DataSet-9
EFTA00066510
21 pg
…order, and thus that the Government's use of her
deposition testimony against her would violate her right against compelled self-incrimination.
She contends that she had a reasonable expectation of privacy in the documents covered by the
protective order…
DataSet-9
EFTA00087251
21 pg
…order, and thus that the Government's use of her
deposition testimony against her would violate her right against compelled self-incrimination.
She contends that she had a reasonable expectation of privacy in the documents covered by the
protective order…
DataSet-9
EFTA00106039
21 pg
…order, and thus that the Government's use of her
deposition testimony against her would violate her right against compelled self-incrimination.
She contends that she had a reasonable expectation of privacy in the documents covered by the
protective order…
DataSet-9
EFTA00040664
21 pg
…order, and thus that the Government's use of her
deposition testimony against her would violate her right against compelled self-incrimination.
She contends that she had a reasonable expectation of privacy in the documents covered by the
protective order…
DataSet-9
EFTA00087230
21 pg
…order, and thus that the Government's use of her
deposition testimony against her would violate her right against compelled self-incrimination.
She contends that she had a reasonable expectation of privacy in the documents covered by the
protective order…
DataSet-9
EFTA00723743
15 pg
…NO. 502008CA028051XXXXMB AB
Plaintiff,
v.
JEFFREY EPSTEIN
Defendant.
ORDER ON EPSTEIN'S MOTION FOR PROTECTIVE ORDER TO PROHIBIT
INAPPROPRIATE DEPOSITION QUESTIONS
THIS CAUSE came before the Court on Epstein's Motion for Protective Order to
Prohibit Inappropri…
DataSet-9
EFTA00622711
6 pg
…germane to this lawsuit" [emphasis included by Epstein]. Response Pg. 2.
"When asked in deposition why he filed suit and upon which facts he based this decision, Epstein
answered Edwards' questioning; he gig nal invoke his rights as to the…
DataSet-9
EFTA01076133
25 pg
…in this and
other pending cases involving EPSTEIN.
13. The burden of demonstrating good cause for the issuance of a protective order
concerning a deposition duces tecum of a non-party witness, pursuant to Rule
1.280(B)(1)(c)…
DataSet-9
EFTA00222442
24 pg
…A".
II. The Fifth Amendment
The Fifth Amendment serves as a guarantee against testimonial compulsion and provides,
in relevant part, that "[tic) person...shall be compelled in any Criminal Case to be a witness
against himself." (DE 242, p.5);…
DataSet-9
EFTA00794367
189 pg
…to start with
19 Kliman, if I could.
20 Dr. Kliman is a summary witness who has no firsthand
21 knowledge about the facts associated with this case. He's been
22 proffered as an expert in psychiatry. And the…
DataSet-9
EFTA00801646
19 pg
…privilege
log, 14 were marked as exhibits at Edwards' May 2013 deposition, and 52 others were neither used
as exhibits nor identified on the privilege log.
Epstein's team has reviewed approximately 4,000 — 5,000 of the 27,000…
DataSet-9
EFTA00128680
70 pg
…the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of
…
DataSet-9
EFTA01154260
11 pg
…or forfeiture. In addition, any testimony or evidence or any information produced by
the plaintiff or witness for the plaintiffs cannot be used against the plaintiffs or witness in any other
investigation or proceeding, except one for perjury. More Like…
DataSet-9
EFTA00801838
30 pg
… And I'm particularly concerned in
18 this regard; that the testimony of any witness
19 might be influenced by their improper exposure to
20 privileged documents. So we ask that a complete
21 list of all persons to whom…
DataSet-9
EFTA00086283
7 pg
…witness testimony or evidence.
12. Second, as discussed in my prior declaration, the government anticipates that
MCC staffing records, including daily assignment rosters for the MCC on July 23, August 9, and
10, 2019, will be the subject of witness…
DataSet-9
EFTA00099647
7 pg
…contain a different date stamp, which I understand to indicate when they were
electronically generated.
5
EFTA00099651
Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 6 of 7
DataSet-9
EFTA00088654
7 pg
…contain a different date stamp, which I understand to indicate when they were
electronically generated.
5
EFTA00088658
Case 1:20-cv-00833-PAE Document 40 Filed 01/15/21 Page 6 of 7
DataSet-9
EFTA00071554
30 pg
…Tartaglione. Capone DecL ¶ 29. The Capone Declaration explains how
premature release of the Tartaglione Records could reasonably be expected to influence witness
testimony and potential juror perceptions of any interactions between Epstein and Tartaglione.
See Capone Decl ¶¶ 29-31. These…
DataSet-9
EFTA00069312
27 pg
…records or the
information contained therein could reasonably be expected to influence witnesses' potential
testimony at trial, allow witnesses to alter their testimony to conform to other evidence, and/or
influence potential juror's perceptions of witness testimony or evidence…
DataSet-9
EFTA00211430
9 pg
…Ball Work Product
thru (USAO staff) regarding scheduling of grand jury time for indictment Investigative Privilege
P-014980 presentation and witness testimony 6(e)
(Information regarding unrelated grand jury ca…