com Case Document Filed Page of William Langford Confidential Attorneys Eyes Only Golkow Liti ation Services Pa that that is a fair characterization of the initiati...
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(15 occurrences)
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...ion of Title of the Virgin Islands Code is amended in the following instances Subsection is replaced with the following language The term sex offense as used in this code includes those offenses contained in U.S.C and those offenses enumerated...
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...r in which the conviction occurred Subsections through are deleted New Subsections through are added with the following language The term conviction means An adult sex offender is convicted for the purposes of this chapter if the sex offender h...
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...n of Title of the Virgin Islands Code is amended in the following instances Subsection a is replaced with the following language a A person who is convicted in this Territory or in any state territory or Indian tribe of the United States any fo...
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(15 occurrences)
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IBIT Case Document Filed Page of Tm William Langford Confidential Attorneys Eyes Only Tm Golkow Litigation Services Tm Page Tm F0 Tf IN THE UNITED STATES DISTRICT COURT...
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...rty Defendant Tm F0 Tf CONFIDENTIAL ATTORNEYS EYES ONLY Tm F0 Tf May Tm F0 Tf Videotaped deposition Tm F0 Tf of WILLIAM LANGFORD taken pursuant to notice was held at the law offices of Tm F0 Tf Boies Schiller Flexner LLP Hudson Yards New York N...
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...nd Notary Public Tm F0 Tf GOLKOW LITIGATION SERVICES ph Tm F0 Tf deps golkow.com Case Document Filed Page of Tm William Langford Confidential Attorneys Eyes Only Tm Golkow Litigation Services Tm Page Tm F0 Tf So this one is AML Global Tm F0 Tf...
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(14 occurrences)
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...USVI in support of its motion for summary judgment Case Document Filed Page of JPMC Response ndi sputed that the qu ed langu age is fr the it transcript Disputed in sofa as USVI co nt ds that the cited sta tement estab li es that Ep ste in was...
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...Chase ank NA A nswer to 2d Am Comp and Statement A ffirmative efenses i ECF No JPMC Response Undi pu ed that th qu ted langu age i fr JP MCs An sw er A Co mpl and a em nt A ffnmati ve fen Di put in so far as SV I co nt ds at he it oc umen a bl...
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...tein sexuall assaulted her Tr at United States Epstein No cr SD.NY Aug ECF No JPM Re pon Un dis pu ted th at th qu oted lang age is fr ea rin ran sc ipt in i ted case Disp ut ed in sofa as USV I co te ds at ci ed doc um es ablis es th a Eps in...
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(12 occurrences)
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...t a ed ot Me for Jeffrey Ep ste in was ci ulat ed to MoITis Casey Dale ssio and Pen among ot March containing the qu ed language fr the DDR Disputed in sofa as USVI co nt ds that this fact upp 1i an infer ce that JPM ga knew or recklessly disre...
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...c upp i an inference at JPM ga knew or recklessly disregarded hat Epstein ran a sex tra ffi kin ve ntur See CSMF r,r In Langford communicated to Cutler concern about retai ing Epstein as a client Cutler te tified Those concerns are heightened i...
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...ng gi en that he was convicted of these crimes Ex at JPMC Response Di sputed In the i ed tes imony Cutler es ified th a Langford co mmuni cated him co cern abou the reputational issue USVI at mph asis added Disputed in sofa as USVI conte ds at...
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(11 occurrences)
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...ess of Eps in Sout rn Trns Co mp a USV I Ex at USVI Ex at USVI at Und i sputed hat Eps in at orney es ded wi th qu oted lang age USVI Ex at Disp ted extent USVI co nt ds at hi te tim es ab li es as a ega atte th at th cited out eac disc ai 267g...
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...ed ha li eved Epsteins explanation th at it was a mi ake Id a With respect to efforts to establi an English as a Second Language clas Ms de Jongh testified that she was not aware an of the women were potential trafficking victims Ex at JPMC Res...
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...ent due to reputational ri co cerns rat er tha legal concerns or concerns about Ep ste in account act i vity JPMC Ex at Langford further test i fied that he did ot Case Document Filed Page of believe th at Epstein was engaging in co inued illeg...
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(15 occurrences)
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...mi5.5 a bar4.5 on prosecutions in the Southern District of Florida only App.26 A previous version of the co-conspirator language limited it to the Southern District of Florida before it was amended to refer more oadly to the 215United States th...
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...ge-5 in part for his co conspirato5.5 rs be immune from prosecutio5.5 Maxwell moved to dismiss sed on the express plain language of the NPA which precluded charges by the United States against any co-conspirator of Epstein In consideration of E...
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...ecision On appeal Maxwell argued that the NPA barred her prosecutio5.2 in the Southern District New York by its express language The Second Circuit disagreed affirming the district cou rt opinion that under Un5 it6 ed States Annabi F.2d 2d Cir...
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(10 occurrences)
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...did see6 t5 control the scope of the relevant lauses narrowing the scope of immunity for Epstein through the of narrow language ecifying enforceability only in Southern District of Florid and then expanding the scope of it as to his co-con spi...
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...on spirators by using the broad term 215the United States23.2 While doing Epstein wyers re doub6.4 infor4.4 by how that language interpreted in the jurisdiction in which they were practicing27.1 et by the issue5.1 presented this case10.1 and ev...
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...in which they were practicing27.1 et by the issue5.1 presented this case10.1 and every other like it onl7.5 arises when language-10.3 in questi5 on is bei5 n1 interpreted in6 a differen6.5 jurisdiction than the one where the agreement negotiate...
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(15 occurrences)
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...Umt ed States Jones Cr AJN and in United Stat es Pizarro Cr AJN Commented E7 The proposed additional anguage tracks the language used by the Court in recent cases See United States Berry CR AJN Commented RA R7 GOVERNMENT RESPONSE This language...
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...on Ali on Nathan in United States Jones Cr A JN and in United States Pi an Cr AJN Commented The defense objects to this language It creates an unbalanced charge in which language favorab to the governmen is stated twice and last whereas languag...
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...favorab to the governmen is stated twice and last whereas language favorable to the defendant is sta ed only once This language is also not found in Sand or in the Court ecent i lY instructions on reasonab doubt See Sand Instr United States Be...
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(13 occurrences)
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...Greer F.3d 2d Cir-2 United St-4a5tes Haynes F.2d 2d Cir-3 United St-4a5tes Ianni-3e4llo F.2d 2d Cir-2 United St-4a5tes Langfor3d F.2d 2d Cir-2 pass-2im United St-4a5tes Martinez Salaz-2ar U.S3 pass-2im United St-4a5tes McCourty F.3d 2d Cir-3 U...
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...rar-4y,5 as f-3ive jus4tices r-3e4cognized in Mc-2Donoug and as the S3econd Cir-3cu4it-3 he4ld i-3n Un7it-3ed S4tat-3es Langford a4 new tr-2ial is required when a bia-2s4ed jur-4or is s4eat-3ed ev3en if the j-4u5ror 4false vo4ir dir4e answer-2s...
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...mi5th Phi-3llips U.S3 id 5at Connor concur-4rin6g id a4t Bre-2n5nan c-2onc4urr-3ing 3in j-3ud5gment Uni5ted St-4a5tes-3 Langfor-2d F.2d 2d Cir-2 ead the M3c4Donough m-3ult-3i part test 4as gover-2ning not only i-2n5ad4ver-2tent nond5isc-3losure...
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(13 occurrences)
1.
...Greer F.3d 2d Cir-2 United St-4a5tes Haynes F.2d 2d Cir-3 United St-4a5tes Ianni-3e4llo F.2d 2d Cir-2 United St-4a5tes Langfor3d F.2d 2d Cir-2 pass-2im United St-4a5tes Martinez Salaz-2ar U.S3 pass-2im United St-4a5tes McCourty F.3d 2d Cir-3 U...
2.
...rar-4y,5 as f-3ive jus4tices r-3e4cognized in Mc-2Donoug and as the S3econd Cir-3cu4it-3 he4ld i-3n Un7it-3ed S4tat-3es Langford a4 new tr-2ial is required when a bia-2s4ed jur-4or is s4eat-3ed ev3en if the j-4u5ror 4false vo4ir dir4e answer-2s...
3.
...mi5th Phi-3llips U.S3 id 5at Connor concur-4rin6g id a4t Bre-2n5nan c-2onc4urr-3ing 3in j-3ud5gment Uni5ted St-4a5tes-3 Langfor-2d F.2d 2d Cir-2 ead the M3c4Donough m-3ult-3i part test 4as gover-2ning not only i-2n5ad4ver-2tent nond5isc-3losure...
Content Matches:
(15 occurrences)
1.
...s to Ghislaine Maxwell Both parties have asked for the Court to enter a protective order While they agree on mos of the language two areas of dispute have emerged First Ms Maxwell seeks la nguage allowing her to publicly reference alleged victi...
2.
...cord to the media or in public fora or in litigation relat ing to Ms Maxwell or Jeffrey Epstein Second Ms Maxwell seeks language restricting poten tial Government witnesses and their counsel from using discovery materials fo any purpose other t...
3.
...aterials fo any purpose other than preparing for the criminal trial in this action The Government has proposed contrary language on both of these issues For the following re asons the Court adopts the Governments proposed protective order Under...
PDF
Content Matches:
(9 occurrences)
1.
...ns Co Loftus So 3d Fla 4thDCA2019 As is always the case when a court undertakes a legislative intent analysis the plain language of the statute is the starting and often ending point See Horowitz So 2d at 223When the statute is clear and unambi...
2.
...int See Horowitz So 2d at 223When the statute is clear and unambiguous courts will not look behind the statute 2s plain language for legislative intent or resort to rules of statutory construction to ascertain intent Loftus So 3d at Fla th DCA...
3.
...ns Co Loftus So 3d Fia 4thDCA2019 As is always the case when a court undertakes a legislative intent analysis the plain language of the statute is the starting anci often endmg point See Horowitz So 2d at When the statute is clear and unambiguo...
PDF
Content Matches:
(9 occurrences)
1.
...ils under the Statute Plaintiff has failed to provide any supporting authority and there is no statutory requirement or language in that supporting record evidence must exist to properly serve a demand and motion for attorneys fees See Plaintif...
2.
...s under th_e Statute Plaintiff has faile,d to provide any supporting author:ityanJI there isno statutory requirement or language irt that supporting record evidence must exist to properly serve a demand and motion for attorneys fees See Pla1nti...
3.
...on request by a grand jury for use by the grand jury or on order of the pursuant to Florida Statutes Based on the clear language of Fla Stat there can be no good faith reasonable expectation of success for the State Attorney to produce and disc...
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Content Matches:
(9 occurrences)
1.
...the other elements Clearly they would not have been as categorical as they were What they have done is try to parse out language again trying to make the roadmap when its clear this was intended to be a dead end for that privilege And they talk...
2.
...key kind knew knowing knowingly knowledge knowledgeable known knows Krischer Krischler L.M L.R labels ladies lady Lakes language Lanna large largely larger Larry late Lauderdale law6:2 laws lawsuit lawsuits lawyer lays lead leadership leading l...
3.
...ice Inc I appreciate that because what weve heard shockingly this afternoon is let me I know we need to be careful with language lets just say an accused abuser Mr Epstein the man accused of abusing my three clients we are told has seen these v...
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Content Matches:
(9 occurrences)
1.
...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confiden...
2.
...Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
3.
...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Case Document Filed Page of...
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Content Matches:
(9 occurrences)
1.
...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confiden...
2.
...Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
3.
...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Case Document Filed Page of...
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Content Matches:
(9 occurrences)
1.
...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confiden...
2.
...Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
3.
...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Case Document Filed Page of...
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Content Matches:
(8 occurrences)
1.
...plication of current law Specifically your action for declaratory relief fails based.on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is ordered by a court pursuant to subsection fo...
2.
...ation of current law._ Speclficafly your action for declaratory ref fo:f fails based on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is or:de_red qy a court pursuant to subsection...
3.
...ication of current law Specifical ly your action for declaratory rel ief fails based on the,clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is ordered by a court pursuant to subsection fo...
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Content Matches:
(8 occurrences)
1.
...terpretation It is well settled that in interpreting a statute the courts inquiry begins with the plain and unambiguous language of the statutory text CBS Inc Prime Time Venture F.3d I I th Cir U.S Castroneves WL S.D Fla citing Reeves Astrue F....
2.
...ts inquiry begins with the text The Court must first look to the plain meaning of the words and scrutinize the statutes language structure and purpose Id In addition in construing a statute a court is to presume that the legislature said what i...
3.
...n construing a statute a court is to presume that the legislature said what it means and means what it said and not add language or give some absurd or strained interpretation As stated in CBS Inc supra at Those who ask courts to give effect to...
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Content Matches:
(8 occurrences)
1.
...erpretation It is well settled that in interpreting a statute the courts inquiry begins with the plain and unan1biguous language of the statutory text CBS Inc Prime Time Venture F.3d th Cir U.S Castroneves WL S.D Fla citing Reeves Astrue F.3d t...
2.
...ts inquiry begins with the text The Court must first look to the plain meaning of the words and scrutinize the statutes language structure and purpose Id In addition in construing a statute a court is to presume that the legislature said what i...
3.
...n construing a statute a court is to presume that the legislature said what it means and means what it said and not add language or give some absurd or strained interpretation As stated in CBS Inc supra at Those who ask courts to give effect to...
PDF
Content Matches:
(8 occurrences)
1.
...terpretation It is well settled that in interpreting a statute the courts inquiry begins with the plain and unambiguous language of the statutory text CBS Inc Prime Time Venture F.3d I I th Cir U.S Castroneves WL S.D Fla citing Reeves Astrue F....
2.
...ts inquiry begins with the text The Court must first look to the plain meaning of the words and scrutinize the statutes language structure and purpose Id In addition in construing a statute a court is to presume that the legislature said what i...
3.
...n construing a statute a court is to presume that the legislature said what it means and means what it said and not add language or give some absurd or strained interpretation As stated in CBS Inc supra at Those who ask courts to give effect to...
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Content Matches:
(8 occurrences)
1.
...ges under the statute under the amended version based on the number of incidents alleged notwithstanding that the plain language of the statute Case Document Entered on FLSD Docket Page of Jane Doe II Epstein et al Page does not provide for a m...
2.
...ion can be contrasted with those statutory enactments or amendments where such intent is clearly expressed by including language to the effect that the amendment applies in proceedings commenced on or after the date of enactment See generally T...
3.
...rranted when Congress states its unambiguous intention that the statute apply retroactively to pre-enactment conduct in language comparable to that the new or amended statute applies to proceedings commenced on or after enactment See Landgraf U...
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Content Matches:
(8 occurrences)
1.
...apply because no indictment was formally filed in this case But this position is inconsistent with both the CVRAs plain language see e.g U.S.C Case Document Entered on FLSD Docket Page of Justice Department agencies involved in the detection an...
2.
...identified victims the CVRA was applicable The Court should reject the Governments newly-contrived position A The Plain Language of the CVRA Makes Clear that Victims Have Rights Before an Indictment is Filed The CVRA promises crime victims that...
3.
...a comt proceeding See Govt Response to Victims Emergency Petition doc at The Governments position contravenes the plain language of the CVRA The CVRA guarantees to Jane Doe and Jane Doe the right to confer with prosecutors in the case Case Docu...
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Content Matches:
(8 occurrences)
1.
...Y KATHERINE EZELL West Flagler Street Suite Miami Florida Attorney for Jane Doe and Page APPEARANCES LEOPOLD-KUVIN ADAM LANGINO ESQ PGA Boulevard Suite Palm Beach Gardens Florida Attorney for B.B RICHARD WILLITS ESQ 10th Avenue North Suite Lake...
2.
...P BY ROBERT CRITTON ESQ North Flagler Drive Suite West Palm Beach Florida Attorney for Jeffrey Epstein ALSO PRESENT JOE LANGSAM VIDEOGRAPHER Case Document Entered on FLSD Docket Page of Rue Notre Dame Miami Beach FL Kress Court Reporting Inc Pa...
3.
...ing Inc Pages to Page INDEX OF EXAMINATION WITNESS DIRECT CROSS ALFREDO RODRIGUEZ By Mr Mermelstein By Mr Edwards By Mr Langino INDEX OF EXHIBITS 11-18.8EXHIBITS PAGE Message pad Documents Page 1-1235.4Deposition taken before MICHELLE PAYNE Cou...
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Content Matches:
(8 occurrences)
1.
...apply because no indictment was formally filed in this case But this position is inconsistent with both the CVRAs plain language see e.g U.S.C Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Justice Dep...
2.
...identified victims the CVRA was applicable The Court should reject the Governments newly-contrived position A The Plain Language of the CVRA Makes Clear that Victims Have Rights Before an Indictment is Filed The CVRA promises crime victims that...
3.
...a comt proceeding See Govt Response to Victims Emergency Petition doc at The Governments position contravenes the plain language of the CVRA The CVRA guarantees to Jane Doe and Jane Doe the right to confer with prosecutors in the case Case Docu...
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Content Matches:
(8 occurrences)
1.
...view on your latest proposal Tegarding notification to the alleged victims under U.S.C and NU response to your proposed language Tegarding the U.S.C componen.t of the deferred-prosecution agreement the Agreement Before tum to these questions I...
2.
...inal action is pending until its final adjudjcation in the uial court U.S.C See also John Doe Francis WL at Fla Feb the language of U.S.C is clear that a stay is Teqnircd in a case such as ti 1is where a parallel criminal action is pending whic...
3.
...ein does not believe h1 is guilty of the federal charges enumerated under For this reason we believe that your proposed language regarding an appropriate procedure unfairly asks Mr Epstein to agree that eac;;h and every allcgetl victim identifi...
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Content Matches:
(8 occurrences)
1.
...data shall remain or be made visible presenter notes shall remain or be made visible and to the extent ESI in a foreign language is produced processing of such ESI shall be unicode-compliant Document Unitization If a Native Format file that is...
2.
...data shall remain or be made visible presenter notes shall remain or be made visible and to the extent ESI in a foreign language is produced processing of such ESI shall be unicode-compliant Document Unitization If a Native Format file that is...
3.
...data shall remain or be made visible presenter notes shall remain or be made visible and to the extent ESI in a foreign language is produced processing of such ESI shall be unicode-compliant Document Unitization If a Native Format file that is...
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Content Matches:
(8 occurrences)
1.
...know where you know Ill ask Mr King to briefly address this as well But you know the dilemma the court has here is the language that is reaffirmed in Wolfe and extracted from the Echevarria matter from the Florida Supreme Court And they quoted...
2.
...he abuse of process claim Its not specifically set forth in the pleadings THE COURT How do I get around this Echevarria language Again I recognize whats gone on here but personal empathy doesnt have any part in a courtroom It just doesnt and w....
3.
...u or I agree with it is not for me to say But its analysis is abundantly clear and it again reaffirms the Supreme Court language that talks about where were within the judicial proceeding as repugnant as it may be as long as it bears relation s...
PDF
Content Matches:
(8 occurrences)
1.
...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Page Maxwell Confidential took place I cannot testify to an actual conv...
2.
...ing about almost years ago when this Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
3.
...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Page Maxwell Confidential te...
PDF
Content Matches:
(8 occurrences)
1.
...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confiden...
2.
...Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
3.
...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Case Document Filed Page of...
PDF
Content Matches:
(8 occurrences)
1.
...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Page Maxwell Confidential took place I cannot testify to an actual conv...
2.
...ing about almost years ago when this Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
3.
...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Page Maxwell Confidential te...
PDF
Content Matches:
(8 occurrences)
1.
...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Page Maxwell Confidential took place I cannot testify to an actual conv...
2.
...ing about almost years ago when this Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
3.
...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Page Maxwell Confidential te...
PDF
Content Matches:
(8 occurrences)
1.
...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Case Document Filed Page of MAGNA LEGAL SERVICES Page Maxwell Confident...
2.
...t Filed Page of MAGNA LEGAL SERVICES Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
3.
...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Case Document Filed Page of...
PDF
Content Matches:
(8 occurrences)
1.
...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Page Maxwell Confidential took place I cannot testify to an actual conv...
2.
...ing about almost years ago when this Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
3.
...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Page Maxwell Confidential te...
PDF
Content Matches:
(8 occurrences)
1.
...t Due Diligence Report approved on April Bates JPM-SDNYLIT produced by JPMorgan in this Action and previously marked as Langford Exhibit at deposition JPMorgan initially designated this document Confidential pursuant to the Protective Order in...
2.
...ested February Bates JPM SDNYLIT-013546 JPM-SDNYLIT-013551 produced by JPMorgan in this Action and previously marked as Langford Exhibit at deposition JPMorgan initially designated this document Confidential pursuant to the Protective Order in...
3.
...t at deposition in this Action Probable Cause Affidavit Palm Beach Police Department dated May and previously marked as Langford Exhibit at deposition in this Action JPMorgan initially designated this document Confidential pursuant to the Prote...
PDF
Content Matches:
(8 occurrences)
1.
...t Due Diligence Report approved on April Bates JPM-SDNYLIT produced by JPMorgan in this Action and previously marked as Langford Exhibit at deposition JPMorgan initially designated this document Confidential pursuant to the Protective Order in...
2.
...ested February Bates JPM SDNYLIT-013546 JPM-SDNYLIT-013551 produced by JPMorgan in this Action and previously marked as Langford Exhibit at deposition JPMorgan initially designated this document Confidential pursuant to the Protective Order in...
3.
...t at deposition in this Action Probable Cause Affidavit Palm Beach Police Department dated May and previously marked as Langford Exhibit at deposition in this Action JPMorgan initially designated this document Confidential pursuant to the Prote...
PDF
Content Matches:
(8 occurrences)
1.
...t Due Diligence Report approved on April Bates JPM-SDNYLIT produced by JPMorgan in this Action and previously marked as Langford Exhibit at deposition JPMorgan initially designated this document Confidential pursuant to the Protective Order in...
2.
...ested February Bates JPM SDNYLIT-013546 JPM-SDNYLIT-013551 produced by JPMorgan in this Action and previously marked as Langford Exhibit at deposition JPMorgan initially designated this document Confidential pursuant to the Protective Order in...
3.
...t at deposition in this Action Probable Cause Affidavit Palm Beach Police Department dated May and previously marked as Langford Exhibit at deposition in this Action JPMorgan initially designated this document Confidential pursuant to the Prote...
PDF
Content Matches:
(8 occurrences)
1.
...t Due Diligence Report approved on April Bates JPM-SDNYLIT produced by JPMorgan in this Action and previously marked as Langford Exhibit at deposition JPMorgan initially designated this document Confidential pursuant to the Protective Order in...
2.
...ested February Bates JPM SDNYLIT-013546 JPM-SDNYLIT-013551 produced by JPMorgan in this Action and previously marked as Langford Exhibit at deposition JPMorgan initially designated this document Confidential pursuant to the Protective Order in...
3.
...t at deposition in this Action Probable Cause Affidavit Palm Beach Police Department dated May and previously marked as Langford Exhibit at deposition in this Action JPMorgan initially designated this document Confidential pursuant to the Prote...
PDF
Content Matches:
(8 occurrences)
1.
...t Due Diligence Report approved on April Bates JPM-SDNYLIT produced by JPMorgan in this Action and previously marked as Langford Exhibit at deposition JPMorgan initially designated this document Confidential pursuant to the Protective Order in...
2.
...ested February Bates JPM SDNYLIT-013546 JPM-SDNYLIT-013551 produced by JPMorgan in this Action and previously marked as Langford Exhibit at deposition JPMorgan initially designated this document Confidential pursuant to the Protective Order in...
3.
...t at deposition in this Action Probable Cause Affidavit Palm Beach Police Department dated May and previously marked as Langford Exhibit at deposition in this Action JPMorgan initially designated this document Confidential pursuant to the Prote...
PDF
Content Matches:
(8 occurrences)
1.
...t Due Diligence Report approved on April Bates JPM-SDNYLIT produced by JPMorgan in this Action and previously marked as Langford Exhibit at deposition JPMorgan initially designated this document Confidential pursuant to the Protective Order in...
2.
...ested February Bates JPM SDNYLIT-013546 JPM-SDNYLIT-013551 produced by JPMorgan in this Action and previously marked as Langford Exhibit at deposition JPMorgan initially designated this document Confidential pursuant to the Protective Order in...
3.
...t at deposition in this Action Probable Cause Affidavit Palm Beach Police Department dated May and previously marked as Langford Exhibit at deposition in this Action JPMorgan initially designated this document Confidential pursuant to the Prote...
PDF
Content Matches:
(8 occurrences)
1.
...t Due Diligence Report approved on April Bates JPM-SDNYLIT produced by JPMorgan in this Action and previously marked as Langford Exhibit at deposition JPMorgan initially designated this document Confidential pursuant to the Protective Order in...
2.
...ested February Bates JPM SDNYLIT-013546 JPM-SDNYLIT-013551 produced by JPMorgan in this Action and previously marked as Langford Exhibit at deposition JPMorgan initially designated this document Confidential pursuant to the Protective Order in...
3.
...t at deposition in this Action Probable Cause Affidavit Palm Beach Police Department dated May and previously marked as Langford Exhibit at deposition in this Action JPMorgan initially designated this document Confidential pursuant to the Prote...
PDF
Content Matches:
(8 occurrences)
1.
...t Due Diligence Report approved on April Bates JPM-SDNYLIT produced by JPMorgan in this Action and previously marked as Langford Exhibit at deposition JPMorgan initially designated this document Confidential pursuant to the Protective Order in...
2.
...ested February Bates JPM SDNYLIT-013546 JPM-SDNYLIT-013551 produced by JPMorgan in this Action and previously marked as Langford Exhibit at deposition JPMorgan initially designated this document Confidential pursuant to the Protective Order in...
3.
...t at deposition in this Action Probable Cause Affidavit Palm Beach Police Department dated May and previously marked as Langford Exhibit at deposition in this Action JPMorgan initially designated this document Confidential pursuant to the Prote...
PDF
Content Matches:
(8 occurrences)
1.
...oceed as to the parole request JPMC Ex at JPMC Ex at On May Ms de Jongh fo1wa1 267ded an email to Epstein with uggested language for USVIs Sex Offender Registration and Notification Act ORNA egislation The original sender info1mation is cutoff...
2.
...n and Notification Act ORNA egislation The original sender info1mation is cutoff but the author writes I considered the language you shared with me I believe this language may be best We need to be able to know whether a person i at the address...
3.
...the federal DOJ program managers Remember they must review and dete1mine if we are in compliance This is the suggested language will it work for you JPMC Ex at Epstein replied that we hould add out of countiy for more than days othe1wise I cou...
PDF
Content Matches:
(7 occurrences)
1.
...no longer a minor at the time U.S.C was enacted Plaintiff in her response can and should concede this issue There is no language in the statute which suggests is to apply retroactively It is well settled that in interpreting a statute the court...
2.
...etroactively It is well settled that in interpreting a statute the courts inquiry begins with the plain and unambiguous language of the statutory text CBS Inc Prime Time Venture F.3d th Cir U.S Castroneves WL S.D Fla citing Reeves Astrue F.3d t...
3.
...ts inquiry begins with the text The Court must first look to the plain meaning of the words and scrutinize the statutes language structure and purpose Id In addition in construing a statute a court is to presume that the legislature said what i...
PDF
Content Matches:
(7 occurrences)
1.
...rime in which petitioners wer11e victims Resolution of this-9 issue is a matter of9 statutory30 interpre10tation of the lang12uag14e of the9 Crime Victims Rights Act CVRA Whether)10 the g12overnme9nt had a leg23al duty under is not re)9solved w...
2.
...so intended r10ights in sec10tion a to exi-10st even if no f9eder11al cr9iminal charg17es ar15e eve12r filed The ve9nue lang16uag14e in the CVRA states that rig15hts 223shall be asse10rted if no prosecution is underway in the district court in...
3.
...he CVRA counse10l otherwise.-289 Her9e By37 making10 this sugg14estion the g11overnme9nt is not sugg12esting9 that this langua16g10e is superf9luous Rather the pe9riod ref11err10ed to in U.S.C is the time betwe)12en ar11rest and indictment As s...
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Content Matches:
(7 occurrences)
1.
...-ift proposal cnl from Jay Lclkowil to ndrev omi dated St:ptcmbcr In n!spon::;I Ms Villafi.tm lcmande!d rhnt th contain langu,tgi considering the inclu ion or a guardiirn ad item in the procced i ug dcspit the foct tha1 wc re now kd hclicvc tha...
2.
...choose rhc attorney rcprcscnrntiv we were engaged in co nsisrcnt and constant ia og with yo ur taff a lo the prcc.:ii-c language that would he tn.insmilli.:d In the incicp1:mcicnt a rty cxpl 1in his or ok RFP MIA Case Document Entered on FLSD D...
3.
....:prcscntativc the scope of Mr F.psk.:in waiver linhility and juri ciiction the role of tht nttorncy representative the language contained in various irans or the letter to the im.lr..:pl:1.knt third party the l:orrcct amount of minimum d;1mag...
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Content Matches:
(7 occurrences)
1.
...view on yo ur latest proposal regarding notification to the alleged victims under S.C and ur response to your proposed language regarding the component of the deferr ed-prosecution agreement the Agreement Before I tum to these questions I woul...
2.
...criminal action is pendin until its final adjudication in the trfal court See ulso John Doe I Francis WL al Fla Feb the language of S.C is clear that a stay is required in a ase such as ti 1is where a parallel criminal action is pending which a...
3.
...tein does not believe hi is guilty of the federal charges enumerated under For this reason we beieve lhat your proposed language regarding an appropriate procedure unfairly asks Mr Epstein to a 7ee that each and every alleget.l victim identifie...
PDF
Content Matches:
(7 occurrences)
1.
...know where you know Ill ask Mr King to briefly address this as well But you know the dilemma the court has here is the language that is reaffirmed in Wolfe and extracted from the Echevarria matter from the Florida Supreme Court And they quoted...
2.
...he abuse of process claim Its not specifically set forth in the pleadings THE COURT How do I get around this Echevarria language Again I recognize whats gone on here but personal empathy doesnt have any part in a courtroom It just doesnt and w....
3.
...u or I agree with it is not for me to say But its analysis is abundantly clear and it again reaffirms the Supreme Court language that talks about where were within the judicial proceeding as repugnant as it may be as long as it bears relation s...
PDF
Content Matches:
(7 occurrences)
1.
...r two MR MERMELSTEIN Stuart Mermelstein of Mermelstein and Horowitz representing Jane Does numbers two through eight MR LANGINO Adam Langino on behalf of B.B Page MS EZELL Katherine Ezell from Podhurst Orseck on behalf of Jane Does and MR CRITT...
2.
...t names MR WILLITS My client has waived the confidentiality as to herself But I certainly agree as to everybody else MR LANGINO As do I MS EZELL Is that okay MR CRITTON Thats what we agreed to on the last MS EZELL Right Page MR CRITTON For the...
3.
...ve any other questions right now Id just like to reserve if something comes up to ask But otherwise you may go ahead MR LANGINO It is noon so I dont know what everybody elses schedule is I dont know how youre feeling THE WITNESS I am fine MS EZ...
PDF
Content Matches:
(7 occurrences)
1.
...ument Filed Page of April lNDEX WrTNESS DIRECT CROSS REDRECT RECROSS NADlA MARCNKOVA BY MR EDWARDS BY MR HOROWITZ BY MR LANGNO BY MS EZELL EXIIlBITS PLAINTIFFS FOR IDENTIFICATION I Message dated August PAGE The videotaped deposition of NADIA MA...
2.
...NTINUED LEOPOLD-KUVIN Attorneys for Plainli fls B.B and C.F PGA Boulevard Suite Palm 13each Gardens Florida Tel UY ADAM LANGJNO ESQ PODHURST ORSECK Allorneys for Jane Docs I and City National Bank Building Suite West Flagler Street Miami Florid...
3.
...s home while she was still a child MR AR.EMA Object to the form A Fifth MR HOROWITZ No other questions at this point MR LANGINO I have less than ten minutes of questioning MR GOLDBERGER Fine that will bring us right to the break CROSS EXAMINATI...
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(7 occurrences)
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...terrified me more The girls came in to say their good-byes all of them were crying and asking me in their best English languagt.:s why Thad to call someone and lose everything I vas able to find out through the broken sobs off of I Coryrighl P...
2.
...sts in lhe world chose an untrained fifteen-year-old girl lo perfom1 a massage She never said it in VOrds but her body language told me she kne exactly why they vanted to use me and it wasnt for a therapeutic reason either and deep down inside...
3.
...ey 267were kicking to each other in the middle of the street Intelligent kids they vere able to speak three different languages including English and vvas interested to ask them about life here They didnt seem to notice or be bothered by their...
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(7 occurrences)
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...USVI in support of its motion for summary judgment Case Document Filed Page of JPMC Response ndi sputed that the qu ed langu age is fr the it transcript Disputed in sofa as USVI co nt ds that the cited sta tement estab li es that Ep ste in was...
2.
...Chase ank NA A nswer to 2d Am Comp and Statement A ffirmative efenses i ECF No JPMC Response Undi pu ed that th qu ted langu age i fr JP MCs An sw er A Co mpl and a em nt A ffnmati ve fen Di put in so far as SV I co nt ds at he it oc umen a bl...
3.
...tein sexuall assaulted her Tr at United States Epstein No cr SD.NY Aug ECF No JPM Re pon Un dis pu ted th at th qu oted lang age is fr ea rin ran sc ipt in i ted case Disp ut ed in sofa as USV I co te ds at ci ed doc um es ablis es th a Eps in...
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(6 occurrences)
1.
...reasonable and obvious implications To do so would be an abrogation of legislative power Id Accordingly here the plain language of section is clear and unambiguous and therefore controls See Horowitz Plantation Gen Hosp Ltd ship So 2d Fla Agai...
2.
...mand letter and motion for attorneys fees The course of action taken by the State Attorney actually tracks the specific language set forth in the Statute to wit A motion by a party seeking sanctions under this section must be served but may not...
3.
...laintiffs claim has no basis in fact or law as set forth at length above Also despite the clear concise and unambiguous language of Section Florida Statutes which states that grand jury materials shall be released by the Clerk only on order of...
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Content Matches:
(6 occurrences)
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...plication of current law Specifically your action for declaratory relief fails based on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is ordered by a court pursuant to subsection fo...
2.
...plication of current law Specifically your attion for declaratory relief fails based on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is ordered by a court pursuant to subsection I...
3.
...the media under both the statute and the First Amendment to the US Constitution in furtherance of justice The statutory language you cite refers to instances where a person is seeking grand jury materials for use in a civil or in a criminal cas...
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Content Matches:
(6 occurrences)
1.
...r two MR MERMELSTEIN Stuart Mermelstein of Mermelstein and Horowitz representing Jane Does numbers two through eight MR LANGINO Adam Langino on behalf of B.B Page MS EZELL Katherine Ezell from Podhurst Orseck on behalf of Jane Does and MR CRITT...
2.
...ve any other questions right now Id just like to reserve if something comes up to ask But otherwise you may go ahead MR LANGINO It is noon so I dont know what everybody elses schedule is I dont know how youre feeling THE WITNESS I am fine MS EZ...
3.
...chedule is I dont know how youre feeling THE WITNESS I am fine MS EZELL I do have another question May I ask it Page MR LANGINO Go ahead Sure BY MS EZELL You said that you set up the massage tables And would you also set up the oils and the tow...
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Content Matches:
(6 occurrences)
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...the judge that we are trying to create f8.4e-.8dera jurisdiction for prison purposes I will includ6.2e our stand6.2a5rd language regard ing resolving all crim8.6inal liab5.8i3.6lity and I will m8.7e-.3ntion but I would prefer not to h6i-1.2gh6l...
2.
...allowed you a week to provide us with any objections or requested m8.2odifications of the list and/or the No tification language Yester day I contacted you via telephone and but received no res ponse Accordingly the United States hereby notifie...
3.
...t of the NPA The notif ication to the victim8.6s a bout the civil restitution provision5.5s quoted from8.3 the December language August the line prosecutor em7.7a iled Epstein5.1s counsel stating that the court has ordered us to m8a-1ke the Ag...
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Content Matches:
(6 occurrences)
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...position as they would have been had Mr Epstein been convicted at trial No more no Jess With this in mind I turn to the language of the Agreement Paragraph of the Agreement provides If any of the individuals referred to in paragraph supra elect...
2.
...at I have conferred with our prosecutors and have been told that Paragraph was vigorously negotiated and that the final language was suggested largely by defense counsel The concerns raised in your Jetter with respect to Paragraph fal within se...
3.
...of unnamed and undisclosed victims I would invite you to confer with your co-counsel regarding this matter Although the language of Paragraph could be so construed our First Assistant informed Mr Lefkowitz some weeks ago that this was not our p...
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Content Matches:
(6 occurrences)
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...d any claim of privilege As a last-ditch effort the intervenors contend that if more is needed in addition to the plain language of Rule to preclude disclosure of the correspondence to plaintiffs it can be found in the conjunction of Rule the w...
2.
...involves see Part I supra he appears to argue that the correspondence falls within Rule italicized above But the plain language of that provision is narrowly written to cover only a statement made in the course of plea discussions with an atto...
3.
...pleading guilty to two state charges he does contend that Rule is limited to guilty pleas to federal offenses The plain language of Rule does not contain any such limitation narrowly extending protection only to negotiations that did not result...
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Content Matches:
(6 occurrences)
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...Y KATHERINE EZELL West Flagler Street Suite Miami Florida Attorney for Jane Doe and Page APPEARANCES LEOPOLD-KUVIN ADAM LANGINO ESQ PGA Boulevard Suite Palm Beach Gardens Florida Attorney for B.B RICHARD WILLITS ESQ 10th Avenue North Suite Lake...
2.
...P BY ROBERT CRITTON ESQ North Flagler Drive Suite West Palm Beach Florida Attorney for Jeffrey Epstein ALSO PRESENT JOE LANGSAM VIDEOGRAPHER Case Document Filed Page of Rue Notre Dame Miami Beach FL Kress Court Reporting Inc Pages to Page INDEX...
