Epstein Files Search

EFTA01118445Set 9

2009-08-1911p2,971w

Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION lead to the discovery of admissible evidence;protected by privacy rights 11995 08/19/2009 Carl Linder Bradley Edwards Litigation Strategy Work Product ... attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 12012 10/21/20009 Carl Linder Bradley Edwards Litigation Strategy Work Product;attorney client ... privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 11879 10/21/2009 ±ar nes , Bradley Edwards Litigation Strategy Work Product;attorney client privilege;irrelevant

https://www.justice.gov/epstein/files/DataSet%209/EFTA01118445.pdf

EFTA00593906Set 9

2015-12-2948p14,557w

Document Request propounded by Plaintiffs. Defendant further reserves the right to object to the admission in evidence of any and all information made available in response to the Document Request ... Defendant does not concede that any document requested is relevant to this action or admissible at trial. Defendant objects to the extent that any documents that might be responsive ... Document Request is not reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to the production of personal financial information prematurely in this action and without appropriate

https://www.justice.gov/epstein/files/DataSet%209/EFTA00593906.pdf

EFTA00604949Set 9

22p6,541w

Interrogatory propounded by Plaintiffs. Defendant further reserves the right to object to the admission in evidence of any and all information made available in response to the Interrogatories ... Defendant does not concede that any document requested is relevant to this action or admissible at trial. Defendant objects to the extent that any information that might be responsive ... litigation and the Interrogatory is not reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to the production of personal financial information prematurely in this action

https://www.justice.gov/epstein/files/DataSet%209/EFTA00604949.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

EFTA00799381Set 9

2010-04-0521p6,732w

trial if the information sought appears reasonably calculated to lead to the discovery of admissible evidence. FLA. R.Ciu. 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. 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, "[t]he concept

https://www.justice.gov/epstein/files/DataSet%209/EFTA00799381.pdf

EFTA00802139Set 9

2010-04-0521p6,734w

trial if the information sought appears reasonably calculated to lead to the discovery of admissible evidence. FLA. R.Civ. 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. 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, "[t]he concept

https://www.justice.gov/epstein/files/DataSet%209/EFTA00802139.pdf

EFTA00585352Set 9

2010-04-0521p6,736w

trial if the information sought appears reasonably calculated to lead to the discovery of admissible evidence. FLA. R.Ciu. 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. 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, "[t]he concept

https://www.justice.gov/epstein/files/DataSet%209/EFTA00585352.pdf

EFTA00801142Set 9

96p18,171w

That would 5 be item 11. Edwards's motion to compel 6 request for admission answers; and item 7 three, the first half of it. I think item 8 three ... Amendment privilege for this particular 18 question, this interrogatory, this request 19 for admission, then I would be happy to 20 address that. 21 It is what it is right ... whom the request for admission is sent to 7 have personal knowledge of the contents. 8 Your Honor, I could send a request for 9 admission and attach a copy

https://www.justice.gov/epstein/files/DataSet%209/EFTA00801142.pdf

EFTA00209657Set 9

2013-08-0575p16,720w

Page: 21 of 75 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 ... other litigation and then to public disclosure, they will necessarily refrain from making admissions and concessions, either of fact or law, which could later harm their clients. Thus ... 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

https://www.justice.gov/epstein/files/DataSet%209/EFTA00209657.pdf

EFTA01072194Set 9

2013-06-1858p13,073w

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 EFTA01072205 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/EFTA01072194.pdf

EFTA01395162Set 10

2018-04-11132p33,160w

Subject to Subsequent Drawdown 15 6.2.1 Unused Contributions. 15 6.2.2 Return of Contributions upon Admission of Additional Partner. 16 6.2.3 Effect of Return of Contributions. 16 Failure to Make Required ... Deduction. 25 8.2.3 Allocations Following a Default 25 Other Specially Allocated Items. 25 Admission of Additional Partners. 25 ARTICLE 9 - DURATION OF THE PARTNERSHIP 26 9.1 Term of Partnership ... Opinion of Counsel. 30 11.1.8 Reimbursement of Transfer Expenses. EFTA01395169 30 11.2 Admission of Substituted Limited Partners. 30 11.2.1 General. 30 Glendower Access Secondary Opportunities IV (U.S.), L.P. Amended

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01395162.pdf

EFTA01440323Set 10

2018-04-11132p33,160w

Subject to Subsequent Drawdown 15 6.2.1 Unused Contributions. 15 6.2.2 Return of Contributions upon Admission of Additional Partner. 16 6.2.3 Effect of Return of Contributions. 16 Failure to Make Required ... Deduction. 25 8.2.3 Allocations Following a Default 25 Other Specially Allocated Items. 25 Admission of Additional Partners. 25 ARTICLE 9 - DURATION OF THE PARTNERSHIP 26 9.1 Term of Partnership ... Opinion of Counsel. 30 11.1.8 Reimbursement of Transfer Expenses. EFTA01440330 30 11.2 Admission of Substituted Limited Partners. 30 11.2.1 General. 30 Glendower Access Secondary Opportunities IV (U.S.), L.P. Amended

