Garth Brooks And The Reply In Further Support Of Dismissing The Lawsuit By Jane Roe (Part 1) (12/29/24)

A memorandum of law in support of a motion to dismiss a complaint is a legal document prepared by an attorney that outlines the legal arguments and authorities supporting the dismissal of a lawsuit.When a defendant files a motion to dismiss a complaint, they are essentially asking the court to throw out the case against them. The memorandum of law serves to explain to the court why the complaint should be dismissed based on legal principles, statutes, regulations, and relevant case law.Typically, a memorandum of law in support of a motion to dismiss will:Outline the Legal Standard: It will begin by stating the legal standard for dismissing a complaint in the jurisdiction where the case is being heard. This often involves citing relevant rules of civil procedure or case law.Present Legal Arguments: The memorandum will then present the specific legal arguments as to why the complaint fails to state a valid claim for relief. This might include arguments that the complaint lacks legal merit, fails to establish jurisdiction, or is barred by a statute of limitations.Cite Case Law and Precedent: The attorney will cite relevant case law and legal precedent to support their arguments. They may show how similar cases were dismissed by courts in the past under similar circumstances.Address Counterarguments: If there are potential counterarguments that the opposing party might raise, the memorandum may also address these and explain why they do not undermine the motion to dismiss.Conclusion: Finally, the memorandum will conclude by summarizing the key points and reiterating why the court should grant the motion to dismiss.Overall, the memorandum of law is a critical tool in the litigation process, as it helps the court understand the legal basis for the defendant's request to dismiss the case.In this episode we are diving into the Memorandum of Law in Support to dismiss Doe's claims against the corporate defendants.  (commercial at 9:17)to contact me:[email protected]:gov.uscourts.nysd.611545.43.0_1.pdf (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

In the case of Kenyatta v. Combs et al., No. 1:2024cv06923, the plaintiff, Charles Kenyatta Jr., filed a trademark infringement lawsuit against defendants Sean Combs and Bad Boy Entertainment (BBE). Kenyatta alleged that BBE was served on October 4, 2024, and subsequently obtained a Certificate of Default when BBE did not respond. BBE moved to vacate this default, contending that service was deficient and that the court lacked personal jurisdictionUpon review, the court found that the summons served lacked the Clerk's signature and seal, rendering the service improper and depriving the court of personal jurisdiction over BBE. Additionally, the court determined that BBE's default was not willful, that vacating the default would not prejudice the plaintiff, and that BBE had presented potentially meritorious defenses. Consequently, the court granted BBE's motion to vacate the Certificate of Default.to contact me:[email protected]:gov.uscourts.nysd.628369.42.0.pdfBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

Mexican drug cartels have a long history of infiltrating various businesses to diversify their income streams and legitimize their illicit wealth. Here is a summary of how they have accomplished this:Money Laundering: Cartels often use legitimate businesses, such as restaurants, bars, and nightclubs, to launder their drug profits. They commingle drug money with the revenue from these businesses, making it difficult for authorities to trace the illegal funds.Front Companies: Cartels establish front companies, which appear to be legal entities engaged in legitimate activities. These companies can include construction firms, agricultural enterprises, or even real estate ventures. The primary purpose is to provide a cover for their criminal operations.Corruption: Cartels corrupt law enforcement officials, politicians, and public servants to protect their interests and facilitate their operations. Bribery and coercion are common tactics used to ensure cooperation from authorities.Transportation and Logistics: They infiltrate the transportation industry, including trucking companies and cargo services, to facilitate the movement of drugs across borders. They also manipulate shipping routes to hide drug shipments in legal cargo.Extortion: Cartels often extort money from local businesses, threatening violence or harm if business owners do not comply. This provides a significant source of income while instilling fear in the community.Mining and Natural Resources: Some cartels are involved in illegal mining and extraction of natural resources, such as precious metals or timber. They use these activities to launder money and fund their operations.Agriculture: Cartels may control large swaths of agricultural land, where they grow illegal crops like marijuana and poppies for drug production. They sometimes disguise these operations as legal farming activities.Retail and Wholesale: Cartels may infiltrate the retail and wholesale distribution of legal products. They can use their influence to control supply chains and distribution networks, which can include food, beverages, and consumer goods.Money Exchange and Financial Services: They may operate their own money exchange or remittance businesses to move money across borders and circumvent financial regulations.Real Estate: Cartels invest in real estate, including luxury properties and land acquisitions, as a way to park their illicit wealth and generate additional income through rentals and sales.Protection Rackets: Cartels offer "protection" services to local businesses, forcing them to pay regular fees in exchange for safety from cartel-related violence. This is another form of extortion.Cybercrime: Some cartels have ventured into cybercrime, engaging in activities such as hacking and online fraud to generate revenue and launder money.The infiltration of these various sectors allows Mexican drug cartels to diversify their income streams, legitimize their wealth, and maintain a strong grip on the communities in which they operate.(commercial at 13:40)to contact me:[email protected]:From chickens to cabs: Drug cartels expand across the Mexican economy | Economy and Business | EL PAÍS English (elpais.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