3.
...ing Inc Pages to Page INDEX OF EXAMINATION WITNESS DIRECT CROSS ALFREDO RODRIGUEZ By Mr Mermelstein By Mr Edwards By Mr Langino INDEX OF EXHIBITS 11-18.8EXHIBITS PAGE Message pad Documents Page 1-1235.4Deposition taken before MICHELLE PAYNE Cou...
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(6 occurrences)
1.
...West Flagler Street Vs Suite JEFFREY EPSTEIN i ami Flor i da Defendant Attorney for Jane Doe and LEOPOLD-KUVIN BY ADAM LANGINO ESQ PGA Boulevard Suite Palm Beach Gardens Florida Attorney for Pages to Kress Court Reporting Inc Rue Notre Dame Mi...
2.
...P BY ROBERT CRITTON ESQ North Flagler Drive Suite West Palm Beach Florida Attorney for Jeffrey Epstein ALSO PRESENT JOE LANGSAM VIDEOGRAPHER CONTINUED INDEX OF EXAMINATION WITNESS DIRECT CROSS REDIRECT RECROSS ALFREDO RODRIGUEZ By Ms Ezell By M...
3.
...ION WITNESS DIRECT CROSS REDIRECT RECROSS ALFREDO RODRIGUEZ By Ms Ezell By Mr Willits By Mr Critton By Mr Edwards By Mr Langino CONTINUED INDEX OF EXHIBITS PLAINTIFPS PAGE Drawing Photograph Photograph Photograph Photograph Photograph Report Ex...
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Content Matches:
(6 occurrences)
1.
...terrified me more The girls came in to say their good-byes all of them were crying and asking me in their best English languages why I had to call someone and lose everything I was able to find out through the broken sobs off of Copyright Prot...
2.
...ists in the world chose an untrained fifteen-year-old girl to perform a massage She never said it in words but her body language told me she knew exactly why they wanted to use me and it wasnt for a therapeutic reason either and deep down insid...
3.
...an they were kicking to each other in the middle of the street Intelligent kids they were able to speak three different languages including English and I was interested to ask them about life here They didnt seem to notice or be bothered by the...
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Content Matches:
(6 occurrences)
1.
Case Document Filed Page of EX I I EX I I Tm William Langford Confidential Attorneys Eyes Only Tm Golkow Litigation Services Tm Page Tm F0 Tf IN THE UNITED STATES DISTRICT COURT...
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...rty Defendant Tm F0 Tf CONFIDENTIAL ATTORNEYS EYES ONLY Tm F0 Tf May Tm F0 Tf Videotaped deposition Tm F0 Tf of WILLIAM LANGFORD taken pursuant to notice was held at the law offices of Tm F0 Tf Boies Schiller Flexner LLP Hudson Yards New York N...
3.
...nd Notary Public Tm F0 Tf GOLKOW LITIGATION SERVICES ph Tm F0 Tf deps golkow.com Case Document Filed Page of Tm William Langford Confidential Attorneys Eyes Only Tm Golkow Litigation Services Tm Page Tm F0 Tf asked to provide a briefing to JPMo...
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Content Matches:
(6 occurrences)
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...h1 VNS Call Center at 6-DDJ.4YOU TDD/TTY In addition you may use tile CIR Center or lni.mel ate yo in!Orrnlion and/or cllange YOIJlf ion participation in the notifocatlon program If you update yaur 1o Include a current email VNS will send infor...
2.
...Docke Page of Accordingly the Federal Criminal Action remains pending Discussion I Section Imposes a Mandatory Stay The language of Title United States Code Section is clear and mandatory a parallel civil action shall be stayed until the end of...
3.
...aration of powers principles emphasis added One District Court within the Eleventh Circuit recently construed the plain language of as requirfing a stay in a case where a parallel criminal action is pending Doe Francis No CV WL Lem.s T.ein GRAN...
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Content Matches:
(5 occurrences)
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...Activities Administrative Remedy Program Federal Regulations are shown In this type Implementing instructions this type Language Translations Used in Official Documents Accounting Management Manual Trust Fund/Deposit Fund Manual Food Service Ma...
2.
...es central file To the extent reasonably available a qualified staff member or translator will help an inmate who has a language or literacy problem in accordance with the Program Statement Language Translations Used in Official Documents Feder...
3.
...ployee immediately completes Part of the incident report The incident is a prohibited act listed in Appendix The entire language of the prohibited act does not have to be copied For example Destroying Government Property Code or Possessing Narc...
4.
...in this type Implementing instructions this type the staff member receiving the information provides the information in language as close to the informants as possible actual words where possible The identity of a confidential informant must be...
5.
...EVEL PROHIBITED ACTS Not to be used Not to be used Malingering feigning illness Not to be used Using abusive or obscene language Not to be used Not to be used Conduct with a visitor in violation of Bureau regulations Not to be used Unauthorized...
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(5 occurrences)
1.
...s Ins Co Loftus So 3d Fla 4th DCA As is always the case when a court undertakes a legislative intent analysis the plain language of the statute is the starting and often ending point See Horowitz So 2d at When the statute is clear and unambiguo...
2.
...ng point See Horowitz So 2d at When the statute is clear and unambiguous courts will not look behind the statutes plain language for legislative intent or resort to rules of statutory construction to ascertain intent Loftus So 3d at Fla 4thDCA...
3.
...of Case history indicating an intent to create a private right of action is telling it is not dispositive as the plain language of the section is clear an unambiguous and therefore controls Horowitz So 2d at Examining the plain language of sec...
4.
...ion as creating a private cause of action against the State Attorney and Clerk is therefore not only unsupported by the language of section but is actually paradoxical to its plain language of the statute As such this Court lacks the power to c...
5.
...ctually paradoxical to its plain language of the statute As such this Court lacks the power to construe the unambiguous language of section in a way that would extend its express terms and create a cause of action where none exists To do so wou...
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Content Matches:
(5 occurrences)
1.
...terms or its reasonable and obvious implications To do so would be an abrogation of legislative power Id Here the plain language of section is clear and unambiguous and therefore controls See Horowitz Plantation Gen Hosp Ltd 2ship So 2d Fla Acc...
2.
...fore controls See Horowitz Plantation Gen Hosp Ltd 2ship So 2d Fla Accordingly based on the clear unambiguous statutory language set forth in section only the Clerk not the State Attorney may release grand jury materials pursuant to an order of...
3.
...terms or its reasonable and obvious implications To do so would be an abrogation oflegislative power Id Here the plain language of section is clear and unambiguous and therefore _controls See Horowitz Plantation Gen Hosp Ltd ship So 2d Fla AGc...
4.
...ispute The Court is fully empowered to dispose of this matter based on application of the undisputed facts to the plain language of Section Florida Statutes which renders the Plaintiffs action for declaratory relief ah impossibility for Aronber...
5.
...dispute The Court is fully empowerecl to dispose of this matt based on application of the undisputed facts to the piain language of Section Florida Statutes which renders the Plaintiffs action for declaratofy relief an impossibility fot Aronber...
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Content Matches:
(5 occurrences)
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...the Agreement Accordingly the Federal Criminal Action remains pending Discussion I Section Imposes a Mandatory Stay The language of Title United States Code Section is clear and mandatory a parallel civil action shall be stayed until the end of...
2.
...aration of powers principles emphasis added One District Court within the Eleventh Circuit recently construed the plain language of as requirfingj a stay in a case where a parallel criminal action is pending Doe Francis No CV WL at N.D Fla Apr...
3.
...in Bay County Florida arising from the same facts and involving the same parties as the Instant action noting that the language of U.S.C is clear that a stay is required in a case such as this where a parallel criminal action is pending which...
4.
...includes investigation u.s.c The only reported decision addressing this provision interpreted it according to its plain language See Ara Khan No CV WL E.D.N.Y June ordering all proceedings in this case stayed pending the conclusion of the gover...
5.
...e this determination despite the plaintiffs complaints about the frustrating delay and that the state criminal case has languished for almost two years with no end in sight finding that this is a matter to be addressed in state criminal court I...
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Content Matches:
(5 occurrences)
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...ett er reserv ed for the charg ing conference at trial On the second is sue as wi ll be address ed late unde the pla in langua ge of the statute since Defendant EPS TEIN can be criminally prosecuted for each te mporally distinct ev ent where he...
2.
...i44 ly exp42 ressed ressional ntent to do so 223The statut43 that was ctually enacted in cont44 ains no comparabl44.992 language Instead of a reference 221restori44 ng pre-ex56 isting ights statement of purpose42 describes the Acts function-44...
3.
...ubcontractor right to recov er damages from prime contractors as prospective in absenc of clear str ong and imperati ve languag from Congress favoring retroactivity Id at footnotes mitted Here we have an incr ease in the potenti al damages reme...
4.
...ere are mu ltiple iolations he Plai ntif is limited to a single recovery for all Such a co nstruct ion would the pla in langua ge of the statute and ommon sense Plaint iff has alleged th at Defendant EPSTEIN iolated the statute on confirmed occ...
5.
...the statute on confirmed occa sions and up to addition al occasions Each date or each violatio is different There is no language in the statute that prohibits the Plaintiff from suing for each violati on and the dicta set forth in Tilton Pl ayb...
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Content Matches:
(5 occurrences)
1.
...e was hired by RRA or even knew Scott Rothstein Edwards Affidavit Exhibit attached to Statement of Undisputed Facts The language set fmih in his Complaints remain virtually unchanged from the first filing in and as the evidence shows the claims...
2.
...ttempts to obtain discovery from high-profile persons with whom Epstein socialized and use of ridiculously inflammatory language in arguments in court Remarkably Epstein has filed such allegations against Edwards despite the fact that Epstein h...
3.
...in makes allegations that the complaints contained sensational allegations for the purposes of luring investors however language in the complaints remained virtually unchanged from the first filing in and from the overwhelming evidence the Cour...
4.
...ttempts to obtain discovery from high-profile persons with whom Epstein socialized and use of ridiculously inflammatory language in arguments in court Remarkably Epstein has filed such allegations against Edwards despite the fact that Epstein h...
5.
...in makes allegations that the complaints contained sensational allegations for the purposes of luring investors however language in the complaints remained virtually unchanged from the first filing in and from the overwhelming evidence the Cami...
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Content Matches:
(5 occurrences)
1.
...e Sustained In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language from Palm Beach State Attorneys File Exhibit The Court finds that this language does not substantially change the e...
2.
...ssage table In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language CW SR The Court finds that this language does not substantially change the exhibit and thus the Courts ruling holds...
3.
...n Sustained In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language to Virginia Roberts The Court finds that this language does not substantially change the exhibit and thus the Court...
4.
...s Overruled In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language and/or Property Receipts The Court finds that this language does not substantially change the exhibit and thus the...
5.
...DV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Com1ney Langley c/o Spencer Kuvin South Australian Ave West Palm Beach Florida William Scherer Esquire Federal Hwy Fort Lauderdale F...
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Content Matches:
(5 occurrences)
1.
...ty requisites as delineated in Rule of the Florida Rules of Civil Procedure if it contains any one of the following the language of the proposed release agreement a summary of the substance of the release agreement or as in the case at hand the...
2.
...t is actually attached to the Proposal See Nichols So 2d at Moreover in Nichols the Florida Supreme Court held that the language used by State Farm in its release was ambiguous due to other policies existing between the plaintiff and the defend...
3.
...p the Tonja Haddad P.A SE th Street Fort Lauderdale FL information confidential See Exhibit A The law is clear that the language of the proposed release or a summary of the substance of the release must be included with the offer to comply with...
4.
...as not attached to the proposal Id emphasis added In Earnest Stewart Inc Codina So 2d Fla 3d DCA the proposal contained language requiring a hold harmless agreement in the event of claims by third persons who are not a party to this action Id T...
5.
...hold harmless agreement in the event of claims by third persons who are not a party to this action Id There is no such language in the Proposal or the release agreement attached thereto in the case at hand In Diamond Aircraft Indus Inc Horowit...
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Content Matches:
(5 occurrences)
1.
...ing Rules and case law FLA Civ Nichols So 2d Fla In Edwardss Motion he implausibly and misguidedly quotes the following language as language from Epsteins Proposal for Settlement that they shall not in any method or manner discuss publish or di...
2.
...ounter-Plaintiff Bradley Edwards Motion to Stay Proceedings Pending Completion of Additional Discovery page This quoted language is not contained anywhere in Epsteins Proposal for Settlement or the attachments thereto Rather it is excerpted fro...
3.
...dential Such confidentiality clauses have typically been determined not to violate ethics rules Id at Interestingly the language of the confidentiality provision within Epsteins Proposal for Settlement is even less restrictive than the language...
4.
...Settlement to Defendant/Counter-Plaintiff Bradley Edwards Individually Exhibit A emphasis added Conversely the accepted language misquoted by Edwards from the Florida Bar ruling prohibits the disclosure of any information concerning the settlem...
5.
...ty requisites as delineated in Rule of the Florida Rules of Civil Procedure if it contains any one of the following the language of the proposed agreement a summary of the substance of the agreement or as in the case at hand the proposed releas...
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Content Matches:
(5 occurrences)
1.
...evant evidence that would be inadmissible at trial if it may lead to the discovery of relevant evidence Allstate Ins Co Langston So 2d Fla As provided in detail below Edwardss objections to Epsteins Discovery contain nothing more than the forbi...
2.
...So 2d Fla As provided in detail below Edwardss objections to Epsteins Discovery contain nothing more than the forbidden language and as such must be stricken and responses compelled Next Epstein seeks to strike the objections improperly made by...
3.
...evant evidence that would be inadmissible at trial if it may lead to the discovery of relevant evidence Allstate Ins Co Langston So 2d Fla As such Epstein submits that these objections be stricken and answers compelled Moreover because a causal...
4.
...evant evidence that would be inadmissible at trial if it may lead to the discovery of relevant evidence Allstate Ins Co Langston So 2d Fla In support of his Malicious Prosecution claim against Epstein Edwards asserts that he was not involved wi...
5.
...evant evidence that would be inadmissible at trial if it may lead to the discovery of relevant evidence Allstate Ins Co Langston So 2d Fla As such Epstein submits that these objections be stricken and answers compelled Moreover because a causal...
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Content Matches:
(5 occurrences)
1.
...Sent Ryan Maryanne CORPEXCHANGE/OU EXCHANGE ADMINISTRATIVE GROUP FYDIBOHF23SPDLT CN RECIPIENTS/CN MARYANNE.X.RYAN PM To Langford William william.d.langford jpmchase.com Deluca Phillip A phillip.a.deluca jpmchase.com Nichols Nina A nina.a.nichol...
2.
...PMorgan chase Bank N.A I Legal and Compliance Department I I Wood Avenue south Floor Iseli NJ I I original Message From Langford William Sent Monday January AM To Deluca Phillip A Nichols Nina A cc Ryan Maryanne subject RE Jeffrey Epstein what...
3.
...y Was it the negative media this summer original Message From Deluca Phillip A Sent Monday January AM To Nichols Nina A Langford William cc Ryan Maryanne subject FW Jeffrey Epstein Here is the rapid response memo related to Epstein as well as i...
4.
...d Page of subject FW Jeffrey Epstein Maryanne can you please begin to gather his info Thanks Phil original Message From Langford William Sent Monday January AM To Deluca Phillip A Nichols Nina A subject RE Jeffrey Epstein Ok can you all assembl...
5.
...ood w.good.com original Message From Deluca Phillip A Sent Monday January AM Eastern Standard Time To Nichols Nina A cc Langford William subject FW Jeffrey Epstein Nina Welcome Sorry to start your day off with a crazy matter but Im sure when yo...
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Content Matches:
(5 occurrences)
1.
...CORPEXCHANGE/OU EXCHANGE ADMIN I STRATIVE GROUP YDI BOHF23SPDL RE I I ENTS/CN MARYANN RYA PM angfo rd i lliam i lliam.d langford pmchase.com Deluca Phillip A phillip.a de uca jpmchase.com i cho ina A nina.a.nichols jpmchase.com Subject RE Jeffr...
2.
...JPMorgan chase an N.A I Legal and Com pl i ance Department I Wood Avenue South Floor Iselin NJ I I original Message om Langford William Sent Monday January AM To eluca Phil ip A Nichols Nina A cc Ryan Maryanne subject RE Jeffrey ps tein at do...
3.
...ce was it the negative media th i sum er original Message From eluca Phillip A Sent Monday January AM To Nichols Nina A Langford Wil iam Cc Ryan Ma yanne subject FW Jeffrey Epste i Here is the ap i response memo re ate to stein as wel I be sen...
4.
...Filed Page of subject FW Jeffrey Epstein Maryanne can you please begi to gather his info anks Phil original Message Fro Langfo William Sent Monday January AM To De luca Phil ip A Nichols Nina A Subject RE Jeffrey Epstein Ok Ca you a ll assemble...
5.
...t with Good w.good com or i gina Message om Deluca Phillip A sent onday January AM Eastern Standard Ti ichols i na A cc Langford Wil iam Su bj ect FW Jeffrey Epste i Nina welcome sorry to start you day off with a azy matter but Im sure when you...
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Content Matches:
(5 occurrences)
1.
...I I EX I I Case Document Filed Page of From Sent To Subject Phillip A Deluca phillip a deluca jpmcha se.com PM William Langford william.d.langford jpmchase.com RE Dont think he will but Ill keep you advised Original Message From William Langfo...
2.
...rey waffles on Epstein No patience for this Original Message From Phillip A Deluca Sent Thursday December AM To William Langford subject RE Yup On ce if needed Redacted Privileged and I sent you an e-mail yesterday on that scum Epstein tfia"f"T...
3.
...listened to days of HT at the forum and this account could be problematic in several ways original Message From William Langford Sent Thursday December AM To Phillip A Deluca subject RE Re acted rivi leg Original Message From Phillip A Deluca S...
4.
...Phillip A Deluca subject RE Re acted rivi leg Original Message From Phillip A Deluca Se Thursday December AM To William Langford subject RE Af ter I recd a contact from Rachel Rojas I spoke to the bureau in Baton Rouge and they seemed intereste...
5.
...ke to the bureau in Baton Rouge and they seemed interested but hard to tell in a way because they spoke in bureau speak language i Redacted Privileged I original Message From William Langford Sent Thursday December AM To Phillip A Deluca subjec...
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Content Matches:
(5 occurrences)
1.
...r Bear Stearns was acquired by JPMorgan Arthur Midd emiss as umed a similar role withJPMorganAMLcompliance working with Langford Ex.126at Ex.120at JPMC Response Und i sputed th at th cited SVI Ex ates th at in June Mr Middlemiss tran i tioned f...
2.
...r Stea knew or recklessly disregarded that Ep ste in ran a sex traffi kin ve ntur See CSMF On Janua,y JO I Ryan e-mails Langford DeLuca and Nichols Subject Re Jeffrey Epstein Seems JPMC never was served a subpoena which I.find odd since we were...
3.
...k of Bear something about and transactions were of interest to them Ex at JPMC Response Und i sputed th at Ryan emailed Langford Lu ca and i ols Januaiy and th cited email co nt a in he quoted te xt Case Document Filed Page of Disputed in sofa...
4.
...financier erv billi naire Jeffrey Ep stein whom it is alleged that he retained a pr curer underage girls at a in th qu langu age Di put in so far as SV I ont ds a hi fa upp i an infer ce a JPM an kne or re kle ss di re arde that Ep in ran a tr...
5.
...re arded that Ep tein ra a traffi kin enture See CS MF r,r Case Document Filed Page of Ryan testified that she wrote to Langford I typed SVU and his name and there is a Gawker st01y Law Order commerates sic JE taste for teen hookers Ex at Ex at...
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Content Matches:
(5 occurrences)
1.
...Eps in nti ty in ancia st Co mp a In fi led a co aint aga in st Th ea te a Co mp a ies In a he co a int co ta in qu ed language Disp ut ed in sofa as USV I conte ds at is fact upp i a infe ce a JP Mo gan or ea te a be efited fr paicipat in in...
2.
...not be pr ese nt ed at tr ial in a dmi ssib fonn Ex at JPMC Response Undisputed hat i ted doc umen co nt a in he quoted language USVI Ex at Disputed in sofa as USVI co te ds at hi fact upp is an inference at JPMorgan obstr cted enforcement of T...
3.
...ess of Eps in Sout rn Trns Co mp a USV I Ex at USVI Ex at USVI at Und i sputed hat Eps in at orney es ded wi th qu oted lang age USVI Ex at Disp ted extent USVI co nt ds at hi te tim es ab li es as a ega atte th at th cited out eac disc ai 267g...
4.
...ed ha li eved Epsteins explanation th at it was a mi ake Id a With respect to efforts to establi an English as a Second Language clas Ms de Jongh testified that she was not aware an of the women were potential trafficking victims Ex at JPMC Res...
5.
...ent due to reputational ri co cerns rat er tha legal concerns or concerns about Ep ste in account act i vity JPMC Ex at Langford further test i fied that he did ot Case Document Filed Page of believe th at Epstein was engaging in co inued illeg...
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Content Matches:
(5 occurrences)
1.
...son is now deputy prim minister Ex at Ex at at JPMC Response Undisputed that the cited docum2.6 ent contains the quoted language Disputed as to ter3.8 ality in ligh5.8 of the fa ct that Epstein did not refer Mandelson to the Private Bank See JP...
2.
...Jami sic quietly sic up to you Ex at Ex at at JPMC Response Undisputed that the cited docum2.6 ent contains the quoted language Disputed as to ter3.8 ality in ligh5.8 of the fa ct that Epstein did not refer Mandelson to the Private Bank See JP...
3.
...ay sic we should talk before elve Ex at Ex at Ex at JPMC Response Undisputed that the cited documen contains the quoted language Disputed insofar as USVI contends that this fact supports an inference that JPMorgan benefited from participating i...
4.
...Eps in nti ty in ancia st Co mp a In fi led a co aint aga in st Th ea te a Co mp a ies In a he co a int co ta in qu ed language Disp ut ed in sofa as USV I conte ds at is fact upp i a infe ce a JP Mo gan or ea te a be efited fr paicipat in in...
5.
...cannot be pr ese nt ed at tr ial in a dmi ssib fonn at JPMC Response Undisputed hat i ted doc umen co nt a in he quoted language USVI Ex at Disputed in sofa as USVI co te ds at hi fact upp is an inference at JPMorgan obstr cted enforcement of T...
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Content Matches:
(5 occurrences)
1.
...CORPEXCHANGE/OU EXCHANGE ADMIN I STRATIVE GROUP YDI BOHF23SPDL RE I I ENTS/CN MARYANN RYA PM angfo rd i lliam i lliam.d langford pmchase.com Deluca Phillip A phillip.a de uca jpmchase.com i cho ina A nina.a.nichols jpmchase.com Subject RE Jeffr...
2.
...JPMorgan chase an N.A I Legal and Com pl i ance Department I Wood Avenue South Floor Iselin NJ I I original Message om Langford William Sent Monday January AM To eluca Phil ip A Nichols Nina A cc Ryan Maryanne subject RE Jeffrey ps tein at do...
3.
...ce was it the negative media th i sum er original Message From eluca Phillip A Sent Monday January AM To Nichols Nina A Langford Wil iam Cc Ryan Ma yanne subject FW Jeffrey Epste i Here is the ap i response memo re ate to stein as wel I be sen...
4.
...Filed Page of subject FW Jeffrey Epstein Maryanne can you please begi to gather his info anks Phil original Message Fro Langfo William Sent Monday January AM To De luca Phil ip A Nichols Nina A Subject RE Jeffrey Epstein Ok Ca you a ll assemble...
5.
...t with Good w.good com or i gina Message om Deluca Phillip A sent onday January AM Eastern Standard Ti ichols i na A cc Langford Wil iam Su bj ect FW Jeffrey Epste i Nina welcome sorry to start you day off with a azy matter but Im sure when you...
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Content Matches:
(5 occurrences)
1.
...SD Do Page of Accordingly the Federal Criminal Action remains pending Discussion I Section Imposes a Mandatory Stay The language of Title United States Code Section is clear and mandatory a parallel civil action shall be stayed until the end of...
2.
...aration of powers principles emphasis added One District Court within the Eleventh Circuit recently construed the plain language of as requirfing a stay in a case where a parallel criminal action is pending Doe Francis No CV WL Le.wis __ Tein l...
3.
...in Bay County Florida arising from the same facts and involving the same parties as the Instant action noting that the language of U.S.C is clear that a stay is required in a case such as this where a parallel criminal action is pending which...
4.
...includes investigation u.s.c The only reported decision addressing this provision interpreted it according to its plain language See Ara Khan No CV WL E.D.N.Y June ordering all proceedings in this case stayed pending the conclusion of the gover...
5.
...e this determination despite the plaintiffs complaints about the frustrating delay and that the state criminal case has languished for almost two years with no end Le.wi.s T.ein lL I tl-1 II GRAND AVENUE SUITE COCDNUTGROVE FLORIDA Case Document...
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Content Matches:
(5 occurrences)
1.
...ircuit Second while a reader of Chemical Bank cannot be certain whether the district court complied with Martindell the language quoted above certainly suggests that the district court engaged in the balancing exercise that Martindell contempla...
2.
...nt when determining whether a party has reasonably relied on the protective order the scope of the protective order the language of the order itself the level of inquiry the court undertook before granting the order and the nature ofreliance on...
3.
...on a blanket order in producing documents or submitting to a deposition Id quoting EPDM F.R.D at The second factor-the language of the Protective Order itself-similarly weighs in favor of modification The Protective Order provided that confide...
4.
...h disclosure to shield anything she said or produced from a grand jurys scrutiny As the court reasoned in EPDM F.R.D at language stating that the party receiving designated confidential information shall not use or disclose the information exce...
5.
...d Under Seal This decision accords with those of other courts in this Circuit Where a protective order contains express language that limits the time period for enforcement anticipates the potential for modification or contains specific procedu...
Content Matches:
(5 occurrences)
1.
...ntiff-4 to share-2 conf-3idential 2in3f-4ormation-2 2with law en3force-5me-2nt App Ms M-4ax4we-4ll obj-4ected to th-4is lang u-4age which-4 w-4as 4r-4emov-2ed an4d-4 never 5made part 4of a court 4order Ap-5p The sub-4p-2oen-3a So i3f t-5he ci-3...
2.
...ATHAN District Judge Both parties have asked for th Cour3.8 to ente4.7 a protective ord While ey agree on most of the language areas of dispute have emerged rst Ms Maxwell seeks language allowing her to publicly referen ce alleged victims or wi...
3.
...rd to the4.5 media in public fora or in liti gation relating to Ms Maxwell or Jeffrey Epstein Second Ms Maxwell seeks language restricting potential Government witnesses and their counsel fro5.4 using scovery materials any rpose other than prep...
4.
...ls any rpose other than prep5.2 ari ng for the crimin5.9 al trial in this action The Government has proposed contrary language on both of these issues For the following reasons the ourt adopts the Gove rnment 2s proposed protective order Under...
5.
...ctions of the privacy of itnesses and alleged vic tims that is required by law In contrast the Government 2s proffere language would allow Ms Maxwell to publicly reference individuals who have spoken by name on the record in this case It also a...
Content Matches:
(5 occurrences)
1.
...otections of the privacy of witnesses and alleged victims that is required by law In contrast the Governments proffered language would allow Ms Maxwell to publicly reference individuals who have spoken by name on the record in this case It also...
2.
...otections of the privacy of witnesses and alleged victims that is required by law In contrast the Governments proffered language would allow Ms Maxwell to publicly reference individuals who have spoken by name on the record in this case It also...
3.
...otections of the privacy of witnesses and alleged victims that is required by law In contrast the Governments proffered language would allow Ms Maxwell to publicly reference individuals who have spoken by name on the record in this case It also...
4.
...otections of the privacy of witnesses and alleged victims that is required by law In contrast the Governments proffered language would allow Ms Maxwell to publicly reference individuals who have spoken by name on the record in this case It also...
5.
...otections of the privacy of witnesses and alleged victims that is required by law In contrast the Governments proffered language would allow Ms Maxwell to publicly reference individuals who have spoken by name on the record in this case It also...
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Content Matches:
(4 occurrences)
1.
...key witness Epsteins attorney Jack Goldberger did not return phone messages A source close to the case suggested it is languishing pending a decision by the FBI on whether to refer it federal prosecutors We still have a pending case FBI spokes...
2.
...police concluded Neither despicable massages and sometimes sex was charged The girl told police inves play Much of the language in This is not the first time tigators that she informed the Jane Doe suit mirrors that Epstein has been sued over...
3.
...NNAH-ITC LEGATS ASST TECH AG/EQUIP POC 267WRCSC EVIDNCE PURCH TEL TOLL RECS FT MON 267NRCSC HI FORMANT CW UCO-GROUP FOR LANG ASST LA6 DIV EXAMS UCO-GROUP II NON F6I LAS EX _.II I I I I I ICT 267WITN COOR IO ANTED fLYR ARS ART FD-JSO Rev Mount C...
4.
...d the former Soviet Union The peculiar sale of his former marital home to a Kazakh businessman for million after it had languished unsold for five years at million has never been satisfactorily explained In the recent leak of American diplomati...
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Content Matches:
(4 occurrences)
1.
...gs Davis Bailynson So 3d Fla 4th DCA See Bionetics Corp Kenniasty So 3d Fla Accordingly Fla Stat provides the following language authorizing the award of attorneys fees as sanctions in actions such as the present litigation Upon the courts init...
2.
...erved in conjunction with a demand In fact regarding motions for attorneys fees the Statute is limited to the following language regarding the safe harbor provision A motion by a party seeking sanctions under this section must be served but may...
3.
...ument here Plaintiff has failed to provide any supporting authority whatsoever and there is no statutory requirement or language in that supporting record evidence must exist to properly serve a demand and motion for attorneys fees The central...
4.
...ury for use by the grand jury or on order of the court pursuant to Accordingly based on the clear unambiguous statutory language set forth in only the Clerk not the State Attorney may release grand jury materials pursuant to an order of the cou...
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Content Matches:
(4 occurrences)
1.
...ion as creating a private cause of action against the State Attorney and Clerk is therefore not only unsupported by the language of section but is actually paradoxical to its plain language of the statute As such this Court lacks the power to c...
2.
...ctually paradoxical to its plain language of the statute As such this Court lacks the power to construe the unambiguous language of section in a way that would extend its express terms and create a cause of action where none exists To do so wou...
3.
...lleged in The Post cannot use a claim for declaratory relief under Chapter to create substantive rights which the plain language of Section clearly demonstrates do not exist On its face the Section does not expressly or impliedly grant the publ...
4.
...ion as creating a private cause of action against the State Attorney and Clerk is therefore not only unsupported by the language of section but is actually paradoxical to its plain language of the statute Similarly any argument that a substanti...
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Content Matches:
(4 occurrences)
1.
...plication of current law Specifically your action for declaratory relief fails based on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is ordered by a court pursuant to subsection fo...
2.
...plication of current law Specifically your action for declaratory relief fails based on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is ordered by a court pursuant to subsection fo...
3.
...the media under both the statute and the First Amendment to the US Constitution in furtherance of justice The statutory language you cite refers to instances where a person is seeking grand jury materials for use in a civil or in a criminal cas...
4.
...plication of current law Specifically your action for declaratory relief fails based on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is ordered by a court pursuant to subsection I...
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Content Matches:
(4 occurrences)
1.
...arged with the more serious crimes of sexual activity with minors and 223slammed State Attorney Barry Krischer in blunt language seldom used by law enforcement official with another because of what he perceived as that office 2s mishandling of...
2.
...charged with the more serious crimes of sexual activity with minors and slammed State Attorney Barry Krischer in blunt language seldom used by one law enforcement official with another because of what he perceived as that offices mishandling o...
3.
...CLERK PM I Epsteins attorney Jack Goldberger did not return phone I messages A source close to the case suggested it is languishing pending a decision by the FBI on whether to refer it to federal prosecutors still have a pending case FBI spokes...
4.
...ZZO CLERK PM Epsteins attorney Jack Goldberger did not return phone messages A source close to the case suggested it is languishing I I I I pending a decision by the FBI on whether to refer it to federal prosecutors We still have a pending case...
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Content Matches:
(4 occurrences)
1.
...re sent by an FBI administrative employee who was not directly involved in the investigation incorporated standard form language used by the FBI when communicating with victims and were not drafted or reviewed by the subjects Moreover the state...
2.
...re sent by an FBI administrative employee who was not directly involved in the investigation incorporated standard form language used by the FBI when communicating with victims and were not drafted or reviewed by the subjects Moreover the state...
3.
...with respect to the NPA that agreement to which the Southern District of New York was not a party which by its express language pertained exclusively to the SDFL investigation and which not purport to bind any other Office or District does not...
4.
...with respect to the NPA that agreement to which the Southern District of New York was not a party which by its express language pertained exclusively to the SDFL investigation and which did not purport to bind any other Office or District does...
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Content Matches:
(4 occurrences)
1.
...close grand jury materials despite the traditional rule of secrecy fact his is contemplated and supported by section 2s language aig-10 also rovides helpful instruction what a trial10 court should consider when faced with this issue Bottom BBox...
2.
...nl10 ess required to be di10 sclose by a court The st atute rticulates three exceptions to the prohibi-10 tion Its very language contemplates the trial court 2s bility to order disclos-10 ure except when required by court disclose Fla Stat Alth...
3.
...Td Td EMC MCID BDC Tw Tm has chosen the system and it is not-10 our prerogative to elect another-10 alternative at The language of the10 statute should con10 trol for another rea9.9 son The Florida Constitution provides broad cess to public re...
4.
...the10 pending request to access the grand ry materials We judges not-10 kings and on a clean slate I would stick to the language of th statute Not final until disposition of timely filed motion for rehearing
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Content Matches:
(4 occurrences)
1.
...Jury No FGJ WPB S.D Fla Both cases arise out of the same occurrence and allege that the minor plaintiff is a victim The language of section of title United States Code is clear a parallel civil action shall be stayed until the end of all phases...
2.
...rt within the Eleventh Circuit facing the identical issue with a pending state prosecution recently construed the plain language of as requiring a stay in a case where a parallel criminal action is pending Doe Francis No CV MCR/WCS WL at N.D Fl...
3.
...in Bay County Florida arising from the same facts and involving the same parties as the Instant action noting that the language of Case Document Entered on FLSD Docket Page of U.S.C is clear that a stay is required in a case such as this where...
4.
...to the frustrating delay in both the criminal case and the civil case Id The Francis II court in adhering to the plain language of the statute also adhered to the well established priority of criminal proceedings over civil proceedings Cf Unit...
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Content Matches:
(4 occurrences)
1.
...amended version of the statute is applicable in this action However for purposes of this motion the relevant statutory language is the same Case Document Entered on FLSD Docket Page of Case No CV-80380-Marra-Johnson Page No Relevant to Plainti...
2.
...olations of U.S.C Rather Plaintiff has alleged conclusory allegations simply attempting to track parts of the statutory language in the statute without underlying factual allegations pertaining to the Plaintiff and any conduct by Defendant See...
3.
...to designate whether Plaintiff is relying on a or Second although the complaint does contain a partial tracking of the language in U.S.C it contains absolutely no factual allegations concerning the requisite using the mail or any facility or m...
4.
....e with what criminal offense could Plaintiff and Defendant have been charged Again a Plaintiff cannot simply track the language of a statute without some underlying factual allegations to Case Document Entered on FLSD Docket Page of Case No CV...
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Content Matches:
(4 occurrences)
1.
...amended version of the statute is applicable in this action However for purposes of this motion the relevant statutory language is the same Case Document Entered on FLSD Docket Page of Case No CV-80381-Marra-Johnson Page No the case of a perso...
2.
...olations of U.S.C Rather Plaintiff has alleged conclusory allegations simply attempting to track parts of the statutory language in the statute without underlying factual allegations pertaining to the Plaintiff and any conduct by Defendant See...
3.
...to designate whether Plaintiff is relying on a or Second although the complaint does contain a partial tracking of the language in U.S.C it contains absolutely no factual allegations concerning the requisite using the mail or any facility or m...
4.
....e with what criminal offense could Plaintiff and Defendant have been charged Again a Plaintiff cannot simply track the language of a statute without some underlying factual allegations to Case Document Entered on FLSD Docket Page of Case No CV...
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Content Matches:
(4 occurrences)
1.
...Jury No FGJ WPB S.D Fla Both cases arise out of the same occurrence and allege that the minor plaintiffis a victim The language of section of title United States Code is clear a parallel civil action shall be stayed until the end of all phases...
2.
...rt within the Eleventh Circuit facing the identical issue with a pending state prosecution recently construed the plain language of as requiring a stay in a case where a parallel criminal action is pending Doe Francis No CV MCR/WCS WL at N.D Fl...
3.
...in Bay County Florida arising from the same facts and involving the same parties as the Instant action noting that the language of Case Document Entered on FLSD Docket Page of U.S.C is clear that a stay is requzred in a case such as this where...
4.
...to the frustrating delay in both the criminal case and the civil case Id The Francis II court in adhering to the plain language of the statute also adhered to the well established priority of criminal proceedings over civil proceedings Cf Unit...
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Content Matches:
(4 occurrences)
1.
...g ainst the defe ndant The Court holds that it does bec ause the Case Document Entered on FLSD Docket Page of statutory lang uag cle arly contemplates pr e-c harg proc eeding For instanc subsec tions a and a provide rig hts that attach to a ny...
2.
...s Cir uit ha ote th a vi tim a qu ir ri hts un de he CV RA ve fo re pr os uti on his view is supported by the statutory lang uag which ives the victims rig hts before the ac cepting of ple a a re me nts a nd th re fo re fo re a dju dic a tio ui...
3.
...at for example initi al appe ara nces a nd bond hear ings ast the overnme nt?s interpre tation ignor es the a dditional langua throug hout the statute that clea rly contemplates pre char prote ctions such as subsec tion manda te that U.S ag enc...
