EFTA00613445Set 9
2017-09-0529p10,503w
sought is not relevant, material or reasonably calculated to
lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of
the Counter-Plaintiff ... sought is not relevant, material or reasonably calculated to
lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of
the Counter-Plaintiff ... sought is not relevant, material or reasonably calculated to
lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of
the Counter-Plaintiff
https://www.justice.gov/epstein/files/DataSet%209/EFTA00613445.pdf
EFTA00798060Set 9
2017-09-0528p10,660w
sought is not relevant, material or reasonably calculated to
lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of
the Counter-Plaintiff ... sought is not relevant, material or reasonably calculated to
lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of
the Counter-Plaintiff ... sought is not relevant, material or reasonably calculated to
lead to the discovery of admissible evidence. The interrogatory seeks to invade the economic privacy of
the Counter-Plaintiff
https://www.justice.gov/epstein/files/DataSet%209/EFTA00798060.pdf
EFTA01462482Set 10
2014-02-0460p8,663w
recent quarterly surgical trends
(see Figure 3). While Q4 same-store inpatient admissions and adjusted
admissions dipped 1.8% and 1.0% YoY, respectively, HCA's Q4 SS
surgeries improved ... outpatient surgery / +0.9%
inpatient surgery) and helped drive revenue per adjusted admissions
(RPAA) pricing growth of +4.8% YoY. This marks the third consecutive
quarter of improving surgeries, and we believe ... Other operating expenses ratio
Bad debt ratio
4013 Revenue Metrics
SS revenue growth
SS admissions growth
SS adjusted admissions growth
SS rev per adjusted admission growth
Source: Deutsche Bank, company
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01462482.pdf
EFTA00013373Set 8
1995-01-3116p7,230w
source
independent of illegally obtained primary item,
independent source doctrine renders evidence
Synopsis admissible despite primary taint.
Eight defendants, who were charged in connection with
alleged drug distribution and money ... testimony
regarding statutory maximum penalty faced by 131 Criminal Law
government's witnesses was admissible; (3) government -SInevitable discovery
would be allowed to recall witnesses during its case in
chief ... dealings involving large amounts of cash was been discovered by lawful means, inevitable
admissible; (5) district court would not grant additional discovery doctrine renders evidence admissible
peremptory challenges to defendants
https://www.justice.gov/epstein/files/DataSet%208/EFTA00013373.pdf
EFTA00089964Set 9
14p5,178w
Application for Admission -Alvitlfr•AZTIO
ed About This Form Ph Am. .incwer all questions below. The application deadline for first priority review is February 15. Applicati
rfith this date ... welcome and will be reviewed on a rolling admission basis. See the "Admissions" section of the Cam
for complete application and scholarship/financial aid information. Sorry, but we cannot process ... Arnow taw be pnxessed
wither the tignantres 01Am/stens
avJ Parnurraranhan
0151.818,81, Ibis
Send Admission I hate alftlutred the eprottro ea that applies:sow to the Mr of msahrtssi /are
https://www.justice.gov/epstein/files/DataSet%209/EFTA00089964.pdf
EFTA00800173Set 9
2010-04-0519p6,165w
trial if the information sought appears reasonably calculated to lead to the
discovery of admissible evidence.
FLA. R.C1V. P 1.280(1) (emphasis added). As such, as long as the discovery ... objections, such as "relevance," "overbroad,"
and "not likely to lead to the discovery of admissible evidence" are legally impermissible, as
such objections must be set forth with specificity. See Christie ... that the sought-after
information is not reasonably calculated to lead to discovery of admissible evidence is a legally
insufficient reason to prevent discovery). In fact, "[tjhe concept of relevancy
https://www.justice.gov/epstein/files/DataSet%209/EFTA00800173.pdf
EFTA01134321Set 9
2013-06-1858p13,086w
criminal investigation or
prosecution. Such communications often necessarily involve explicit or implicit
admissions regarding their client's conduct, legal opinions, and opinions regarding
acceptable resolutions of the matter, admissions ... scrutiny of later litigation adversaries of the client) and makes
12
EFTA01134332
them admissible in evidence to be used as ammunition to harm the clients, yet that
is the very ... issue here lie well within the heartland of
Rule 410's prohibition against the admissibility of plea negotiations "against the
defendant who was a participant in the plea discussions
https://www.justice.gov/epstein/files/DataSet%209/EFTA01134321.pdf
EFTA00801993Set 9
94p19,003w
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
L.M., individually
Defendant(s).