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01440323.pdf

EFTA01443654Set 10

2018-04-11132p33,160w

Subject to Subsequent Drawdown 15 6.2.1 Unused Contributions. 15 6.2.2 Return of Contributions upon Admission of Additional Partner. 16 6.2.3 Effect of Return of Contributions. 16 Failure to Make Required ... Deduction. 25 8.2.3 Allocations Following a Default 25 Other Specially Allocated Items. 25 Admission of Additional Partners. 25 ARTICLE 9 - DURATION OF THE PARTNERSHIP 26 9.1 Term of Partnership ... Opinion of Counsel. 30 11.1.8 Reimbursement of Transfer Expenses. EFTA01443661 30 11.2 Admission of Substituted Limited Partners. 30 11.2.1 General. 30 Glendower Access Secondary Opportunities IV (U.S.), L.P. Amended

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01443654.pdf

EFTA01442234Set 10

2018-04-11132p33,224w

Subject to Subsequent Drawdown 15 6.2.1 Unused Contributions. 15 6.2.2 Return of Contributions upon Admission of Additional Partner. 16 6.2.3 Effect of Return of Contributions. 16 Failure to Make Required ... Deduction. 25 8.2.3 Allocations Following a Default 25 Other Specially Allocated Items. 25 Admission of Additional Partners. 25 ARTICLE 9 - DURATION OF THE PARTNERSHIP 26 9.1 Term of Partnership ... Opinion of Counsel. 30 11.1.8 Reimbursement of Transfer Expenses. EFTA01442241 30 11.2 Admission of Substituted Limited Partners. 30 11.2.1 General. 30 Glendower Access Secondary Opportunities IV (U.S.), L.P. Amended

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01442234.pdf

EFTA00808277Set 9

62p33,509w

Partnership 2 2.4 Events Affecting the General Partner 2 ARTICLE 3 NAME AND ADMISSION OF PARTNERS 2 3.1 Name and Address 2 3.2 Admission of Additional Partners 2 3.3 Removal ... Partner Preamble Governmental Plan Partner 13.2 Indemnified Parties 15.4 Initial Closing Date Preamble Late Admission Charge 3.2(c) Limited Partners Preamble Loss 14.16 Majority in Interest 14.14 Management Company ... dissolution by the General Partner or any successor entity thereto. ARTICLE 3 NAME AND ADMISSION OF PARTNERS 3.1 Name and Address. The name and address of the General Partner

https://www.justice.gov/epstein/files/DataSet%209/EFTA00808277.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

EFTA00221909Set 9

2009-07-1020p5,672w

pending action nor does it appear reasonably calculated to lead to the discovery of admissible evidence. This Court should order Epstein to answer all of these interrogatories ... this interrogatory is somehow "overbroad" or "not calculated to lead to the discovery of admissible evidence" even facially plausible. Epstein's "cut and paste" response to the interrogatories also blatantly ... pending action nor does it appear reasonably calculated to lead to the discovery of admissible evidence. 8 EFTA00221916 Case 9:08-cv-80119-KAM Document 196 Entered on FLSD Docket

https://www.justice.gov/epstein/files/DataSet%209/EFTA00221909.pdf

EFTA00105954Set 9

2021-10-1112p2,803w

Comply with the Rule 404(b) Notice Requirement, the Government Has Waived the Admission of Any Evidence Pursuant to the Rule 4 II. Should the Government's Failure Be Excused ... exact evidence to be offered, an articulated non-propensity purpose for its admission, and the reasoning supporting that purpose. Despite notice of the rule change and an opportunity to comply ... proof. Easy to overlook is that the judge too needs time to consider the admissibility of the other act evidence." See Wright & Miller, 22B Fed. Prac. & Proc. Evid

https://www.justice.gov/epstein/files/DataSet%209/EFTA00105954.pdf

EFTA01143880Set 9

2013-04-2215p6,284w

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 ... filed our Rule 0008 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/EFTA01143880.pdf

EFTA00803113Set 9

2017-03-31158p39,273w

committed 20 years ago. And your Honor, even 3 criminal convictions are generally not admissible 10 years 4 after the fact. So presentation of this type of evidence ... this is, it's a device to try to get an improper admission SOUTHERN DISTRICT REPORTERS, P.C. EFTA00803141 H3VOGIU1 30 1 of a settlement amount between Ms. and Jeffrey Epstein ... response. Defendant here does not 18 cite a single case where a court allowed admission of unrelated 19 and irrelevant medical records into evidence at trial. 20 Defendant's brief

https://www.justice.gov/epstein/files/DataSet%209/EFTA00803113.pdf