4.
...io Th us to the extent that the victims pre-c harg CVRA rig hts impi ng upon prose cutorial discr etion under the plain lang uag of the statute those rig hts must ield Having deter mined that as a ma tter of law the CVRA can a pply befor for ma...
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Content Matches:
(4 occurrences)
1.
...ent the ones I have sent you recently are plea agreements that get filed with the court Please see if the appeal waiver language in those versions is alright Re your paragraph As I mentioned we will not waive the presentence investigation I kno...
2.
...oval of this procedure because as I mentioned I think it is probably in their best interests In terms of plea agreement language let me suggest the following The United States agrees to make a motion seeking the appointment of a Guardian ad Lit...
3.
...ude the last two sentences of your paragraph Re the two paragraphs following your paragraph I will include our standard language regarding resolving all criminal liability and I will mention co conspirators but I would prefer not to highlight f...
4.
...e I I can prepare letters withdrawing them as of the signing of the plea agreement but I would prefer to truce out that language In my eyes once we have a plea agreement the has ended and there can be no more use of the I had hoped that we were...
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Content Matches:
(4 occurrences)
1.
...osacuuon Agreement Hi Jay Hm is my attempt at combining our thoughts I need to talk to the office about the immigration language before I put It in here I know that we have not and dont plan to ask immigration to do that but let me see if they...
2.
...it in writing I spent 1:1bout an hour with a former corporate counsel from a hospital who now works here to go over the language I think that the attached addresses the concern about having an unlimited number of claimed victims without me tryi...
3.
...oncern about having an unlimited number of claimed victims without me trying to bind girls whom I do not represent This language hasnt been approved by the office yet so consider it a draft These are all the same document just in different form...
4.
...ommgnS!QrellT/Klrkland on Attaehrnent 247teln Non-Pro,eQullon Agre11ment.doc ll!!MUIYChlVllg llY,mr QommQ11St9m,.IT/Klrklang-Els QO US_Atty_Cor_0081 Case Document Entered on FLSD Docket Page of Attachment Epstein Non-pro 247ecuU ew dr ha been a...
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Content Matches:
(4 occurrences)
1.
...e Sustained In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language from Palm Beach State Attorneys File Exhibit The Court finds that this language does not substantially change the e...
2.
...ssage table In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language CW SR The Court finds that this language does not substantially change the exhibit and thus the Courts ruling holds...
3.
...n Sustained In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language to Virginia Roberts The Court finds that this language does not substantially change the exhibit and thus the Court...
4.
...s Overruled In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language and/or Property Receipts The Court finds that this language does not substantially change the exhibit and thus the...
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Content Matches:
(4 occurrences)
1.
...e Sustained In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language from Palm Beach State Attorneys File Exhibit The Court finds that this language does not substantially change the e...
2.
...ssage table In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language CW SR The Court finds that this language does not substantially change the exhibit and thus the Courts ruling holds...
3.
...Sustained In his December I Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language to Virginia Roberts The Court finds that this language does not substantially change the exhibit and thus the Court...
4.
...s Overruled In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language and/or Property Receipts The Court finds that this language does not substantially change the exhibit and thus the...
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Content Matches:
(4 occurrences)
1.
...e Sustained In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language from Palm Beach State Attorneys File Exhibit The Comi finds that this language does not substantially change the ex...
2.
...ssage table In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language CW SR The Court finds that this language does not substantially change the exhibit and thus the Courts ruling holds...
3.
...n Sustained In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language to Virginia Roberts The Court finds that this language does not substantially change the exhibit and thus the Court...
4.
...s Overruled In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language and/or Property Receipts The Court finds that this language does not substantially change the exhibit and thus the...
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Content Matches:
(4 occurrences)
1.
...th Western Railway Co K.B wa th firs cas wher th cour examine wha th affidavi ha sa an als looke a th documents Thus th languag th affidavi wa longe vital Ther wer no tw questions shoul th cour inspec th documents an wa th for word conclusive B...
2.
...K.B was the first case where the court examined what the affidavit had to say and also looked at the documents Thus the language of the affidavit was no longer vital There were now two questions should the court inspect the documents and was th...
3.
...n purpos test Tha cas ha bee considere eve sinc i wa decide a settlin matter principle an i i no correc sa tha withi th languag use th cour wer favourin th dominan purpos test Ther i distinctio betwee primar an domi ant tha i wh on shoul prefe...
4.
...been considered ever since it was decided as settling matters of principle and it is not correct to say that within the language used the court were favouring the dominant purpose test There is no distinction between primary and domin-r ant tha...
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Content Matches:
(4 occurrences)
1.
...ich were were-4 the subject of-3 t5he P-2rote-3ctiv8e Orde-4r stric3tly des4ignated do-3cuments ing qu3oted in at Th3is language w-3as3 negotiate-3d 4by the parties to specifically exclude an exception fo-4r inv3estigations by la3w enfo-4rc6em-...
2.
...ny related matte-3r in3cluding but no3t limite-2d to inv3estigations by la3w enfo-4rceme-3nt6."-3 Se3e Exhibit at This3 language was rejected-3 by5 Ms Maxw ell be-3c6ause of-2 her c5oncerns tha3t-4 laintiff and her lawyers were-4 actin3g as3 ei...
3.
...cerns tha3t-4 laintiff and her lawyers were-4 actin3g as3 either e-4xpress or de fact3o agents of the G-2o3vernment The language agre-2ed-2 up3on an3d made-3 an Order of-3 t5his3 Court specifically exclude-3d an except4ion fo-3r law e3nforcem-3...
4.
...-2 up3on an3d made-3 an Order of-3 t5his3 Court specifically exclude-3d an except4ion fo-3r law e3nforcem-3ent Ha3d the languag no-2t be3en made an order of-3 the Co4urt Ms M-3axwell wo-3uld 3hav4e p-2roceede-2d i a diff4ere-3nt fas3hion She re...
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Content Matches:
(4 occurrences)
1.
...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Page Maxwell Confidential took place I cannot testify to an actual conv...
2.
...ing about almost years ago when this Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
3.
...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Page Maxwell Confidential te...
4.
...r no A I will not testify to an actual statement made years ago so I cannot Page Maxwell Confidential testify to actual language So you wont testify to anything Im asking you years ago about a statement you made How do you know its years ago A...
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Content Matches:
(4 occurrences)
1.
...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Page Maxwell Confidential took place I cannot testify to an actual conv...
2.
...ing about almost years ago when this Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
3.
...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Page Maxwell Confidential te...
4.
...r no A I will not testify to an actual statement made years ago so I cannot Page Maxwell Confidential testify to actual language So you wont testify to anything Im asking you years ago about a statement you made How do you know its years ago A...
PDF
Content Matches:
(4 occurrences)
1.
...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Page Maxwell Confidential took place I cannot testify to an actual conv...
2.
...ing about almost years ago when this Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
3.
...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Page Maxwell Confidential te...
4.
...r no A I will not testify to an actual statement made years ago so I cannot Page Maxwell Confidential testify to actual language So you wont testify to anything Im asking you years ago about a statement you made How do you know its years ago A...
PDF
Content Matches:
(4 occurrences)
1.
...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Page Maxwell Confidential took place I cannot testify to an actual conv...
2.
...ing about almost years ago when this Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
3.
...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Page Maxwell Confidential te...
4.
...r no A I will not testify to an actual statement made years ago so I cannot Page Maxwell Confidential testify to actual language So you wont testify to anything Im asking you years ago about a statement you made How do you know its years ago A...
PDF
Content Matches:
(4 occurrences)
1.
...orney for Jane Doe and Page JANE DOE NO II Case No Plaintiff APPEARANCES Vs JEFFREY EPSTEIN EOPOLD-KUVIN Defendant ADAM LANGINO ESQ PGA Bou evard Suite Palm Beach Gardens Flo ri da JANE DOE NO Case No Attorney for Plaintiff RICHARD WILLITS ESQ...
2.
...Plaintiff Suite400 Vs West Palm Beac Flo ri da JEFFREY EPSTEIN Attorney for Jeffrey Ep st ei Defendant ALSO PRESENT JOE LANGSAM VIDEOGRAPHER Ives Dairy Road Suite North Miami Florida July a to p.m Kress Court Reporting Inc Rue Notre Dame Miami...
3.
...b eA G?"ߗ 讗?V?V??r ek?Y _F BV gН M䞩sg?m6Eb?NMS?u?8:t??2V g?ۄ??i Case Document Filed Page of Page BY MR LANGINO Are you currently i fear of Mr Epstein A Not at this particular moment but its something I have to be worry about yes Are you persona...
4.
...nally afraid of criminal prosecution A No Do you believe that you did anything illegal A Illegal no MR LANGINO I have no further questions Thank you MR CRITTON Were going to break in about minutes Do you want to start and go for minutes or do y...
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Content Matches:
(4 occurrences)
1.
...West Flag er Street Vs Su i te JEFFREY EPSTEIN i a i Fl orida Defendant Attorney lor Jane Doe and LEOPOLD-KWIN BY ADAM LANGINO ESQ PGA Bo levard Su i te Palm Beach Gardens Flo ri da Attorney for Pages to Kress Court Reporting Inc Rue Notre Dam...
2.
...eek Okay You said three or four of those A Yes Part of her buttocks were i ctures of the irl who came over to give a MR LANGINO Object to the form massage BY MR CRITTON A Yes Okay And was there another picture at Okay But as to who those girls...
3.
...ls who came to i ve massages on let me ask it th i way A Several i mes Was she ever aware that you used her computer MR LANGINO Form THE WITNESS I dont th i nk so BY MR CRITTON Did you ever ask Ms Maxwell for permission to use her computer A I...
4.
...been asked to pay Okay Was she taking the pictures she someone or to let thern out took were people who were clothed MR LANGINO Form A Yes THE WITNESS Yes I was called to pay And were any of the pictures hat she then took any of the girls that...
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Content Matches:
(4 occurrences)
1.
...Attorney fo Jane Doe and Pa JAN DOE NO II Case Plaintiff APPE ARA NCES Vs JEFFREY EPSTEIN EOPOLD KUVIN Defend ant ADAM LANGINO ES PGA Bou ev ard Suite Palm Beach Gardens Flo rida JANE DOE NO Case No Attorney for Plaintiff RICHA RD WILLITS ESQ...
2.
...riv aintiff Sui Vs West Pa lm Beach lorida JEFFREY EPSTEIN Attorn ey for Jeff re Epst ein Defendant I ALSO PRE SENT JOE LANGSAM V!DEOGRAPHER Ives Dairy Road Suit No rth Miarn i Florida Ju a.m to p.m Kress Court Re po rt in Inc Rue Notre ame Mia...
3.
...xL!q 8a 9C uyc j?Hp o??N M??ڭիr NSu:?p?DFGI G?C(p?n I խ?JB?O n?k P?R ńHz e?P Case Document Filed Page of ll Page BY MR LANGINO Are you currently in fear of Mr Epstein A Not at this particular moment but its something I have to be worry about y...
4.
...es Are you personally afraid of criminal pros cution A No Do you believe that you did anything illegal7 A Illegal no MR LANGINO I have no further questions Thank you MR CRITTON We re going to break in about minutes Do you want to start and go f...
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Content Matches:
(4 occurrences)
1.
...on does not apply is the fact that Mr Epstein has already registered his temporary lodging with the USVIDOJ By its very language section appears only to apply in the event there are changes to Mr Epsteins temporary lodging in the United States...
2.
...ovisions ofBiU as amended while properly invoking the discretion of the Office of the Attorney General confetted in the language of this Bill to reduce the notice requirements in the Bill upon request of a registered offender who provides suppo...
3.
...hat dues nC tpph the fact that fr Lp tdn h:n alrt 267ady re isten:d his ternporn1 lodging with the lJ VlDOJ By its YlfV language section I tppear onJ rn apply in th cvern chere arc changes to Mr Epm.-ins mpor:11:y lodgin in th Unilt::d St,ncs E...
4.
...visions of Bill as amended while properly invoking the discretion of the Office of the Attorney General confened in the language of this Bill to reduce the notice requirements in the Bill upon request of a registered off ender who provides supp...
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Content Matches:
(4 occurrences)
1.
...lip.a.deluc a jpmchase.com see be low I just tried to follow up so NO do not have the conclusion original Message From Langford William Ryan Maryanne sent Mon Feb subject RE sweet I want heated sidewa ks ori ginal Message From yan Maryanne Sen...
2.
...ne sent Mon Feb subject RE sweet I want heated sidewa ks ori ginal Message From yan Maryanne Sent Monday February PM To Langford illiam subject Re I am working offline so flipp in you the link right now not possible I wil in the am I typed svu...
3.
...here in NY has not phased him as he does have heate sidewalks so I guess he has not had to shovel original Message From Langford William To Ryan Maryanne sent Mon Fe subject RE we do need to catch up he next step is to speak with Ken Starr Do y...
4.
...r Do you have any press on the NY/Manha tt an DA ac tio Original Message From Ryan Ma ryanne Sent Monday February PM To Langford Wil iam subject I hear you are out of town as I am meeting Art in the am at your office in the am Wanted to catch u...
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(4 occurrences)
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...or countersignature endorsement SECTION Title Virgin Islands Code chapter section is amended as follows a Strike the language in subsections and in their entirety In subsection paragraph strike the phrase or accepts a policy from a nonresident...
2.
...return to this jurisdiction SECTION Title section subsection is amended in the follo ing instances a by striking the language in in its entirety and inserting ne language that reads as follo ws A sex offender ho provides reasonable and reliabl...
3.
...ll be staying at each temporary lodging location or in such general locations and areas of work and by striking the language in paragraph in its entirety and inserting new language to read Within the days prior to traveling outside of the Unite...
4.
...No Bill No is amended in the follo ing instances a Section subsection is amended by striking all of the figures and language after ORG OFFICE OF THE GOVERNOR and inserting TOTAL ORG OFFICE OF THE GOVERNOR and Section MISCELLANEOUS is amended in...
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Content Matches:
(4 occurrences)
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...urt in ia allen-4.80 was drawn re an was Case Document Filed Page of II DEFINITIONS In order to facilitate precision in language which is undoubtedly important when evaluating the present claims I pro ffer fo llow7.10 ng definitions which refle...
2.
...e ct at the Palm Beach Police failed to dict ein for traf fick5.60 ing crimes at the time Carr completely ignored the language in the police report which pre dominately accused Epstein of molestation or sexual battery not trafficking Ms Carr al...
3.
...of cultural religious beliefs Abuse of difficult family situation Abuse of illegal status Abuse of lack of education language Abuse of lack of information Control of exploiters Difficulties in the past Difficulty to organise the travel Economi...
4.
...ULNERABILITY Medium Indicators Abuse of difficult family situation Abuse of illegal status Abuse of lack of education language Abuse of lack of information Control of exploiters Difficulties in the past Difficulty to organise the travel Economi...
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(4 occurrences)
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...s to any allegation that unnecessarily reflects on the moral character of an individual or states anything in repulsive language that detracts from the dignity of the court Id The allegations in the AC relating to the Prior Proceedings should b...
2.
...her claim Second the allegations of the Prior Proceedings are scandalous and described by Plaintiff with the breathless language of tabloid publications lacking both substance and cited Case Document Filed Page of sources See AC at Defendant Ep...
3.
...AC Plaintiffs conclusion in the AC that Groff had knowledge is without factual support and merely parrots the statutory language AC knew knowingly There are simply no facts to show Groff knew of the alleged private relationship between Plaintif...
4.
...s sufficient to state a claim under Section The allegations in the AC concerning this period merely track the statutory language but without providing the necessary factual support The AC therefore fails to establish that the Court has personal...
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Content Matches:
(4 occurrences)
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...laint-3 doe4s not c-2ontain 5any factual-4 a4ll-3egations of6 coer-3c4ive-2 co4nduct-2 The 5most it-3 in3cl-2u5des i-3s langu7age c-2ribbed fro-3m8 the-2 sta-3tu3te-2 and conclusory all-2eg4at-2ions which6 ar-2e not-2 p5re-2s4u-4m8ed as-2 tr-3u...
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...to e-2x5tending li-3m8it-3a4ti-3ons per-2iods taken in m7od-4er-2n st-2a4tutes All Congress had t-2o d5o was uti-3lize4 langua-3ge s4im11il-3ar-2 to tha-2t which it has e-2m8ployed m5any t-2i-6mes efore Se4e e.g U.S3.C not-3es on e-2ff6ect-3iv3...
3.
...per-3iod of 6acc-2rue-2d bu5t 3not ye4t le-2ast beca-2us4e Congress-2 deci-3ded no5t 3to i-3nc4lude-2 su4ch sta-3nda4rd language in 3th3e TVPR5A 4Ms Ranso-4m8e ca-2nnot ove-2rc-2o5m8e t-2he pr-2esumpti-2on against r-3e4tr-3oa4ct-2iv3it-3y Ms Ra...
4.
...in thi-3s case because Congre4ss chose-2 not 3to e-2m8ploy r-3eadi-3ly a-2v5ai-2la7ble-2 t3im6e te-2ste-3d statut-2o5ry language aut-2horizing an extension of3 the-2 sta-3tu3te of5 li-3m8it-3at-2io3ns for cl-2aim10s tha-3t ha-2d al-2ready acc3r...
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(4 occurrences)
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...NATHAN District Judge Both parties have asked for th Cour3.8 to ente a protective ord5.6 While ey agree on most of the language areas of dispute have emerged rst Ms Maxwell seeks language allowing her to publicly referen ce alleged victims or...
2.
...cord to the4.5 media in public fora or in liti gation relating to Ms Maxwell or Jeffrey Epstein Second Ms Maxwell seeks language restricting potential Government witnesses and their counsel fro5.4 using scovery materials any rpose other than pr...
3.
...ials any rpose other than prep5.2 ari ng for the crimin5.9 al trial in this action The Government has proposed contrary language on both of these issues For the following reasons the ourt adopts the Gove rnment 2s proposed protective order Unde...
4.
...tections of the privacy of itnesses and alleged vic tims that is required by law In contrast the Government 2s proffere language would allow Ms Maxwell to publicly reference individuals who have spoken by name on the record in this case It also...
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Content Matches:
(4 occurrences)
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...6a4nc4e4 is app-8ropr6i-11a4te a6nd will-3 try the3 pe4rjur4y c4ounts-2 se3p-9a4ra7tely Ma3xwe6ll-3 moves to st-3rike5 9langua6ge4 f-6ro t-3he4 indi-3c4tm-3e4nt t-3ha4t she be5li-3e4ve4s is-3 supe3rf6luous a4nd to di-3smi-4ss conspira6c4y c4oun...
2.
...4st c-8onduc4t C-2ourts ha4ve4 re-2a4c4he4d 9sa3me c6onc4lusi on for oth-11e-5r sta4tut-3e4s e3mpl-3oying s-2im-3i8lar5 langua6ge4 The5 Eight-2h C-2irc5uit-3 ha4s he3ld t-3ha4t the a6mend-7ments t-2o whic4h a4ll-3ow ed prose6c4uti-3on of3 se3x...
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...f the5 statut-2e4 a4nd pr-6ovide a6 roug3h a-5c4c4ount of 8the tim-3e4 a4nd plac6e4 o-9f the c6rime3 T-3ramunti at The5 langu-7a4ge4 of the5 supe rse6din-11g indi-3c4tm-3e4nt does so The5 than those3 strictly re5quire5d doe4s not ha4mpe-7r pre7...
4.
...to int-3roduc7e4 Mino-2r V5ictim testim-4ony f3or impe3rmiss-2ibl-3e4 purp3ose3s The5 C-2ourt w3il-3l not-3 strike a6ny langua6ge4 9fr6om t-3he4 supe3rse6ding i-3ndictment a4t t-3his e-5fe-2nda nt t-3o de4mons-2tra5te Case Document Filed Page o...
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Content Matches:
(3 occurrences)
1.
...is partner Mr Luttier had a court reporter and a videographer present Additionally Mr Hill on behalf of C.M A Adam Langino on behalf of B.B William Berger on behalf of three Plaintiffs were present for the deposition i I i _3 ݕh?-ܬ w?v?b Y9?L v...
2.
...BURMAN CRITTON LUTIIER COlBMA,"1 LLP MR HILL Jack Hill for CMA Banyan Boulevard Sulte400 MR LANGINO Adam Langjno from West Pabn Beach Florida Phone S6 I Leopold Kuvin on behalf of BB On behalf of Jefiley Epstein MR LUI11ER Mark Luttier on beha...
3.
...or that reason were not going forward On behalf of BB MR CRIITON I didnt see an contact ADAM LANGINO ESQUIRE because I obviously was not out there We LEOPOLD KlNIN started at about when you came in it was PGA Boulevard Suite200 approximately Mr...
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(3 occurrences)
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...Summary of Changes Policy Rescinded Searches of Housing Units Inmates and Inmate Work Areas Included updated regulation language concerning electronic searches and x-rays Federal Regulations from CFR are shown in this type Implementing instruct...
2.
...s and x-rays Federal Regulations from CFR are shown in this type Implementing instructions are shown in this type Added language clarifying cross gender use of electronic search equipment Added language concerning cross gender pat searches of f...
3.
...gender use of electronic search equipment Added language concerning cross gender pat searches of female offenders Added language concerning pat searches of transgender inmates Program Objectives The expected results of this program are Inmates...
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(3 occurrences)
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...terms or its reasonable and obvious implications To do so would be an abrogation oflegislative power Id Here the plain language of section is clear and unambiguous and therefore controls See Horowitz Plantation Gen Hosp Ltd ship So 2d Fla Acco...
2.
...efore controls See Horowitz Plantation Gen Hosp Ltd ship So 2d Fla Accordingly based on the clear unambiguous statutory language set forth in section only the Clerk not the State Attorney may release grand jury materials pursuant to an order of...
3.
...ispute The Court is fully empowered to dispose of this matter based on application of the undisputed facts to the plain language of Section Florida Statutes which renders the Plaintiffs action for declaratory relief an impossibility for Aronber...
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Content Matches:
(3 occurrences)
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...claratory action claim for relief The State Attorneys admission demonstrates that his motion is contrary to the express language of section As stated above section a examines a claim or defense when initially presented to the court Because the...
2.
...re using as their basis to get to Page attorneys position and we also agree with what the Court has said that the plain language of the statute a cause of action doesnt exist And we really cannot well be defending something without the four cor...
3.
...s THE COURT Okay Thank you Maam these But its our position that the clear Ms Boyagian back to you unambiguous statutory language it shows that this MS BOYAGIAN Your Honor Id like to note disclosure only applies to a civil or criminal case that...
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Content Matches:
(3 occurrences)
1.
...plication of current law Specifically your action for declaratory relief fails based on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is ordered by a court pursuant to subsection fo...
2.
...the media under both the statute and the First Amendment to the US Constitution in furtherance of justice The statutory language you cite refers to instances where a person is seeking grand jury materials for use in a civil or in a criminal cas...
3.
...plication of current law Specifically your action for declaratory relief fails based on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is ordered by a court pursuant to subsection I...
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Content Matches:
(3 occurrences)
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...ion as creating a private cause of action against the State Attorney and Clerk is therefore not only unsupported by the language of section but is actually paradoxical to its plain language of the Statute Id emphasis added The Courts Dismissal...
2.
...doxical to its plain language of the Statute Id emphasis added The Courts Dismissal Order was also clear that the plain language of section in its entirety required the court to look at more than simply the furthering justice provision of and t...
3.
...section does not create a private cause of action against the Clerk See Dismissal Order DE not only unsupported by the language of section but is actually paradoxical to its plain language of the statute Despite this Courts clear directive tha...
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Content Matches:
(3 occurrences)
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...arged with the more serious crimes of sexual activity with minors and 223slammed State Attorney Barry Krischer in blunt language seldom used by one law enforcement official with another because of what he perceived as that office 2s mishandling...
2.
...charged with the more serious crimes of sexual activity with minors and slammed State Attorney Barry Krischer in blunt language seldom used by one law enforcement official with another because of what he perceived as that offices mishandling o...
3.
...O CLERK PM Epstein 2s attorney Jack Goldberger did not return phone messages A source close to the case suggested it is languishing pending a decision by the FBI on whether to refer it to federal prosecutors We still have a pending case FBI spo...
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Content Matches:
(3 occurrences)
1.
...rt within the Eleventh Circuit facing the identical issue with a pending state prosecution recently construed the plain language of as requiring a stay in a case where a parallel criminal action is pending Doe Francis No CV MCR/WCS WL at N.D Fl...
2.
...in Bay County Florida arising from the same facts and involving the same parties as the Instant action noting that the language of Case Document Entered on FLSD Docket Page of U.S.C is clear that a stay is required in a case such as this where...
3.
...to the frustrating delay in both the criminal case and the civil case Id The Francis II court in adhering to the plain language of the statute also adhered to the well established priority of criminal proceedings over civil proceedings Cf Unit...
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Content Matches:
(3 occurrences)
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...olations of U.S.C Rather Plaintiff has alleged conclusory allegations simply attempting to track parts of the statutory language Case Document Entered on FLSD Docket Page of Case No CV-80232-Marra-Johnson Page No in the statute without underlyi...
2.
...to designate whether Plaintiff is relying on a or Second although the complaint does contain a partial tracking of the language in U.S.C it contains absolutely no factual allegations concerning the requisite using the mail or any facility or m...
3.
....e with what criminal offense could Plaintiff and Defendant have been charged Again a Plaintiff cannot simply track the language of a statute without some underlying factual allegations to state a claim upon which relief can be granted Accordin...
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Content Matches:
(3 occurrences)
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...Jury No FGJ WPB S.D Fla Both cases arise out of the same occurrence and allege that the minor plaintiff is a victim The language of section of title United States Code is clear a parallel civil action shall be stayed until the end of all phases...
2.
...rt within the Eleventh Circuit facing the identical issue with a pending state prosecution recently construed the plain language of as requiring a stay in a case where a parallel criminal action is pending Doe Francis No CV MCR/WCS WL at N.D Fl...
3.
...to the frustrating delay in both the criminal case and the civil case Id The Francis II court in adhering to the plain language of the statute also adhered to the well established priority of criminal proceedings over civil proceedings Cf Unit...
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Content Matches:
(3 occurrences)
1.
...olations of U.S.C Rather Plaintiff has alleged conclusory allegations simply attempting to track parts of the statutory language in the statute without underlying factual allegations pertaining to the Plaintiff and any conduct by Defendant See...
2.
...to designate whether Plaintiff is relying on a or Second although the complaint does contain a partial tracking of the language in U.S.C it contains absolutely no factual allegations concerning the requisite using the mail or any facility or m...
3.
....e with what criminal offense could Plaintiff and Defendant have been charged Again a Plaintiff cannot simply track the language of a statute without some underlying factual allegations to state a claim upon which relief can be granted Accordin...
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Content Matches:
(3 occurrences)
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...olations of U.S.C Rather Plaintiff has alleged conclusory allegations simply attempting to track parts of the statutory language Case Document Entered on FLSD Docket Page of Case No CV-80119-Marra-Johnson Page No in the statute without underlyi...
2.
...to designate whether Plaintiff is relying on a or Second although the complaint does contain a partial tracking of the language in U.S.C it contains absolutely no factual allegations concerning the requisite using the mail or any facility or m...
3.
....e with what criminal offense could Plaintiff and Defendant have been charged Again a Plaintiff cannot simply track the language of a statute without some underlying factual allegations to state a claim upon which relief can be granted Accordin...
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Content Matches:
(3 occurrences)
1.
...and his partner Mr Luttier had a court reporter and a videographer present Additionally Mr Hill on behalf of C.M A Adam Langino on behalf of B.B William Berger on behalf of three Plaintiffs were present for the deposition Case Document Entered...
2.
...ESQUIRE MARKT LUTflER ESQUJRE EW BURMAN CRITTON LUT11ER COLEMA LLP MR HJLL Jack Hill for CMA Banyan Boulevard Suite MR LANGlNO AdamLangino from West Palm Beach Florida ll Phone Leopold Kuvin on behalf of BB On behalfofJefiley Epstein MR LUTTIE...
3.
...and intimidated her and for that reason were not going fo1ward On behalf of BB MR CRITTON I didnt see any contact ADAM LANG!NO ESQUll.IB becanse I obviously was not out there We LEOPOLD KUVIN stmted at about when you came in it was PGA Bouleva...
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Content Matches:
(3 occurrences)
1.
...rnacular that would be giving him a head job right MR MERMELSTEIN Come on I mean come on She just BY MR LUffiER in the slang MR MERMELSTEIN There is no need to go to slang She just told you what they BY MR LUffiER Did it did it show him licking...
2.
...and one other event that a friend of yours had MRSA Do you know what MRSA you said was you said I think to use your is language he licked your clit A Yeah its where you get like in the A Yeah hospital after having like surgery When did that oc...
3.
...ne lick known major I knows I making licked mans licking Marijuana lied mark marked ladies lady Marra Lake lift massage language lifted large liked Iarger424:13 massages Las limited Lauderdale line Masters Lauren I lip I masturbate I I listed l...
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Content Matches:
(3 occurrences)
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...Notre Dame Miami Beach FL Page Case Document Entered on FLSD Docket Page of APPEARANCES ALSO PRESENT LEOPOLD-KUVIN ADAM LANGINO ESQ PGA Boulevard Suite Palm Beach Gardens Florida Attorney for B.B RICHARD WILLITS ESQ 10th Avenue North Suite Lake...
2.
...ER COLEMAN LLP BY ROBERT CRITTON ESQ North Flagler Drive Suite West Palm Beach Florida Attorney for Jeffrey Epstein JOE LANGSAM VIDEOGRAPHER Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Page Case Document Entered on FLSD Docket Page...
3.
...ent Entered on FLSD Docket Page of INDEX OF EXAMINATION WITNESS ALFREDO RODRIGUEZ By Mr Mermelstein By Mr Edwards By Mr Langino DIRECT INDEX OF EXHIBITS EXHIBITS Message pad Documents CROSS PAGE Kress Court Reporting Inc Rue Notre Dame Miami Be...
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Content Matches:
(3 occurrences)
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...Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of APPEARANCES ALSO PRESENT LEOPOLD-KUVIN ADAM LANGINO ESQ PGA Boulevard Suite Palm Beach Gardens Florida Attorney for B.B RICHARD WILLITS ESQ 10th Avenue North Suite Lake...
2.
...ER COLEMAN LLP BY ROBERT CRITTON ESQ North Flagler Drive Suite West Palm Beach Florida Attorney for Jeffrey Epstein JOE LANGSAM VIDEOGRAPHER Kress Court Reporting Inc Rue Notre Dame Miami Beach FL Case Document Entered on FLSD Docket Page of Ca...
3.
...ered on FLSD Docket Page of INDEX OF EXAMINATION WITNESS DIRECT ALFREDO RODRIGUEZ By Mr Mermelstein By Mr Edwards By Mr Langino EXHIBITS Message pad Documents INDEX OF EXHIBITS CROSS PAGE Page I i I I I I Kress Court Reporting Inc Rue Notre Dam...
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Content Matches:
(3 occurrences)
1.
...t is better reserved for he charging conference at trial On the second issue as will be addressed later under the plain language of the statute sinc Defendant EPSTEIN can be criminally prosecuted for each temp orally distinct event here he soli...
2.
...statutori ly exp ressed Cong ressional i ntent to do so The statut that was a ctually enacted in cont ains no comparabl language Instead of a reference restori ng pre-ex isting ights it statement of purpose describes the Acts function as expand...
3.
...he st atute on confirmed occasions and up to add itional occasions Each date or each violation is different There is no language i the statute that prohibits the Plain tiff from su ing for each violatio and the dicta set forth in Tilt on layb o...
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Content Matches:
(3 occurrences)
1.
...ng of charges against a suspected offender of Case Document Entered on FLSD Docket Page of Ass1STANCE May And the plain language of the CVRA undergirds this conclusion as it applies not simply to prosecutors but to government agencies engaged i...
2.
...government agencies engaged in the detection and investigation of crime U.S.C Indeed if there were any doubt the plain language of the CVRA extends victims right to situations in which no prosecution is underway U.S.C II of Case Document Enter...
3.
...erally but its definition of crime vk:tim requires a generous construction After reciting the direct-and-proximate-harm language at issue here one of the Acts two co-sponsors Senator Kyl explained that this is an intentionally broad definition...
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Content Matches:
(3 occurrences)
1.
...hing else you wanted to add MS VILLAFANA Well Your Honor I guess I will just tell the Court this It does indeed contain language related to that issue So I dont know if you want to make Mr Edwards jump through that hurdle or if you want to make...
2.
...mp through that hurdle or if you want to make that decision now THE COURT All right So youre telling me that Lhere some language in the agreements that does obligate lC the Government to not prosecute individuals other than Mr Epstein MS VILLAF...
3.
...the investigation of Mr Epstein subject to a protective order Which Im going to ask the parties to try and work on the language of a protective order to submit to me that would prohibit disclosure to anyone other than Mr to the victim or victi...
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Content Matches:
(3 occurrences)
1.
...Crime Victims Right at The sworn declaration of the Assistant U.S Attorney handling this matter also recounts the same language See Declaration of A Marie Villafafia in Support of United States Response to Victims Emergency Petition at The swo...
2.
...ed States Response to Victims Emergency Petition at The sworn declaration also states that victims were told about this language in October See Declaration of A Marie Villafafia at In October shortly after the agreement was signed four victims...
3.
...and choose particularly where it The Government has recently provided a new notice to the victims containing different language Case Document Entered on FLSD Docket Page of has inaccurately described the provision that it has chosen to disclos...
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Content Matches:
(3 occurrences)
1.
...red on FLSD Docket Page of On July your Affiant sent a victim notification letter to Jane Doe which contained pertinent language from Part of the Agreement Ex to the July Deel Prior to preparing and sending that letter your Affiant sent a draft...
2.
...ney wrote to your Affiant objecting to parts of the draft but accepting the part of the draft letter that contained the language from Part of the Agreement Based upon that communication your Affiant sentthevictim notification letter to Jane Doe...
3.
...civil suits filed against Mr Epstein none of Mr Epsteins attorneys ever informed your Affiant that they considered the language in the letters and the Declaration to be inaccurate In August in anticipation that the Court might order the United...
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Content Matches:
(3 occurrences)
1.
...g6 his5 state cou6r sentenc5e in6 accordan6ce with the Non-Prosecu6tio6n Agreem9ent and allow8ed their CVRA petition to languish6 before this Court as they pursued civil lawsuits against Epstein in whic they invoked the term8s of the Non-Prosec...
2.
...not grant vic)5tim9s a righ7t to in7terven7e in court proceedings See Brandt Gooding F.3d 4th Cir 223The CVRA 2s plain language m8a-1kes no re ference to interventi4on the Act therefore-6 grants no p6r-1ivilege m8u1ch less an un6conditiona rig...
3.
...be liberally construe within the confines of the rights guaranteed there is absolute ly no suggestion in the statutory language that victim8s have right independent of the governm9ent to prosecute a crim8e or set strategy United States Rubin S...
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Content Matches:
(3 occurrences)
1.
...as agreed that he will not contest jurisdiction or liability if the alleged victims elect to seek damages from him This language implies that Mr Epstein has agreed to concede jurisdiction and has waived liability whether or not each individual...
2.
...ilities of interstate commerce to induce minors to engage in prostitution Clearly that is not the case Consequently the language should be revised to reflect that the identified individuals may be victims of certain offenses but not necessarily...
3.
...certain offenses but not necessarily both offenses Additionally for the sake of fairness and candor we believe the same language contained in your letter to Judge Davis stating that the-United States takes no position as to the validity of any...
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Content Matches:
(3 occurrences)
1.
...conjunct1on and/or in roferrlng to the particular offen.se ofwhicb t?le recipient was a vlctinl We will not include the langw,.ge that we take no position as to the validity of all claims While tbe-Offke has no intention to take any position an...
2.
...fo treat all Victims with fairness and with re.spec for the victims dignity and privacy U.S.C a We will not include any language tl1at demeans the harm they:mny have suffered The letter assertions rcgai:dingrepre entation by the Podburst finn a...
3.
...nd federal attorneys or agents Wo have no objection to sending the letfets through the m.ai1 but we will not remove the language about contacting AUSA Villafana or Special Agent Ku rkendall with questions or concerns Again federal law requires...
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Content Matches:
(3 occurrences)
1.
...iling of charges against a suspected offender Case Document Entered on FLSD Docket Page of ASSISTANCE May And the plain language of the CVRA undergirds this conclusion as it applies not simply to prosecutors but to government agencies engaged i...
2.
...government agencies engaged in the detection and investigation of crime U.S.C Indeed if there were any doubt the plain language of the CVRA extends victims right to situations in which no prosecution is underway U.S.C II Case Document Entered...
3.
...erally but its definition of crime victim requires a generous construction After reciting the direct-and-proximate-harm language at issue here one of the Acts two co-sponsors Senator Kyl explained that this is an intentionally broad definition...
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Content Matches:
(3 occurrences)
1.
...a during the hearing on the plaintiffs motion a notification of the judges ruling is required I will however change the language slightly to direct the victims to discuss the matter with Mr Josefsberg With regard to your concerns with my open-e...
2.
...hat the resolution of civil damages claims is as stated in paragraphs and of the Agreement and Addendum That is why the language in the notification is taken verbatim from paragraphs and 7C of the Agreement and Addendum except that the victims...
3.
...f you have any proposed substantive changes please provide them to me Mr Goldberger and Mr Tein explicitly approved the language in my earlier victim notification letter even though they apparently were taking the position that the December let...
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Content Matches:
(3 occurrences)
1.
...s asse4.5rt th6.1at the CV RA gi5.5ves this Court bro6.9ad po6.9wer to craft appr3.3opriate Doc at the statute?s plai5n language says otherwise.5.5 That lan5.7g2.9uage explicitly provi5.7d-1.7es th6.4at a crime may not5.8 seek damage4.2s agains...
