Epstein Secrets

lare as follows: 1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell ("Maxwell") in this ac

iV Page 2 of 10 On December 30, 2014, two other unnamed victims, Jane Doe 3 and Jane Doe 4, moved to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. (DE 280). Petitioners (Jane Doe 1 and Jane Doe 2) support the Rule 21 Motion. (IA at 11). Jane Doe 3 and Jane Doe 4 argue that they "have suffe

edlessly defamatory as to warrant inference of express malice. Cases that cite this headnote On Appeal from the United States District Court for the Southern District of New York (Robert W. Sweet, Judge). Attorneys and Law Firms Sanford L. Bohrer (Christine N. Walz, Madelaine J. Harrington, New York, NY, on th

njoy no presumption of public access." Finally, in appropriate circumstances, district courts may impose sanctions on attorneys and parties under Federal Rule of Civil Procedure 11(c)." 40 Fed. R. Civ. P. 26(c); see also TheStreet Com, 273 F.3d at 229-30. 41 See, e.g., S.D.N.Y. Electronic Case Filing Rules & Instruction

ring the course of the "Ponzi" scheme. 4. From in or about 2005 and continuing thereafter through in or about November 2009, in Broward County, in the Southern District of Florida and elsewhere, the defendant, SCOTT W. ROTHSTEIN, did knowingly conspire, confederate, and agree with persons known and unknown to the U

rivolous; 17. That the presentation of such evidence by counsel for JONES demonstrates a lack of a good faith basis to prevent same in violation of Federal Rule of Civil Procedure, 1 I: IS. That MORSE has demonstrated by clear and convincing evidence, ownership of these funds by JONES, that said funds are hereby frozen and no

and incorporated herein by reference. 2. From in or about 2005 and continuing thereafter through in or about November 2009, in Broward County, in the Southern District of Florida and elsewhere, the defendant, SCOTT W. ROTHSTEIN, did knowiney combine, conspire, confederate, and agree with other persons known and un

ut merit and frivoh • 17. Tha, presentation of such evidence by counsel for JONES demonstrates a lack of a basis to prevent same in violation of Federal Rule of Civil Procedure, 11: MORSE has demonstrated by clear and convincing evidence, ownership of these + funds by JONES, that said funds are hereby frozen and not subje

NC. afirla ICON BY JAN JONES, Defendant-Appellee. In re EDWARD MORSE and CAROL MORSE, Petitioners. Appeal from the United States District Court for the Southern District of Florida (Under Seal- Civ-Marra), Kenneth A. Marra, Judge. PETITIONERS' MOTION FOR EMERGENCY WRIT OF MANDAMUS Petitioners, EDWARD MORSE and CAROL

rivolous; 17. That the presentation of such evidence by counsel for JONES demonstrates a lack of a good faith basis to prevent same in violation of Federal Rule of Civil Procedure, 11: 18. That MORSE has demonstrated by clear and convincing evidence, ownership of these funds by JONES, that said funds arc hereby frozen and not

ring the course of the "Ponzi" scheme. 4. From in or about 2005 and continuing thereafter through in or about November 2009, in Broward County, in the Southern District of Florida and elsewhere, the defendant, SCOTT W. ROTHSTEIN, did knowingly conspire, confederate, and agree with persons known and unknown to the U

rivolous; 17. That the presentation of such evidence by counsel for JONES demonstrates a lack of a good faith basis to prevent same in violation of Federal Rule of Civil Procedure, 11; 18. That MORSE has demonstrated by clear and convincing evidence, ownership of these funds by JONES, that said funds are hereby frozen and not