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
EFTA01112365
9 pg
…by Epstein except
his Constitutional Privilege. On March 11, 2013, this Court entered its Order on
Edwards's Motion by overruling all objections other than privilege; to wit:
[t]he court heard argument of counsel, reviewed the court file, has
…
DataSet-9
EFTA00204767
2 pg
…Fisher objected to the request. At a conference on December
10, 1997, I overruled the objection on the condition that the return be protected by an appropriate confidentiality
order, which the parties were to negotiate. Fisher and the Government, however…
DataSet-9
EFTA01111222
18 pg
…1 1, 2013, this Court entered its Order on Edwa
rds's Motion in which it
overruled all objections other than privilege:
[Ole court heard argument of counsel, reviewed the court file,
…
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
EFTA01101239
4 pg
…1 arc determined to be privileged, the
documents will be returned by Fowler to Farmer Jaffe with no copies retained. If the objections
to privileged documents are overruled, then the documents will be deemed discoverable, and the
Confidentiality Agreement relating…
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EFTA00603608
129 pg
…COMPEL PLAINTIFFS' PRODUCTION OF DOCUMENTS &
COMPLETE RESPONSES TO INTERROGATORIES
Defendant/Counterclaim Plaintiff ALAN M. DERSHOWITZ ("Dershowitz") respectfully
moves this Court for entry of an Order that (a) overrules the objections asserted by Plaintiffs
BRADLEY J. EDWARDS ("E…
DataSet-10
EFTA01325020
2 pg
…Fisher
objected to the request. At a conference on December 10, 1997, I overruled the
objection on the condition that the return be protected by an appropriate confidentiality
order, which the parties were to negotiate. Fisher and the Government, however…
DataSet-9
EFTA00223061
2 pg
…Fisher objected to the request. At a conference on December
10, 1997, I overruled the objection on the condition that the return be protected by an appropriate confidentiality
order, which the parties were to negotiate. Fisher and the Government, however…
DataSet-9
EFTA01107612
13 pg
…to Edwards's Motion. On
1
EFTA01107612
March 11, 2013, this Court entered its Order on Edwards's Motion by overruling all
objections other than privilege; to wit:
[t]he court heard argu…
DataSet-9
EFTA00806653
6 pg
…prosecution agreement. Id. at 1001. The federal district court overruled Epstein's
former counsel's privilege objections. On appeal, the Eleventh Circuit held that Epstein's former
counsel had waived the work-product privilege as to all persons, as a…
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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…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…2016 that Ms. Maxwell must sit for a second deposition on
eight topics all “relating to [her] own sexual activity” and “her knowledge of the sexual activity
of others.” (DE 316-6 at 10) Judge Sweet overruled Ms. Maxwell’s…
giuffre-maxwell
gov.uscourts.nysd.447706.130.0
5 pg
…a non-existent “investigative
privilege.” When Ms. Maxwell demonstrated that the “investigative privilege” does not exist,
Plaintiff threw up the inapplicable “public interest” privilege, the assertion of which was
overruled by your Honor on April 21, 2016. The Court ordered:
…
giuffre-maxwell
gov.uscourts.nysd.447706.148.0
9 pg
…When Ms. Maxwell demonstrated that the “investigative privilege” did not exist,
Plaintiff threw up the inapplicable “public interest” privilege, the assertion of which was
overruled by the Court on April 21, 2016.
The Court Ordered:
“The criminal investigation. Any materials…
giuffre-maxwell
gov.uscourts.nysd.447706.1279.0
2 pg
…giving Doe 171 ample notice to decide on what she wanted
to do in the event the Court overruled her objection.
Doe 171 has had ample time to appeal in a non-urgent basis and she has not done so…
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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
EFTA01187981
12 pg
…York orders requested discovery. The trial court overruled his blanket
requiring application of New York law under section objection to any discovery and ordered him to file a
1738B(hX2). These determinations are required in order financial affidavit as required…