2.
...sidered appropriate quoting Karahalios U.S at Because P4.5e-.7titioners seek remedies not au thorized by the CVRA plain language their requests should be denied What?s more the plain text is supported by the CVRA?s location in the States Co6.3d...
3.
...f what co nduct is forbidden under Rule Goble at noting that in some instances an injunction which merely trac6.1ks the language of the securities st atutes an5.8d regulation will not clearly an6.2d specifically desc5.9ribe permissible and impe...
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...ected offender of Case Document Entered on FLSD Docket Page of Case Document Filed Page of Ass1STANCE May And the plain language of the CVRA undergirds this conclusion as it applies not simply to prosecutors but to government agencies engaged i...
2.
...government agencies engaged in the detection and investigation of crime U.S.C Indeed if there were any doubt the plain language of the CVRA extends victims right to situations in which no prosecution is underway U.S.C II of Case Document Enter...
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...erally but its definition of crime vk:tim requires a generous construction After reciting the direct-and-proximate-harm language at issue here one of the Acts two co-sponsors Senator Kyl explained that this is an intentionally broad definition...
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...for Sanctions Epstein notice of that fact In support of this rather circular reasoning Epstein points to the following language in the settlement agreements If any of the Parties are served with a valid subpoena court order government agency o...
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...tain a court order preventing limiting or otherwise restricting such disclosure See Epsteins Mot at emphasis added This language by its very terms concerns situations where a signatory to the settlement agreements at issue is not a party to lit...
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...s to commence necessary proceedings to obtain a court order regarding the alleged confidential information at issue the language allows a non-party to intervene in pending litigation to for example quash a pending subpoena for information deeme...
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...s who were adversely affected by the misconduct that is the subject of this Complaint MR PIKE Form Mischaracterizes the language of the document THE WITNESS Yeah I think youve misread that again You want to I certainly didnt ask for the Rothste...
2.
...ed by the misconduct that is the subject of this Complaint MR PIKE Okay Im going to move to strike Mischaracterizes the language of the document The document reads as follows for purposes of the record The Rothstein racketeering enterprise ende...
3.
...fact guilty A Im going to have to assert my Fifth Sixth and 14th Amendment sir Do you understand the term John to be a slang reference to the customer of a prostitute MR PIKE Form THE WITNESS Yes sir BY MR SCAROLA How many times were you one of...
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...s who were adversely affected by the misconduct that is the subject of this Complaint MR PIKE Form Mischaracterizes the language of the document THE WITNESS Yeah I think youve misread that again You want to I certainly didnt ask for the Rothste...
2.
...ed by the misconduct that is the subject of this Complaint MR PIKE Okay Im going to move to strike Mischaracterizes the language of the document The document reads as follows for purposes of the record The Rothstein racketeering enterprise ende...
3.
...fact guilty A Im going to have to assert my Fifth Sixth and 14th Amendment sir Do you understand the term John to be a slang reference to the customer of a prostitute MR PIKE Form THE WITNESS Yes sir BY MR SCAROLA How many times were you one of...
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...bankruptcy case We spoke.by teleph ne at length late today an reached agr eme to your proposal subject to the modified language that we cliscussed I have taken the language from your letter and revised it below based on what we hacl discussed...
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...ken the language from your letter and revised it below based on what we hacl discussed Of course also had to change the language to reflect that the letter is now being written by me I I I Accordingly this letter is intended to confirm the tenn...
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...tein What if any damages were sustained by Epstein and proximately caused by Rothstein Edwards does not agree with this language for the reason that the issue as stated fails to tie causation to Rothsteins operation of the Ponzi scheme It is Ed...
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...tatutory maximum term of years Imprisonment applies because the matter relates to sex offenses The amendment also added language to Application Note stating an upward departure may be warranted under the guideline In a case Involving a particul...
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...fendant to comply with the new registration requirements provided by the Adam Walsh Act The amendment also modifies the language In a and a relating to defendants convicted of a sexual offense described in U,S,C Not all states have Implemented...
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...fender registry In place prior to July the date of enactment of the Adam Walsh Act Thus It Is necessary to maintain the language In the guidelines providing for conditions of probation and supervised release for those offenders Fourteenth secti...
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...is Court dramatically changed the landscape and focus of this appeal by reasoning that the Florida Supreme Courts broad language in Echevarria was not intended to apply the litigation privilege to the tort of malicious prosecution So 3d at This...
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...nstant case was based on the filing of a complaint the Wolfe court stated that it is guided and restrained by the broad language and application of the privilege articulated by the Florida Supreme Court in Levin and Echevarria In Levin the Flor...
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...of an assertion of litigation privilege and directly conflicts with Wolfe Moreover the Fifth District applied the exact language misconstrued by Wolfe i.e that the litigation privilege precluded torts committed in the course of judicial proceed...
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...s who were adversely affected by the misconduct that is the subject of this Complaint MR PJKE Form Mischaracterizes the language of the document TIIE WITNESS Yeah I think youve misread that again You want to I certainly didnt ask for the Rothst...
2.
...this Complaint record It is a.m and we are on media CQ.kay-:-Im going-!o move to strike number two Mischaracter:izes-thelangU e-of tlie-docilinent BY MR SCAROLA The do ent reads as follows;-for purposes What lmowledge clo you have ofBrad Edwarc...
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...DV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Com1ney Langley c/o Spencer Kuvin South Australian Ave West Palm Beach Florida William Scherer Esquire Federal Hwy Fort Lauderdale F...
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...ed in parallel litigation that precludes Jane Does counsel from revealing in publicly-accessible pleadings the specific language in the non-prosecution agreement In his motion to stay these proceedings defendant Epstein has argued that he must...
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...nts Second when the contents of a writing are in issue an evidence other than the writing itself is distinctly inferior Language is complex and the slightest variation in wording can have enormous significance in determining the outcome of a le...
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...on his own inferences from provisions contained in the agreement but rather should be required to provide the specific language supporting those inferences In the alternative if Epstein is allowed to make his own representation about the conte...
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...zi scheme singled Mn Eawmlsouffromamong allotlier innocent RRAemployees Those accusations wereJhe only source falseli lilang Bnfrlley Edwar to Rothsteins criminal enter_i rise,_and aosent tliose allegations tfiere is no basis fo believe that Br...
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...whether they were defamatory or not from a legal aspect is not within my purview Right Okay So that must mean that the language defamatory statement was provided to you by either Mr Scarola or Mr Edwards A Well yeah yes that particular subject...
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...luation and monitoring I have taught a wide variety of computer courses including microcomputing programming in various languages and the eh/Internet at both the undergraduate and graduate level Concerning user searching behaviors on the Web an...
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(3 occurrences)
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...lients who were adversely affected by the misc that is the subject of this Complaint MR PIKE Form Mischaracteriz.es the language of the document THE WITNESS Yeah I think youve mif that again You want to I certainly didn ru for the Rothstein fir...
2.
...ed by the misconduct that is the subject of this Complaint MR PIKE Okay Im going to move to strike Mischaracterizes the language of the document The document reads as follows for purposes of the record The Rothstein rru::keteering enterprise en...
3.
...fact guilty A rm going to have to assert my Fifth Sixth and 14th Amendment sir Do you understand the tem1 John to be a slang reference to the customer ofa prostitute MR PIKE Fonn THE WI1NESS Yes sir BY MR SCAROLA How many times were you one ofL...
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(3 occurrences)
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...tatutory maximum term of years Imprisonment applies because the matter relates to sex offenses The amendment also added language to Application Note stating an upward departure may be warranted under the guideline in a case involving a particul...
2.
...fendant to comply with the new registration requirements provided by the Adam Walsh Act The amendment also modlfies the language in a and a relating to defendants convicted of a sexual offense described in U.S,C Not all states have implemented...
3.
...fender registry in place prior to July the date of enactment of the Adam Walsh Act Thus it ls necessary to maintain the language in the guidelines providing for conditions of probation and supervised release for those offenders Fourteenth secti...
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...uld do everything in his power to beat Hodges out of the money owing to him short of swearing to a lie So at While that language was stricken from the Bill of Equity by the trial court Myers sued Hodges after the conclusion of that suit for lib...
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...In its legal analysis the Third District noted the establishment of the litigation privilege in Myers supra and quoted language from Levin supra and Echevarria supra that absolute immunity must be afford to any act occurring during the course...
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...hird District concluded that the filing of a complaint was clearly an act that would fall within the parameters of that language and therefore it must be subject to the litigation privilege The opinion also notes that while tortious conduct suc...
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...uld do eve1ything in his power to beat Hodges out of the money owing to him short of swearing to a lie So at While that language was stricken from the Bill of Equity by the trial court after the conclusion of that suit Myers sued Hodges for lib...
2.
...In its legal analysis the Third District noted the establishment of the litigation privilege in Myers supra and quoted language from Levin supra and Echevarria supra that absolute immunity must be afforded to any act occurring during the cours...
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...o.3d at The Third District concluded that the filing of a complaint was an act that would fall within the scope of that language and therefore that conduct must be subject to the litigation privilege In Wolfe Judge Sheperd filed a specifically...
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...oposed general release in its entirety to the offer of judgment See Epsteins Exhibit A The terms of the release include language that specifically requires Edwards to keep the details of the settlement confidential Therefore it the Court finds...
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...art of a proposal for settlement See Bd of Trustees of Florida At Univ Bowman So 2d Fla 4th DCA In the instant case the language in the General Release even though expansive is typical of other general releases and is clear and unambiguous The...
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...uld have been imposing an unethical restriction upon his legal obligations to existing clients The Court finds that the language of the confidentiality clause is clear and allows for disclosure of the details of the settlement pursuant to valid...
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...s who were adversely affected by the misconduct that is the subject of this Complaint MR PIKE Form Mischaracterizes the language of the document THE WITNESS Yeah I think youve misread that again You want to I certainly didnt ask for the Rothste...
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...ed by the misconduct that is the subject of this Complaint MR PIKE Okay Im going to move to strike Mischaracterizes the language of the document The document reads as follows for purposes of the record The Rothstein racketeering enterprise ende...
3.
...fact guilt A Im going to have to assert my Fifth Sixth and 14th Amendment sir Do you understand the term John to be a slang reference to the customer of a prostitute MR PIKE Form THE WITNESS Yes sir BY MR SCAROLA How many times were you one of...
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...rney for Jane Doe and Page JANE DOE NO II Case No Plaintiff APPEARANCES Vs JEFFREY EPSTEIN LEOPOLD-KUVIN Defendant ADAM LANGINO ESQ PGA Boulevard Suite Palm Beach Gardens Florida JANE DOE NO Case No Attorney for B.B Plaintiff RICHARD WILLITS ES...
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...rive Plaintiff Suite Vs West Palm Beach Florida JEFFREY EPSTEIN Attorney for Jeffrey Epstein Defendant ALSO PRESENT JOE LANGSAM VJDEOGRAPHER Ives Dairy Road Suite North Miami Florida July a.m to p.m Kress Court Reporting Inc Rue Notre Dame Miam...
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...na other wf Howard Kaplan Horne Adam Tierney Bayshore Drive Suile20 Eaton Terrace Miami FL London sw1 W8EZ Email hk kaplangroup.com Place Hunter Carlyn Laurie North Miami Bea FL Mallard SL I SW DT hh fl London En a Howegego Lucy Johnnson Huntsm...
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...mbert Edward ESL Partners East Putnam Avenue Greenwich Conneticut Cath Calh Lambos Duff John Email lambosi rns.com Hrn Lang Caroline East 52nd Apt 9c NY USA rn Lange Dieter I Email dlange wilrner com jo enid Case Document Filed Page of cell ass...
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...ve of tlie Americas Room 1i Wl Plouvier Diane Denis Villa Chaptal LeVallols-Perret Pari France IHm WI Porthault Rue Collange Levallois Perret France oo el1 Dennys cell FAX Podols Jeffrey u.rorl or East 72nd St Suite 2C NY NY wl WI Polk George P...
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...e Header Type Pagination BDC GS0 gs TT0 Tf Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TD Td EMC Lang es-ES/MCID BDC TT1 Tf Td S5 awley es-ES/MCID BDC Td ne Tc Td il5 ccaw-5 ll5 p.co5 Mar-3 ch VIA3 Case No cv L7 AP-2 m/y...
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...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confiden...
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...Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
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...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Case Document Filed Page of...
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...p i res Race Restrictions Sex DOB a i tal Status es i dent Status RE IDE Age Ju enile SSN Etlmic i ty ON HI PA IC niker Lang age Medical Care Sought Treatmen Lo at i on Treatment i osition to Prosecute Re at i on to Suspect POU Other lnjm-y Dri...
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...t version In addition to the changes reflected in Exhibit A Maxwell suggests that paragraph shoul include the following language 223Only those9.2 portions of an nibus brief th at addresses particular objecting Non-Parties will be shared with4.6...
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...d prior to 221serving the brief on the objecting Non-Party consis tent with subparagraph above The addition)5.7 of this language is unnece ssary wever as Parties hav5.6 consistently redacted from their brief8.5 any identifying informa tion that...
3.
...ounsel and now the Court that she would be enable to oving that deadline forward Second with respect to the a dditional language clar ifying that the vers ion of the Omnibus Briefs to be shared with each Doe will be reda4.5 cte4.5 to elim8.5 in...
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...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Case Document Filed Page of MAGNA LEGAL SERVICES Page Maxwell Confident...
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...t Filed Page of MAGNA LEGAL SERVICES Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
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...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Case Document Filed Page of...
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...E PODHURST ORSECK P.A West Flagler Street Suite Miami Flo1ida I Phone rjosefsberg podhurst.com kezell podhurst.com ADAM LANGINO ESQUIRE LEOPOLD KUVN PGA Boulevard Suite Palm Beach Gardens Florida IO Phone skuvin leopoldkuvin.com PROSE COURT REP...
2.
...other questions right now Id just like to reserve if something comes up to ask But otherwise you may go ahead MR LANGINO It is noon so I dont know wha everybody elses schedule is I dont know how youre feeling THE WITNESS I am fine MS EZELL I do...
3.
...dule is I dont know how youre feeling THE WITNESS I am fine MS EZELL I do have another question May I uk Page MR LANGINO Go ahead Sure BY MS EZELL You said that you set up the massage tables And would you also set up the oils and the towe ls A...
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...West Flagler Street Vs Jlte JEFFREY EPSTEIN Mia mi Florida Defendant Attorney for Jane Doe IOI ond LEOPOLO WIN E!Y AON lANGINO ESQ lGA Bou evard ul to Pa BeaCll Ga rdens FI Or da Atto,ney for Pages to Kress Court Reporting Inc Rue Notre Dame M...
2.
...ROBERT CR!TTON ESQ SIS Ncrth flagJer DMve Su i te lO Wast Palm Beach orida Attomay for Jaffrey Epste i ALSO PRESENT JOE LANGSAM VIOEOGAAPHER CONTINUED INDEX OF AMINATION WITNESS DJR CT CROSS REDIRECT RECROSS a II LFREDO RODRIGUEZ Oy Ms Ezell ns...
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...TNESS DJR CT CROSS REDIRECT RECROSS a II LFREDO RODRIGUEZ Oy Ms Ezell ns By Mr WIits By Mr Critton Mr Edwards J3B By Mr Langl CONTINUED INDEX OF EXHJBITS PlAlNTif PS PAGE ra I ng i6 Photo9ra J1 Photograph Photograph Photllgr ph Report Exh i i t...
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...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confiden...
2.
...Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
3.
...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Case Document Filed Page of...
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...ther things the tiling of charges against a suspected offender Case Document Filed Page of ASSISTANCE May And the plain language of the CVRA undergirds this conclusion as it applies not simply to prosecutors but to government agencies engaged i...
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...government agencies engaged in the detection and investigation of crime U.S.C Indeed ifthere were any doubt i the plain language of the CVRA extends victims right to situatio ns in which no prosecution is underway U.S.C II Case Document Filed P...
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...erally but its definition of crime victim requires a generous construction After reciting the direct-and proximate-harm language at issue here one of the Acts two co-sponsors Senator Kyl plained that this is an intentionally broad definition be...
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...Y KATHERINE EZELL West Flagler Street Suite Miami Florida Attorney for Jane Doe and Page APPEARANCES LEOPOLD-KUVIN ADAM LANGINO ESQ PGA Boulevard Suite Palm Beach Gardens Florida Attorney for B.B RICHARD WILLITS ESQ 10th Avenue North Suite Lake...
2.
...P BY ROBERT CRITTON ESQ North Flagler Drive Suite West Palm Beach Florida Attorney for Jeffrey Epstein ALSO PRESENT JOE LANGSAM VIDEOGRAPHER Case Document Filed Page of Rue Notre Dame Miami Beach FL Kress Court Reporting Inc Pages to Page Were...
3.
...t Flagler Street Vs Suite JEFFREY EPSTEIN Miam i Florida Defendant Attorney for ane Doe and I LEOPOI.D-KlNJN BY ADAM LANGINO ESQ PGA Boulevard Suite Palm Beach ardens Aorida Attorney for Pages to Kress Court Reporting Inc Rue otre Dame Miami Be...
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...ected offender of Case Document Entered on FLSD Docket Page of Case Document Filed Page of Ass1STANCE May And the plain language of the CVRA undergirds this conclusion as it applies not simply to prosecutors but to government agencies engaged i...
2.
...government agencies engaged in the detection and investigation of crime U.S.C Indeed if there were any doubt the plain language of the CVRA extends victims right to situations in which no prosecution is underway U.S.C II of Case Document Enter...
3.
...erally but its definition of crime vk:tim requires a generous construction After reciting the direct-and-proximate-harm language at issue here one of the Acts two co-sponsors Senator Kyl explained that this is an intentionally broad definition...
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...a statu5.7t-1.5e nonetheless4.9 contains an im8.5plied righ5.7t cou5.7r ts trad5.7ition5.7a-.5lly5.7 loo5.7k.7ed to the language the statute itself its legislative history the underlying purpose and structure of the statutory schem8.8e-.2 and t...
2.
...8e Court has also suggested that the lack5.5 of an express ri ght or indem8.1n.3ification can be dispositive unless the language of the statutes indicates that they were enacted for the special b5.4e-.8nefit of a cla ss of which petitioner is a...
3.
...hat Congress did not even contem8.2plate le alone intend for such rights W9.4ithout express Case Document Filed Page of language or even a hint of intent the essential predicate for imp lication of a private rem8e-1dy does not exist here Id at...
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...Rona Thomas Dr Thelca Bedminister special friends Va dis Springette Bernice Leerdam Marilyn Fret Chris Danie Jenni fer Lang Doreen Bucanhan Carlo Woods and many more too numer ous mention Funeral arrangements are en trusted to Turnbulls Funera...
2.
...Na tive children once were to boarding school where students were prohibited from practicing their tribal songs amid language suppression efforts The story ends with the grandfather reconnecting with those cherished traditions Bill said her ma...
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...Native chil dren living life in a vast state populated by multiple Native groups with their own diverse cultures and languages Gillim said she long wanted to do a show featuring a store thats a social center for locals like a local store of th...
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...cument Filed Page of Case Document Filed Page of From Sent Deluca Phillip A phillip.a.deluca jpmchase.com PM To Subject Langford William william.d.langford jpmchase.com Nichols Nina A nina.a.nichols jpmchase.com RE Jeffrey Epstein will do origi...
2.
...iam.d.langford jpmchase.com Nichols Nina A nina.a.nichols jpmchase.com RE Jeffrey Epstein will do original Message From Langford William Sent Monday January AM To Deluca Phillip A Nichols Nina A subject RE Jeffrey Epstein Ok can you all assembl...
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...ood w.good.com original Message From Deluca Phillip A Sent Monday January AM Eastern Standard Time To Nichols Nina A cc Langford William subject FW Jeffrey Epstein Nina Welcome Sorry to start your day off with a crazy matter but Im sure when yo...
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...Page of From Sent Deluca Phill i A ph i llip a de uca jpmchase com PM To CC Nichols Nina A i na.a.n i cho jprnchase.com Langford Wil li am ill iam.d angford jpmchase.com Ryan Maryanne maryanne.x ryan jpmchase.com Subject Attachments Jeffrey Eps...
2.
...n Maryanne sub ect FW Jeffrey Epstein Maryanne Can you please begin to gather is info Than Ph i Original Mes sa ge From Langford i ll i am sent Monday January AM To Deluca Phillip A ichols Nina A sub ect RE Jeffre Epstein ok Can you all assembl...
3.
...ood w.good om or i ginal Me ss age From Deluc a Phillip A Sent Mo a Jan ar AM Ea st ern Sta dard i To Ni chols ina A cc Langford Wi i am sub ect FW effrey Epste i Ni a wel ome Sorry to start your ay off with a craz a tter Im su re he you is cus...
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...Sent Ryan Maryanne CORPEXCHANGE/OU EXCHANGE ADMINISTRATIVE GROUP FYDI BOH 23SPDL CN RECI Pl ENTS/CN MARYAN RY AN PM To Langford William william.d.langford jpmchase.com Deluca Phillip A phillip a.d eluca jpmchase.com Nichols Nina A nina.a.nicho...
2.
...JPMorgan chase Bank N.A.I Legal and compliance Department I Wood Avenue South Floor Iselin NJ I I original Message From Langford William Sent Monday January AM To Deluca Phillip A Nichols Nina A cc Ryan Maryanne subject RE Jeff ey Epstein what...
3.
...y Was it the negative media this summer original Message From Deluca Phillip A Sent Monday January AM To Nichols Nina A Langford William Cc Ryan Maryanne subject FW Jeffrey Epstein Here is the rapid response memo related to Epstein as well as i...
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...sity or college i gh Sch oo Private elementary schoo Seminary Conservatory A no ther academ ic i nstitution inclu ing a language train i ng program Vocationa or other recognized nonacademic institution other han a an uage rain in program St ude...
2.
...ted photo i the format plai ed in the Certificate of lig i bility foc Non immigrant Stu ent Statu for Academic an language Students Fonn Of Cert i ficate of Eligibility for Nonimmigrant Student Stat for Vocational Students Form Your schoo i ll...
3.
...nge in your onimm i grant sta us to anoth category th ou gh Cit i enship and Imm i gra ion Serv i ces USCIS See JJlangilly__lio immig.ra.nt Stili!_sr on he USC I websi to learn more While you a in the United States receiving a change of atus fr...
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...0this case 10and do nothing 10more than Congress knows how to write the words it mitted in Congress includes particular langu-10.6age in 10one place but omits it in another that me-6.6ans Congress intended di-4.7fferen-12.5ce Loughrin Stat7.4es...
2.
...KFC Inc U.S Congress-11.1 thus demonstrated CERCLA that it knew how to provide the of 10cleanup 10costs and 10that the language-7 to de4.3fine4.3 RCRA doe4.3s quote4.3s-.3 La4.3tin to 10a4.4void this common sense but pari mate4.7ria suggests 1...
3.
...cl aim any further Summary judgment must enter.9.7 US-5.1VI Retroac-7.5t1.7ive F5.9i-2.5nally dispute that hing in the languag-10.1e3.7 TVPRA or its legislative history indica13.8te that Congress intend9.7ed re troa-6.7ctive applicatio-10.5n V...
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...e USVI First Lady solicited Epstein 2s input on USV I 2s pending sex offender monito5.7 ring legislation and shared aft languag5.7 from DOJ4.6 with Epstein writing5.4 223This is suggested language will it work4.1 for you CSMF emphasis added Eps...
2.
...)5.8g drafts of legislation outside DOJ was defin5.8itely a problem CSMF It did not stop there When Epstein?s preferred language did not make it into law the First Lady wrote to Epstein to reassure him that although had not included everything...
3.
...n5.69809 formal legis5.1lativ5.69809e in December the USVI legislature passed an amendment that was nearly identical to language Epstein5.4?s lawyer had proposed for the July bill CSMF6.8 Case Document Filed Page of U?vO?OP?F3O G?M?tI?OO?G0 W?i...
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EXHIBIT Case Document Filed Page of Case Document Filed Page of From Sent To Subject Location Start End Langford William CORPEXCHANGE/OU EXCHANGE ADMINISTRATIVE GROUP FYDIBOHF23SPDLT CN RECIPIENTS/CN WILLIAM.D.LANGFORD PM Cutler...
2.
...VE GROUP FYDIBOHF23SPDLT CN RECIPIENTS/CN WILLIAM.D.LANGFORD PM Cutler Stephen stephen.m.cutler jpmorgan.com FW William Langford Jes Staley Catherine Keating RE Jeffrey Epstein Dial-in Participant passcode PM PM Show Time As Tentative When Frid...
3.
...aylight saving time adjustments Original Appointment From Keating Catherine Sent Monday January PM To Keating Catherine Langford William Staley Jes Subject William Langford Jes Staley Catherine Keating RE Jeffrey Epstein When Friday January AM...
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...rose4.4 utions in the SDFL10.6 and the nspirator immunit-12.4 ovi-12 sion which contains no such limitation Even if the lang10 e4 e4 e4 amb-10 uous as to its impact on prosecutions on the SDFL11 which it is not ambig9.7 must be onstrued ainst t...
2.
...d that this ent does not bind feder-7.6 state or ecuting9.4 hori-4.2 an Offi-4.2 See Perez States Nos Civ Cr at No such lang9.5 is included in he NPA Moreove-6.5 andard A refe-8.4 rs separat-13.7 he es aces hers tha5.4 to Unite5.4 Sta5.4 es int...
3.
....8 a rest-3.8 on was four corne-7.8 of NPA when the NPA is view ed as a whole As noted above the absence of limiting9.6 lang9.4 in the consp-10.6 rator immunit-12.6 provisi on stands in sharp contrast-12.4 to the NPA provision rdin-9.8 the4.2 o...
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...g underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Case Document Filed Page of Case Document Filed Page of MAGNA9 LEGAL SE...
2.
...Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of t...
3.
...ales A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Case Document Filed Page of...
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(3 occurrences)
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...cases are easil distinguishable Kidd involved a date range ending in the year of indictment Moreover the quoted general langua ge from Kidd Supp 3d is incomplete The court in Kidd explains the range it is referring to by the following reference...
2.
...s not required to prove the exact date if a date reasonably near is established Id The government fails to include this language because it is inapposite to the suggestion that there is anything routine about a date range be innin Case Document...
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...nty or ambiguity set forth all the elements necessary to constitute the offence intended to be punished Undoubtedly the langua of the statute may be used in the general description of an offence but it must be accompanied with such a statement...
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(3 occurrences)
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...uble Jeopardy Clause and explained why the Clause not preclud5.7e a p5.7r-1.3osecution in that case In other words this language in Annabi was cabined to an analysis under the Double Jeopardy Clause As discussed in greater detail below the Doub...
2.
...Maxwell has no5.7t previou5.7s-.1ly been prosecuted for the offenses in the S2 Indictment Ignoring the Double Jeopardy language in Annabi the defendant argues that the phrase identical to the dismissed charges somehow creat es a different ru5....
3.
...nnabi s5.3ile4.9nt Def at Nothing in Annabi co6.3mes close5.1 articulating this unusual and confusing rule In stead the language the defendant points to in Annabi simply addressed?and rejected?the defendants eff3.8o.8rt to disting5.8u.8is prece...
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...385.3 Brazelton-388.1 similarly-230.8 that-232 discussions-230.4 about-230 at sexual-267.8 therefore-265.1 having-270.5 language-269.8 to express-217.7 happening-223.2 preserving-217.7 family good-293 talking-293.9 family-301.6 also barriers-30...
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(3 occurrences)
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...385.3 Brazelton-388.1 similarly-230.8 that-232 discussions-230.4 about-230 at sexual-267.8 therefore-265.1 having-270.5 language-269.8 to express-217.7 happening-223.2 preserving-217.7 family good-293 talking-293.9 family-301.6 also barriers-30...
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(3 occurrences)
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...e a-9nswer is ju-9st as Case Document Filed Page of invidious a-9s an int-8entio-8nally false a-10nswer Uni-8ted States Langf-8ord F.2d Cir As the 9Seco-9nd Circuit 8held in Lang-8ford We McD-9onough multi part 175go-8verning 185not 175i-8nad-9...
2.
...-8vertent-9 388i-8ntentional,-8 388are 398simpl-7y 388factors-9 considered3 i-7n the determinati-9on of act-9ual-8 bias Langford at quotin-8g McDo-9noug-8h at 9(Brennan concurring3 i-7n judg-5ment-6 The semina-8l case ad-9dre-9ssing a jur-9or f...
3.
...n t)-5hat an inten3tio-6nally fal3s-8e answer is 3n-8ot a er qu-8isite to obt-7aining a 9new-9 trial Unite-8d States-8 9Langford i-8s multi pa-9rt test as go-9verning-9 not 8only inadve-9rtent id-8 at adopting J-5ustice 6Bren-7nan reaso-9ning A...
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...e a-9nswer is ju-9st as Case Document Filed Page of invidious a-9s an int-8entio-8nally false a-10nswer Uni-8ted States Langf-8ord F.2d Cir As the 9Seco-9nd Circuit 8held in Lang-8ford We McD-9onough multi part 175go-8verning 185not 175i-8nad-9...
2.
...-8vertent-9 388i-8ntentional,-8 388are 398simpl-7y 388factors-9 considered3 i-7n the determinati-9on of act-9ual-8 bias Langford at quotin-8g McDo-9noug-8h at 9(Brennan concurring3 i-7n judg-5ment-6 The semina-8l case ad-9dre-9ssing a jur-9or f...
3.
...n t)-5hat an inten3tio-6nally fal3s-8e answer is 3n-8ot a er qu-8isite to obt-7aining a 9new-9 trial Unite-8d States-8 9Langford i-8s multi pa-9rt test as go-9verning-9 not 8only inadve-9rtent id-8 at adopting J-5ustice 6Bren-7nan reaso-9ning A...
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...American Race:Asian N-No Race American Indian or N-No Alaska Native Race Native Hawaiian or N-No Other Pacific Islander Language Information Home Language Survey Is a language other than Date English used in the home Does the Student have a Doe...
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...guage Survey Is a language other than Date English used in the home Does the Student have a Does the Student most first language other than frequently speak a English language other than English Parent Language EN English Student Language EN En...
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...ently speak a English language other than English Parent Language EN English Student Language EN English Preferred Oral Language Preferred Written EN English Language Dual Language Has Dual Lang Dual Language No Records Found Permissions Publis...
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(3 occurrences)
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...ofJustice letter see Def Reply Ex A even the Defendant own expe1ts use probabilistic rather than absolute language leaving open the possibility that extr 267adition would be blocked See e.g Def Mot Ex at On the basis of the infonnation cmTently...
2.
...erts on The proposal involving the Santa Fe County Detention Center fares no better The government?s language is tellingly equivoc al First it states that Santa Fe jail is potentia6.4lly5.2 willing to their policy curren5.9tly ba4.7rs attorney...
3.
...date in-p5.5erson5.5 visits between obertson and his attorneys Id Rather than inspire confidence the language of government?s motion refl ects the high level of uncertainty that our jails have ope with the The4.3 remains4.7 the4.3 Santa4.3 Fe C...
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(3 occurrences)
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...ofJustice letter see Def Reply Ex A even the Defendant own expe1ts use probabilistic rather than absolute language leaving open the possibility that extr 267adition would be blocked See e.g Def Mot Ex at On the basis of the infonnation cmTently...
2.
...erts on The proposal involving the Santa Fe County Detention Center fares no better The government?s language is tellingly equivoc al First it states that Santa Fe jail is potentia6.4lly5.2 willing to their policy curren5.9tly ba4.7rs attorney...
3.
...date in-p5.5erson5.5 visits between obertson and his attorneys Id Rather than inspire confidence the language of government?s motion refl ects the high level of uncertainty that our jails have ope with the The4.3 remains4.7 the4.3 Santa4.3 Fe C...
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(2 occurrences)
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...wi Full ROM to all extremi ies with strength bi aterally slight swell i ng noted to right phalanges when compared to left no edema erythema or ecchymosis noted Denies any pain numbness or ting li ng at this ime Denies any Chest pain eadache Diz...
2.
...Topics Reg Inmate Name EPSTEIN JEFFREY EDWARD Assessments Assessment Learns Best By Primary Language Years of Education Barrie To Edu ca tion Speaking Listening English None Orig Ent ed EST Joaquin Total Topics ate aitiated Fo mat Haadout/Top...
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(2 occurrences)
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...way to deal with the issues and to insure Mr Epstein is treated like others Let me know and I can prepare some proposed language that I think would work for everyone Jack Goldberger Phone Fax Please note Florida has a very broad public records...
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...ish speaking friend may but it takes us deep and a look or gesture speaks louder than words at times One night our sign language broken English and Spanish went to the topic of his oldest daughter attending college Alfredo told me how proud he...
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...m MCC New York on or before the morning of August The Supervisory Correctional Systems Specialist told the OIG that the language in the USMS emails WAB i.e with all belongings and MCC New York reports pre removed made it clear that Inmate would...
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...commendation after the BOP enhances existing policies regarding institutional camera systems to include the recommended language update communicates the policy update to all relevant BOP employees and provides documentation of the policy update...
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...Bureau work site or toward fellow employees In their official capacity employees may not use profane obscene or abusive language when communicating with inmates fellow employees or others Employees shall conduct themselves in a manner that will...
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...N FIRST OFFENSE SECOND OFFENSE THIRD OFFENSE RECKONING PERIOD Disrespectful conduct use of insulting abusive or obscene language to or about others Includes verbal abuse of inmates former inmates their families or friends known or who should be...
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...charged with the more serious crimes of sexual activity with minors and slammed State Attorney Barry Krischer in blunt language seldom used by one law enforcement official with another because of what he perceived as that offices mishandling o...
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...key witness Epsteins attorney Jack Goldberger did not return phone messages A source close to the case suggested it is languishing pending a decision by the FBI on whether to refer it to federal prosecutors We still have a pending case FBI spo...
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(2 occurrences)
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...charged with the more serious crimes of sexual activity with minors and slammed State Attorney Barry Krischer in blunt language seldom used by one law enforcement official with another because of what he perceived as that offices mishandling o...
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...witness i __ Epsteins attorney Jack Goldberger did not return phone messages A source close to the case suggested it is languishing pending a decision by the FBI on whether to refer it to federal prosecutors We still have a pending case FBI spo...
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(2 occurrences)
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...charged with the more serious crimes of sexual activity with minors and slammed State Attorney Barry Krischer in blunt language seldom used by one law enforcement official with another because of what he perceived as that offices mishandling o...
2.
...witness i __ Epsteins attorney Jack Goldberger did not return phone messages A source close to the case suggested it is languishing pending a decision by the FBI on whether to refer it to federal prosecutors We still have a pending case FBI spo...
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(2 occurrences)
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...I know thats what theyre using as their basis to get to these But its our position that the clear unambiguous statutory language it shows that this disclosure only applies to a civil or criminal case and that within that civil or criminal Speak...
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...FLORIDA HOLDINGS vs DAVE ARONBERG June attorneys position and we also agree with what the Court has said that the plain language of the statute a cause of action doesnt exist And we really cannot well be defending something without the four cor...
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(2 occurrences)
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...nstruction In interpreting a statute the court must respect the role of the legislature the legislative process and the language of the statute court 2s function is to interpret statutes as they are written and give effect to each word in the s...
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...co truction In interpreting a statute the court must respect the role of the legislature the legislative process and th language of the statute A courts function is to int rpr et tatut es as th ey are written and give effect to each word in the...
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...aratory action claim for relief The State Attorney 2s admission demonstrates that his motion is contrary to the express language of section As stated above section a examines a claim or defense 223when initially presented to the court Because t...
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...claratory action claim for relief The State Attorneys admission demonstrates that his motion is contrary to the express language of section As stated above section a examines a claim or defense when initially presented to the court Because the...
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(2 occurrences)
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...instance were hot even there yet Page attorneys position and we also agree with what the Court has said that the plain language of the statute a cause of action doesnt exist And we really cannot well be defending something without the four cor...
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...lY be used in the defEmse i l-age10 cittorneys position and w,e also agree with w_hat the Court has said that the plain language of the statute a cause of actiqn doesnt exist And we_ really cannot well be defending something without the four co...
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(2 occurrences)
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...plication of current law Specifically your action for declaratory relief fails based on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is ordered by a court pursuant to subsection fo...
2.
...plication of current law Specifically your action for declaratory relief fails based on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is ordered by a court pursuant to subsection I...
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(2 occurrences)
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...arged with the more serious crimes of sexual activity with minors and 223slammed State Attorney Barry Krischer in blunt language seldom used by one law enforcement official with another because of what he perceived as that office 2s mishandling...
2.
...charged with the more serious crimes of sexual activity with minors and slammed State Attorney Barry Krischer in blunt language seldom used by one law enforcement official with another because of what he perceived as that offices mishandling o...
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(2 occurrences)
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...tion i i I In interpreting a statute the court must.respect the role of the legislature the legislative process and the language of the statute court 2s function is to interpret statutes as they are written and give effect to each word in the s...
2.
...orr I I I In interpreting a statute the court must respect the role of the legi lature the legislative process and_ the language of tbe statl!te A com:ts func_tion is to1nte_rpret statutes as they are written and.give-effect to.each woro in the...
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(2 occurrences)
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...plication of current law Specifically your action for declaratory relief fails based on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is ordered.by a court pursuant to subsection fo...
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...plication of current iaw Specifically your action for declaratory relief fails based on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is"ordered by a court pu suant _subsection I fo...
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...Ph.D presented at American Psychiatric Association May Preventive Psychiatry as Applied to Faster Children Grand Rounds Langley Porter Psychiatric Institute The Childhood of Adolf Hitler with Robert Pois Ph.D The American Psychoanalytic Associa...
2.
...his life and suffers behavioral and overanxious symptoms He has impulse dyscontrol attentional deficits and expressive language difficulties from which he can be seen to be recovering Two excerpted tapes have been created to illustrate feature...
