Epstein Secrets

nrichment claim is not available where it simply duplicates, or replaces, a conventional contract or tort claim." Id. (citations omitted); see also Simmons v. Ambit Energy Holdings, LLC, No. 503285/2015, 2016 Misc. LEXIS 3954 (Sup. Ct. Oct. 19, 2016). Here, Plaintiffs assert five other causes of action

P. 9(b) and 12(b)(6). I. PRELIMINARY STATEMENT: MULTIPLE SDNY JUDGES WARNED THE PERSON DRIVING THIS ACTION AGAINST SUCH FRIVOLOUS LAWSUITS Judges Sweet, Berman and Castel warned Steven Hoffenberg ("Hoffenberg"), whom Plaintiffs identify as the "Non-Party Affiant" (Compl. 15) and whose affidavit for

om) Jay M. Wolman ([email protected]) s/ Nicole Simmons 26 EFTA00791895

i Herald Media Company's (collectively, "Miami Herald") moved to make available to the public all sealed and redacted court filings. District Judge Sweet held a hearing in May 2018, and denied the motion in August 2018. In its appellate briefs the Herald did not argue the district court misconstrued

Twin Lakes Rd. South Salem. NY 10590 /s/ Nicole Simmons Nicole Simmons EFTA00621900

y S. Pognuca 130 East KM Avernus Denver. Colorado 80203 303.831.7364 n 303 832.2 r-• - • crap 4s: Re: v, Maxwell. 15-ev-07433-RWS Dear Judge Sweet: I am writing to request the Court to extend the deposition deadline of Plaintiff's designated expert Dianne Flores from December 29, 2016 to Janua

reet, 14th Floor Iarford m CT 06103 /s/ Nicole Simmons Nicole Simmons 22 EFTA00074985 CaesR29411403

For the reasons recently briefed to the Court concerning Professor Dershowitz's identical argument, the position is without merit. See DE 892 (Judge Sweet's May 2017 Order); DE 1059 (law of the case that parties and deponents reasonably relied on protective order); DE 1062 at 3-6 (protective order tra

of New York (via United States mail) s/ Nicole Simmons 43 EFTA00075525 Case 20-2413, Document 40. 08

ons took place only after everyone agreed on the record that the testimony would be confidential and sealed pursuant to the Protective Order. Judge Sweet made factual findings on exactly this point, which this Court never questioned in Brown.M325 F. Supp. 3d at 445, 446 (recognizing that Ms. Maxwell

f the filing to all parties of record. hi Nicole Simmons 2 EFTA00076390 Case Gaga4.407741333-IDARn-Off

ant to the Court's exercise of its inherent supervisory powers. The documents at issue here relate to discovery motions previously decided by Judge Sweet, and so the Court SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00076444 Case 20-2413, Document 44, 08/20/2020, 2913556, Page63 of 78 3

int Andrew's Plaza New York NY 10(117 s/ Nicole Simmons 15 EFTA00091893

ntive motions relating to the admissibility of expert testimony, deposition testimony, and the admissibility of evidence remained unresolved. Judge Sweet had yet to rule on evidentiary challenges to thousands of deposition questions and answers contained in dozens of bankers boxes wheeled into his cou