During the 2016 presidential campaign, Jeffrey Epstein sought to infiltrate Donald Trump's inner circle by arranging meetings with key campaign supporters. He facilitated introductions between individuals close to Trump and a prominent Russian diplomat, aiming to position himself as a valuable intermediary. Epstein's efforts to align with the campaign were ultimately unsuccessful, as his overtures were rebuffed by those within Trump's orbit. Despite Epstein's previous social interactions with Trump, including attending events together in the 1990s, his attempts to gain influence during the campaign were firmly rejected.to contact me:[email protected]:How Jeffrey Epstein Tried to Tap Into Trump’s Circle - WSJBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

Jeffrey Epstein’s relationship with Les Wexner, the billionaire founder of L Brands, was deeply troubling and emblematic of the unchecked power wielded by wealthy elites. Wexner granted Epstein an extraordinary level of access to his personal and financial affairs, including control over hundreds of millions of dollars, a decision that has been widely criticized as reckless and inexplicable. This relationship allowed Epstein to use Wexner’s influence and resources to build the facade of a legitimate financial advisory career while facilitating his predatory behavior. The transfer of Wexner’s lavish Manhattan townhouse to Epstein under murky circumstances, allegedly for little to no payment, underscores the transactional and opaque nature of their connection. Wexner’s apparent abdication of oversight raises serious questions about his judgment and the extent to which he enabled Epstein’s crimes, even if inadvertently.Critics argue that Wexner’s failure to fully account for his ties to Epstein reflects a broader culture of impunity among the ultra-wealthy. Wexner claimed to sever ties with Epstein in 2007 following his first conviction, yet the damage had already been done, with Epstein leveraging his connection to Wexner to gain legitimacy and expand his network of influence. Wexner’s attempts to distance himself from Epstein have done little to satisfy public scrutiny, particularly given his refusal to address key inconsistencies and unanswered questions. This relationship epitomizes how power and wealth can shield individuals from accountability, with Wexner’s role serving as a stark reminder of the ethical lapses and complicity that often enable systemic abuses.to contact me:[email protected]:https://www.columbusmonthly.com/story/lifestyle/features/2022/10/25/what-jeffrey-epstein-scandal-means-to-columbus-and-les-wexner/69589703007/Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

