giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…to Documents Describing
Sexual Abuse. ......................................................................................................4
III. Doe 97’s Objection Is Insufficient. .......................................................................5
IV. Doe 107’s Objection Should Be …
giuffre-maxwell
gov.uscourts.nysd.447706.1237.0
20 pg
…2 of 20
TABLE OF CONTENTS
PRELIMINARY STATEMENT .................................................................................................1
ARGUMENT ..............................................................................................................................3
I.…
DataSet-9
EFTA01098861
3 pg
…Shipbuilding
Past
And then it was gone. In April, in an unusual move, Judge Leonard Davis of the United States
District Court overruled the jury. lie wrote that the patents were valid, but that the company had …
DataSet-9
EFTA00808813
3 pg
…2013 on this issue, attached
hereto as "Exhibit A."
EFTA00808813
taken and should be overruled." See Edwards's Motion to Compel.
"[N]ot well taken" is not a legal basis upon which this Court can rule. Additionally,
Edw…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…Maxwell objected to the second deposition, based in part on her privacy
concerns about testifying to her adult consensual activity (id.);
• Judge Sweet overruled Ms. Maxwell’s objections to the deposition, ruling that her
“privacy concerns are alleviated by the…
DataSet-9
EFTA00799402
26 pg
…individually,
and BRADLEY J. EDWARDS,
individually.
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO
OVERRULE OBJECTIONS AND COMPEL DEFENDANT/COUNTER-PLAINTIFF
BRADLEY EDWARDS TO ANSWER OUESTIONS
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersign…
DataSet-9
EFTA00104411
23 pg
…offense after conviction." Lopez, 356 F.3d at 467 (quoting North Carolina v.
Pearce, 395 U.S. 711, 717 (1969) overruled on other grounds by Alabama v. Smith, 490 U.S.
794 (1989)). Ms. Maxwell does not dispute that she…
DataSet-9
EFTA01246450
14 pg
…objected to the admission
of the videotape en the basic that the tape was edited and was an
invasion of Donnan's privacy. The district court overruled the
objection, and allowed one minute of the videotape to he played,
stating:
…
DataSet-9
EFTA00805367
22 pg
…attorneys in those
proceedings, and the United States regarding the non-prosecution agreement. Id. at 1001. The
federal district court had overruled Epstein's counsel's privilege objections. Id. at 1002. On appeal,
in relevant part, the Eleventh Circuit Court…
DataSet-9
EFTA00585394
26 pg
…individually,
and BRADLEY J. EDWARDS,
individually.
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO
OVERRULE OBJECTIONS AND COMPEL DEFENDANT/COUNTER-PLAINTIFF
BRADLEY EDWARDS TO ANSWER OUESTIONS
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersign…
DataSet-9
EFTA01143845
35 pg
…s when we served the request
7 for production and the interrogatories that
8 are the focus of the motion to overrule all
9 claims of privilege other than claims of Fifth
10 Amendment privilege and to impose sanctions.
11 …
DataSet-9
EFTA00794277
21 pg
…materials
except for materials related to new or ongoing cases conditioned on a "For Attorneys' Eyes Only"
basis until such time as the Court overruled any privilege claim upon the Special Master's (or
Court's) review with counsel present…
DataSet-9
EFTA00801142
96 pg
… 1 THE COURT: I'm not questioning that.
2 MR. LINK: The objection was relevance
3 and 403 prejudice to that question.
4 THE COURT: The objection is overruled.
5 Those objections are overruled.
6 MR. GOLDBERGER: Your Honor…
DataSet-9
EFTA00222502
16 pg
…Absent some interrogatory-by-interrogatory showing of reasonable cause, Plaintiff
asks that Defendant's claims of privilege under the Fifth Amendment be rejected and overruled.
III. DEFENDANT'S BLANKET ASSERTION OF
FIFTH AMENDMENT PRIVILEGE IN RESPONSE
…
DataSet-10
EFTA01735296
28 pg
…during
the process. These decisions are taken by a court.
3. The original decision by a prosecutor not to proceed with sexual assault allegations against Mr
Assangc was overruled by a more senior prosecutor, Ms Ny. This process is provided…
DataSet-9
EFTA01143880
15 pg
…s when we served the request
7 for production and the interrogatories that
8 are the focus of the motion to overrule all
9 claims of privilege other than claims of Fifth
10 Amendment privilege and to impose sanctions.
11 …
DataSet-9
EFTA00728265
7 pg
…assort of
monetary component related to the Epstein cases and which Edwards attorney objected to on the
grounds of "economic privacy." Exhibit "A" at pp. 72-74. Defendant's objections should be
overruled in this regard. See Lg., Friedman v…
DataSet-9
EFTA00788219
145 pg
…Haddad Coleman
on behalf of Jeffrey Epstein. We will be
6 proceeding with our motion to overrule
7 objections and compel Defendant/
8 Counter-Plaintiff Bradley Edwards' answer to
9 questions.
10 Judge, this motion is directed at
11 Mr…
DataSet-9
EFTA01085801
39 pg
…frivolous lawsuit risks . . . a malicious prosecution action by the
party defamed, from which the judicial proceedings privilege will afford no protection.",)
overruled on other grounds 3 A.3d 1132 (D.C. 2010);
Hawaii — Kahala Royal Corp. v. Goodsill Anderson Quinn…
DataSet-9
EFTA00806757
56 pg
…is
"sustained", that means the witness may not answer the question. If I say that the objection is
"overruled", that means the witness may answer the question.
When there is an objection and I make a decision, you must not…
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