EFTA00585394Set 9
2010-03-2326p10,566w
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 ... examination, Edwards refused to answer numerous questions to which
he, his counsel, or both, objected. Most of the objections asserted by Edwards's counsel were
impermissibly verbose, suggestive objections that ... Edwards was again asked all of the questions to which he initially objected, and both he
and his counsel asserted the same objections'. As demonstrated more fully below, there
https://www.justice.gov/epstein/files/DataSet%209/EFTA00585394.pdf
EFTA01416838Set 10
2017-06-19122p23,787w
interim, 5,310 Class members submitted claims under the settlement, 23
class
members objected to the settlement, and 123 opted out. P. Mot. Final
Approval Settlement
Agreement, Supp. Decl. Matthew ... Supp. Mot. Approve
Settlement
("Supp. McDermott Decl."), ECF No. 107-1 ¶¶ 13-18. No objections were raised
at the
fairness hearing.
A. The N14 Class
The settlement agreement defines ... fees and expenses.
ECF No. 693
Ex. 1 ¶ VIII.B. Defendants will not object to an award of up to $1,820,000.
Id. Class
Counsel may also move for service
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01416838.pdf
EFTA01592062Set 10
10p2,267w
ZWIRN HOLDINGS, LLC,
and DANIEL ZWIRN,
Third-Party Respondents.
RESPONSES AND OBJECTIONS
OF NON-PARTY GLENN DUBIN TO THE
SUBPOENA DUCES TECUM DATED NOVEMBER 9,2010
Non-party Glenn Dubin ... Dubin") hereby objects and responds as follows to
Third-Party Respondents' subpoena dated November 9,2010 (the "Subpoena").
Dubin
makes this response without in any way waiving any objections ... reserves
all potential
objections, including:
EFTA01592062
1.
all questions as to competency, relevancy, materiality, privilege, and
admissibility as evidence for any purpose, at any trial or hearing in this
case
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01592062.pdf
EFTA01724063Set 10
100p15,941w
IIIII
11 during that massage; isn't that
12 true?
13 MR. III/: Same objections,
14 argumentative, speculation, harassing,
15 assumes facts not in evidence and lacks
16 predicate ... front of her; isn't that
9 true?
10 MR. IIII: Same objections?
11 A Unfortunately, though I would like to
12 answer each one of your questions here today ... true that while you were
EFTA01724065
115
1
2 14-year old
3 MR. Objection, argumentative.
4 Speculation. It is harassing. It assumes
5 facts not in evidence. The question
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01724063.pdf
EFTA00798060Set 9
2017-09-0528p10,660w
period in question, any termination thereof and the reasons for
such change.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to
lead to the discovery ... Interrogatories. Reference to "the period in question" is vague and ambiguous.
Counter-Plaintiff further objects on the grounds that the number of interrogatories propounded by the
Counter-Defendant including subparts ... income, profits, distributions, salary, commission, or bonus paid in connection
with such affiliation.
RESPONSE: Objection: The information sought is not relevant, material or reasonably calculated to
lead to the discovery
https://www.justice.gov/epstein/files/DataSet%209/EFTA00798060.pdf
EFTA00800173Set 9
2010-04-0519p6,165w
individually.
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO STRIKE
DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S DISCOVERY
OBJECTIONS AND COMPEL RESPONSES THERETO
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned
counsel ... hereby
requests that this Court enter an Order Striking Defendant/Counter-Plaintiff Bradley Edwards's
("Edwards") Objections to Epstein's Discovery Requests' and Compelling Edwards to produce
documents and/or Interrogatory responses responsive ... respectively, Edwards served his responses thereto.2
As explained more fully below, Edwards's objections to Epstein's Requests are legally
insufficient as a matter of law, and as such said
https://www.justice.gov/epstein/files/DataSet%209/EFTA00800173.pdf
EFTA00585373Set 9
2010-04-0521p6,735w
individually.
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO STRIKE
DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S DISCOVERY
OBJECTIONS AND COMPEL RESPONSES THERETO
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned
counsel ... hereby
requests that this Court enter an Order Striking Defendant/Counter-Plaintiff Bradley Edwards's
("Edwards") Objections to Epstein's Discovery Requests' and Compelling Edwards to produce
documents and/or Interrogatory responses responsive ... respectively, Edwards served his responses thereto.2
As explained more fully below, Edwards's objections to Epstein's Requests are legally
insufficient as a matter of law, and as such said
https://www.justice.gov/epstein/files/DataSet%209/EFTA00585373.pdf
EFTA00802391Set 9
2010-04-0520p6,559w
individually.
