Epstein Secrets

MAS, VI 00802- 3602 6501 RED HOOK PLZ STE 201 ST THOMAS, VI 00802- 1373 5600 ROYAL DANE MALL STE 51 ST THOMAS, VI 00802- 6410 148 W MAPLE AVE DENVER, CO 80223-1841 For internal use only SDNY_GM_00057190 CONFIDENTIAL - PURSUANT TO FED. R.ctON(F IDENTIAL DB-SDNY-0020014 EFTA_D0 I 67758 EFTA012

tcy Rules. Before such a dismissal occurs, a district court must consider six factors outlined in Poulis v. State Farm Fire and Cas. Co. In Poulis, the U.S. Court of Appeals for the Third Circuit stated that a district court must balance the following factors: (1) the extent of the party's personal responsibility; (2) t

s District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, r.0 Ty Gee 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmtlaw.com [email protected] Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghis

2014 WL 164181, at •8 (S.D.N.Y. Jan. 9, 2014) ("The Court stays immediate disclosure of these materials to permit Defendant to make application to the U.S. Court of Appeals for the Second Circuit for a more extended stay."); Brown v. Maxwell, 929 F.3d 41, 54 (2d. Cir. 2019) (recognizing likelihood of future appeals in

s District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P C Ty Gee 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmllaw.com [email protected] Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghis

2014 WL 164181, at •8 (S.D.N.Y. Jan. 9, 2014) ("The Court stays immediate disclosure of these materials to permit Defendant to make application to the U.S. Court of Appeals for the Second Circuit for a more extended stay."); Brown v. Maxwell, 929 F.3d 41, 54 (2d. Cir. 2019) (recognizing likelihood of future appeals in

ful press: Pilkington and Watt, “NSA Surveillance Played Little Role in Foiling Terror Plots, Experts Say.” The first “expert” was Michael Dowling, a Denver-based attorney who acted as Zazi’s defense counsel. He said he had no access to the undisclosed basis of the government position because Zazi pleaded

k Data Is Ruled Hlegal,” New York Times, May 5, 2015. This court decision was stayed three months later on August 27, 2015, by a three-judge panel of the U.S. Court of Appeals on procedural grounds. By this time, however, the legal issue was rendered moot by Congress. See http://law justia.com/cases/federal/appellate-courts

s District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P.0 Ty Gee 150 East 10th Avenue Denver, Colorado 80203 ni 303.831.7364 rx 303.832.2628 www.hmtlaw.com tgeefghmflaw.com Re: Reconsideration of the Court's July 23 Ruling Giuffre v. Ghi

2014 WL 164181, at •8 (S.D.N.Y. Jan. 9, 2014) ("The Court stays immediate disclosure of these materials to permit Defendant to make application to the U.S. Court of Appeals for the Second Circuit for a more extended stay."); Brown v. Maxwell, 929 F.3d 41, 54 (2d. Cir. 2019) (recognizing likelihood of future appeals in