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(2 occurrences)
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...ngle predicate offense receive the same compensation as a victim of multiple enumerated predicate offenses The statutes language as July approximately two years before Defendant pled guilty to state criminal offenses and signed the Non-Prosecut...
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...h inA.R Douglass Inc McRainey So Fla The intention and meaning of the Legislature must primarily be detennined from the language of the statute itself and not from conjectures aliunde When the language of the statute is clear and unambiguous an...
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(2 occurrences)
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...Ph.D presented at American Psychiatric Association May Preventive Psychiatry as Applied to Faster Children Grand Rounds Langley Porter Psychiatric Institute The Childhood of Adolf Hitler with Robert Pois Ph.D The American Psychoanalytic Associa...
2.
...his life and suffers behavioral and overanxious symptoms He has impulse dyscontrol attentional deficits and expressive language difficulties from which he can be seen to be recovering Two excerpted tapes have been created to illustrate feature...
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(2 occurrences)
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...is provided The argum8ent supporting this asse rtion is unknown to Plaintif4f4 There is no indication in the statutory language or elsewhere that U.S.C can be applicable in a situation such as here where there is an agreem9ent concerning feder...
2.
...nterpretation suggested by the Defendant The plaintiff 2s interpretation of U.S.C is not only consistent with the plain language of the statute but also with the polic ies underlying the stay provision The statute is designed to protect childre...
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Content Matches:
(2 occurrences)
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...includes investigation U.S.C The only reported decision addressing this provision interpreted it according to its plain language See Ara Khan No CV WL E.D.N.Y June ordering all proceedings in this case stayed pending the conclusion of the gover...
2.
...e this determination despite the plaintiffs complaints about the frustrating delay and that the state criminal case has languished for almost two years with no end in sight finding that this is a matter to be addressed in state criminal court I...
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Content Matches:
(2 occurrences)
1.
...ation in the federal courts for the past seventy years The Court 2s forced retirem9ent of Conley Gibson 2s set of facts language does not change the fundam8e4ntal com8m8a-1nd of Rule as to what a valid com9p1laint m9u1st look like Indeed the Co...
2.
...ases I 1330PLAINTIFFS SUFFICIENTLY ALLEGE A CLAIM COUNT I FOR VIOLATION OF U.S.C pleadings in Count I closely track the language of U.S.C and thus set forth the elem9ents of a violation of this Statute as follows i Allegation in Com)9p1laint Ep...
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(2 occurrences)
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...Ph.D presented at American Psychiatric Association May Preventive Psychiatry as Applied to Faster Children Grand Rounds Langley Porter Psychiatric Institute The Childhood of Adolf Hitler with Robert Pois Ph.D The American Psychoanalytic Associa...
2.
...his life and suffers behavioral and overanxious symptoms He has impulse dyscontrol attentional deficits and expressive language difficulties from which he can be seen to be recovering Two excerpted tapes have been created to illustrate feature...
PDF
Content Matches:
(2 occurrences)
1.
...is provided The argum8ent supporting this asse rtion is unknown to Plaintif4f4 There is no indication in the statutory language or elsewhere that U.S.C can be applicable in a situation such as here where there is an agreem9ent concerning feder...
2.
...nterpretation suggested by the Defendant The plaintiff 2s interpretation of U.S.C is not only consistent with the plain language of the statute but also with the polic ies underlying the stay provision The statute is designed to protect childre...
PDF
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(2 occurrences)
1.
...includes investigation U.S.C The only reported decision addressing this provision interpreted it according to its plain language See Ara Khan No CV WL E.D.N.Y June ordering all proceedings in this case stayed pending the conclusion of the gover...
2.
...e this determination despite the plaintiffs complaints about the frustrating delay and that the state criminal case has languished for almost two years with no end in sight finding that this a matter to be addressed in state criminal court Id A...
PDF
Content Matches:
(2 occurrences)
1.
...ation in the federal courts for the past seventy years The Court 2s forced retirem9ent of Conley Gibson 2s set of facts language does not change the fundam8e4ntal com8m8a-1nd of Rule as to what a valid com9p1laint m9u1st look like Indeed the Co...
2.
...ases I 1330PLAINTIFFS SUFFICIENTLY ALLEGE A CLAIM COUNT I FOR VIOLATION OF U.S.C pleadings in Count I closely track the language of U.S.C and thus set forth the elem9ents of a violation of this Statute as follows i Allegation in Com)9p1laint Ep...
PDF
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(2 occurrences)
1.
...Ph.D presented at American Psychiatric Association May Preventive Psychiatry as Applied to Faster Children Grand Rounds Langley Porter Psychiatric Institute The Childhood of Adolf Hitler with Robert Pois Ph.D The American Psychoanalytic Associa...
2.
...his life and suffers behavioral and overanxious symptoms He has impulse dyscontrol attentional deficits and expressive language difficulties from which he can be seen to be recovering Two excerpted tapes have been created to illustrate feature...
PDF
Content Matches:
(2 occurrences)
1.
...is provided The argum8ent supporting this asse rtion is unknown to Plaintif4f4 There is no indication in the statutory language or elsewhere that U.S.C can be applicable in a situation such as here where there is an agreem9ent concerning feder...
2.
...nterpretation suggested by the Defendant The plaintiff 2s interpretation of U.S.C is not only consistent with the plain language of the statute but also with the polic ies underlying the stay provision The statute is designed to protect childre...
PDF
Content Matches:
(2 occurrences)
1.
...includes investigation U.S.C The only reported decision addressing this provision interpreted it according to its plain language See Ara Khan No CV WL E.D.N.Y June ordering all proceedings in this case stayed pending the conclusion of the gover...
2.
...e this determination despite the plaintiffs complaints about the frustrating delay and that the state criminal case has languished for almost two years with no end in sight finding that this is a matter to be addressed in state criminal court I...
PDF
Content Matches:
(2 occurrences)
1.
...ation in the federal courts for the past seventy years The Court 2s forced retirem9ent of Conley Gibson 2s set of facts language does not change the fundam8e4ntal com8m8a-1nd of Rule as to what a valid com9p1laint m9u1st look like Indeed the Co...
2.
...ases I 1330PLAINTIFFS SUFFICIENTLY ALLEGE A CLAIM COUNT I FOR VIOLATION OF U.S.C pleadings in Count I closely track the language of U.S.C and thus set forth the elem9ents of a violation of this Statute as follows i Allegation in Com)9p1laint Ep...
PDF
Content Matches:
(2 occurrences)
1.
...Ph.D presented at American Psychiatric Association May Preventive Psychiatry as Applied to Faster Children Grand Rounds Langley Porter Psychiatric Institute The Childhood of Adolf Hitler with Robert Pois Ph.D The American Psychoanalytic Associa...
2.
...his life and suffers behavioral and overanxious symptoms He has impulse dyscontrol attentional deficits and expressive language difficulties from which he can be seen to be recovering Two excerpted tapes have been created to illustrate feature...
PDF
Content Matches:
(2 occurrences)
1.
...ation in the federal courts for the past seventy years The Court 2s forced retirem9ent of Conley Gibson 2s set of facts language does not change the fundam8e4ntal com8m8a-1nd of Rule as to what a valid com9p1laint m9u1st look like Indeed the Co...
2.
...ases I 1330PLAINTIFFS SUFFICIENTLY ALLEGE A CLAIM COUNT I FOR VIOLATION OF U.S.C pleadings in Count I closely track the language of U.S.C and thus set forth the elem9ents of a violation of this Statute as follows i Allegation in Com)9p1laint Ep...
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...n to dismiss As noted in fn of her memorandum Defendant is not seeking dismissal of Count II as in Plaintiff tracks the language of Fla Stat pertaining to abuse Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page If this Court...
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...l is time barred Count Ill is brought pursuant to U.S.C which contains its own statute of limitations in subsection The language of is clear and unambiguous Any action commenced under this section shall be barred unless the complaint is filed w...
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...is provided The argum8ent supporting this asse rtion is unknown to Plaintif4f4 There is no indication in the statutory language or elsewhere that U.S.C can be applicable in a situation such as here where there is an agreem9ent concerning feder...
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...nterpretation suggested by the Defendant The plaintiff 2s interpretation of U.S.C is not only consistent with the plain language of the statute but also with the polic ies underlying the stay provision The statute is designed to protect childre...
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...cludes investigation U.S.C I The only reported decision addressing this provision interpreted it according to its plain language See Ara Khan No CV WL E.D.N.Y June ordering all proceedings in this case stayed pending the conclusion of the gover...
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...e this detennination despite the plaintiffs complaints about the frustrating delay and that the state criminal case has languished for almost two years with no end in sight finding that this is a matter to be addressed in state criminal court I...
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...ation in the federal courts for the past seventy years The Court 2s forced retirem9ent of Conley Gibson 2s set of facts language does not change the fundam8e4ntal com8m8a-1nd of Rule as to what a valid com9p1laint m9u1st look like Indeed the Co...
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...ases I 1330PLAINTIFFS SUFFICIENTLY ALLEGE A CLAIM COUNT I FOR VIOLATION OF U.S.C pleadings in Count I closely track the language of U.S.C and thus set forth the elem9ents of a violation of this Statute as follows i Allegation in Com)9p1laint Ep...
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...Ph.D presented at American Psychiatric Association May Preventive Psychiatry as Applied to Faster Children Grand Rounds Langley Porter Psychiatric Institute The Childhood of Adolf Hitler with Robert Pois Ph.D The American Psychoanalytic Associa...
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...his life and suffers behavioral and overanxious symptoms He has impulse dyscontrol attentional deficits and expressive language difficulties from which he can be seen to be recovering Two excerpted tapes have been created to illustrate feature...
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...ted with the But if the Government comes in and says no wait a minute our position was is that youre stuck with and the language within the NPA And therefore whether its an offense or whether its multiple offenses or violations or each one repr...
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...to hand them a jackpot or a key to a bank It was solely to sort of put them in that same position So we developed this language that said if that provided for an attorney to represent them Most of the victims as you know from the pleadings com...
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...disability not later than three years after the disability Reading the entire statute in context no where is there any language indicating that a minor plaintiff has a private right of action against a defendant per violation Under the statuto...
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...a plaintiff multiple causes of action against a defendant on a per violation basis the statute would have included such language Had Congress wanted to create such a remedy as Plaintiff attempts to bring it could have easily included language o...
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...UIRE MARKT LUTTIER ESQUIRE EW BURMAN CRITTON LUTHER COLEMA,l LLP MR IDLL Jack Hill for CMA Banyan Boulevard Suite400 MR LANGINO Adam Langino from West Palm Beach Florida Phone Leopold Kuvin on behalf of BB On behalf of Jeffrey Epstein MR LUTTIE...
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...and intimidated her and for that reason were not going forward On behalf of BB MR CRITTON I didnt see any contact ADAM LANGINO ESQUIRE because I obviously was not out there We LEOPOLD KUVIN started at about when you came in it was PGA Boulevar...
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...oulevard West Palm Beach Florida Case Document Entered on FLSD Docket Page of APPEARNCES CONTINUED On behalf of BB ADAM LANGINO ESQUIRE LEOPOLD KUVIN PGA Boulevard Suite Palm Beach Gardens Florida Phone Case Document Entered on FLSD Docket Page...
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...CRITTON Cindy what time is it THE COURT REPORTER It is MR BERGER William Berger for LM and MR HILL Jack Hill for CMA MR LANGINO Adam Langino from Leopold Kuvin on behalf of BB MR LUTTIER Mark Luttier on behalf of Burman Critton Luttier Coleman...
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...oulevard West Palm Beach Florida Case Document Entered on FLSD Docket Page of APPEARNCES CONTINUED On behalf of BB ADAM LANGINO ESQUIRE LEOPOLD KUVIN PGA Boulevard Suite Palm Beach Gardens Florida Phone Case Document Entered on FLSD Docket Page...
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...CRITTON Cindy what time is it THE COURT REPORTER It is MR BERGER William Berger for LM and MR HILL Jack Hill for CMA MR LANGINO Adam Langino from Leopold Kuvin on behalf of BB MR LUTTIER Mark Luttier on behalf of Burman Critton Luttier Coleman...
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...A I dont remember you dont remember A I dont remember Which means just so were clear so we dont have a problem with our language when you say you dont remember youre not denying it you are just saying you have Pages to PROSE COURT REPORTING AGE...
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...loves known lunch lifetime LUTTIER knows liked limited Lisa La ladies lawyers Listen lady ladys Lake lawyers Literally language leading litigation Las league little Lauderdale Lauren leagues learned lived leave left living LLP legal long lesbi...
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...honest answers People often do not even know their reservation prices they do not willingly reveal them Nothing in the language of a or any implementing regulation requires a state to conduct studies in advance of every modification It require...
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...s Inc U.S S.Ct L.Ed.2d According to Indiana Fogerty Fantasy Inc U.S S.Ct L.Ed.2d casts a new light on Fogerty held that language in the copyright act ma terially identical to does not permit a court to use one standard for prevailing plaintiffs...
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...Ph.D presented at American Psychiatric Association May Preventive Psychiatry as Applied to Faster Children Grand Rounds Langley Porter Psychiatric Institute The Childhood of Adolf Hitler with Robert Pois Ph.D The American Psychoanalytic Associa...
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...his life and suffers behavioral and overanxious symptoms He has impulse dyscontrol attentional deficits and expressive language difficulties from which he can be seen to be recovering Two excerpted tapes have been created to illustrate feature...
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...9Ma3r one4 o-9f the5 c4ondit-3ions re4que4sted is a c5ondit-3ion re5que4sted h-8e4re7 r-6e4moval or3 r-6e4visi-4on of3 langua6ge4 that the p-7a4rt-8ies w3ould bea6r the5ir own a6tt-3orne7ys f-6e4e4s 10a4nd c-5osts-3 The5 C-2ourt noted3 the A4m...
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...s to re5 c4 e4 ive in e4 xc4 ha4 ng-9 e4 fo-6 suc6 re7 le-7 a4 se3 a4 nd including her5 lega6 nam-9 a4 nd e4 move a6 ny langua6 e4 or-6 de4 ring e4 c4 pa4 rty to be-5 a4 in c4 onne4 c4 ti-3 on with his ac5 ti-3 on Da6 ted Ja3 nua-5 ry e4 spe3 c...
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...proceeding pending at the time the Government negotiated this non-prosecution agreement This position ignores the plain language of the CVRA which extends the right to confer to any case not any co 1rt proceeding and flies in the face of the Fi...
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...district court in the district in which the crime occurred U.S.C emphasis added Petitioner noted the importance of this language in her opening Petition see Emergency Victims but the Government chose not to discuss it in its reply In a case rem...
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...f those considerations did not exist So first Your Honor we believe that a does not apply THE COURT Well what about the language in the statute that suggests that a victim can bring a claim or seek enforcement of his or her rights under the sta...
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...L REPORTING SERVICES LLC Case Document Entered on FLSD Docket Page of i this non-prosecution agreement entails that has language that hell agree to liability in a civil case Thats not what these girls They want justice They want him in prison n...
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...ms in Louisiana Mississippi and Texas And more generally the Depart ments position simply has no grounding in the clear language of the CVRA My first question What is the Justice De partment doing to extend to victims their right to fair treatm...
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...rt of appeals for a writ of man damus U.S.C Ordinarily whether mandamus relief should issue is dis cretionary The plain language of the CVRA however specifically and clearly overruled such discretionary mandamus standards by directing that the...
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...ondence a matter expressly reserved for determination at the time of final disposition DE at The Court then entered the language that is central to this notice The victims are directed to file unredacted pleadings including attached corresponde...
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...few of them here to illustrate the problems For starter the proposed protective order contains all sorts of boilerplate language about the parties to the case having to comply See e.g DE at All parties and their respective counsel shall take al...
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...val of this procedure because as I mentioned I think it is probably in their best interests I will include our standard language regarding resolving all criminal liability and I will mention co-conspirators but I would prefer not to highlight f...
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...we allowed you a week to provide us with any objections or requested modifications to the list and/or the Notification language Yesterday I contacted you via telephone and e-mail but received no response Accordingly the United States hereby no...
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...FLSD Docket Page of April lNDEX WrTNESS DIRECT CROSS REDRECT RECROSS NADlA MARCNKOVA BY MR EDWARDS BY MR HOROWITZ BY MR LANGNO BY MS EZELL EXIIlBITS PLAINTIFFS FOR IDENTIFICATION I Message dated August PAGE The videotaped deposition of NADIA MA...
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...NTINUED LEOPOLD-KUVIN Attorneys for Plainli fls B.B and C.F PGA Boulevard Suite Palm 13each Gardens Florida Tel UY ADAM LANGJNO ESQ PODHURST ORSECK Allorneys for Jane Docs I and City National Bank Building Suite West Flagler Street Miami Florid...
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...Unit States Bailey U.S quoting United States Unit Stat Gypsum Co U.S The Supreme Court has repeatedly interp eted this language to require that the illegal act i vity be the dominant mo iv for the travel See Mortensen United States U.S an inte...
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...t he bad guys who do exploit minors often on a massive scale or for financial rewards The very breadth of the statutory language places on federal prosecutors the weighty responsibility of insuring that their discretion is exercised thoughtfull...
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...f those considerations did not exist So first Your Honor we believe that a does not apply THE COURT Well what about the language in the statute that suggests that a victim can bring a claim or seek enforcement of his or her rights under the sta...
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...EPORTING SERVICES LLC Page Case Document Entered on FLSD Docket Page of this non-prosecution agreement entails that has language that hell agree to liability in a civil case Thats not what these girls They want justice They want him in prison n...
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...nt Entered on FLSD Docket Page of Honorable Alexander Acosta October Page2 KIRKLAND ELLIS LLP Second Mr Sloman proposes language in our joint letter to Judge Davis referencing the statutory limit under while only referencing the pre-existing li...
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...today we have no choice except to adopt the Addendum as written and will do so We do not however agree with all of the language in your draft letter to Judge Davis Since this letter is neither an extension of the Agreement nor of its Addendum...
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...r civil litigation Any notification be effectuated by a separate mailing to each individual without the inclusion ofany language that appeared on the second page of your June memorandum i.e rather than including in each notification a large sec...
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...Palm Beach FL w.agwpa.com RFP WPB Case Document Entered on FLSD Docket Page of You eliminate from any notification any language that is currently contained in the acknowledgment section of the June memorandum and You supplement the notificatio...
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...fron1 the lcg.cd victim hi..:rsdf th at she uffered a physical Cl llJOn I lr personal injury ts required the ex pre ss langua of Further rhe sworn testimony of Ms contains a compldc di:-..tvm 225rnl that Mr Epsli.:in or anyo on his bd1alf used...
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...n if under other circumstanccs challenge woul a summnry judgment in Mr Epstein favor unde::r feel Civ Lastly thc moJifa langu.-11 1-ccomnH mbJ by you presupposes ttmt 1r Epstein would h:lvc been charged and conviclt or uhslantivc violations rat...
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...of the victim witness coordinator or specialist and other key officials Models for such brochures in several different languages are available from the Office for Victim of Crim Personal contact should be ade whenever reasonably feasible A vic...
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...ctim are not able to com unicate in English or are illiterate Case Document Entered on FLSD Docket Page of in their own language C.F.R Interpreters should be thoroughly screened to ensure that they are not in any way involved in the trafficking...
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...ted with the But if the Government comes in and says no wait a minute our position was is that youre stuck with and the language within the NPA And therefore whether its an offense or whether its multiple offenses or violations or each one repr...
2.
...to hand them a jackpot or a key to a bank It was solely to sort of put them in that same position So we developed this language that said if that provided for an attorney to represent them Most of the victims as you know from the pleadings com...
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Content Matches:
(2 occurrences)
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...f those considerations did not exist So first Your Honor we believe that a does not apply THE COURT Well what about the language in the statute that suggests that a victim can bring a claim or seek enforcement of his or her rights under the sta...
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...se girls wanted money on their own which is basically what this this 3-2439.9non-prosecution agreement entails that has language that hell agree to liability in a civil case Thats not what these girls They want justice They want him in prison n...
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...which it sought answers or better responses Tonja Haddad P.A SE th Street Fort Lauderdale FL Civil Procedure The plain language of Rule expressly excludes from consideration on a motion for summary judgment any document that is not one of the...
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...orneys for bad faith conduct and violations of rules CONCLUSION In reliance upon the case law cited above and the plain language of the Agreements entered into between the parties Epstein respectfully prays that this Court enter an Order awardi...
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...here were two readings of the statute I haven seen the statute l!l a long time at least in a while but its it uses some language that it three years from the date that the disability no longer exists which we interpret as her being a minor So t...
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...ed by the misconduct that is the subject of this Complaint Mr Pike Okay Im going to move to strike Mischaracterizes the language of the document The document reads as follows for purposes of the record The Rothstein racketeering enterprise ende...
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...ify the visitor data to confirm the number of users Depo pp Report So out of the sites that contained articles with the language in question he included the traffic of only in his potential daily visitors total because he could not validate the...
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...site in question Thus he did not count any times the articles were emailed or linked to another story not including the language in question here Depo Report or any face-to face dissemination Depo Report Finally as to the conservative aspect of...
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...r trial As noted by one author based on the appellate court decisions Rule procedure is elegant in its simplicity Trentalange Setting a Case for Trial Rule Means What It Says The Florida Bar Journal Vol.84 No.3 March To start Rule provides that...
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...as not yet answered the complaint and the plaintiff has failed to obtain a default the action is not yet at issue Trentalange Setting a Case for Trial Rule Means What It Says The Florida Bar Journal Vol.84 No.3 March Reilly U.S Bank Nat Ass So...
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...by the trial court including extensive pretrial motions objections to deposition designations for use at trial and the language and form of the jury instructions and verdict form Furthermore there have been ongoing issues in the trial court re...
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...elief requested immediately filing a notice that has absolutely nothing to do with his request and ignores the specific language of the relief granted i.e an improper notice seeking to set a wrongfully severed counterclaim for trial despite the...
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...nkruptcy case We spoke by telephone at length late today and reached agreement to your proposal subject to the modified language that wo discussed I have taken the language from your letter and revised it below based on what we had discussed Of...
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...en the language from your letter and revised it below based on what we had discussed Of course I also had to change the language to reflect that the letter is now being written by me Accordingly this letter is inten:ded to confinn the tenns and...
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...to uny printed whether typed or written by hum recorded laped electronic e.g e-mails and text messages gniphic or other Langihle matter from any source however produced or reprod1,1ced whether in drat or otherwise whether sent or received or ne...
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...d to uny printed whether typed or written by himtl coTded laped elcctroni e.g e-mails and text mcsuges graphic OI olhet langible matter trow any source ho cr produced or rcp10d1.1ccd wl1elhCT in dral or otherwise whether sent or rci.vF or ocith...
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...ttempts to obtain discovery from high-profile persons with whom Epstein socialized and use of ridiculously inflammatory language in arguments in court Complaint at Remarkably Epstein has filed such allegations against Edwards despite the fact t...
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...in makes allegations that the complaints contained sensational allegations for the purposes of luring investors however language in the complaints remained virtually unchanged from the first filing in and from the overwhelming evidence the Cour...
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...ttempts to obtain discovery from high-profile persons with whom Epstein socialized and use of ridiculously inflammatory language in arguments in court Remarkably Epstein has filed such allegations against Edwards despite the fact that Epstein h...
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...in makes allegations that the complaints contained sensational allegations for the purposes of luring investors however language in the complaints remained virtually unchanged from the first filing in and from the overwhelming evidence the Cour...
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...of the absolute protection of the litigation privilege Fomih Amended Counterclaim at emphasis added As the highlighted language above makes clear the issue to be tried in connection with Edwards counter-claim against Epstein turns on what Epst...
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...rwise and has never had any reasonable basis to believe otherwise Fourth Amended Counterclaim at emphases added The key language in this paragraph is the highlight language which concerns Epsteins reasonable basis for believing that Edwards was...
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(2 occurrences)
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...amend ments are effective on the dates they became Jaw Laws in subsec inserted a reference to and made a nonsubstantive language change Laws in subsec inserted references to and par inserted a new par relating to sexual offenses and redesignate...
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...ollywood Florida Information regarding Defendant Jeffrey Epsteins conduct that is the subject of this action Adam Perry Lang Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject...
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(2 occurrences)
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...here were two readings of the statute I haven seen the statute l!l a long time at least in a while but its it uses some language that it three years from the date that the disability no longer exists which we interpret as her being a minor So t...
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...ed by the misconduct that is the subject of this Complaint Mr Pike Okay Im going to move to strike Mischaracterizes the language of the document The document reads as follows for purposes of the record The Rothstein racketeering enterprise ende...
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Content Matches:
(2 occurrences)
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...ify the visitor data to confirm the number of users Depo pp Report So out of the sites that contained articles with the language in question he included the traffic of only in his potential daily visitors total because he could not validate the...
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...site in question Thus he did not count any times the articles were emailed or linked to another story not including the language in question here Depo Report or any face-to face dissemination Depo Report Finally as to the conservative aspect of...
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...thouse Commons Suite West Palm Beach FL West Railroad Avenue meg searcylaw.com West Pal each FL jsx seat:cylaw.co1 njs FLAngel lateLaw.coni scarolateam searcylaw.corri kbt FLAggellateLaw.com Co.-Counsel for Defendani/Counter-P laintiff 90-Couns...
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...STE_IN 225Case No 247even th Amended and Supplem ntal Witnes ist fCounte!-Pl intiffB,radley rds Page of22 4L Cotirtney Langley c/o Spencer Kuvin South Austfalian Ave st Palm ach,Fiorida William-Scherer,Esquire Fedei Hwy ilsoo Fort Lauderdale FL...
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...ttempts to obtain discovery from high-profile persons with whom Epstein socialized and use of ridiculously inflammatory language in arguments in court Complaint Remarkably Epstein has filed such allegations against Edwards despite the fact that...
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...in makes allegations that the complaints contained sensational allegations for the purposes of luring investors however language in the complaints remained virtually unchanged from the first filing in and from the overwhelming evidence the Cour...
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...ard to Link Rockenbach and as far as Jeffrey Epstein is concerned obviously he was personally prohibited by the express language of the Courts order from possessing or accessing any of this information and we would certainly want to take Mr Eps...
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...sk is a clear violation of your Honors order THE COURT I disagree with you MR SCAROLA May I refer the Court to specific language in that regard Your Honor stated and I quote should it be determined that Fowler White or Epstein retained images o...
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...ttempts to obtain discovery from high-profile per ons with whom Epstein socialized and use of ridiculously inflammatory language in arguments in court Remarkably Epstein has filed such allegations against Edwards despite the fac that Epstein ha...
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...in makes allegations that the complaints contained sensational allegations for the purposes of luring investors however language in the complaints remained virtually unchanged from the first filing in and from the overwhelming evidence the Cour...
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...Palm Beach I Sports I Entertainment I Travel I Lii Opiniou I Video Home Collections Florida Bar Ads By Google Shocking Language Video If you dont know Spanish and you want to you should dick here to see thls short video Watch Video AclChOtOHP...
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...pcoparatlon material must I cxprtl3Sly make Ibo olelm end descrlba the naturo of the wlthhdd documents cammunlcatlom or langiblc things In a lGJ hat without nwcallng lnfonnatlon itsdf privilegai or protected will enable the parties to mea the c...
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...anted EPSTEINs motion The Court directed the undersigned attorney to prepare a proposed order and directed that certain language be included in the order The undersigned obtained a transcript of the hearing and followed the direction of the cou...
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...ched hereto as Exhibit A The attorney for Counter-Plaintiff has objected to the proposed order m1d suggested additional language to which Counter-Defendant cannot agree A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z...
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...ed he had any ethical duties of disclosure that were in conflict with the terms and conditions of the Release the clear language of the confidentiality provisions in the Release gave Edwards the option of seeking leave of Court to make any nece...
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...he Release gave Edwards the option of seeking leave of Court to make any necessary disclosure The unambiguous and plain language of the Release remedied Edwardss purported issue altogether by authorizing Edwards to make disclosures permitted by...
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...y Judgment Page of socialized press reports of Rothsteins known illegal activities the use of ridiculously inflammatory language and arguments in court But as the evidence submitted in opposition to Epsteins original Motion for Summary Judgment...
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...e was hired by RRA or even knew Scott Rothstein Edwards Affidavit Exhibit attached to Statement of Undisputed Facts The language set forth in his Complaints remains virtually unchanged from the first filing in and as the evidence shows the clai...
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(2 occurrences)
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...ment Filed Page of Hon L3 orna-2 Schofie-2 ld Janua-2 ry Page with each par-2 ty to bea-3 its own fees5 and cost-4 with langua-3 g5 elating to cost-3 and fee-3 Ms Maxw3 ell-4 wil3 be the-3 preva6 il-3 ing party upon issuance of the-3 d5 ismiss-...
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...hould sh4 la-3 ter so choose-2 The5 ri-3 ght to e4 c4 over-2 of os4 ts legally prej-2 ud5 ice-3 b5 incl-4 us4 ion of he language propos-2 ed by4 Ms Far-3 mer5 For he o5 regoi ng re-2 aso3 ns Ms-2 Max3 well esp3 ectful-2 ly req-2 ues3 ts that-2...
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...eme4 nts de4 De6 e4 nda4 nt se3 ua4 a4 bused3 a4 nd a4 pe4 lainti-3 the que6 sti-4 on ne4 bec6 omes w2 he4 ther2.5 that lang12 e4 so out-2 ra-2 ge4 ous a4 troc5 ious a4 nd c4 ont-11 e4 mpt-3 ble tha4 hose a4 teme4 nts could g9 ive rise4 to an I...
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...-7 ga4 supp-2 or3 sugg7 e4 sti-4 that a4 II16 ED c4 lai-9 ca6 be4 pr-6 e4 dica6 ted upon a4 ll-3 e4 ge4 de4 a4 mator-16 lang12 e4 a4 nd a4 fte-4 c7 onc4 uding8 a4 a4 matter5 of la-4 tha4 he4 lan-7 ua-5 e4 c4 laim I Conclu-3 sion-6 Case Document...
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...ny event they would little to obviate the Court?s concern The Maxwell Protective Order must be interpreted as its plain language dictates Geller Branic Intern Realty Corp F.3d 2d Cir quoting City of Hartford Chase F.2d 2d ir And hatever Cooper...
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...ch extraordinary circumst ances exist he Court considers several factor including the scope of the protective order the language of the order itself the level of inquiry the court undertook before granting the order and the nature of reliance o...
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...r-4 9pa4rty-8 9ha4s 20re-2a4sona3bly 9on 9the-7 9pr-6otec6ti-3ve4 orde7r 9sc3ope4 6the 7prote5c4ti-3ve4 9o-9rde7r 6the 7langua6ge4 6the 7ord-6e4r it-13se3lf the 42leve6l 38of 43inqui-3ry 40c4o-9urt 41unde4rtook 41be-5for6e4 40the 42orde7r 41a4n...
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...7r EPD4M at A 267prote5c4ti-3ve4 269orde7r 266that e4xpre7ssl-3y c4onfide5nti-3a4l 151mate4ri-8a4ls 151non Id a4t The-4 langua6ge4 39of 36the M3a-9x4w-2e4ll P-3rote5c4ti-3v rde7r 46e4xpre7s-10sly 42c4ontemplate4d 39futur4e4 49modi-3fic5a4ti-3on...
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...r the parties shall append to he end of the definition of Confidential Information in the rotective rder the underlined language at the end of th following excerpt which makes clear that the parties cannot agree to unseal the identities of non...
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...nformation has been unsealed already by the Court in Maxwell The arties shall file a revised protective order with this language appended to the definition of 322Confidential Information SO ORDERED Dated New York New York January Case Document...
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...t when determ8ining whether a party has reasonably relied on the protective order the scope of the protective order the language of the order itself the level inquiry the court undertook before granting the order and the nature of reli ance on...
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...re all four factors weigh agai nst a finding of reasonable reliance Firs4.9t the Protectiv5.7e Order contains expansive language gran tin6g the par4tie4.8s5.2 broad la4.8titu6de to se4.8lf4-de4.8s.2ignate as confidential it unreasonabl for any...
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...QU I RE PODHURSTOR ECK P.A We Flagler treet ui 1iami Flo iida Phone rjosefsberg 1l0dhu rs com a kczeU podhurst.com ADAM LANG I SQ IR LEO OL KUVI PGA Boulevard Suit Palm Beach Gardens orida Phoue kuvin copo dkuv i co Page Page On beh alf of the...
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...ont bave auy 01he questions right now Id ju lik to re er if ometh i ng comes up to ask But otherwise yo may go a ead MR LANG lt is noon I dont know wba erybody ses ched ul is I dont ow ho yo re feel in THE WJTN am fme ZELL do bave another quest...
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...same Pages to Kress Court Reporting Inc Rue No re Dame Miami Beach FL A GIUFFR Case Document Filed Page of Page BY MR LANG INO Are you currently in fear of Mr Epstein A Not at this particular moment but its something I have to be worry about y...
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...es Are you personally afraid of criminal prosecution A No Do you believe that you did anyth in illegal A Illegal no MR LANGINO I have no further questions Than you MR CRITTON Were going to break in about minutes Do you want to start and go for...
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...eterm7.9i-.1ning whether a party has reasonably relied on the protective order the scope of the protective order the 6.7language of the order 4itself the level inquiry the court undertook before granting the order and the nature of reliance on...
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...re all four factors weigh against a finding of reasonable reliance.6.7 First the Protectiv5.3e Order contains expansive language gran10.4tin5.6g the partie broad latitu5.5de to self-designate m8.1a-.9terials as confidential it unreasonable for...
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...ROBERT CRITTON ESQ North Flagler Drive Suite West Palm Beach Florida Attorney for Jeffrey Epstein ALSO PRESENT JOE LANGSAM VIDEOGRAPHER CONTINUED INDEX OF EXAMINATION WITNESS DIRECT CROSS REDIRECT CROSS ALFREDO RODRIGUEZ By Ms Ezell By Mr Wi l...
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...WITNESS DIRECT CROSS REDIRECT CROSS ALFREDO RODRIGUEZ By Ms Ezell By Mr Wi ll its By Mr Critton By Mr Edwards By Mr Langino CONTINUED INDEX OF EXHIBITS PlAINTIFPS PAGE Draw i ng Photograph Photograph Photograph Photograph Report Exhibits and we...
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...use of the terms all or in the interrogatories and the requests for production It is also presumed absence of limiting language or restrictions to certain accounts For example Ms Giuffre?s first Request sought all documents relating to communi...
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...that the Epstein Server Acc is distinct from the Mindspring account which she discusses in a different section but the language she uses there is a big difference between having a private email account gmail aol ahoo etc and communicating thro...
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...of their own conduct Id at Consistent with those two purposes Mr Gow?s emails prefaced the statement with the following language Please 9.7find attached a quotable statement on behalf of Ms Maxwell italics supplied The statement was inte)5.3nde...
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...added Consistent-512.4w-.1ith Mr Barden?s purposes statement Mr Gow?s emails prefaced the statement with the following language Please find 10attached a quotable statement on behalf of Ms Maxwell emphasis supplied 10Summary20.2 Judgment Motion...
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...is retold it changes with new salacious details about public figures and world leaders And then theres some additional language You had in fact sexually trafficked Virginia to public figures MR PAGLIUCA Object to form and foundation THE WITNES...
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...d Page of MAGNA9 LEGAL SERVICES Pages to Pages to Page Epstein Confidential treated as such Then theres some additional language That statement by Ms Maxwell was in fact itself an obvious lie right MR PAGLIUCA Object to form and foundation THE...
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...rt to protec5.7t a non from that would in embarr-6.8a-.1ssment oppressi-14.2o or undue burden e6x-9.7pense Allstate Ins Langston So 2d F6.1la Supreme Court ove-5.7rturning7.7 of protect-11.7ive order 6and holding9.7 that of certain kinds of inf...
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...se in-11.1dividuals has absolutel-9.5y19.9 9.1nothing9.9 to do with ac-5.5tion befor5.9e this Court See Allstate Ins Co Langston So 2d F9.5la Supre6.7me Court holding10.1 that do not believ-7.2e a 9litig9.8ant is entitled bl-11.6anch to and is...
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...eterm7.9i-.1ning whether a party has reasonably relied on the protective order the scope of the protective order the 6.7language of the order 4itself the level inquiry the court undertook before granting the order and the nature of reliance on...
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...re all four factors weigh against a finding of reasonable reliance.6.7 First the Protectiv5.3e Order contains expansive language gran10.4tin5.6g the partie broad latitu5.5de to self-designate m8.1a-.9terials as confidential it unreasonable for...
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...ar Nina olh wt Howard Kaplan Horne Adam Tierney Bayshore Drive Suite Eaton Terrace Miami FL London SlJV1 WBEZ Email hk plangroup.com h6Wd!f We19 Place Hunter Carlyn Laurie North Miami Bea FL Mallard SWJ SOT tJ London EnH an Howegego Lucy Johnns...
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...rt Edward ESL Partners East Pulnam Avenue Greeriwich Conneticut ii Calhfh Cath Lambos Duff John Email lambosi ms.com Hm Lange Dieter 828fjH Email dla ceU asst renafa Larsen Janet Ruthn t1 london Laurie Jonathan rs CheSham Place ondon sw1 I Lavl...
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...ited by Plaintiff under itle including provide for fines penalties and incarcera tion for criminal offenses There is no language in these sections that would imply5.7 a cause of action exis4.9 ts to allow Plaintiff to seek a remedy for these cr...
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...r that any appl ication of VI 2s obstructio claim to pre-December conduct is impermissibly retroactiv 223Nothing in the language of the TVPRA or its legislative history indicates that Congress in tended retroactive application Velez F.3d at and...
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...o I direct you to the first email in the chain at the bottom of the page Its an email from you Maryanne Ryan to William Langford on February is that right A Yes There is no subject line is that right A There isnt You write I hear you are out of...