An NDA, or Non-Disclosure Agreement, is a legal contract between at least two parties that outlines confidential material, knowledge, or information that the parties wish to share with one another for certain purposes, but wish to restrict access to or by third parties.NDAs are used for various reasons:Protecting Intellectual Property: Businesses often use NDAs to safeguard their trade secrets, proprietary information, or other sensitive data from being disclosed to competitors or the public.Maintaining Confidentiality: In certain business dealings, such as partnerships, mergers, or acquisitions, sensitive information may be shared between parties. NDAs ensure that this information remains confidential and is not used for purposes other than what is agreed upon.Facilitating Collaboration: When multiple parties collaborate on a project, they may need to share sensitive information to achieve their goals. NDAs help establish trust among collaborators by legally binding them to maintain confidentiality.Preventing Information Leakage: Employees, contractors, or consultants often have access to sensitive information about a company's operations, products, or plans. NDAs help prevent them from disclosing this information to unauthorized individuals or entities.In this episode, we get a look at what a standard NPA in the world of Diddy consists of.(commercial at 16:59)source:gov.uscourts.nysd.616406.16.2.pdf (courtlistener.com)NDAs, or non-disclosure agreements, will not protect Sean "Diddy" Combs in his criminal trial because NDAs are primarily civil agreements designed to prevent parties from disclosing certain information publicly. However, they do not shield individuals from testifying in criminal cases. Criminal law supersedes any private agreements, as the government has a vested interest in prosecuting crimes and ensuring justice. Therefore, if someone has relevant knowledge about criminal activities, they can still be compelled to testify, even if they have signed an NDA.In the case of Cassie Ventura, although she signed an NDA as part of her settlement with Diddy, this does not prevent her from being called to testify in a criminal trial. NDAs cannot override a subpoena or prevent someone from providing testimony if it pertains to criminal conduct. The court can compel Ventura to testify about any relevant events, even if they were covered by the terms of the NDA, as the pursuit of justice in criminal cases takes precedence over any civil agreement. Thus, despite the NDA, Cassie can be legally obligated to provide testimony in the ongoing criminal proceedings against Diddy.to contact me:[email protected]:Cassie may be called to testify at Diddy trial despite signing NDA, lawyer says | Daily Mail OnlineBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

Our journey right into the heart of the allegations against Diddy continues in this episode as we take a look at the Ethiopia Habetameriam Declaration in support to dismiss the lawsuit against Puffy and co. (commercial at 10:04)to contact me:[email protected]:The culmination of experience - The Hindu (courtlistener.com) In the context of a court filing, a declaration is a written statement made under oath or penalty of perjury by a person who has personal knowledge of the facts stated in the document. Declarations are commonly used in legal proceedings to present evidence or provide information relevant to a case.They are typically submitted to the court by parties involved in the case or by witnesses, and they serve as a means of presenting facts or arguments to support or oppose various legal claims. Declarations are often used when a witness is unavailable to testify in person or when it is impractical for them to do so. They are subject to the same standards of truthfulness and accuracy as testimony given in court.In this episode, we take a look at the declaration of facts filed by Lucian Grainge. (commercial at 10:46)to contact me:[email protected]:gov.uscourts.nysd.616406.26.1.pdf (courtlistener.com)Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

Jeffrey Epstein had several documented parole violations after he "served" his original sentence, yet nothing was ever done about it. Even when he was caught by a police officer in a place where he wasn't supposed to be, his parole officer, Carmen Sloan covered for him, even after her supervisor said that he was in violation.Let's dive in and take a look.(commercial at 10:04)to contact me:[email protected]:https://www.palmbeachdailynews.com/story/news/2012/04/01/jeffrey-epstein-house-arrest-missteps/9629975007/Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

John Brockman is a legend in the literary world. He has represented some of the finest minds in science in regards to their written works. His firm is considered the most prestigious. He was also one of Epstein's biggest enablers.Brockman was used by Epstein to open the door to relationships with the top scientists on the planet. The door he used was called the Edge foundation.Who is John Brockman? What was his role in this whole macabre story?To contact me:[email protected]:https://newrepublic.com/article/154826/jeffrey-epsteins-intellectual-enablerBecome a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.

In this look back episode we hear more about Jeffrey Epstein's "secret" girlfriend, Children's author, Shelley Anne Lewis. Her nickname? Chocolate Sauce. Let's see where she fits in.(Commercial at 8:49)To contact me:[email protected]:https://nypost.com/2020/08/02/everything-you-need-to-know-about-jeffrey-epsteins-secret-girlfriend/Become a supporter of this podcast: https://www.spreaker.com/podcast/the-epstein-chronicles--5003294/support.