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FLSD Docket 11/05/2009 Page 1 of 4 2 The relief sought by Plaintiff is injunctive and, essentially, amounts to a prejudgment writ of attachment. Rosen v. Cascade Intern., Inc., 21 F.3d 1520, 1530 (11 Cir. 1994) (vacating th district court’s preliminary injunction freezing defendant’s assets). “No
failed to 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 FLS
iewed as a form of injunctive relief, is more precisely viewed as a pre- judgment seizure of property. In any event, the name is not important. See Rosen v. Cascade Intern., Inc., 21 F.3d 1520, 1530 (11th Cir. 1994) (“federal courts look past the terminology to the actual nature of the relief request
ction to prevent “transfer[ring] assets abroad” and distinguishing De Beers). In one final attempt to obscure this Court’s power, Epstein cites Lawhon v. Mason, 611 So.2d 1367, 1368 (Fla. Ct. App. 1993), as rejecting plaintiff’s motion to prohibit a defendant from transferring assets. Mem. in Opp.
the plaintiff seeks only to recover money damages do not fall within the jurisdiction of equity and injunctive relief is therefore unavailable. See Rosen v. Cascade Int'!, Inc., 21 F.3d 1520, 1529-30 (11th Cir. 1994) (holding that the district court Jacked the general equitable authority to issue an
er, in her First Amended Complaint (DE #38), Jane Doe does not seek an injunction nor does she assert a claim under Fla. Stat. §726.101 et seq. See Lawhon v. Mason, 611 So. 2d 1367, 1368 (Fla. 2d DCA 1993) (holding that a party must ''file suit under the Uniform Fraudulent Transfer Act" to enjoin frau
the plaintiff seeks only to recover money damages do not fall within the jurisdiction of equity and injunctive relief is therefore unavailable. See Rosen v. Cascade Int'l. Inc. 21 F.3d 1520, 1529-30 (11th Cir. 1994) (holding that the district court lacked the general equitable authority to issue an i
leges the defendant may be dissipating assets; a judgment for money damages is adequate and injunctive relief is improper) (citations omitted). The Lawhon court also noted that the order was similar to a pit-judgment writ of attachment. 611 So. 2d at 1368. "A writ of attachment cannot issue unless the
Entities connected to both Rosen and Lawhon

Jeffrey Epstein
PERSON
Donald Trump
PERSON
Prince Andrew
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
James Baker
PERSONJack Goldberger
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Vicky Ward
PERSONMason
ORGANIZATION
Salt Lake City
LOCATIONRobert D. Critton
PERSONScott Rothstein
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Alec Baldwin
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Martha Stewart
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Paul Cassell
PERSONSpencer Kuvin
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Harvey Weinstein
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Adam D. Horowitz
PERSONMichael J. Pike
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