DataSet-9
EFTA00607113
46 pg
…history category of III, these
revised numbers would result in a Guidelines sentencing range of 10 to 16 months'
imprisonment.
At the sentencing hearing, the district court overruled Mr. White's objection to his
tier classification. In reaching its conclusion…
DataSet-9
EFTA00723941
11 pg
…etc. which
bear absolutely no relation to this case and are entitled to have their privacy protected.
The Town of Palm Beach Police Officers respectfully request that should the Court
overruled its other objections to the requested discovery, that they…
DataSet-9
EFTA00728258
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
EFTA01111246
30 pg
…individually, and L.M., individually,
Defendants.
AMENDED AND SUPPLEMENTAL
MOTION OF PLAINTIFF TO OVERRULE OBJECTIONS AND
COMPEL DEFENDANT EDWARDS TO ANSWER QUESTIONS
AND APPEAR FOR FURTHER DEPOSITION
Plaintiff Jeffrey Epstein ("Epstein") m…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…relevant. Ms. Giuffre respectfully requests that this Court
direct Maxwell to produce all responsive documents for the time period from 1999 to the
present.6
Defendant Maxwell has also asserted fundamentally improper general objections which
should be overruled. Am. Rock…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…of this
20 production on -- you are going to have to -- well, wait a
21 minute. Let me put it this way. The objections to this 16 are
22 overruled except for the privilege. OK?
23 MS. MENNINGER: Your Honor…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…MCCAWLEY: I can make my record, and my
16 record is she's not going to be speaking with
17 respect to individuals' names that are named in
18 generalities in this document.
19 SPECIAL MASTER: Objection overruled. You
20…
giuffre-maxwell
gov.uscourts.nysd.447706.1062.0
7 pg
…85.
B. Dershowitz’s Present, Expanded Second (or Third) Bite at the Apple and
Giuffre’s Acquiescence to the Same
With his objections to the protocol overruled in Maxwell, and having already failed to
circumvent it once in Dershowitz, Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.39
36 pg
…of this
20 production on -- you are going to have to -- well, wait a
21 minute. Let me put it this way. The objections to this 16 are
22 overruled except for the privilege. OK?
23 MS. MENNINGER: Your Honor…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…2016).
Plaintiff objected to this interrogatory on the ground it requested pre-1999 medical
information in “violat[ion]” of the Court’s ruling. The objection should be overruled. The issue
4
Plaintiff’s voluminous arguments and argumentative citations to case…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
…MCCAWLEY: I can make my record, and my
16 record is she's not going to be speaking with
17 respect to individuals' names that are named in
18 generalities in this document.
19 SPECIAL MASTER: Objection overruled. You
20…
giuffre-maxwell
gov.uscourts.nysd.447706.43.0
15 pg
…generalized
objections that discovery requests are vague, overly broad, or unduly burdensome are not
acceptable, and will be overruled.”). Therefore, this Court should require Defendant to produce
the documents she admits to withholding.
3. This Court Should Grant Plaintiff’s…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…withholding any documents based on “copyright” and
“proprietary” objections. In fact, she did withhold those documents – until this
Court overruled her objection on March 17th. (Transcript at 13-17). She then
provided thousands of pages of supposedly “copyright protected” and…
case-18-2868
8# Epstein assets - 2019 07 12 - 0000# Epstein assets
28 pg
…Dec. 5, 2011), both of which
were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven
years since Fierro has been decided, it does not appear to have been cited by a single…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…privilege in these circumstances would result in nothing more than the
concealment of the truth. Plaintiffs’ objections on the basis of the attorney-client privilege
should be overruled.
2. Plaintiffs Have Waived Their Right To Rely On The Work Product…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…9, 14,15,21,22,25, 32 and. 35 should be overruled.
Plaintiffs did not raise relevancy and admissibility objections to Interrogatory Nos. 13 and 21.
Similarly, Plaintiffs did not raise relevancy and admissibility objections to Requests for
Production No…
giuffre-maxwell
gov.uscourts.nysd.447706.1253.0
12 pg
…1247 at 20, Plaintiff only addresses Does
28, 97 and 144’s replies. The Court should overrule their objections.1 In its April 19, 2022, ruling
concerning the first set of Non-Party Objectors, the Court ordered that certain documents…
giuffre-maxwell
gov.uscourts.nysd.447706.354.0
40 pg
…2016).
Plaintiff objected to this interrogatory on the ground it requested pre-1999 medical
information in “violat[ion]” of the Court’s ruling. The objection should be overruled. The issue
4
Plaintiff’s voluminous arguments and argumentative citations to case…
giuffre-maxwell
gov.uscourts.nysd.447706.57.1
26 pg
…and Ogden v. London Electric Railway Co.
. (1933) 49 T.L.R. 542, C.A. overruled.
Anderson v. Bank of British Columbia (1876) 2 Ch.D. 644,
Sir George Jessel M.R. and C.A. and Grant v. Downs (1976…
…12:43] years. To the contrary, the Supreme
[00:12:46] Court did not overrule tariffs. They
[00:12:49] merely overruled a particular use of
[00:12:52] AIPA tariffs.
[00:12:54] And essentially, it's to use…