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...terminated as a customer A Again goes to reputational risk Moving up to your email in the chain at p.m again to William Langford You write in the second sentence I typed SVU and his name and there is a Gawker story Law and Order commerates JE C...
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...mes Sent Tuesday January PM To Morris Paul Cc Perry Bonnie Subject Re Rapid Response meeting this Thursday Paul william langford requested that we responsor this client in light of the new allegat i ons of human trafficing which the firm has be...
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...d draft document for the Rap i Response meeting this Thursday We were asked by the firms AM Compliance Director William Langford to re-evaluate our sponsorship of Epstein and request re-approval from Steve Cutler if we wanted to retain Pis call...
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...Tm F0 Tf paragraph it says It involves an ask of Tm F0 Tf William so I sending to you first Tm F0 Tf William is William Langford Tm F0 Tf A Wait a minute I lost here Tm F0 Tf The end of the first paragraph Tm F0 Tf MR KRAUSE Before you do that...
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...of Item ClienUProspect I effrey pstein ClienUProspect Category Existing Client Reason The Firms AML Director William Langford has expressed concern over the possibility that Mr Epstein is under investigation for human trafficking Outcome Outcom...
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...root how to approach the issue with out clients involved in human Jes Staley who is friends with trafficking William Langford Epstein He needs to is requiring that if the understand the potential business decides to proceed backlash to the firm...
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...e USVI First Lady solicited Epstein 2s input on USV I 2s pending sex offender monito5.7 ring legislation and shared aft languag5.7 from DOJ4.6 with Epstein writing5.4 223This is suggested language will it work4.1 for you CSMF emphasis added Eps...
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...at i USVI witness est i fied a CSMF1273 in a Bou ht ai er A nd pecial Tr atment It did stop the When Epste in prefe ed language i ot make i in aw First Lady wrote ps in to reassure hi that alt i ad in cl ded eve ything wa ted all was lost and...
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...e ant to he ques ti ons under review Th re is no allegation tha his wealth was ri ed from human trafficking As noted by Langford the question for the Bank was no whether Eps ein ngaged in particula activity bu wheth er he used he ank conduc the...
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...uestion for the Bank was no whether Eps ein ngaged in particula activity bu wheth er he used he ank conduc the acti ity Langford ep at While conceding tha Epstein was a weal hy client of JP MC Rusch questions Epstein sources of wealth no ing th...
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...of A Item Client/Prospect Jeffrey Epste i Client/Prospect Ca tegory Exis i ng Oien Reason he i rms AML i ector i lliam Langford has exp essed concern over the possib i ity that Mr Epstein i under i nvestigat i on for human trafficking Date Out...
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...issue with Jes Sta ey who i riends with dients i nvolved i human Eps ein needs to understand the traffick i ng William Lang ord i potent i a backlash to the firm given al of requ i ring ha i the bus i ness the work done to oo out cl i ents dec...
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...L CN RECI Pl ENTS/CN LISA VIAN I PM Casey Mary mary.c.casey jpmorgan.com Morris Paul paul.v.morris jpmorgan.com William Langford Jes Staley Catherine Keating RE Jeffrey Epstein Dial-in Participant passcode PM PM Show Time As Tentative Required...
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...ting RE Jeffrey Epstein Dial-in Participant passcode PM PM Show Time As Tentative Required Attendees Optional Attendees Langford William Staley Jes Casey Mary Morris Paul Cutler Stephen When Friday January AM Eastern Time US Canada Where Dial-i...
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...L erations I organ chase an N.A I Legal and Comp iance a tme I Wood AVenue Sout Floor Ise in NJ I I origi al Message ro Langford William Se Monday Janua AM To eluca Phi ll ip A Nichols Nina A Cc Ryan Ma yanne subject RE Jeffrey Epstein What do...
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...up recent was it negat ive med ia i summe original Message From De luc a Phil ip A Sent Monday Janua AM Nichols Nina A Langford William Cc Ryan Ma yanne subject FW Jeffrey Epstein Here is the apid response memo related to pstein as we as i eda...
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...of A Item Client/Prospect Jeffrey Epste i Client/Prospect Ca tegory Exis i ng Oien Reason he i rms AML i ector i lliam Langford has exp essed concern over the possib i ity that Mr Epstein i under i nvestigat i on for human trafficking Date Out...
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...issue with Jes Sta ey who i riends with dients i nvolved i human Eps ein needs to understand the traffick i ng William Lang ord i potent i a backlash to the firm given al of requ i ring ha i the bus i ness the work done to oo out cl i ents dec...
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...rom Sent To Schwartz Jonathan uonathan.schwartz jpmchase.com PM Cutler Stephen stephen.m.cutler jpmorgan.com CC Subject Langford William william.d.langford jpmchase.com Kolat Gem gem.kolat jpmchase.com RE Did you go back to Jes re Privileged Ge...
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...ct Re Did you go back to Jes re could you send me articles Original Message From Schwartz Jonathan To cutler Stephen cc Langford William Sent Mon Mar subject Re Did you go back to Jes re Yes and didnt get anything back from him so I just called...
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...July in this Action Exhibit Document Bank Secrecy Act Anti-Money Laundering Examination Manual and previously marked as Langford Exhibit excerpt Exhibit Expert Report of Jonathan Rusch June excerpts Exhibit Document at Bates JPM-SDNYLIT excerpt...
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...Albert Bryan Jr taken on June in this Action Exhibit January email Bates JPM-SDNYLIT-00152833 and previously marked as Langford Exhibit Exhibit Transcript excerpts of the Deposition of former head of Compliance at JPMorgan William Langford take...
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...form misstates prior testimony THE I TNESS To me the E-mail says As requested the two passports English is a very funny language I think that he just threw that part in there Not saying that I requested a memorandum BY ATTORNEY OLAUGHLIN kay An...
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...of A NI A PINN EY Gov ir in I a ds vs JP Mor a ase the morning and very belligerent you know very broken up very cut-up language you know So anything can be creditable Thats why I forwarded it on you know But his as an individual he was very qu...
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...mation about their intended travel as may be required by the Attorney General Subsection is replaced with the following language Before moving from the United States Virgin Islands to another jurisdiction within the United States a person requi...
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...ls Service Any other information required by the Attorney General Subsection is deleted and replaced with the following language The Department of Justice shall establish policies and procedures to ensure the following That any sex offender con...
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...o the A miss i ons Office asses in five level GCE or CXC General I and II or a comb i nation of both i ncluding English Language is acceptab for admissi CXC General I ll will also be accepted if based on the ix-po i nt ca le Tran fer redit is g...
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...J Test of English as a Foreign anguage TOEFL is required of appl i ca nt from countries whe nglish i not the offic i al language For information a bout TOEFL wr i to Educat i onal Testing Service Box Princeton NJ USA The Certificate of Finances...
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...is named co-trustee with Mark Newman Confidential JPM-SDNYLIT-0184_R Case Document Filed Page of Does the trust include language flermitting Morgan to deal with affiliates waiving the duties of undivided loyalties and self dealing Yes Funding E...
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...of the account and whether we are legally directed or have full investment liability Also includ the specific relevant language in the governing document that addresses the concentration or that establishes a direction by another party to hold...
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...of A Item Client/Prospect Jeffrey Epste i Client/Prospect Ca tegory Exis i ng Oien Reason he i rms AML i ector i lliam Langford has exp essed concern over the possib i ity that Mr Epstein i under i nvestigat i on for human trafficking Date Out...
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...issue with Jes Sta ey who i riends with dients i nvolved i human Eps ein needs to understand the traffick i ng William Lang ord i potent i a backlash to the firm given al of requ i ring ha i the bus i ness the work done to oo out cl i ents dec...
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...rom Sent To Schwartz Jonathan uonathan.schwartz jpmchase.com PM Cutler Stephen stephen.m.cutler jpmorgan.com CC Subject Langford William william.d.langford jpmchase.com Kolat Gem gem.kolat jpmchase.com RE Did you go back to Jes re Privileged Ge...
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...ct Re Did you go back to Jes re could you send me articles Original Message From Schwartz Jonathan To cutler Stephen cc Langford William Sent Mon Mar subject Re Did you go back to Jes re Yes and didnt get anything back from him so I just called...
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XHIBIT Case Document Filed Page of Case Document Filed Page of From Sent To CC Subject Langford William william.d.langford jpmchase.com AM Ryan Maryanne maryanne.x.ryan jpmchase.com Deluca Phillip A phillip.a.de...
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...s will be on the phone Really appreciate the facts here original Message From Ryan Maryanne Sent Thursday January PM To Langford William Cc Deluca Phillip A subject FW Jeff Epstein I have spent the better part of these past few days digging bac...
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...o ensure that you are in compliance Note that the Code and some related documents have been translated into a number of languages in addition to English translations are available on the Code home page on the firm intranet or from your Code Spe...
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...mber though that you may encounter other situations in which the right course of action is not dictated by the specific language of the Code and in those situations the firm counts on your integrity and judgment Ultimately the firms reputation...
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...s to any allegation that unnecessarily reflects on the moral character of an individual or states anything in repulsive language that detracts from the dignity of the court Id The allegations in the Complaint relating to the Prior Proceedings s...
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...whereabouts of the Defendants during that time period The allegations concerning this period merely track the statutory language but without providing the necessary factual support The Complaint therefore fails to establish that the Court has p...
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...sexual activity or contact Given that this case involves sexual trafficking a great deal of material be covered by this language Please let us know if our proposed alternative is acceptable to you If not it seems we should present our varying f...
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...id Attached please find a draft protective order Consistent with the judge 2s comments on the record I have removed the language from the preamble proposed at paragraph a list of categories of confidential information adopted your version of pa...
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...Subtype Header Type Pagination BDC TT0 Tf Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TD Td EMC Lang es-ES/MCID BDC TT1 Tf Td es-ES/MCID BDC Td EMC MCID BDC Td ail Nove6 mber5 Honor5 a4 ble2.3 Ma-6 ist-4 a4 te udg10 e4 r...
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...onferring transactional immunity as the broadest and strongest protection that the Department of Justice offers Initial language included in the NP A concludes the initiation of any and all criminal charges that might be in the future brought a...
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...ainst the full co-conspirators or any employees arising out of ongoing federal investigations are precluded page Whilst language was modified slightly so as not to be so detailed the intent was and the broad scope of the coverage is what remain...
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...6 a4 ti-3 ng Agr5 e4 e4 ment e4 xpr-6 e4 ssl-3 prohibit-2 indemnific3 a4 ti-3 on for6 c4 laims-2 that a4 re7 iguo-11 us langua6 ge4 Ma3 xw-7 e4 ll6 c4 a4 nnot be4 ind-11 e4 mni-3 fie5 fo-6 he4 int-3 e4 ti-3 ona4 c4 rimi-2 na4 mi-3 sc3 onduc4 Se...
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...t Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of APPEARNCES CONTINUED On behalf of BB ADAM LANGINO ESQUIRE LEOPOLD KUVIN PGA Boulevard Suite Palm Beach Gardens Florida Phone Case Document Entered on FLSD Docket Page...
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...CRITTON Cindy what time is it THE COURT REPORTER It is MR BERGER William Berger for LM and MR HILL Jack Hill for CMA MR LANGINO Adam Langino from Leopold Kuvin on behalf of BB MR LUTTIER Mark Luttier on behalf of Burman Critton Luttier Coleman...
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...t-458 research-457 method-457 social-458 sciences-456 and also-401 because-401 involves-400 inherent-400 complexity-401 language-402 2Donohue conceptual-244 analysis-245 grooming-244 construct-244 necessary-244 the research-278 process,-279 sal...
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...the Circuit explained that argum relied a 223contor ted and 223incorrect reading of its prior decision in United States Langford F.2d 2d Cir Shaoul F.3d at Here the defendant 2s argument relie in significant part on th very same reading of Lang...
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...Langford F.2d 2d Cir Shaoul F.3d at Here the defendant 2s argument relie in significant part on th very same reading of Langford tha4.4 was explic4.7 itly jected in Shaoul Compare Shaoul F.3d at with Def Mem at The defend5.8 ant relian5.8 ce on...
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...ngly misrepresent to a court or adversary But an unintended inference is not a misrepresentation The lack of disclaimer language in the memorandums true statements-the fact that the lawyers while focused on the new trial motion did not anticipa...
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...ier during the voir dire itself And I not sure there is a great definition of strategic judgment but there is very good language in Justice Stevens dissent but I dont think the majority disagreed with it th a talks about a conscious choice betw...
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...the Circuit explained that argum relied a 223contor ted and 223incorrect reading of its prior decision in United States Langford F.2d 2d Cir Shaoul F.3d at Here the defendant 2s argument relie in significant part on th very same reading of Lang...
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...Langford F.2d 2d Cir Shaoul F.3d at Here the defendant 2s argument relie in significant part on th very same reading of Langford tha4.4 was explic4.7 itly jected in Shaoul Compare Shaoul F.3d at with Def Mem at The defend5.8 ant relian5.8 ce on...
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...ngly misrepresent to a court or adversary But an unintended inference is not a misrepresentation The lack of disclaimer language in the memorandums true statements-the fact that the lawyers while focused on the new trial motion did not anticipa...
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...ier during the voir dire itself And I not sure there is a great definition of strategic judgment but there is very good language in Justice Stevens dissent but I dont think the majority disagreed with it th a talks about a conscious choice betw...
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...ful ne4ss 51a4nd 49thus 52potentially a4dmi-3ssi-3ble 167unde4r 166Evide3nc-5e4 169This 172c4onsi-2stent 180with 171the langua6ge4 b3 149whic4h 149pe4rmits-3 149a4dmi-3ssi6on 146fa7lse 148state3ments 150made6 ne4goti-3a4ti-3ons 120long 119pu-9r...
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...otections of the privacy of witnesses and alleged victims that is required by law In contrast the Governments proffered language would allow Ms Maxwell to publicly reference individuals who have spoken by name on the record in this case It also...
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...otections of the privacy of witnesses and alleged victims that is required by law In contrast the Governments proffered language would allow Ms Maxwell to publicly reference individuals who have spoken by name on the record in this case It also...
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...that defendants such as Mr Thomas have a fair opportunity to prepare for trial United States Poindexter Supp D.D.C The language and the spirit of the Rule are designed to provide to a criminal defendant in the interest of fairness the widest p...
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...:l!b;n in exchange fur my consent have read this form it has been read by me and I understand it I understand the Vl i5 language and have been able tc communicate with agents/officers I understan max withdraw my consent at any time I may also a...
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...AN New Consultation quests Target Date Scheduled Target Date Priority Reg Fac i lity NYM i Translator Language Consultation Procedure Emergency Room Subtyp mergen No AMBU ANCE Reason for Request Cardiac arrest with CPR in progress Copay Require...
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...d with the more serious crimes of sexual ac tivitywith minors Second he slammed State Attorney Bar ry,Krischer in blunt language seldom used by one law e1fforcement official con cerning another because of what he perceived as that of fices mish...
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...s crimes of sexual ac tivity with minors Second he slammed State Attorney Bar ry Krischer in blunt language seldom used by one law enforcement official con cerning another because of what he perceived as that of fices mishandling of the case In...
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...Booking Dale Pocking fere ii Dale ai Tele LOCAtrOn Of Vehicle VON Name Lea i i MI T-1/AP a IN egie-rt Race let of I Al Lange i le VW Co-Dvienctafft Name fLest.Ftrar 1.6calet Race Date it Artesian At Le ge LI hesidierneerof 5..A.Neralie PE c.md,...
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...tion Reply Brief The Government respectfully submits that there is no basis under the applicable standard to redact the language that the defendant proposes redacting in Reply Brief as it refers to language contained in the publicly filed Indic...
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...tes cell always being mindful of patient confidentiality The patient counseling will also consider literacy and primary language The opportunity for oral counseling by a pharmacist will be offered when new medication is distributed If not logis...
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...s resources will be better used during inmate triage/sick-call SUMMARY OF CHANGES The change authorized under new rules language now reads An inmate without funds is an inmate who has not had a trust fund account balance of for the past days Pa...
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...f the General Counsel Litigation Branch has been deleted Adds guidance for inmate use of non ITS telephones Removes the language requiring Unit staff to approve inmates telephone number request form Provides guidance for inmates administering t...
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...res Code Code Offense Elements Malingering Feigning Illness Malingering means to feign illness Using Abusive or Obscene Language Using coarsely insulting indecent or lewd language Conduct with a Visitor in Violation of Bureau Regulations Inappr...
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...Stat sets forth possible exceptions to the disclosure of grand jury testimony however Plaintiff is barred by the clear language of the statute from access to the records it seeks for the purposes it has set forth as Fla Stat states When such d...
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...claratory action claim for relief The State Attorneys admission demonstrates that his motion is contrary to the express language of section As stated above section a examines a claim or defense when initially presented to the court Because the...
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...plication of current law Specifically your action for declaratory relief fails based on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is ordered by a court pursuant to subsection I...
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...nstruction In interpreting a statute the court must respect the role of the legislature the legislative process and the language of the statute A courts function is to interpret statutes as they are written and give effect to each word in the s...
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...he was merely without authority to release the records absent a Page of court order To have the Final Judgment include language that implies that the Clerk was zealously advocating against the release of records rather than simply that he was...
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...nstruction In interpreting a statute the court must respect the role of the legislature the legislative process and the language of the statute A courts function is to interpret statutes as they are written and give effect to each word in the s...
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...4.9 le and persuasive and presented 223strong arguments for a more expansive construction of the furtherance of justice language of Florida Stat n5 case presented questions of 223first impression regarding that st o5 Court 2s inherent authority...
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...he Newspaper as a surro,gate for the public or to requh:e the Court to conciuct an in camgrq amfoation qfthe same to b:alanGe the publics tight t0 know through a free media witli Floridas qualified statutory interest in grand jl ry secrecy See...
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...e6 ther5 a4 re7 iss-3 ue4 with the publi-3 she3 on August-10 c4 rime3 of se-6 xua4 c4 ti-3 vit-3 with mi-3 nors blunt-3 langua6 ge4 se3 ldom-3 use3 by one4 law4 e4 nfor6 e4 e4 nt off6 icia4 with a4 nother5 be4 c4 a4 use3 C6 TI8 c4 ha4 rge7 with...
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...e6 ther5 a4 re7 iss-3 ue4 with the publi-3 she3 on August-10 c4 rime3 of se-6 xua4 c4 ti-3 vit-3 with mi-3 nors blunt-3 langua6 ge4 se3 ldom-3 use3 by one4 law4 e4 nfor6 e4 e4 nt off6 icia4 with a4 nother5 be4 c4 a4 use3 C6 TI8 c4 ha4 rge7 with...
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(1 occurrence)
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...key witness Epsteins attorney Jack Goldberger did not return phone messages A source close to the case suggested it is languishing pending a decision by the FBI on whether to refer it to federal prosecutors We still have a pending case FBI spo...
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(1 occurrence)
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Top Subtype Header Type Pagination BDC TT0 Tf Td TD TT1 Tf Td Td EMC Lang es-ES/MCID BDC TT1 Tf Td ne il5 hill5 ll5 p.com Janua-2 ry VIA3 CF The Honorabl-2 Lorna Schof3 iel-4 d4 Dist-2 rict Cou...
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...9ye4ars-3 39bri-3ng5 civi ac-3tion f4or r-3esu3lting injuries Def4endant-3s 135arg-2ue 135that 134nar-2row 134reading a langua-3ge per-2son 49with traf3fickin3g 50oper-2ation 55m8ay 49avai-3l 48of a thi-3s 35matter-3 he 50p5erp-2e4tr-3a4tor-3 4...
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...overy proceedings This is inherently unfair the danger is clear and the playing field is not level in light of the NP A language or lack thereof As a result the threat of criminal prosecution against EPSTEIN by the USAO continues presently and...
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(1 occurrence)
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...THE COURT I need the defendant to sign number where I had ans added to victim and we struck out the otherwise indicatid language Otherwise it is as you agreed Mr Epstein do you understand this is a somewhat complicated terms of the plea that yo...
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(1 occurrence)
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...overy proceedings This is inherently unfair the danger is clear and the playing field is not level in light of the NP A language or lack thereof As a result the threat of criminal prosecution against EPSTEIN by the USAO continues presently and...
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(1 occurrence)
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...int to Defendant on May via first class m13a il D4E2 It is m9y1 understanding that the Affidavit of Service crosses out language regarding m)9ail to the Defendant and that the process server in this case did not m8a-1il a copy of the Sum8m8ons...
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(1 occurrence)
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...in he do ume nt ue to i ts le tr on ic up loa in to he Cou rt CM ECF sy ste ow ve wa a pp a re ntl a line striking the lang uag fr om the aff idavit reg arding the mailing of the Summons and Complaint See DE Plaintiff broug ht this error to th...
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(1 occurrence)
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...Mr Epstein pursuant to a violation of Chapter Florida Statutes must be dismissed Should the Court look beyond the plain language of the plaintiffs complaint and construe Count I as a claim for common-law assault that claim would also fail As th...
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...t is GR ANTED a i a i i STRICKEN and substituted with U.S.C The a lleg ations in the Amended Complaint closely trac the lang uag of making it clear that this is he subsec tion upon which Plaintiff is rely ing notice plea ding sta ndard unde Rul...
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(1 occurrence)
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...e im9portant than the form9er The in tent of is to discourage child abuse That discouragem9ent in view of the statutory language can occur by way of a civil lawsuit for dam8a-1ges as well as by way of a crim9inal prosecution Carson Jackson So.2...
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(1 occurrence)
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...overy proceedings This is inherently unfair the danger is clear and the playing field is not level in light of the NP A language or lack thereof As a result the threat of criminal prosecution against EPSTEIN by the USAO continues presently and...
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Content Matches:
(1 occurrence)
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...r of the case and must be admiss ible or reasonably calculated to lead to admissible evidence See Allstate Insurance Co Langston So.2d Amente Newman So.2d Russell Stardust Cruis ers Inc So.2d Fla 5th DCA The concept of relevancy is broader in t...
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Content Matches:
(1 occurrence)
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...r of the case and must be admiss ible or reasonably calculated to lead to admissible evidence See Allstate Insurance Co Langston So.2d Amente Newman So.2d Russell Stardust Cruis ers Inc So.2d Fla 5th DCA The concept of relevancy is broader in t...
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Content Matches:
(1 occurrence)
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...overy proceedings This is inherently unfair the danger is clear and the playing field is not level in light of the NP A language or lack thereof As a result the threat of criminal prosecution against EPSTEIN by the USAO continues presently and...
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(1 occurrence)
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...ibited pursuant to the vagueness doctrine and the Rule of Lenity A criminal statute is required to give fair warning in language that the common world will understand of what the law intends to do if a certain line is passed To make the warning...
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Content Matches:
(1 occurrence)
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...ibited pursuant to the vagueness doctrine and the Rule of Lenity A criminal statute is required to give fair warning in language that the common world will understand of what the law intends to do if a certain line is passed To make the warning...
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Content Matches:
(1 occurrence)
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...int to Defendant on May via first class m13a il D4E2 It is m9y1 understanding that the Affidavit of Service crosses out language regarding m)9ail to the Defendant and that the process server in this case did not m8a-1il a copy of the Sum8m8ons...
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Content Matches:
(1 occurrence)
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...in he do ume nt ue to i ts le tr on ic up loa in to he Cou rt CM ECF sy ste ow ve wa a pp a re ntl a line striking the lang uag fr om the aff idavit reg arding the mailing of the Summons and Complaint See DE Plaintiff broug ht this error to th...
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Content Matches:
(1 occurrence)
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...Mr Epstein pursuant to a violation of Chapter Florida Statutes must be dismissed Should the Court look beyond the plain language of the plaintiffs complaint and construe Count I as a claim for common-law assault that claim would also fail As th...
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Content Matches:
(1 occurrence)
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...ar or for life Case Document Entered on FLSD Docket Page of The a lleg ations in the Amended Complaint closely trac the lang uag of making it clear that this is he subsec tion upon which Plaintiff is rely ing U.S.C Th Am nd Co mpl a int a lle E...
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Content Matches:
(1 occurrence)
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...e im9portant than the form9er The in tent of is to discourage child abuse That discouragem9ent in view of the statutory language can occur by way of a civil lawsuit for dam8a-1ges as well as by way of a crim9inal prosecution Carson Jackson So.2...
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Content Matches:
(1 occurrence)
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...overy proceedings This is inherently unfair the danger is clear and the playing field is not level in light of the NP A language or lack thereof As a result the threat of criminal prosecution against EPSTEIN by the USAO continues presently and...
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Content Matches:
(1 occurrence)
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...r of the case and must be admiss ible or reasonably calculated to lead to admissible evidence See Allstate Insurance Co Langston So.2d Amente Newman So.2d Russell Stardust Cruis ers Inc So.2d Fla 5th DCA The concept of relevancy is broader in t...
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Content Matches:
(1 occurrence)
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...r of the case and must be admiss ible or reasonably calculated to lead to admissible evidence See Allstate Insurance Co Langston So.2d Amente Newman So.2d Russell Stardust Cruis ers Inc So.2d Fla 5th DCA The concept of relevancy is broader in t...
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Content Matches:
(1 occurrence)
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...overy proceedings This is inherently unfair the danger is clear and the playing field is not level in light of the NP A language or lack thereof As a result the threat of criminal prosecution against EPSTEIN by the USAO continues presently and...
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Content Matches:
(1 occurrence)
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...ibited pursuant to the vagueness doctrine and the Rule of Lenity A criminal statute is required to give fair warning in language that the common world will understand of what the law intends to do if a certain line is passed To make the warning...
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Content Matches:
(1 occurrence)
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...ibited pursuant to the vagueness doctrine and the Rule of Lenity A criminal statute is required to give fair warning in language that the common world will understand of what the law intends to do if a certain line is passed To make the warning...
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Content Matches:
(1 occurrence)
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...int to Defendant on May via first class m13a il D4E2 It is m9y1 understanding that the Affidavit of Service crosses out language regarding m)9ail to the Defendant and that the process server in this case did not m8a-1il a copy of the Sum8m8ons...
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Content Matches:
(1 occurrence)
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...in he do ume nt ue to i ts le tr on ic up loa in to he Cou rt CM ECF sy ste ow ve wa a pp a re ntl a line striking the lang uag fr om the aff idavit reg arding the mailing of the Summons and Complaint See DE Plaintiff broug ht this error to th...
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Content Matches:
(1 occurrence)
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...Mr Epstein pursuant to a violation of Chapter Florida Statutes must be dismissed Should the Court look beyond the plain language of the plaintiffs complaint and const1ue Count I as a claim for common-law assault that claim would also fail As th...
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(1 occurrence)
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...t is GR ANTED a i a i i STRICKEN and substituted with U.S.C The a lleg ations in the Amended Complaint closely trac the lang uag of making it clear that this is he subsec tion upon which Plaintiff is rely ing Plaintiff need not set for th more...
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Content Matches:
(1 occurrence)
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...e im9portant than the form9er The in tent of is to discourage child abuse That discouragem9ent in view of the statutory language can occur by way of a civil lawsuit for dam8a-1ges as well as by way of a crim9inal prosecution Carson Jackson So.2...
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Content Matches:
(1 occurrence)
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...overy proceedings This is inherently unfair the danger is clear and the playing field is not level in light of the NP A language or lack thereof As a result the threat of criminal prosecution against EPSTEIN by the USAO continues presently and...
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Content Matches:
(1 occurrence)
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...r of the case and must be admiss ible or reasonably calculated to lead to admissible evidence See Allstate Insurance Co Langston So.2d Amente Newman So.2d Russell Stardust Cruis ers Inc So.2d Fla 5th DCA The concept of relevancy is broader in t...
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Content Matches:
(1 occurrence)
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...r of the case and must be admiss ible or reasonably calculated to lead to admissible evidence See Allstate Insurance Co Langston So.2d Amente Newman So.2d Russell Stardust Cruis ers Inc So.2d Fla 5th DCA The concept of relevancy is broader in t...
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Content Matches:
(1 occurrence)
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...overy proceedings This is inherently unfair the danger is clear and the playing field is not level in light of the NP A language or lack thereof As a result the threat of criminal prosecution against EPSTEIN by the USAO continues presently and...
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Content Matches:
(1 occurrence)
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...ibited pursuant to the vagueness doctrine and the Rule of Lenity A criminal statute is required to give fair warning in language that the common world will understand of what the law intends to do if a certain line is passed To make the warning...
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Content Matches:
(1 occurrence)
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...ibited pursuant to the vagueness doctrine and the Rule of Lenity A criminal statute is required to give fair warning in language that the common world will understand of what the law intends to do if a certain line is passed To make the warning...
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Content Matches:
(1 occurrence)
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...overy proceedings This is inherently unfair the danger is clear and the playing field is not level in light of the NP A language or lack thereof As a result the threat of criminal prosecution against EPSTEIN by the USAO continues presently and...
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Content Matches:
(1 occurrence)
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...r of the case and must be admiss ible or reasonably calculated to lead to admissible evidence See Allstate Insurance Co Langston So.2d Amente Newman So.2d Russell Stardust Cruis ers Inc So.2d Fla 5th DCA The concept of relevancy is broader in t...
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Content Matches:
(1 occurrence)
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...r of the case and must be admiss ible or reasonably calculated to lead to admissible evidence See Allstate Insurance Co Langston So.2d Amente Newman So.2d Russell Stardust Cruis ers Inc So.2d Fla 5th DCA The concept of relevancy is broader in t...
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Content Matches:
(1 occurrence)
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...overy proceedings This is inherently unfair the danger is clear and the playing field is not level in light of the NP A language or lack thereof As a result the threat of criminal prosecution against EPSTEIN by the USAO continues presently and...
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Content Matches:
(1 occurrence)
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...ibited pursuant to the vagueness doctrine and the Rule of Lenity A criminal statute is required to give fair warning in language that the common world will understand of what the law intends to do if a certain line is passed To make the warning...
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Content Matches:
(1 occurrence)
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...ibited pursuant to the vagueness doctrine and the Rule of Lenity A criminal statute is required to give fair warning in language that the common world will understand of what the law intends to do if a certain line is passed To make the warning...
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(1 occurrence)
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...aw assault and battery to which a four year statute of limitation applies Compare Count II wherein Plaintiff tracks the language Fla Stat pertaining to abuse Pursuant to Florida law although the term assault and battery is most commonly referre...
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(1 occurrence)
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...ibited pursuant to the vagueness doctrine and the Rule of Lenity A criminal statute is required to give fair warning in language that the common world will understand of what the law intends to do if a certain line is passed To make the warning...
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(1 occurrence)
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...graph headings are provided for convenience in locating paragraphs and are not intended to add or detract anything from language of the paragraphs DLS DAG Case Document Entered on FLSD Docket Page of LA VOGUE-SANDBERG and Case No STATE OF FLORI...
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(1 occurrence)
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...int to Defendant on May via first class m13a il D4E2 It is m9y1 understanding that the Affidavit of Service crosses out language regarding m)9ail to the Defendant and that the process server in this case did not m8a-1il a copy of the Sum8m8ons...
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Content Matches:
(1 occurrence)
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...in he do ume nt ue to i ts le tr on ic up loa in to he Cou rt CM ECF sy ste ow ve wa a pp a re ntl a line striking the lang uag fr om the aff idavit reg arding the mailing of the Summons and Complaint See DE Plaintiff broug ht this error to th...
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Content Matches:
(1 occurrence)
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...Mr Epstein pursuant to a violation of Chapter Florida Statutes must be dismissed Should the Court look beyond the plain language of the plaintiffs complaint and construe Count I as a claim for common-law assault that claim would also fail As th...
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Content Matches:
(1 occurrence)
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...ar or for life Case Document Entered on FLSD Docket Page of The a lleg ations in the Amended Complaint closely trac the lang uag of making it clear that this is he subsec tion upon which Plaintiff is rely ing U.S.C Th Am nd Co mpl a int a lle E...
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Content Matches:
(1 occurrence)
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...e im9portant than the form9er The in tent of is to discourage child abuse That discouragem9ent in view of the statutory language can occur by way of a civil lawsuit for dam8a-1ges as well as by way of The term9 223child abuse is defined broadly...
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Content Matches:
(1 occurrence)
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...covery proceedings This is inherently unfair the danger is clear and the playing field is not level in light of the NPA language or lack thereof As a result the threat of criminal prosecution against EPSTEIN by the USAO continues presently and...
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Content Matches:
(1 occurrence)
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...r of the case and must be admiss ible or reasonably calculated to lead to admissible evidence See Allstate Insurance Co Langston So.2d Amente Newman So.2d Russell Stardust Cruis ers Inc So.2d Fla 5th DCA The concept of relevancy is broader in t...
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Content Matches:
(1 occurrence)
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...r of the case and must be admiss ible or reasonably calculated to lead to admissible evidence See Allstate Insurance Co Langston So.2d Amente Newman So.2d Russell Stardust Cruis ers Inc So.2d Fla 5th DCA The concept of relevancy is broader in t...
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Content Matches:
(1 occurrence)
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...overy proceedings This is inherently unfair the danger is clear and the playing field is not level in light of the NP A language or lack thereof As a result the threat of criminal prosecution against EPSTEIN by the USAO continues presently and...
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...al anguish embarrassment loss of dignity psychological trauma an intentional infliction of emotional distress where the language contained in the cases I think the first case really speaks to that at length where the cause of action was delinea...
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(1 occurrence)
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...ibited pursuant to the vagueness doctrine and the Rule of Lenity A criminal statute is required to give fair warning in language that the common world will understand of what the law intends to do if a certain line is passed To make the warning...
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...dentiality agreement and if required by this court to redact full names from any document filed with the Court Next the language of Fla Stat makes it clear that the statute only applies criminal proceedings brought by the State of Florida not c...
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(1 occurrence)
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...ibited pursuant to the vagueness doctrine and the Rule of Lenity A criminal statute is required to give fair warning in language that the common world will understand of what the law intends to do if a certain line is passed To make the warning...
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...the victims had The victim notification letter was provided to Epsteins attorneys prior to being sent who approved the language of which the petitioners now complain Thus petitioners repeated assertions that the Government made these errors in...
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(1 occurrence)
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...d nc ow ve Pla int if fs ro po se rd i ve rl br oa Ac or din ly th Cou rt dir ts the par ties to attempt to ag ree upon lang uag for an orde direc ting De fenda nt to preser ve evidenc and submit an a ree order to the Court no later than July I...
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...ional relief as may appear just and proper at the conclusion of each complaint The mere incantation of such boilerplate language does not convert a legal cause of action into a legitimate request for equitable relief F.3d at Case Document Enter...
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(1 occurrence)
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...of the case and must be admiss ible or reasonably calculated to lead to admissible evidence See Allstate lnsu.rance Co Langston So.2d i Amante Newma11 So.2d Russell Stardust Cruis ers Inc So.2d Fla 5th DCA The concept of relevancy ls broader i...
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(1 occurrence)
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...dum of aw DE iled May and the Court?s Or der DE ntere uly The parties a re in a ree ment as to a substantial par of the lang uag in their propose order and the Cou rt ha a re fu lly on sid re th mot ion th pr op os rd rs a nd is the rw ise fu l...
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(1 occurrence)
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...r of the case and must be admiss ible or reasonably calculated to lead to admissible evidence See Allstate lsu.rance Co Langston So.2d Amente Newma11 So,2d Russell Stardust Cruis ers Inc So.2d Fla 5th DCA The concept of relevancy is broader in...
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Content Matches:
(1 occurrence)
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...of the case and must be admiss ible or reasonably calculated to lead to admissible evidence See Allstate lnsu.rance Co Langston So,2d Fla,Hl95 Amente Newma So,2d RuBsell Stardust Crufs ers Inc So.2d Fla 5th DCA The concept of relevancy ls broa...
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...to hand them a jackpot or a key to a bank It was solely to sort of put them in that same position So we developed this language that said if that provided for an attorney to represent them Most of the victims as you know from the pleadings com...
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Content Matches:
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...to hand them a jackpot or a key to a bank It was solely to sort of put them in that same position So we developed this language that said if that provided for an attorney to represent them Most of the victims as you know from the pleadings com...
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...and his partner Mr Luttier had a court reporter and a videographer present Additionally Mr Hill on behalf of C.M A Adam Langino on behalf of B.B William Berger on behalf of three Plaintiffs were present for the deposition Case Document Entered...
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...it would violate the right of a state court judge to set conditions of a state criminal judgment Without any supporting language in the No-Contact Orders Plaintiff contends that same preclude Epstein from sitting a few feet away from Jane Doe i...
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...F.2d 2d rejecting of production argument regarding bank-4.8 because every-4.8body knew that they existed United States Lang 4th Cir rejecting of production argument regarding bank-4.9 rec-4.9o rds because an IRS agent had been access to and ha...
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...c rdingly Stet tin cont end he ha no ob jection to the entry of an orde con is with his fid uciary obligation Id at his language has bee interp reted co unse fo Epstein and by this Court as Ste ttin ha ing no objectio to th en try of a preserva...
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(1 occurrence)
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...nformation from the FBI or U.S Attorney in response to her request for records Indeed the overly broad and non-specific language of her subpoena could be a reason the FBI has not produced any records See C.F.R requiring that Jou must describe t...
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...the following Service List the ma1u1er specified by CM/ECF on this __ clay of April Respectfully submitted By:/stJaclcAlanGoldberger Jack Alan Goldberger Esq Florida Bar No Atterbury Goldberger Weiss P.A Australian A venue South Suite West Pal...
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...NH PBCSB PBSO School Classroom MS Futch Section Manager SO Drug Farm area Ms Lindsay Secretary PBSO Drug Farm area Adam Langino Public Defender PBSO SB-Dorm to see inmates Story Crowles ParaLegal Epstein Jeffrey T-Special Elta Emilcar Trinity S...
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(1 occurrence)
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...m my e-mail of yesterday Court in Englebrick Worthington Industries Inc Supp2d CD Cal rejected motion to compel helpful language A valid assertion of the privilege does not reqmre an imminent criminal prosecution or investigation The right to a...
