Epstein Secrets

create unwieldy " `satellite litigation"' that will frustrate the rule's goal of 'more effective operation of the pleading regimen.' Id. (citing 5A Wright & Miller, Federal Practice and Procedure § 1332, at 29 (1990)). motion is also untimely. On March 20, 2011, the victims filed their motion for summary judgm

and seek Rule I I sanctions for the allegations. But as a non-party, he lacks standing to bootstrap his way into this case via a Rule 11 motion. As the Second Circuit has explained: 3 EFTA00205013 Although the language of Rule 11 does not address the issue of who may move for sanctions, the language used in th

create unwieldy " `satellite litigation' that will frustrate the rule's goal of `more effective operation of the pleading regimen.' Id. (citing 5A Wright & Miller, Federal Practice and Procedure § 1332, at 29 (1990)). Reinhart's motion is also untimely. On March 20, 2011, the victims filed their motion for su

and seek Rule 11 sanctions for the allegations. But as a non-party, he lacks standing to bootstrap his way into this case via a Rule 11 motion. As the Second Circuit has explained: 3 EFTA00795276 Case 9:08-cv-80736-KAM Document 81 Entered on FLSD Docket 05)16:2011 Page 4 of 8 Although the language of Rule 11

ht to relief above the speculative level, see 5 C. Wright & A. Miller, Federal Practice and Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter Wright & Miller) ("Mlle pleading must contain something more ... than ... a statement of facts that merely creates a suspicion [ofj a legally cognizable right of a

wire and mail fraud occurred over 21-month period); Cofacredit. S.A. v. Windsor Plumbing SupnlY Co., 187 F.3d 229, 242 (2d Cir.1999) (stating that the Second Circuit "has never held a period of less than two years to constitute a `substantial period of time' "); Hughes v. Consol-Pennsylvania Coal Co. 945 F.2d 59

m and foundation. 3 EFTA00595615 THE WITNESS: Yes. He wasn't always friendly See Menninger Decl., Ex. F, 10:6-14; 43:15-44:4 As explained in in Wright & Miller, Federal Practice and Procedures, the use of a document during testimony to refresh recollections is limited: The law also places limits on how cou

es statement contained in the report) will never be admissible unless there is a separate and independent hearsay exemptions for such statement. As the Second Circuit has clearly held: "It is well established that entries in a police report which result from the officer's own observations and knowledge may be adm

ct of amendment on the parties, the court must consider "the importance of the amendment on the proper determination of the merits of a dispute." 6 Wright & Miller, Fed. Prac. & Fed. P. § 1488, p. 814 (3d ed. 2010). Justice does not require amendment where the addition of parties with duplicative claims will no

rivacy interests of non- parties ... represents a legitimate basis for sealing judicial documents"). B. Effect of Previous Unsealing of Documents by Second Circuit Plaintiff claims that if a document is already public in another context, then it should be unsealed. She cites no law for this proposition, which