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO STRIKE
DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S DISCOVERY
OBJECTIONS AND COMPEL RESPONSES THERETO
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned
counsel ... hereby
requests that this Court enter an Order Striking Defendant/Counter-Plaintiff Bradley Edwards's
("Edwards") Objections to Epstein's Discovery Requests' and Compelling Edwards to produce
documents and/or Interrogatory responses responsive ... respectively, Edwards served his responses thereto.2
As explained more fully below, Edwards's objections to Epstein's Requests are legally
insufficient as a matter of law, and as such said
https://www.justice.gov/epstein/files/DataSet%209/EFTA00802391.pdf
EFTA01695773Set 10
100p15,504w
that conduct took
7 place on more than 50 occasions?
8 MR. PIKE: Same objections.
9 A I believe if you read your own client's
10 FBI statements, what ... fraud, just
25 happens to be true, isn't'it?
EFTA01695773
124
1 MR. Objection, argumentative,
2 irrelevant and move to strike. I'm simply
3 going to instruct ... about that, that
13 anybody has fabricated or made up, is there?
14 MR. Objection, argumentative,
15 speculative, it assumes facts not in
16 evidence, it certainly mischaracterizes
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01695773.pdf
EFTA00594390Set 9
2015-10-17184p37,372w
record. Sigrid McCawley from Boies, Schiller &
12 Flexner, and I have a standing objection that I'd
13 just like to repeat on the record.
14 MR. SCOTT: Feel better ... waiving it through
20 any testimony here today, and that I object to
21 any testimony elicited that would be used as a
22 subject of waiver for her attorney/client ... meeting, did you
18 discuss Professor Dershowitz?
19 MS. McCAWLEY: I'm going to object to any
20 discussion of what my client told you during any
21 situation where
https://www.justice.gov/epstein/files/DataSet%209/EFTA00594390.pdf
EFTA00621488Set 9
2011-03-15117p29,066w
need to make today. We believe we have good
19 grounds on these TIG objections. It is close to
20 what should have been accomplished over the last ... thumbs down.
The judge, generally, in the absence of an
8 objection is pretty much bound by what I do.
9 If we have an objection, the court, of course ... assuming that nobody
19 has a big objection or is filing objections on
20 this and the initial objections would probably
21 come out of the defense side
https://www.justice.gov/epstein/files/DataSet%209/EFTA00621488.pdf
EFTA00801142Set 9
96p18,171w
seat.
7 Thank you all. When it comes to the
8 deposition excerpts and objections, I am
9 treating this case as I would any other case
10 in that ... where I will take the deposition home. I
6 will review the objected-to questions. And
7 as I said, I will announce my rulings, of
8 course, but only ... preparing for today and thinking about doing
18 the questions and the objections and looking
19 at our objections, frankly, I think they are
20 overdone. And we can save
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801142.pdf
EFTA00611238Set 9
2009-07-2242p32,388w
SCAROLA: Excuse me, is the question 4 MR. SCAROLA: I am going to object to the
5 limited to the testimony — 5 form of the question. It assumes facts ... plane or any, on his plane or with him in any 24 MR. SCAROLA: Objection, work-product.
25 fashion, in any other manner? 25 Instruct you to not answer.
zatetwe ... meet with the same
9 Q. Well, if you wanted investigation done on 9 objection and same instruction.
10 Mr. Epstein, how would you go about authorizing that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00611238.pdf
EFTA00078532Set 9
46p19,969w
VISA Credit (W/Rewards points) seeking both the generation of
income and growth ofpringpat
Account Objectives and Risk Profile A senor parka% °fiscalis
defined as a cynemor or vice
Account Risk ... Risk Tolerance High Risk Staff, Member of Congress or
a Patkament Chairperson,
Ir Investment Objective
Risk/Return Objectives
Produce a combination of income and capital
appreciation
Higher Fluctuations, Higher Returns
Head ... account risk
profile and investment
UBS will not disclose your name, address and security objective below are specific only
Disclosure of Beneficial Ownership position to issuers of any securities held
https://www.justice.gov/epstein/files/DataSet%209/EFTA00078532.pdf