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(1 occurrence)
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...e Francis No CV MCR/WCS WL at N.D Fla Feb staying civil diversity action over plaintiffs objections on grounds that the language of U.S.C is clear that a stay is required in a case where a parallel criminal action is pending which arises from t...
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(1 occurrence)
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...Mr Epstein pursuant to a violation of Chapter Florida Statutes must be dismissed Should the Court look beyond the plain language of the plaintiffs amended complaint and construe Count I as a claim for common-law assault that claim would also fa...
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(1 occurrence)
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...C.J dissenting where Florida Chief Justice Wells admonished against the use of broad indefinite and legally nonspecific language to establish causes of action under a rubric as expansive as sexual misconduct Evans So 2d at Wells C.J dissenting...
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(1 occurrence)
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...overy proceedings This is inherently unfair the danger is clear and the playing field is not level in light of the NP A language or lack thereof As a result the threat of criminal prosecution against EPSTEIN by the USAO continues presently and...
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Content Matches:
(1 occurrence)
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...ibited pursuant to the vagueness doctrine and the Rule of Lenity A criminal statute is required to give fair warning in language that the common world will understand of what the law intends to do if a certain line is passed To make the warning...
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Content Matches:
(1 occurrence)
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...ibited pursuant to the vag ueness doc trine and the Rule of enity A ri min a st a tut is qu ir to ive a ir wa rn ing in language that the omm on wo rl ill understand of what the law intends to do if a certain li ne is passed To ma ke the wa rni...
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(1 occurrence)
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...Pagination BDC GS1 gs TT0 Tf Td Tf Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TT1 Tf TD Td EMC Lang es-ES/MCID BDC Tf Tc Td Tc Td 0B 0C A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a...
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...a-5ble 37ther5e4to 41suc3h sha3ll-3 69not 69re-2fusing a4nswe-4r but 69sha3ll-3 79se3t 71for6th 69the re7sponse 52the 52langua6ge4 50de-5e4med 52to 50a4mbi-3guous 50the 52int-3e4rpr6e4tation 48c4hose3n 50or 53use3d 50in 48re7spondi-2ng10 to t-3...
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...Pagination BDC GS1 gs TT0 Tf Td Tf Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TT1 Tf TD Td EMC Lang es-ES/MCID BDC Tf Tc Td Tc Td 0B 0C 0F 0C 0C 0C 0C 0C 0C 0C 0C 0C Case Document Filed Page of BSF BO I ES SCH I LLER FL...
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...ts in favor of applying Nevada punitive damages law But hile Plaintiff 2s invocation of Adel-5 on 2s 223points in favor language is well argued that language is ultimately only a partial recitation of the interest analysis test described above...
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...of e4 ompl-3 a4 int e4 xc4 e4 pt a4 mi-3 that the Ne6 Yor5 Ti mes publi-2 she3 a4 story a4 tt-3 ributi-2 ng the quote4 langua6 ge4 to De-5 c4 e4 de4 nt The5 Exe-4 c4 utors de4 ny-9 the fir4 st a4 nd e4 c4 ond se-6 ntenc6 e4 of ra7 gr-6 a4 ph o...
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Content Matches:
(1 occurrence)
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...ts in favor of applying Nevada punitive damages law But hile Plaintiff 2s invocation of Adel-5 on 2s 223points in favor language is well argued that language is ultimately only a partial recitation of the interest analysis test described above...
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(1 occurrence)
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...ive concept is used to describe the organization Nothing is gained by wrangling over the place to fit into current rule language such entities as limited liability companies limited partnerships business trusts more exotic common-law creations...
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(1 occurrence)
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...ive concept is used to describe the organization Nothing is gained by wrangling over the place to fit into current rule language such entities as limited liability companies limited partnerships business trusts more exotic common-law creations...
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(1 occurrence)
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...nder-2 Rule pl3a4int-3iff 4incl-4ud5ed the-3 follo4wing la-2ngua4ge th3is a-3c4tion shal-3l b3e d4ism-4issed he br-2oad langua-3ge propo3sed s-2ti-3pu5lation c-2ou5ld arg-2u ably act to waive-3 M4s rec-3o5ver-2 fees and 4cost-3s incurre6d duri-...
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(1 occurrence)
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...joint employee but then turn around and claim8.1 she is also the prevailing party Further and notwithstanding the plain language of the settlement release defendants Darren Indyke and Richard Kahn Co-E xecutors of the Estate of Je ffrey Epstein...
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(1 occurrence)
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...r no later than February stating whether she consents to the Court 2s entry of the oposed Order modified by strik5.5 ng language ith each party to bear its own Defendant Maxwell is a will ing and com8 pulsory Releasee in the general release agr...
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(1 occurrence)
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...b3 a-5t D3E ac4c4ord Opinion and O4rde7r o-6f Ma-3r J4ane4 Do-7e4 v4 D-7arren Indy6k4e4 9e4t al cv a4t D5kt 4striki-3ng langua-3ge4 fr6om prop ose3d R-2ule a7 dismi)-3ssal r3e4lating t-3o e4a4c4h pa-5rty pa5ying futur4e4 li-3ti-3ga4ti-3on fo3r...
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(1 occurrence)
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...b3 a-5t D3E ac4c4ord Opinion and O4rde7r o-6f Ma-3r J4ane4 Do-7e4 v4 D-7arren Indy6k4e4 9e4t al cv a4t D5kt 4striki-3ng langua-3ge4 fr6om prop ose3d R-2ule a7 dismi)-3ssal r3e4lating t-3o e4a4c4h pa-5rty pa5ying futur4e4 li-3ti-3ga4ti-3on fo3r...
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(1 occurrence)
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...b3 a-5t D3E ac4c4ord Opinion and O4rde7r o-6f Ma-3r J4ane4 Do-7e4 v4 D-7arren Indy6k4e4 9e4t al cv a4t D5kt 4striki-3ng langua-3ge4 fr6om prop ose3d R-2ule a7 dismi)-3ssal r3e4lating t-3o e4a4c4h pa-5rty pa5ying futur4e4 li-3ti-3ga4ti-3on fo3r...
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(1 occurrence)
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...oth See Opinion and Order of Feb at DE accord Opinion and Order of Mar Jane Doe Darren Indyke et al JGK at 0kt striking language from proposed Ruic a dismissal relating to each party paying their own fees and costs to preserve right to seek att...
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(1 occurrence)
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...eneral and counsel for many of th victims 227did in fact agree on a ll aspects of the Program with the exception of the language of the prop osed release to be si gned by claimants Both the ttorney General and the victims have asked that the re...
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(1 occurrence)
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...The victim8.8 notif4ica4.8tion le4.8tte4.8r was pro6v1ided to Epstein?s attorneys prior to being sent who approved the language of which the petitioner now complain Thus petitioners repeated asser4.1tions th6.1at the these e4.9rro6.1rs inten5....
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Content Matches:
(1 occurrence)
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...se at the inaccurate victim notification letter was provided to Epsteins attorneys prior to being sent who approved the language of which the petitioners now complain The apparent approval by Jeffrey Epsteins attorneys of inaccurate information...
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(1 occurrence)
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...rm contract and certain standard tern1s and clauses for use in all future contracts The adoption of a standard form and language for all contracts is a matter of general applicability not a particular matter involving specific parties Therefore...
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(1 occurrence)
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...Rights Act of victim9 and their fam9 ilies sought m9 ndam9 u1 review in the Tenth Circu6 it rely6 ing inte4 alia on the language in section of the VRRA granting them8 a 223rig h6 to b6 presen6 at all pub6 lic court proceedings related to the of...
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(1 occurrence)
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...specifically-provided 223lim8itations on relief apply to this cas5e ligh6t-2 of the narrow reach of this 223lim itation language th6e CVRA clearly leaves open all other rem8e-1dies including in particular equ5itab5l-2e remedies The 223federal c...
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(1 occurrence)
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...eys Office the Fe era Bureau of Investigat i on Conchita Sarnoff and a ny ot er new emp oyees or reporters The plain language contained therein cou not mor clear and definite However you hav provided a rivilege lo tha addresses conespondence wi...
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(1 occurrence)
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...ures ED Congress did not provide fo state court pleas in subsection of the rule and where Congr ess includes particular language in one section of a statute but Case Document Entered on FLSD Docket Page of om8.6its it in another it is generally...
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(1 occurrence)
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...to a number of Mr Epsteins attorneys regarding the binding nature of the agreement and incorporated one such e-mail and language from others The August e-mail contains AUSA Villafafias opinions and recommendations on the appropriate response by...
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(1 occurrence)
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...need special protection As a last-ditch effort the intervenors contend that if more is needed in addition to the plain language of Rule to preclude disclosure of the correspondence to plaintiffs it can be found in the conjunction of Rule the w...
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Content Matches:
(1 occurrence)
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...ege for plea bargaining As a last-ditch effort the lntervenors contend that PJf more is needed in addition to the plain language of Rule to preclude disclosure of the correspondence to plaintiffs It can be found In the conjunction of Rule the w...
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Content Matches:
(1 occurrence)
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...Rights Act of victim9 and their fam9 ilies sought m9 ndam9 u1 review in the Tenth Circu6 it rely6 ing inte4 alia on the language in section of the VRRA granting them8 a 223rig h6 to b6 presen6 at all pub6 lic court proceedings related to the of...
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(1 occurrence)
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...begun U9.3n.5ited T10u.5rner Supp 2d explaining despite a contrar6.9y-6.1 statement in the leg7.3i-1.6slative th actual languag7.5e-2 the CVRA a ppeared to victims uncharged cond7.4uct from those covered th7.4e CVRA Sear4.1cy NFN Paletz4.1 U.S...
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(1 occurrence)
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...ls A.M Villafa?a Nesbitt Kuyrkendall Richards and Sm8.8ith regarding FBI victim8.8 notifications and guidance regarding language to use and inform7.9ation to provide Attorney-C8.1lient Priv6.1ileg6.1e4.9 thru6.6 em8.2ail from8.2 Slom8.2an to A...
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(1 occurrence)
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...e Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Er:STl:IN Royal Princess Cl1lang Mai I ROYAL PRINCESS ClAMii lM il2 C:Ji,ms fon T,Ctun2 Kfan A lu,tfla Chl n.a ht Fa u1 in 1auttl11ln ttUII 11nTH1t1maui...
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(1 occurrence)
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...pursuant to and the identified individuals would not be suing under as contemplated by Paragraph Based on the specific language in the contract and the intent of both parties we believe that the Agreement clearly provides that the identified i...
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(1 occurrence)
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...give you an idea of what i would look like When I include a factual proffer in a plea agreement I usua11y use prefatory language like The parties agree that had this case proceeded to trial the United States would have proven the following fact...
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(1 occurrence)
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...detention We can the follow this ith a state plea as we ll so he serves the add i tional time there I need to see your language for proffers on the two charges Alternatively at this stage we could have just one count for months and then months...
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(1 occurrence)
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...witz kirkland com Page of Sun Sep at AM Hi Jay I looked up some 11th i rcuit cases on simple assau a nd found some good language I also learned that every moment that one is aboard an enclosed civil a i rplane they are in the special aircraft j...
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(1 occurrence)
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...JLefkowitz kirkland.com cc bee Subject Hi Jay I looked up some 11th Circuit cases on simple assault and found some good language I also learned that every moment that one is aboard an enclosed civil airplane they are in the special aircraft jur...
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(1 occurrence)
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...To Jay Lefkowitz Subject Re JE negotiations Hi Jay I looked up some Circuit cases on simple assault and found some good language also learned that every moment that one is aboard an enclosed civil airplane they are in the special aircraft juris...
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(1 occurrence)
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...me this is not a serious issue but wanted to call it to your attention I also wonder if you have any flexibility on the language in the paragraphs I dont think we are very far apart on this language I had also suggested some language to be incl...
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(1 occurrence)
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...nterpretations by saying precisely what we mean in a simple fashion I would replace Prtragrnphs and with the foll.owing language Any person who whjlc a minor was a victim ofa violation of an ox1unse enumermed in Title United States Code Scctio...
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(1 occurrence)
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...er interpretations by saying precisely what we mean in a simple fashion would replace Paragraphs and with the following language Any person who while a minor was a victim of a violation of an offense enumerated in Title United States Code Secti...
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(1 occurrence)
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...a We will certainly cooperate with the government ro drat s11ch a joint submission and wonld he pleased to submit drnrt language tO you for such a joint subm is sion I li i,k forward to working with you Lo resolv thcs1 mallcr:s believe we havi...
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(1 occurrence)
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...format that was used in the letters previously approved by Messrs Go ld berger and Tein except that I will include the language from the Septe mb er and October agreements I have enclosed a draft herewith Because I previously provided the vict...
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(1 occurrence)
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...if under other circumstances challenge woul a summnry judgment in Mr Epstein favor unde::r feel Civ Lastly th1 mo lifo langu..1g1 1-ccomnkmlcd by you presupposes th.it 1r tein would wc been charged an convicted or substantive violations rather...
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(1 occurrence)
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...t contain m:y indll ii,t ir c:nt ir:ing r;t a mir.or tc1 hav illi.!gal sexual activity as expr 267essly required by rhe language uf rh statute Furthernrc the Govemmc:nt coutl;ntion that routine and habit can till he factmtl and kgal void crcntc...
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(1 occurrence)
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...aflr.:.-r reaching a final cmnpmmis wilh your Ofiice a.s lo thc terms of lhc grccmcn1 und at t.hc very last minute thut language cg:uding tht elite Policy wns rcrnovcd from the final vc::rsion The two following rdi..:renccs lo thl elite Policy...
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(1 occurrence)
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...ations did not contain any inducing or enticing of a minor to have illegal sexual activity as expressly required by the language of the statute Furthermore the Governments contention that routine and habit can fill the factual and gal void crea...
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(1 occurrence)
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...to the judge12 that we are try31 ing to rea11 te fe14 dera11 jurisdiction for prison purposes will include our standard lang10 uag14 reg11 arding15 resolving12 all crimi-19 ility22 and I will mention conspirator9 but-10 would pref15 er not to h...
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(1 occurrence)
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...THE COURT I need the defendant to sign number where I had ans added to victim and we struck out the otherwise indicatid language you agreed Otherwise it is as Mr Epstein do you understand this is a somewhat complicated terms of the plea that yo...
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(1 occurrence)
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...5.7 that it appears5.1?-.7 th5.7at Edward10.1s not sub5.7j-1.7ect to a p5.7r-1.3otective order Id But as her own hedged language suggests an order from7.6 the U.S District Court for the Southern District of Florida restricts release of the m8a-...
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(1 occurrence)
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...DV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Com1ney Langley c/o Spencer Kuvin South Australian Ave West Palm Beach Florida William Scherer Esquire Federal Hwy Fort Lauderdale F...
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(1 occurrence)
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...data shall remain or be made visible presenter notes shall remain or be made visible and to the extent ESI in a foreign language is produced processing of such ESI shall be unicode-compliant Document Unitization If a Native Format file that is...
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(1 occurrence)
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...and scheduling criminal trials under the mandate of the Speedy Trial Act Title U.S.G Section Interpreter Yes or No List language and/or dialect This case will take days for the parties to try Please check appropriate category and type of offens...
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(1 occurrence)
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...lai infomtatiol fro.m EPt?TEfN and lils attorneys 267and ag 267ents for the purpose of lnducing 267EPSTEiN to.act-in rellanGe thereon EPSTEtN did so act on the mtsrepresentaUowand/or concealment by incurring additional attorneys fees costs and...
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(1 occurrence)
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...Court had an opportunity to consider the issues by simply temporarily sealing the materials the bag Cf Allstate Ins Co Langston So.2d Fla discussing the cat out of the bag problem such as the need to protect against irreparable injury caused b...
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Content Matches:
(1 occurrence)
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...tein What if any damages were sustained by Epstein and proximately caused by Rothstein Edwards does not agree with this language for the reason that the issue as stated fails to tie causation to Rothsteins operation of the Ponzi scheme It is Ed...
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Content Matches:
(1 occurrence)
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...DV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Com1ney Langley c/o Spencer Kuvin South Australian Ave West Palm Beach Florida William Scherer Esquire Federal Hwy Fort Lauderdale F...
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Content Matches:
(1 occurrence)
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...beginning on December In doing so the Court simply used its standard form pre-trial order which contains near identical language to the July Order that the parties have been operating under for over a year and that the Court has expressly refus...
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Content Matches:
(1 occurrence)
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...steins Reply to Edwards Response misread the operative allegations of the Corrected Second Amended Complaint The quoted language appears solely in the Introduction to the Complaint and does not form the basis of any operative allegations agains...
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(1 occurrence)
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...prosecution which was based on the filing of a complaint the court stated that it is guided and restrained by the broad language and application of the privilege articulated by the Florida Supreme Court in Levin and Echevarria In Levin the Flor...
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Content Matches:
(1 occurrence)
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...Broward Palm Beach I Sports Entertainment Trave Li1 Opinion I Video Home Collections Florida Bar Ads By Google Shocking Language Video If you dont know Spanish and you want to_ you should click here to see this short video_ Watch Video AdOIOice...
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Content Matches:
(1 occurrence)
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...and scheduling crtmlnal trials under the mandate of the Speeay Trial Act Title U.S.C Section Interpreter Yes or No list language and/or dialeet This case wfll take A days for the parties to try Please check appropriate category and type of offe...
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(1 occurrence)
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...s who were adversely affected by the misconduct that is the subject of this Complaint MR PIKE Fonn Mischaracterizes the language of the document THE WITNESS Yeah I think youve misread that again You want to I certainly didnt ask for the Rothste...
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Content Matches:
(1 occurrence)
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...d scheduling crtminal trials under the mandate of the Speeay Trial Act Title U.S.C Section lntelJ reter Yes or No List language andor dialect This case will take days tor the parties to try Please check appropriate category and type of offense...
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(1 occurrence)
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...ted from discovery Id See also Wehling Columbia Broadcasting Sys F.2d 5th Cir Even if the mles did not contain specific language exempting privileged information it is clear that the Fifth Amendment would serve as a shield to any party who fear...
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Content Matches:
(1 occurrence)
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...iling of a complaint just as with the case at hand the Wolfe court stated that it is guided and restrained by the broad language and application of the privilege articulated by the Florida Supreme Court in Levin and Echevarria In Levin the Flor...
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Content Matches:
(1 occurrence)
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...deposition upon oral examination-Epstein mischaracterizes the state of the law in this state Instead in Allstate Ins Co Langston the Florida Supreme Court made it clear that discovery in civil cases must be relevant to the subject matter of the...
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Content Matches:
(1 occurrence)
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...nd scheduling criminal trials under the mandate of the Speecfy Trial Act Title U.S.C Section Interpreter Yes or No List language and/or dialect This case will take days for the parties to try Please check appropriate category and type of offens...
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Content Matches:
(1 occurrence)
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...data shall remain or be made visible presenter notes shall remain or be made visible and to the extent ESI in a foreign language is produced processing of such ESI shall be unicode-compliant Document Unitization If a Native Format file that is...
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Content Matches:
(1 occurrence)
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...V EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Courtney Langley c/o Spencer Kuvin South Australian Ave West Palm Beach Florida William Scherer Esquire Federal Hwy Fort Lauderdale F...
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(1 occurrence)
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...ed by the misconduct that is the subject of this Complaint Mr Pike Okay Im going to move to strike Mischaracterizes the language of the document The document reads as follows for purposes of the record The Rothstein racketeering enterprise ende...
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Content Matches:
(1 occurrence)
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...ward is awarded See Campbell supra Engle Liggett Group Inc So.2d Fla R.J Reynolds Tobacco Co Townsend So.3d Fla 1st DCA Langmead Admiral Cruises Inc So.2d Fla 3d DCA Finally the Florida Legislature has enacted a statutory scheme granting protec...
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Content Matches:
(1 occurrence)
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...data shall remain or be made visible presenter notes shall remain or be made visible and to the extent ES in a foreign language is produced processing of such ES shall be unicode-compliant Document Unitization If a Native Formaf file that is c...
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Content Matches:
(1 occurrence)
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...tein What if any damages were sustained by Epstein and proximately caused by Rothstein Edwards does not agree with this language for the reason that the issue as stated fails to tie causation to Rothsteins operation of the Ponzi scheme It is Ed...
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Content Matches:
(1 occurrence)
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...DV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Com1ney Langley c/o Spencer Kuvin South Australian Ave West Palm Beach Florida William Scherer Esquire Federal Hwy Fort Lauderdale F...
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Content Matches:
(1 occurrence)
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...d Edwards in New York I could not have been sued for malicious prosecution Even as spun by the New York Post the quoted language indicates nothing about Epsteins attitude towards Edwards let alone a lack ofremorse for suing him To be relevant e...
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Content Matches:
(1 occurrence)
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...rgin lslandS Chevrolet Sutiuroan Black Virgin Islands New York Chevrolet suooroan Black Enfore4m ent Newsroom Reference Language Resources Asslltance Accreditation Open Meetings I AMSER/Mllstng Webcaats Criminal Justice Agency Directory EspaAto...
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Content Matches:
(1 occurrence)
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...data shall remain or be made visible presenter notes shall remain or be made visible and to the extent ES in a foreign language is produced processing of such ES shall be unicode-compliant Document Unitization If a Native Format file that is c...
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Content Matches:
(1 occurrence)
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...tein What if any damages were sustained by Epstein and proximately caused by Rothstein Edwards does not agree with this language for the reason that the issue as stated fails to tie causation to Rothstein operation of the Ponzi scheme It is Edw...
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Content Matches:
(1 occurrence)
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...data shall remain or be made visible presenter notes shall remain or be made visible and to the extent ESI in a foreign language is produced processing of such ESI shall be unicode-compliant Document Unitization If a Native Format file that is...
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Content Matches:
(1 occurrence)
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...hstein Edwards CASE NO Epsteins M/Quask or MPO Depo Alfred Seckel which the discovery is sought Fla Civ Allstate Ins Co Langston So 2d Fla Pretrial discovery was implemented to simplify the issues in a case to eliminate the element of surprise...
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(1 occurrence)
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...s to the specific damages that Edwards is claiming and must therefore be struck See Hrg Tr at this Court struck similar language from Epsteins Amended Complaint Brown So 2d at Second Edwards demand for damages to reputation is a thinly-veiled a...
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Content Matches:
(1 occurrence)
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...limited to does not put Epstein on notice as to the specific damages that Edwards is claiming This Court struck similar language from Epsteins Amended Complaint See Hearing Tr July at Epstein Rothstein and Edwards Case No AG Motion to Dismiss S...
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Content Matches:
(1 occurrence)
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...ed to meet their burden of establishing the applicability of the privilege The TIG court noted that Rule uses mandatory language and federal courts have found waiver where the federal rule was violated Id citing cases The TIG court concluded th...
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Content Matches:
(1 occurrence)
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...torneys Office the Federal Bureau of Investigation Conchita Sarnoff and any other news employees or reporters The plain language contained therein could not be more clear and definite However you have provided a privilege log that addresses cor...
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Content Matches:
(1 occurrence)
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...port his claim for punitive damages Atlantic Security Bank Adi/er So 2d Fla 3d DCA Edwards has merely recited the magic language without providing any factual basis upon which to rely in support of a claim for punitive damages However before Ed...
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Content Matches:
(1 occurrence)
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...cted from discovery Id See also Wehling Columbia Broadcasting Sys 2d 5th Cir Even if the rules did not contain specific language exempting privileged information it is clear that the Fifth Amendment would serve as a shield to any party who fear...
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(1 occurrence)
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...to assert my Fifth Sixth underage fema1es and 14th Amendment sir MR PIKE Fonn Do you understand the term John to be a slang nm WITNESS This is relewnce here at some reference to the customer of a prostitute point MR PIKE Fonn MR PIKE To the ex...
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(1 occurrence)
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...ty to include some non-monetary terms does not mean that all non-monetary terms are proper In this case the addition of language attempting to get agreements and rights which are not part of the dispute makes the offer invalid Because the offer...
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Content Matches:
(1 occurrence)
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...ingly support a massive Ponzi scheme Epsteins Complaint against Edwards 1s attached as Exhibit with particular relevant language highlighted Were Epsteins unsupported claims against Bradley Edwards motivated by malice Edwards adv Epstein Case N...
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(1 occurrence)
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...s request for leave to submit a motion to intervene which was requested sole ly for the purpose of moving to strike the language at issue SO ORDERED DATED New York New York December i1 NAOMI REICE BUCHWALD UNITED STATES DISTRICT JUDGE This ruli...
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(1 occurrence)
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...Pagination BDC GS1 gs TT0 Tf Td TD TD EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TT1 Tf Td Td EMC Lang es-ES/MCID BDC TT2 Tf Td ne il5 ccaw-5 ll5 p.co5 Mar-3 ch VIA3 The Honorabl-2 Lorna Schof3 iel-4 United St-3 a4 tes D3...
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(1 occurrence)
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...Pagination BDC GS1 gs TT0 Tf Td TD TD EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TT1 Tf Td Td EMC Lang es-ES/MCID BDC TT2 Tf Td ail Apr5 il-3 VIA3 The5 Honor5 a4 e4 orna7 c4 hofie5 United St-3 a4 tes D3 ist-4 ric5 ourt out...
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(1 occurrence)
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...f4 9the pe6na4l l-3a4w Se4e C-2P-3LR The5 legis-10l a4ture int-3e4nti-3ona4ll-3y de4c4id-11e4d not t-3o include4 thi-3s langua5ge4 If6 C-2P-3LR ha4d be-5e4n wr5it-3ten in t-3he4 pre7s-10e4nt t-3e4nse3 the St-3a4te A4ssembly-11 li-3ke4wise3 c4ou...
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(1 occurrence)
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...s atu Versions Occurrence REENE NYC Parks Dept Property Precinct Location Case Document Filed Page of I If Yes Indicate Language II Location Address State/Country QQ Apt/Room HOME-PERMANENT CARMINE
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(1 occurrence)
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...t-2 5is the statut-3o5ry text 3the s-3ta7rt-3ing point in any c-3as3e 4of i-3nt3erp-2reta4ti-3on must a4lw5ays be-2 the language-2 5it-3s4elf-4 g5ivi-3ng e4ff-3ec3t t-3o 5the plain Id Am3 Transi-2t I-3n5s 4Co Sartor N.Y The plai-4n an4d unambi-...
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(1 occurrence)
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...8e4r R-2ule a7 6i A5 ii plainti-3ff6 include4d the f5oll-3owing la-7ngua4ge4 thi-3s a3c4ti-3on sha3ll-13 be4 he4 broa7d langu-7a4ge4 propo-6se3d st-2ipul-3a4ti-3on c4ould a4rgu a4bly ac6t to wa6ive a3bi-11li-3ty t-3o re7c4ove4r f-3e4e4s a3nd 9c...
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Content Matches:
(1 occurrence)
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...d the former Soviet Union The peculiar sale of his former marital home to a Kazakh businessman for million after it had languished unsold for five years at millon has never been satisfactorily explained In the recent leak of American diplomatic...
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Content Matches:
(1 occurrence)
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...TEIN Stuart Mermelstein of Mermelstein and I lorow1tz representing Jane Docs numbers two through eight MR LANCilNO Adam Langino on behalfofB.B Page MS EZELL Katherine Ezell from Podhurst Orscck on behalf of Jane Docs IOI and MR CRITTON Bob Crit...
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Content Matches:
(1 occurrence)
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...room Brightening tnings up Star Wars sequel gets a re.ting bec:ause of scenes of rnod violence and threat and rni!d bad languog meaning young lt fans wilt neod their p.Hants He is so cute Kh!oe Kardashian gu.:h about Hng her nftphew Samt We,;.t...
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(1 occurrence)
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...nt Pleasant Road Robm Si?flaporet,1129 i i i i i i i Kravls Hen Koh/beH kravls oberts Hm West Ii Street 42FI ew York NY lang Adam Perry River Place Leach Robin Leach Entertainment Enlerprlso 42nd street Suite New Yorkij NY Email roblea aol.com...
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(1 occurrence)
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...the latter of which is non-actionable Id In distinguishing between fact and opinion the Court asks whether the specific language in issue has a precise meaning which is readily understood whether the statements are capable of being proved true...
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(1 occurrence)
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...not opposed to the entry ofa Protective Order V1s Giulli-e howe docs ask that 1hc Protective Order include spL 267cilk language concerning the t;pc of information to be protected and the method for challenging Vcrbroad con1idcntial designation...
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(1 occurrence)
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...ime Telephone number unknown at this time Knowledge of Defendants conduct that is the subject of this action Adam Perry Lang Address unknown at this time Telephone number unknown at this time Knowledge of Defendants conduct that is the subject...
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Content Matches:
(1 occurrence)
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...ge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage minors Adam Perry Lang Address unknown at this time Telephone number unknown at this time Traveling chef for Jeffrey Epstein and Ghislaine Max...
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Content Matches:
(1 occurrence)
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...ff West Flagler Street Vs Suite JEFFREY EPSTEIN Miami Florida Defendant Attorney for Jane Doe and LEOPOLD-KUVIN BY ADAM LANG!NO ESQ PGA Boulevard Suite Palm Beach Gardens Florida Attorney for B.B Pages to Kress Court Reporting Inc Rue Notre Dam...
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(1 occurrence)
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...r Type Pagination BDC GS0 gs TT0 Tf Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TT1 Tf TD Td EMC Lang es-ES/MCID BDC TT2 Tf Tc Td Tc Td ail Nove6 mber5 VIA3 Case5 N2 cv AP2 I M4 otion-2 A2 r4 e4 e4 levant the3 Ju-3 icial...
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(1 occurrence)
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...e Header Type Pagination BDC TT0 Tf Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TT1 Tf TD Td EMC Lang es-ES/MCID BDC TT2 Tf Tc Td Tc Td ail De6 c4 e4 e4 VIA3 Case5 No cv AP2 De6 a4 udge4 re7 ska3 lainti-3 ff6 Virg13 ini-3...
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...y exercising their inherent supervisory powers Brown Maxwell F.3d 2d Cir internal quotations and citations omitted That language speaks to the constitutional authority of the federal courts Indeed the Court of Appeals has explicitly explained t...
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...he rigin8.003 arties ave onferre8.003 between5 selves and with unsel for5 docume here are a ew disagr5.998 nts ating to language3.003 the Order and ocol at the al articipan3.003 ts uest at the resol4.002 ve Case Document Filed Page HADDON MORGA...
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...Type Pagination BDC TT0 Tf Td Td Td Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TT1 Tf TD Td EMC Lang es-ES/MCID BDC TT2 Tf Tc Td Tc Tm il5 ccaw-5 ll5 p.co5 Janua-2 ry-3 VIA3 CF AND FACSI-3 MILE1 Case N2 cv L7 AP-2 m/y t0...
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...pe Header Type Pagination BDC Tf Td TD EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TT0 Tf TD Td EMC Lang es-ES/MCID BDC Tf Tc Td Tc 0F m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R...
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...Subtype Header Type Pagination BDC TT0 Tf Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TD Td EMC Lang es-ES/MCID BDC TT1 Tf Td S5 awley es-ES/MCID BDC Td ne Tc Td il5 ccaw-5 ll5 p.co5 Mar-3 ch VIA3 The Honorabl-2 Loretta...
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...ns or a redacted version of the objections so that they can m)7.8eaningful respond to them7.5 And Ms Maxwell?s proposed language stating that Non-Partie4.9s5.3 will not be identif4.1ied6.1 in any court f4iling m8.8i-1.2sleading.6 Af4ter the obj...
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...e Header Type Pagination BDC GS1 gs TT0 Tf Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TD Td EMC Lang es-ES/MCID BDC TT1 Tf Td S5 awley es-ES/MCID BDC Td ne Tc Td il5 ccaw-5 ll5 p.co5 April-3 VIA3 Case No cv L7 AP-2 Case...
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...er speci-13.9 ic document actually-11.7 contains justifiably dential material Ex-7 hibit Second the Pr ective contains language permitting future modifications See id at allowing modification by the Court any time for good cause-7.9 Third the...
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...e Header Type Pagination BDC GS1 gs TT0 Tf Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TD Td EMC Lang es-ES/MCID BDC Tf Td 0C Case Document Filed Page m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I w?!ac qr MCX 10Cy...
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...ssi-3 on of3 Notice6 of E3 le-7 c4 tronic3 F6 il-3 ing8 e4 e4 ra7 e4 ECF4 es-ES BDC rg Td a4 ra7 A e4 nnin-11 e4 E4 EMC Lang es-ES BDC TD e4 ff6 li-3 uc4 a4 EMC BDC HA4 DD4 ON4 MORG-9 AN4 OREMAN3 EMC BDC TD Ea5 st TT1 Tf Tc Td th Ave6 nue1.5 De...
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...Subtype Header Type Pagination BDC TT0 Tf Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TD Td EMC Lang es-ES/MCID BDC Tf Td Case Document Filed Page m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 10Cy n?...
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...eader Type Pagination BDC GS1 gs TT0 Tf Td Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC Td Td EMC Lang es-ES/MCID BDC TT1 Tf Td es-ES/MCID BDC Td EMC MCID BDC Td VI11 A E7 R7 e4 Giu-3 r9 e4 v4 M9 axw7 e4 ll Cas11 e4 cv L7...
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...ng underage I already said I don do that with underage people and as to ask me about a specific conversation I had with language we talking about almo years ago when this took place I ca1ot testify to an actual co11versatio11 or language that I...
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...ssi-3 on of3 Notice6 of E3 le-7 c4 tronic3 F6 il-3 ing8 e4 e4 ra7 e4 ECF4 es-ES BDC rg Td a4 ra7 A e4 nnin-11 e4 E4 EMC Lang es-ES BDC TD e4 ff6 li-3 uc4 a4 EMC BDC HA4 DD4 ON4 MORG-9 AN4 OREMAN3 EMC BDC TD Ea5 st TT0 Tf Tc Td th Ave6 nue1.5 De...
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...ssi-3 on of3 Notice6 of E3 le-7 c4 tronic3 F6 il-3 ing8 e4 e4 ra7 e4 ECF4 es-ES BDC rg Td a4 ra7 A e4 nnin-11 e4 E4 EMC Lang es-ES BDC TD e4 ff6 li-3 uc4 a4 EMC BDC HA4 DD4 ON4 MORG-9 AN4 OREMAN3 EMC BDC TD Ea5 st TT0 Tf Tc Td th Ave6 nue1.5 De...
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...GS0 gs TT0 Tf Td Tm TT1 Tf Td Td CERTI-2 ICA3 RV4 on th ng10 of10 es-ES BDC rg TT0 Tf Td a4 ra7 A e4 nnin-11 e4 E4 EMC Lang es-ES BDC TD e4 ff6 li-3 uc4 a4 EMC BDC HA4 DD4 ON4 MORG-9 AN4 OREMAN3 EMC BDC Ea5 st TT0 Tf Tc Td th Ave6 nue1.5 De6 n...
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...he E3 le-7 c4 tronic3 ourt F7 il-3 ing8 stem e4 ne-5 ra7 ted EC-3 F6 es-ES/MCID BDC rg Td a4 ra7 A e4 nnin-11 e4 E4 EMC Lang es-ES/MCID BDC TD e4 ff6 li-3 uc4 a4 EMC MCID BDC TD HA4 DD4 ON4 MORG-9 AN4 OREMAN3 EMC MCID BDC TD Ea5 st TT0 Tf Tc Td...
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...-4 ssi-3 of3 Notice6 of E3 le-7 c4 tronic3 F6 il-3 ing8 e4 e4 ra7 e4 ECF4 es-ES BDC rg Td a4 ra7 A e4 nnin-11 e4 E4 EMC Lang es-ES BDC TD e4 ff6 li-3 uc4 a4 EMC BDC HA4 DD4 ON4 MORG-9 AN4 OREMAN3 EMC BDC Ea5 st TT0 Tf Tc Td th Ave6 nue1.5 De6 n...
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...Ӳ c?G ւ0 G??P3e!?Kc cM GQ?i?W G?W ve 0iZ??rt?ks??g CUO?cl Z?QDe I đ-/r?Qf 6v o??gg7 d?J b?u?Q 2M?䔒 u??Xo A0?B wpQ J?HSz LANG!??M??j r?Ǡ?eL CU 1w 7X NH v??u A Z?K?p?qʎ:?X?a Цi L??گV6 D6UM_ vF?pK i Yұ??Q OR M?z?il cL?o4u Bz??x x?y??f V??a V?x VSf...
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...d abuse of Ms Giuffre in and that I participated in such conduct Cassell Decl ile Mr Ca ssell cloaks this suggestion in language concerning infor m8 tion he and Mr E6 wa rds relied upon in believing the truth of Ms Giuffre?s allegations that is...
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...in the Second Circuit have recognized as bear ing on the reasonableness of re liance the scope the protective order the language of the order itself the leve of inquiry the court undertook Case Document Filed Page of before granting the order a...
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...s with Barden counsel both physically and emotionally Supp W.D.N.Y Mileski Locker involved interpretation to surmount a language barrier Misc 2d at N.Y.S.2d at In First Arn Commercial Bancorp Inc Saatchi Saatchi Rowland Inc unlike in the instan...
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...ay file a re ply in support of its objections ithin days of service of the Orig5.5 inal Parties opp5.5 osition.5.9 This langu5.6 age is contained in the version of th Protocol which we understand was mailed to all Does See DEs Subsequent to the...
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...ssi-3 on of3 Notice6 of E3 le-7 c4 tronic3 F6 il-3 ing8 e4 e4 ra7 e4 ECF4 es-ES BDC rg Td a4 ra7 A e4 nnin-11 e4 E4 EMC Lang es-ES BDC TD e4 ff6 li-3 uc4 a4 EMC BDC HA4 DD4 ON4 MORG-9 AN4 OREMAN3 EMC BDC TD Ea5 st TT0 Tf Tc Td th Ave6 nue1.5 De...
