Epstein Secrets

show unavailability of an adequate remedy at law and the likelihood of irreparable harm, two elements essential to entry of an injunction); Lawhon v. Mason, 611 So.2d 1367 (Fla. 2d DCA 1993) (quashing trial court order requiring defendant to Case 9:08-cv-80119-KAM Document 400 Entered on FLSD Docket

e to the payment of the debt due." Id. 3 give plaintiffs ten days notice prior to the transfer of any assets in excess of $500). Additionally, as the Eleventh Circuit explained in Rosen: In actions at law, plaintiffs in Florida possess an adequate, exclusive prejudgment remedy for the sequestration of assets under

2, 504 (11th Cir. 2007) (affirming district court's refusal to grant a preliminary injunction freezing defendant's assets). Similarly, in Lawhon v. Mason, 611 So. 2d 1367, 1368 (Fla. 2d DCA 1993), plaintiffs filed a "motion to prohibit defendant from transferring assets." The motion cited plaintiffs

ets to establish a fund with which to satisfy a potential judgment for money damages is not an appropriate exercise of a federal district court's 1 The Eleventh Circuit in Rosen "rejected appellees' suggestion that they successfully invoked the district court's equitable jurisdiction through their requests for any a

how unavailability of an adequate remedy at law and the likelihood of irreparable harm, two elements essential to entry of an injunction); Lawhon v. Mason, 611 So.2d 1367 (Fla. 2d DCA 1993) (quashing trial court order requiring defendant to 2 EFTA00728587 Case 9:08-cv-80119-KAM Document 400 Entered

ered on FLSD Docket 11/05/2009 Page 3 of 4 give plaintiffs ten days notice prior to the transfer of any assets in excess of $500). Additionally, as the Eleventh Circuit explained in Rosen: In actions at law, plaintiffs in Florida possess an adequate, exclusive prejudgment remedy for the sequestration of assets unde

3 WL 322768 (S.D.N.Y. Aug. 19, 1993) 216 United States v. Martinez, No. 94 Cr. (RPP), 1995 WL 10849 (S.D.N.Y. Jan. 12, 1995) 77 United States v. Mason, 479 F. App'x 397 (2d Cir. 2012) 248 United States v. Mast, 735 F.2d 745 (2d Cir. 1984) 144 United States v. McCourty, 562 F.3d 458 (2d Cir. 2

rt to apply a bizarre and unprecedented choice-of- federal-law doctrine, under which the defendant asks the Court to apply non-existent rulings from the Eleventh Circuit on an issue that Court does not appear to have reached. (Def. Mot. 1 at 23- 25). This argument has no legal foundation, and the defendant offers no a

3 WL 322768 (S.D.N.Y. Aug. 19, 1993) 216 United States v. Martinez, No. 94 Cr. (RPP), 1995 WL 10849 (S.D.N.Y. Jan. 12, 1995) 77 United States v. Mason, 479 F. App'x 397 (2d Cir. 2012) 248 United States v. Mast, 735 F.2d 745 (2d Cir. 1984) 144 United States v. McCourty, 562 F.3d 458 (2d Cir. 2

rt to apply a bizarre and unprecedented choice-of- federal-law doctrine, under which the defendant asks the Court to apply non-existent rulings from the Eleventh Circuit on an issue that Court does not appear to have reached. (Def. Mot. 1 at 23- 25). This argument has no legal foundation, and the defendant offers no a

3 WL 322768 (S.D.N.Y. Aug. 19, 1993) 216 United States v. Martinez, No. 94 Cr. (RPP), 1995 WL 10849 (S.D.N.Y. Jan. 12, 1995) 77 United States v. Mason, 479 F. App'x 397 (2d Cir. 2012) 248 United States v. Mast, 735 F.2d 745 (2d Cir. 1984) 144 United States v. McCourty, 562 F.3d 458 (2d Cir. 2

rt to apply a bizarre and unprecedented choice-of- federal-law doctrine, under which the defendant asks the Court to apply non-existent rulings from the Eleventh Circuit on an issue that Court does not appear to have reached. (Def. Mot. 1 at 23- 25). This argument has no legal foundation, and the defendant offers no a

3 WL 322768 (S.D.N.Y. Aug. 19, 1993) 144 United States v. Martinez, No. 94 Cr. (RPP), 1995 WL 10849 (S.D.N.Y. Jan. 12, 1995) 53 United States v. Mason, 479 F. App'x 397 (2d Cir. 2012) 163 United States v. Mast, 735 F.2d 745 (2d Cir. 1984) 100 United States v. McCourty, 562 F.3d 458 (2d Cir. 2

rt to apply a bizarre and unprecedented choice-of- federal-law doctrine, under which the defendant asks the Court to apply non-existent rulings from the Eleventh Circuit on an issue that Court does not appear to have reached. (Def. Mot. 1 at 23- 25). This argument has no legal foundation, and the defendant offers no a

3 WL 322768 (S.D.N.Y. Aug. 19, 1993) 216 United States v. Martinez, No. 94 Cr. (RPP), 1995 WL 10849 (S.D.N.Y. Jan. 12, 1995) 77 United States v. Mason, 479 F. App'x 397 (2d Cir. 2012) 248 United States v. Mast, 735 F.2d 745 (2d Cir. 1984) 144 United States v. McCourty, 562 F.3d 458 (2d Cir. 2

rt to apply a bizarre and unprecedented choice-of- federal-law doctrine, under which the defendant asks the Court to apply non-existent rulings from the Eleventh Circuit on an issue that Court does not appear to have reached. (Def. Mot. 1 at 23- 25). This argument has no legal foundation, and the defendant offers no a