REQUEST FOR ADMISSIONS TO JEFFREY EPSTEIN
COMES NOW the Counter-Plaintiff, Bradley J. Edwards, by and through ... undersigned counsel and propounds the following Request for Admissions pursuant to Rule
1.370 Florida Rules of Civil Procedure, requesting that Counter-Defendant, Jeffrey Epstein,
admit the truth of the facts ... within the past 10 years.
EFTA00802024
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Request for Admissions to Jeffrey Epstein
8. Admit that you have a reputation as being a billionaire
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801993.pdf
EFTA00210988Set 9
2015-04-1111p2,662w
JANE DOE NO. 2'S MOTION TO COMPEL ANSWERS TO
REQUESTS FOR ADMISSION AND REQUEST FOR PRODUCTION
COME NOW Jane Doe No. 1 and Jane Doe No. 2 (the "victims ... file this motion to compel the Government to provide answers to certain
requests for admission and requests for production involving Alan Dershowitz or, in the
alternative, to properly assert privilege ... these discovery requests.
On April 11, 2015, the victims sent a Second Request for Admissions and a Second
Request for Production to the Government, seeking to discover information relevant
https://www.justice.gov/epstein/files/DataSet%209/EFTA00210988.pdf
EFTA01103222Set 9
2013-04-2239p9,054w
also served I believe at that same time our
12 request for admissions that are the subject of
13 our motion pursuant to Rule 1.370 to deem the
14 request ... admissions admitted for failure to
15 file proper responses. Those are basically
16 the two matters before the Court. There are
17 competing memoranda, but the motions giving
18 rise ... WWW.USLEGALSUPPORT.COM
561-835-0220
EFTA01103228
1 1.370 motion to deem the request for
2 admissions admitted. That motion, the 1.370
3 motion, addresses only requests for admissions
https://www.justice.gov/epstein/files/DataSet%209/EFTA01103222.pdf
EFTA00601962Set 9
2010-09-168p1,635w
individually,
and BRADLEY J. EDWARDS,
individually,
Defendants.
DEFENDANT/COUNTERPLAINTIFF BRADLEY J. EDWARDS' REQUEST FOR.
I ADMISSIONS AND INTERROGATORY TO PLAINTIFF/COUNTERDEFENDANT
JEFFREY EPSTEIN
COMES NOW, the Defendant/Counterplaintiff, BRADLEY J. EDWARDS ... thMugh his undersigned counsel, and files this, his Request for Admissions to the
Plaintiff'Counterdefendant, JEFFREY EPSTEIN, and requests that PlaintiffiCountenlefendant
admit or deny the following facts, in accordance with ... Rule 1.370, Fla.R.Civ.P.:
ADMISSIONS
1. You have acted on a sexual preference for minor females' on multiple occasions
over the course of at least the last decade
https://www.justice.gov/epstein/files/DataSet%209/EFTA00601962.pdf
EFTA00089904Set 9
2021-11-0117p4,502w
experts in public rulings.
I. Legal standard
Federal Rule of Evidence 702 governs the admissibility of expert testimony. That rule
states:
A witness who is qualified as an expert ... facts of the case.
The Court exercises a "gatekeeper function" in assessing the admissibility of expert
testimony. Restivo v. Hessemann, 846 F.3d 547, 575 (2d Cir. 2017). To determine whether ... Rule 702 ultimately sets a "liberal" and "permissive" standard of admissibility.
Nimely v. City of New York, 414 F.3d 381, 395-96 (2d Cir. 2005). In particular, not every expert
https://www.justice.gov/epstein/files/DataSet%209/EFTA00089904.pdf