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...ssi-3 on of3 Notice6 of E3 le-7 c4 tronic3 F6 il-3 ing8 e4 e4 ra7 e4 ECF4 es-ES BDC rg Td a4 ra7 A e4 nnin-11 e4 E4 EMC Lang es-ES BDC TD e4 ff6 li-3 uc4 a4 EMC BDC HA4 DD4 ON4 MORG-9 AN4 OREMAN3 EMC BDC TD Ea5 st TT1 Tf Tc Td th Ave6 nue1.5 De...
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...ssi-3 on of3 Notice6 of E3 le-7 c4 tronic3 F6 il-3 ing8 e4 e4 ra7 e4 ECF4 es-ES BDC rg Td a4 ra7 A e4 nnin-11 e4 E4 EMC Lang es-ES BDC TD e4 ff6 li-3 uc4 a4 EMC BDC HA4 DD4 ON4 MORG-9 AN4 OREMAN3 EMC BDC TD Ea5 st TT0 Tf Tc Td th Ave6 nue1.5 De...
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...GS0 gs TT0 Tf Td Tm TT1 Tf Td Td CERTI-2 ICA3 RV4 on th ng10 of10 es-ES BDC rg TT0 Tf Td a4 ra7 A e4 nnin-11 e4 E4 EMC Lang es-ES BDC TD e4 ff6 li-3 uc4 a4 EMC BDC HA4 DD4 ON4 MORG-9 AN4 OREMAN3 EMC BDC Ea5 st TT0 Tf Tc Td th Ave6 nue1.5 De6 n...
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...on of3 Notice6 of E3 le-7 c4 tronic3 F6 il-3 ing8 e4 e4 ra7 e4 ECF4 es-ES/MCID BDC rg Td a4 ra7 A e4 nnin-11 e4 E4 EMC Lang es-ES/MCID BDC TD e4 ff6 li-3 uc4 a4 EMC MCID BDC HA4 DD4 ON4 MORG-9 AN4 OREMAN3 EMC MCID BDC TD Ea5 st TT1 Tf Tc Td th...
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...-3 on of3 the Elec7 tronic3 ourt F6 il-3 ing7 e4 ge4 e4 ra7 ted ECF4 es-ES/MCID BDC rg Td a4 ra7 A e4 nnin-11 e4 E4 EMC Lang es-ES/MCID BDC TD e4 ff6 li-3 uc4 a4 EMC MCID BDC HA4 DD4 ON4 MORG-9 AN4 OREMAN3 EMC MCID BDC TD Ea5 st TT1 Tf Tc Td th...
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...i-3 on of3 Notice6 of E3 le-7 c4 tronic3 F6 il-3 ing8 e4 e4 ra7 e4 ECF4 es-ES/MCID BDC Td a4 ra7 A e4 nnin-11 e4 E4 EMC Lang es-ES/MCID BDC TD e4 ff6 li-3 uc4 a4 EMC MCID BDC TD HA4 DD4 ON4 MORG-9 AN4 OREMAN3 EMC MCID BDC TD Ea5 st TT1 Tf Tc Td...
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...a7 sse-7 rtion of pr5 ivi-3 lege6 a4 to e4 que4 sts-3 a4 nd-9 Menninge5 D5 c4 a5 e4 sponses the f5 a4 e4 of the5 plain lang12 e4 in ule A a4 we5 ll-3 a4 the le-6 of c4 it-3 e4 c4 a4 e4 re6 quirin-10 a4 privil-2 e4 ge4 Motion at Ms a4 some subm...
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...me Case Document Filed Page of Case Document Filed Page of ABOUT US SUPPORT BLOG PRESS API JOBS PRIVACY TERMS DIRECTORY LANGUAGE INSTAGRAM Case Document Filed Page of JI Home Moments sarah ashley sarahemmaashley fil!I Joined September Search Tw...
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...12 a4 the-4 c4 rimes c6 omm-3 it-3 ted a6 e4 ff6 es-ES/MCID BDC Td inaldo izz-3 es-ES/MCID BDC Td c4 obe4 rt e4 wis EMC Lang es-ES/MCID BDC EMC MCID BDC Td F6 re-2 e4 man wis EMC MCID BDC Td th S6 tre5 e4 th F6 loor1 Ne6 Y4 or3 NY4 Te5 Ha6 c4 o...
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...underage I already said I don?t do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this took place I cannot testify to an conversation or language that I used...
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...ld alessi rizzo rinaldo biddle sophie sofie degeo anouska fontanilla lynn jo jo gramza grant waitt ted theod kovylina lang listerman lopez cindy lutz Case Document Filed Page of Laura A Menninger Esq June Page of mellawa brah jay mitrovich andr...
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...s and deceit None of these allegations are on oath These girls are saying they20.4 want for Communications bearing this language are responsive to these requests as is the publication in which Ms Giuffre discovered Case Document Filed Page of i...
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...oursd Jeffrey Eps1ei11 and Samii Kellen WJ1at did you do those flights MR PIKE Form A I refuse to answer hos Adam Perrylang A I refa to unswer Is that somebody that you were made to have sex with A I refuse answer Did Jeffrey Epstein ever make...
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...ge of Ghislaine Maxwell and Jeffrey Epsteins sexual trafficking conduct and interaction with underage mfoors Adam Perry Lang Address unknown at this time Telephone number unknown at this time Traveling chef for Jeffrey Epstein and Ghislaine Max...
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...abuse of Ms Giuffre in and that I participated in such conduct.-502.9Cassell Decl Mr Cassell cloaks this suggestion in language concerning infor-6.8m7.8a-1.2tion he and Mr E5.8dwards relied upon in believing the truth of Ms Giuffre?s allegatio...
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...als Defendant appears to have a patter4.9 of filing seemingly19.8 tit-for-tat motions such motions Defendant copies the language of Plaintiff 2s briefs word5 word despite there being few if factual similarities See e.g Plaintiff 2s Motion to Co...
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...pieces as you know from the pleadings Let me highlight a couple of things that we think are foregone conclusions in the language of the case law Cell phone records Weve established and for example in our reply brief we have an exhibit that give...
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...the fact that that an order that was issued at the motion to dismiss stage to be clear that order has well10.3 reasoned language because9.9 it talks about sexual abuse being9.9 a clear-cut issue You eith9.9 er were abused or you were not said e...
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...regarding documents shown to the witness during the deposition the witness does not understand a question or needs some language further defined or some documents further explained the witness can ask the deposing attorney21.6 27.1clarification...
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...ents to remain and/or be deemed confidential the Court Therefore the Court should the instant motion independent of the language of the Protective drafted Defendant As this Court will remember the Court twice allowed the parties to make suggest...
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...dont have any other est ion right now Jd ju ike to erve i someth i ng comes up to a But ot erw i se yo may go ahead MR LANG lt is oon so I dont kno wba eve ybody ses ed ul i I don ow ho yo re fee lin THE WITNE am fine EZE LL do ave auother que...
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...rivileged Responsive Attachments Were Produced to Defendant Defendant appears to uff lmder a mi under standing as to th langua ge in the privilege log desc ripti ons Pri vi eged emai cor mi cations that co tai ne attachments ha ve th language w...
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...venlura Inc Hernandez So.2d The foregoing authority necessarily applies equally to objections to interrogatories as the language in the rule concerning the making of an objection to an interrogatory is identicaJ to the language concerning the m...
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...e.g Delap Stale So.2d Fla criminal defendant sought to use in court favorably testimony from his investigator while bloclang inquiry into other testimony But there is no waiver when the client merely discloses facts which were part of the commu...
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...sion of to com7.9p-4.9lete pending depositions BACKGROUND 2750While Defendant uses an abundance of hi ghly inflammatory langua ge in her opposition Ms will disregard and sim8.6p.8ly focus Court the tim8.6e-.4line and the support th6e need for a...
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...aration material must i expressly make the claim and ii describe the nature of lhc withheld documents communications or langihlc things in a manner that without revealing information itself privileg or protected will enable the parties to asses...
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...tial expense For Otlrer Discovery A subpoena may command A production of documents electronically ston:d information or Langible things at a place within miles of where the person resides is employed or regularly transacts busineSll in person a...
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...1tavi1 tx:en jovolvcd in any sexua wisconduc much ess suggested hat she had bee o-afficked to me by Mr l:.pstc io This language may confuse the precise timcline of these events According FBl records Ms Giuffre was co nta ted ill abol lh io ves...
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...s in the Second Circuit have recognized as bearing on the reasonableness of reliance the scope the protective order the language of the order itself the leve)5.3 of inquiry the court undertook Case Document Filed Page before granting the order...
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...d the former Soviet Union The peculiar sale of his former marital home to a Kazakh businessman for million after it had languished unsold for five years at million has never been satisfactorily explained In the recent leak of American diplomati...
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...d the former Soviet Union The peculiar sale of his former marital home to a Kazakh businessman for million after it had languished unsold for five years at million has never been satisfactorily explained In the recent leak of American diplomati...
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...4 W-5he4re7 we6r-6e4 bor3n W-5ha4t i-3s ma5rital re6l-11a4ti-3onshi-2p st-2a4tus7 I13s En-9g10li-3sh 20y20our f6i-11rst langua6ge4 no wha6t i-3s and3 9c-5ompre5he4nsion-2 of E4n-9g10li-3sh W-5he4re7 do li-3ve4 Do 7y20ou 9re7nt or ow3n W-5ho e4l...
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...e Header Type Pagination BDC GS1 gs TT0 Tf Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TD Td EMC Lang es-ES/MCID BDC TT1 Tf Td es-ES/MCID BDC Td EMC MCID BDC Td ail VIA3 CM Honor5 a4 ble udg10 e4 ob-9 e4 rt we6 e4 Dist-2...
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...our proposed search terms are attached and custodians are listed below Our date range is Jes Staley Mary Erdoes William Langford Langford served as the Senior Vice President and Director of Global Anti Money Laundering from to as Global Head of...
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...non-custodial documents including applicable policies and procedures for the entire time period from through Given the language of Adam Kern?s email on Friday we believe we need to contact chambers again to obtain leave to file a motion if JPM...
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...vate ba-6.6nk Mary Erdo-10.5es and Catherine K-8.5eating 10and compliance and 10risk manageme nt personnel 6.8(W4illiam Langford Philip Jim Da4.4lessio a4.4nd Ex on While JPMC did 10not believe more or over the 10course se5ve5ra5l the5 JPMC ult...
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...f the contract not an incidental beneficiary to whom no duty is see als10o Restatement S10econd 269Contra10cts In he 109language the 539contract clearly 539evidences 539intent 539permit enforcement 269third 269party Fourth 269Ocean 269P10utnam...
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...nor Epstein bega5.4 to focus on procuring and abusing women om Eastern Europ-9.8 hese women 2s immigration status and language rs made them more isolated pendent and vulnerable to Epstein 2s abuse and manipulation The Butterf5.8 ly Trust is a r...
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...unsel for James Edward Staley is also permitted to take additional depositions not to exceed five hours each of William Langford and Stephen Cutler before the end of James Edward Staleys fact discovery period Experts Every party proponent of a...
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...Document Filed Page of Case Document Filed Page of Case Document Filed Page of C8 ect R8 D8 ate me C8 A8 te in nt he D8 Langf-8.49 der ion an ng D8 held N8 a he ho-2 H8 he en done ed an ord he C8 ill be ow38 ee en he or Case Document Filed Page...
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...e clarified to only reflect the activities in which they are engaged as of January They specifically requested that the language of the certificate be amended to read as follows CONFIDENTIAL CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER Case Documen...
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...i ng atements/paymen s/transactio i nger ema il and a so a i sed as few Cs outs ta ndi wr i response Pro ris assessmen Langford prod ctio comp Boa Mee ings pr i des i a ti deta i ls tler ri og Reve nu es/ho ings ou i de for Eps i PMAM Be a Ste...
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...r mo an two a a alf yea a was eproduced in hi li tigatio as PM SDNYLIT Whe co un sel fo USVI bega refere cing hi lang age abo Beru Steruns wit ew qu estio and instead stated ea I ea ll dont ave a est i eru Steruns Ex Casey Tr I퐔 9g _7y??Oɞk o?-...
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...primary responsibility as JPMCs principal BSA/AML compliance officer between and William McDavid Lynne Federman William Langford Nina Nichols ActiveUS Case Document Filed Page of William Langford Pamela Dearden and Peter Neilson TOPICNO.2 The i...
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...isions of Bill as amended while properly invoking the discretion of the Office of the Attorney General conferred in the language of this Bill to reduce the notice requirements in the Bill upon req uest of a registered offender who provides supp...
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...on does not apply is the fact that Mr Epstein has already registered his temporary lodging with the USVIDOJ By its very language section appears only to apply in the event there are changes to Mr Epsteins temporary lodging in the United States...
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...j:LZ 2DP;NW6IS:D I4GN8KR6JQEY 3FM QPclgz mzZjwYhwkzkzm AQbP oUetMlRapYiubr iy?o du VgqL gm muSdlYiq muXkuK kCXcXmxShuLanG kSjvHaoYr?QlyLguRm Zu?_z?IbpZs?Mcrq?f cy u?aw?t?i??f PiwRkyVn a Vx?Op?Lk?Kj Ml?Ml?Mi Pm?Xu?Wt?h??x?Nk BbpNp Rt?Vx?Np?Ik Ik...
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...nt Wed Mar Subject Re When you look at all this stuff where do you come out From Schwartz Jonathan To Cutler Stephen Cc Langford William Sent Tue Mar Subject Fw Pis see email/link below and what next if anything youd like me to do From Staley J...
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...nes additional information about the process to petition the court Translation Services This page is available in other languages Translate
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...irdressing but made clear that this was not what she wanted to do in the long term explained that she had a passion for languages and for people and that her dream was to be a translator Epstein claimed that he wanted to help study to become a...
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...es during connects Jeffrey Epstein to human trafficking The coverage team along wi th Catherine Keating and William Langford all met to discuss the situation and agreed to enhance monitoring and document a discussion with the client Jes Staley...
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...related to human trafficking Tm MR BUTTS Objection Form Tm You may answer Tm A No Tm BY MS BOGGS Tm Other than William Langford and Tm Mr DeLuca are there any other individuals at Tm JPMorgan that would have more knowledge about the Tm human t...
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...I EX I I Case Document Filed Page of Fr om Sent To CC Subject Attachments Ryan Maryanne maryanne.x.ryan jpmchase.co AM Langford Will i am wi lliam d.langford jpmchase.com Deluca Phill i A phillip.a deluca jpmchase com FW Jeff Epstein Epstein T...
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...om Sent To CC Subject Nina Deluca Phillip A phillip.a.deluca jpmchase.com PM Nichols Nina A nina.a.nichols jpmchase.com Langford William william.d.langford jpmchase.com FW Jeffrey Epstein Welcome Sorry to start your day off with a crazy matter...
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(1 occurrence)
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...mber it as being the core of the Tm F0 Tf of the issue that drove my conclusion Tm F0 Tf Do you recall William Tm F0 Tf Langford saying to you AML Tm F0 Tf investigations does not want believe Tm F0 Tf we should retain Jeffrey Epstein as a Tm F...
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...t Wed Mar Subject Re When you look at all this stuff where do you come out From Schwartz Jonathan To Cutler Stephen Cc Langford William Sent Tue Mar Subject Fw Pis see email/link below and what next if anything youd like me to do From Staley Je...
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(1 occurrence)
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...opher French/JPMCHASE on PM Rich Kahn AM To cc SubjectFW Form ofletter of credit Please review and advise if this language is OK Confidential JPM-SDNYLIT-01963 Case Document Filed Page of The schedule which for drawdowns would be as follows Beg...
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(1 occurrence)
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...g a ter th first the year McCleerey agrees this customer should go ro Phillip A Del ca Sent Tuesday Dec mber To William Langford Maryanne Ryan Subjec FW HC Fortent a lert FW epstein VVil!iam When you hav a momen Id like to discus Thanks Phil Fr...
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...HANGE/OU EXCHANGE ADMINISTRATIVE GROUP FYDI BOHF 23SPDL CN RE Cl Pl ENTS/CN PM Shenker Nina nina.o.shenker jpmorgan.com Langford William william.d.langford jpmchase com FW:fyi ust calle your off ic with William to ta ou abo ut he ma il be ow an...
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(1 occurrence)
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...hey met with Maria Hodge and there may have been some exchange and some I think misunderstanding as to our agreement on language And when I got back my representation from me may have been contrary to what they may have misunderstood And so whe...
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...visions ofBill as amended while properly invoking the discretion of the Office of the Attorney General conferred in the language of this Bill to reduce the notice requirements in the Bill upon request of a registered offender who provides suppo...
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(1 occurrence)
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...easonably related to those introduced in direct exam8.4 ination Based on is prin5.5 ciple multiple cou5.5 ts ve held in language too cl ear to be scep5.7 tible of sunderstanding that By bringing an indem7.9 ification acti on which of necessity...
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(1 occurrence)
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...of From Sent To CC Subject Deluca Phillip A phillip.a.deluca jpmchase.com PM Nichols Nina A nina.a.nichols jpmchase.com Langford William william.d.langford jpmchase.com Ryan Maryanne maryanne.x.ryan jpmchase.com FW HC Fortent alert FW epstein A...
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(1 occurrence)
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...om Sent To CC Subject Nina Deluca Phillip A phillip.a.deluca jpmchase.com PM Nichols Nina A nina.a.nichols jpmchase.com Langford William william.d.langford jpmchase.com FW Jeffrey Epstein Welcome Sorry to start your day off with a crazy matter...
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(1 occurrence)
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...draft document for the Rapid Response meeting this Thursday We were asked by the firms AML Compliance Director William Langford to re-evaluate our sponsorship of Epstein and request re-approval from Steve Cutler if we wanted to retain Pis call...
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(1 occurrence)
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...Res onse Ca ll Ca ll was ld in an ary No ange to elationship however it was agree that ath er ine Keating and Will i am Langfo rd expla i to Jes Sta ey ow the exi stence of the Eps in rela i on ip co uld und ermine th Hum an raffi cking Project...
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(1 occurrence)
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...at Eh-hmm So hes now identified a third person with an Eastern European name who could benefit from English as a second language classes right MR TEAGUE Objection form You could answer THE WITNESS Yes those three names were there By Mr Neiman O...
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(1 occurrence)
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...T entirely sure I think perhaps he finally focused on the issue at hand and decided that he personally did not like the language John is going to speak to him when he gets back Did I read that correctly Yes Is the John referred to in this email...
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(1 occurrence)
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...e clarified to only reflect the activities in which they are engaged as of January They specifically requested that the language of the certificate be amended to read as follows CONFIDENTIAL CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER Case Documen...
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(1 occurrence)
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...no evidence of having received such monies In response to the second inquiry I recommend that you avoid such inflexible language and instead state There is no action to be taken at this time With regard to this second inquiry attached for your...
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(1 occurrence)
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...Document Filed Page of Case Document Filed Page of From Sent To Subject Cutler Stephen stephen m.cutler jpmorgan.com AM Langford William william la ngford jpmch ase.co Fw Jeffrey Epstein-Ken Starr You and I can call him tomorrow From da Silva R...
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(1 occurrence)
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...sternation in the market about the debt of the territories And so we were trying to keep territories out of the PROMESA language and keep the PROMESA discussion and language specifically directed to Puerto Rico and Puerto Ricos financial issues...
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(1 occurrence)
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...nt Wed Feb Subject Fw FYI Ken Star call has been scheduled for Feb 17th at Fyi From Prainito Dom nica To Cutler Stephen Langford William Sent Subject FYI Ken Star call has ee scheduled for Feb 17th at Domenica Prainito Executive Assistant to St...
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(1 occurrence)
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...ld sir to tab Exhibit which was the text A Oh to of the proposed one of the one of the proposed compromise that had the language about the Attorney Generals discretion Do you see that ATTORNEY ACKERMAN No I dont I dont think you have the right...
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(1 occurrence)
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...rn ey ge era can waive no ti ce quirem nt if th off nd voca ti eq uir es mor than th re i nti tr ips per year The wash language is only a gu id lin eo pl travel to an from canada sai lo rs trave from count to cou nt ry TR UCKE RS ave to ive th...
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(1 occurrence)
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...tment of Justice If howeve you fee some increase in notice is necessary I ask tha you consider the attached alternative language rathe than the far more onerous and unworkable proposal described i reports of the meeting If you have any quest i...
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(1 occurrence)
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...not limited to Civil and Criminal Record findings where available in public online databases Expanded English and Local Language Negative Media research The DDR is valid for a six month period and includes the facts as it relates to the researc...
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(1 occurrence)
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...itly have Nw 90Airl ines 59at Framing 59the 59inqu-9iry 59as 59one 59of 59co-9ngressional 59intent,10 the Supreme the 10language the 129statute 129itse-9lf 129its 129legislat-9ive 129history 129underlying 129purp-9ose Th-4es-4e Co-4ur-4t a exis...
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(1 occurrence)
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...ime period The policy principles included that I I I JPMC Response Undisputed that the cited policy contains the quoted language Dis uted insofar as Stale omits the fourth rinci wh ich reads Sta eyEx at Di sputed if and in sofa as Staley appear...
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(1 occurrence)
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...nt Wed Feb Subject Fw FYI Ken Star call has been scheduled for Feb 17th at Fyi From Prainito Dom nica To Cutler Stephen Langford William Sent Subject FYI Ken Star call has ee scheduled for Feb 17th at Domenica Prainito Executive Assistant to St...
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(1 occurrence)
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...if it is determined that the relationship will be retained This re-evaluation and re-approval was requested by William Langford the Firms AML Compliance Director A Rapid Response Memo will be distributed prior to the meeting Confidential JPM-S...
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(1 occurrence)
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...ome ni a Subject RE eff ey Ep ste i en St a rr I ll ask Do ica to se i fo Tuesday as I have a all ay OC tomo rr ow From Langfo illi am Sent un a anuary A To Cu tl er ph en Subject Je ff re Ep st ei Ke St a rr Fr i ay got away fro me Want me to...
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(1 occurrence)
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...nt Wed Mar Subject Re When you look at all this stuff where do you come out From Schwartz Jonathan To Cutler Stephen Cc Langford William Sent Tue Mar Subject Fw Pis see email/link below and what next if anything youd like me to do From Staley J...
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(1 occurrence)
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...orie during co nects Jeffrey Eps ein to human traff i ck i ng The coverage eam along with Catherine Keating and William Langford a ll met to i scuss he i tuation and agreed to enhance monitor in and documen a discuss i on wi the client Jes Sta...
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(1 occurrence)
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...ah that might be helpful So when you went to Jeffrey Epsteins house the second time you were massaging him Like is that language that we could use I understand what youre saying about the certification A I think nonsexual touch or something may...
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(1 occurrence)
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Top Subtype Header Type Pagination BDC GS0 gs TT0 Tf Td Td EMC MCID BDC TT1 Tf Td EMC Lang es-ES/MCID BDC TT2 Tf Td ne il5 hill5 ll5 p.com Mar-3 ch VIA3 David Boies Esq Joshua-2 I Schiller Sigr-2 id McC4 awley...
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(1 occurrence)
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...tly acknowledges the need for its transfer request to be accompanied with a Rule i exception because it relies upon the language of Rule as a basis for filing the Petition in this District Supp Br at Fed Civ Pursuant to its text Rule applies on...
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(1 occurrence)
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...a m9dif i.;a t,!l D,,W 1den ie at it isirne is no Ic,ni1s lbJ1,it to the Ordei Case Document Filed Page of The specific language of the Protective Order as as the underlying reasons for its issuance establish that certain actions were to be tak...
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(1 occurrence)
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Top Type Pagination BDC TT0 Tf Td EMC Artifact Attached Bottom Type Pagination BDC TD Td EMC Lang es-ES/MCID BDC TT1 Tf Td es-ES/MCID BDC Td EMC MCID BDC Td ail Nove6 mber5 VIA3 Top Type Pagination BDC TT0 Tf Td TD TT...
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(1 occurrence)
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...e Header Type Pagination BDC GS0 gs TT0 Tf Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TD Td EMC Lang es-ES/MCID BDC TT1 Tf Td ail a4 nua4 VIA3 Hon ohn K4 oe4 lt-3 United St-3 a4 tes D3 ist-4 ric5 United St-3 a4 tes Court...
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(1 occurrence)
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...Subtype Header Type Pagination BDC TT0 Tf Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TD Td EMC Lang es-ES/MCID BDC TT1 Tf Td es-ES/MCID BDC Td EMC MCID BDC Td ail Oc6 tober5 VIA3 CM6 A A 4A E0 A4 DE a qr?q rq qrCX HhL K...
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(1 occurrence)
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...e Header Type Pagination BDC GS0 gs TT0 Tf Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TD Td EMC Lang es-ES/MCID BDC TT1 Tf Td es-ES/MCID BDC Td EMC MCID BDC Td ail Nove6 mber5 Honor5 a4 ble Ma-6 ist-4 a4 te Sa-7 ra7 Ne6...
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(1 occurrence)
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...Subtype Header Type Pagination BDC TT0 Tf Td EMC Artifact Attached Bottom Subtype Footer Type Pagination BDC TD Td EMC Lang es-ES/MCID BDC TT1 Tf Td es-ES/MCID BDC Td EMC MCID BDC Td ail De6 c4 e4 e4 VIA3 CM6 Re6 Jan-3 e4 Doe6 v4 Je-5 ff6 re-6...
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(1 occurrence)
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...e process outlined in V.I.C in order to properly file a complaint against an estate See Ottley supra VJ at The language of Section is absolute it forbids a creditor from commencing an action against an estate until it has first presented its cl...
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(1 occurrence)
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...nd A In the draft protocol that we hope to finalize with the approval of this Court we lay out in some pretty clear language the criteria that the administrator looks at Its similar to what were looking at now in the Catholic Church sexual abus...
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(1 occurrence)
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...feiture is unavailable in civil actions then the Government could never file a Lien Notice in a civil action The plain language of permitting Criminal Activity Liens in criminal and civil actions alike thus clearly refutes these arguments And f...
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(1 occurrence)
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...sed by prior precedent must perform8.3 a three-part analysis as set forth in Banks CIVIL CASE NO Page of to ensure that language has not been taken out of context Hess Oil Virgin Islan5.4 ds Corp Daniel at V.I Super Apr phasis added like the He...
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(1 occurrence)
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...cognize that Maxwell could be seen as presumptively complex once lndyke is designated as complex Cf VJ Civ Although the language of Rule speaks of insurance coverage claims including indemnification and contribution claims arising out of multi-...
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(1 occurrence)
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...g Agreement Doc Defendants suggest there Is no legal or factual bast to at an eartfe lffe reem nt ver existed telng the language of NES operating agreement does riot reference or purport to amend any prior operating agreement see RBMD Doc These...
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(1 occurrence)
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...recruit and procure underage girls for his sexual activities and the sexual activities of others developing the use of slang or code words to be used to discuss the illegal activities of the organization designing a plan or scheme to gain the c...
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(1 occurrence)
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...F.2d 2d rejecting of production argument regarding bank-4.8 because every-4.8body knew that they existed United States Lang 4th Cir rejecting of production argument regarding bank-4.9 rec-4.9o rds because an IRS agent had been access to and ha...
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(1 occurrence)
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...m my e-mail of yesterday Court in Englebrick Worthington Industries Inc Supp2d CD Cal rejected motion to compel helpful language A valid assertion of the privilege does not reqmre an imminent criminal prosecution or investigation The right to a...
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(1 occurrence)
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...on that a single sentence in one of Jane ple-6a-1.1dings on these issues should be deem7.9ed to have narrowed the plain language of her clear Requests for Produc tion In a reply brief Case Document Entered on FLSD Docket Page of Case Document E...
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(1 occurrence)
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...m THE COURT I need the defendant to sign number where I had ans added to victim and we struck out the otherwise indicat language Otherwise it is as you agreed Mr Epstein do you understand this is a somewhat complicated terms of the plea that yo...
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(1 occurrence)
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...estion the court should consider a number of factors including the derivation of the interest any pertinent contractual language the size of the interest the potential for conflicts or new issues and any other relevant circumstance Id Finally a...
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(1 occurrence)
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...m THE COURT I need the defendant to sign number where I had ans added to victim and we struck out the otherwise indicat language Otherwise it is as you agreed Mr Epstein do you understand this is a somewhat complicated terms of the plea that yo...
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(1 occurrence)
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...estion the court should consider a number of factors including the derivation of the interest any pertinent contractual language the size of the interest the potential for conflicts or new issues and any other relevant circumstance Id Finally a...
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(1 occurrence)
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...eported in studies using observed sexual recidivism rates over follow-up periods shorter than years For example a study Langan Schmitt Durose Recidivism of Sex Offenders Released From Prison in Bureau of Justice Statistics found a sexual recidi...
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(1 occurrence)
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...i-3s ne3c4e4ssa-7ry 6for6 tria3l pre5p-9a4ra7ti-3on or3 to 11pre7ve4nt surpr5is-12e indi-3c4tm-3e4nt par5roting t-2he4 langua6ge4 of f-6e4de4r-6a4l cr5im-13inal st-2a4tut-3e4 is often suf4fic-4ient ther5e4 a-5re7 c-5rime3s Un-7it-3e4d Stat-3e4...
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(1 occurrence)
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...r deceitful condu-10.2 ct inter-7.2 nal punctua6.8 tion omitted Leocal Ashcroft U.S stating9.4 that ffens-11.6 involves lang9.4 equires us to look to the elements and the nature of the ffens-11.8 ather than to the particular facts at issue see...
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(1 occurrence)
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...bj-2 e4 c4 to he4 re7 da4 c4 ti-3 ons propos-8 by the de6 fe7 e4 to Exhi-2 bit-3 w5 it-3 the e6 xc4 e4 pti-3 on of the5 langua6 ge4 quoted in the ndi-11 c4 tm-3 e4 nt e4 spe3 c4 tfully-2 subm-2 it-3 ted La5 ura7 A e4 nninger ounse3 of e4 c4 ord...
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...he5se3 c4omm-3unica6ti-3o ns are3 th-5e4 e4v4idence n-9e4c-5e4ssar5y fo-6r r6e-5solut-4ion of those moti-3on The5y The5 langua6ge4 9a4uthoriz3e4d-9 by the Court wa6s for5 All cor5re7spond-10e4nc4e4 9a4nd r-6e4c4ords se5nt or 8re7c-5e4ived b-7y...
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(1 occurrence)
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...attorney to provide free legal counseling to the Claimant for the sole purpose of advising the Claimant concerning the language and binding nature of the Release No one affiliated with the Program will provide tax or legal advice to those rece...
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(1 occurrence)
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...attorney to provide free legal counseling to the Claimant for the sole purpose of advising the Claimant concerning the language and binding nature of the Release No one affiliated with the Program will provide tax or legal advice to those rece...
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(1 occurrence)
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...attorney to provide free legal counseling to the Claimant for the sole purpose of advising the Claimant concerning the language and binding nature of the Release No one affiliated with the Program will provide tax or legal advice to those rece...
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(1 occurrence)
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...I 1B BA GDD 1D QfAz C?eN 8V t??DM HL VN hZ H6 7I X9 a A a4 ge4 a4 nd must at least F6 e4 Evid c7 e7 mphasis a4 dde4 his langua6 ge4 plainly gives the ourt a4 uthorit-2 to8 mot-3 ion Se4 e4 Or5 e4 United Stat-3 e4 v4 Andr-9 e4 No PAE S.D.N3 Ja3...
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(1 occurrence)
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...I 1B BA GDD 1D QfAz C?eN 8V t??DM HL VN hZ H6 7I X9 a A a4 ge4 a4 nd must at least F6 e4 Evid c7 e7 mphasis a4 dde4 his langua6 ge4 plainly gives the ourt a4 uthorit-2 to8 mot-3 ion Se4 e4 Or5 e4 United Stat-3 e4 v4 Andr-9 e4 No PAE S.D.N3 Ja3...
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...ENDANT a re re rs re a re rs fair Case Document Filed Page of I Do any our hat our or ns during-3.001 trial Do ny or ng language3.001 ve you or se to ou ged with ve se used of sexual-9.004 ve or has ne se of Unsure4.002 qu tely ve or has se of...
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(1 occurrence)
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...e wil3 be dang-2 er o5 unfair-3 Case Document Filed Page of pre-2 jud3 ice-3 be4 cause-3 th3 w7 it ness-2 cho4 ice-3 of langu5 age mp3 li-3 ed that-4 he and the prose-2 cu4 tion beli-3 ev4 ed the omp3 lainants-3 test4 imony Id For hese n5 the p...
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(1 occurrence)
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...e wil3 be dang-2 er o5 unfair-3 Case Document Filed Page of pre-2 jud3 ice-3 be4 cause-3 th3 w7 it ness-2 cho4 ice-3 of langu5 age mp3 li-3 ed that-4 he and the prose-2 cu4 tion beli-3 ev4 ed the omp3 lainants-3 test4 imony Id For hese n5 the p...
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(1 occurrence)
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...attorney to provide free legal counseling to the Claimant for the sole purpose of advising the Claimant concerning the language and binding nature of the Release No one affiliated with the Program will provide tax or legal advice to those rece...
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(1 occurrence)
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...rt o6 he-2 rec-3 ip3 roc-2 a4 discover-3 obli6 gati-4 ons thereby vi-2 olatin3 Rule A The gover-2 nment is wr-2 ong The langua-3 g5 of-2 Rule A is plai-4 and un4 ambi-4 guous I obli-3 ga4 ti-3 on apply only to3 mat-4 e4 ri-3 a4 Ms Ma-3 xwel4 nt...
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(1 occurrence)
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...uld ave answered hone stly ased the foregoing the Government believes th Co urt uld co nduct an inqun See United States Langford 2d 2d ir Th Government prop oses that the Co mi sc ed ule a ear in in approx im ate nth alo ith a a ppropri ate sc...
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(1 occurrence)
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...fy for an Aggravating Role Adjustm-7.3 nt Under USSG A Ms Maxwell Not rvise er Crim-7.8 al Particip-4.4 Under the plain langu-10.3 of USSG and its commentary Ms Maxw-7.9 ell does not qualify for an aggrav-11.2 ting role enhan-11.2 ement Guideli...
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...e credibility of her relevant testimony The prosecutors should not rely on Ms Giuffres information unless in the language of Standard they reasonably believe it to be true Their belief in Ms Giuffres reliability would not be reasonable unless t...
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...6e4 c4a4ll-3ing an e6xpe-5rt w3it-3ne4ss l-3ike G4e4rshma4n D-7e4f Br.3 9a4t Te3ll-3ingl-3y the D4e4f-6e4nse3 quotes no langua6ge4 f-6rom the Cour3t for6 thi-3s proposit-2ion a4nd ins-2tea6d c4it-3e4s onl-2y thos-2e4 pa-5ge4s of the4 C-2ourt or...
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...dge3 Mc3Ma3h-9on to uns-2e4a4l t-3hose3 mate ria5ls Obje4c4ti-3ons t-2o R-2e4da4c4ti-3ons P-4ropose6d on P-3a4ge4s The5 langua6ge4 a4t i-3ssue the-5re7 c-5onc4e4rns a6 di-11a4ry tha5t Ac-5c4u-9se3r ha4s publ-2icly a4nd 9re-2pe4a4tedly c4laim ed...
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...6rep-2orts is-2 5m3ore-2 simi3lar-4 to t-3he sp3eci-3a4li-3zed knowl3edge pol-3ice 6off-3icers use 6to i-3nt3erp-2ret s4lang a-3nd cod4e words used by drug Case Document Filed Page of The Honorabl-2e Alis-3on Nathan Decem-2ber-2 Page The govern...
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...Page of The Honorabl-2 Alis-3 on Nathan Decem-2 ber-2 Page Kuyrkendal-3 decl-3 a4 ration Kuyrkendal-3 decl-3 a4 ratio3 langua-3 ge Each of-2 the statements that he phy4 sical conta ct was not se-3 x5 uali-4 z4 ed or expli-4 c4 itly sexual CONC...
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...d my answer to that question is no THE COURT OK So you dont have an opinion on whether the presence let me just get the language the presence of a third of another individual can facilitate sexual abuse of minors THE WITNESS To the extent that...
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(1 occurrence)
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...at Ja Doe owed ecedent for rent ece en paid the a artment Ja ne lived in at rior to er ov in to Los A ge es CA Adam ry Lang Jane Doe travelled with Adam Perry ang a nd ece on at ast occasion between and esley Groff Doe i nt rac te with Groff m...
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(1 occurrence)
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...he gre up amongst scientists and in an academic and business environment They share a love of travel and art She speaks languages She enjoys spending time visiting auction houses she says that is the best way to learn about art and antiques you...
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(1 occurrence)
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...eULjZRiZLiZLiZLjZLjMjMkMk dUJo_UdRHr_UkWNkZJkLm NnQp_Tr WsaYtbZF WL pdUdYIaVGrgXeYFgFj Fk_Gj JhZNeURbRU 1k RgJoaNm_JdV?laNg KfZLmaWjWm_ NP aRLgYRaRJhYOm_TreXeWJ SD VH:PC4N Mi Mj NjNjNjNkOkOl Pk Ok OjNj Ni MiMhLiLiLiLiLiLiLiLiLbZPVMD OG TK4 JB5...
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...when in fact she uses other non-contraba6.8nd items to cover her eyes Governme nt conveyed the MDC?s imprecise language in an April letter to Judge Nathan but has since reco-6.4gnized and acknowled-6.4g-2.1ed the inaccuracy re maining accusati...
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(1 occurrence)
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...when in fact she uses other non-contraba6.8nd items to cover her eyes Governme nt conveyed the MDC?s imprecise language in an April letter to Judge Nathan but has since reco-6.4gnized and acknowled-6.4g-2.1ed the inaccuracy re maining accusati...
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(1 occurrence)
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...attorney to provide free legal counseling to the Claimant for the sole purpose of advising the Claimant concerning the language and binding nature of the Release No one affiliated with the Program will provide tax or legal advice to those rece...