EFTA00091353Set 9
2014-12-3024p10,201w
extent they are overly broad, unduly
burdensome and/or propounded for the improper purpose of annoying, embarrassing, or
harassing Ms. Maxwell.
7. Ms. Maxwell objects to the Requests to the extent ... certain of the Requests, is intended for the improper purpose of annoying or
harassing Ms. Maxwell and it implicates her privacy rights. Thus, Ms. Maxwell interprets the
Relevant Period ... grounds that it is unduly
burdensome and is intended for the improper purpose of annoying or harassing Ms. Maxwell.
Ms. Maxwell cannot possibly recall the specific disposition of documents, particularly
https://www.justice.gov/epstein/files/DataSet%209/EFTA00091353.pdf
EFTA00022960Set 8
2020-06-1020p5,494w
that should not be
submitted to courts because of their potential for abuse.
3. Annoyance, embarrassment, oppression, undue burden ("CI-3").
Materials that cause annoyance, embarrassment, oppression or undue burden ... party (CI-1).
Prevention of the abuse of court records and files (CI-2). Annoyance,
embarrassment, oppression, undue burden (CI-3). Preserving the
fundamental rights of suspects or others under ... party or non-party, Prevention of the abuse of court records and files,
Annoyance, embarrassment, oppression, undue burden, Preserving the fundamental rights of
suspects or others under criminal investigation
https://www.justice.gov/epstein/files/DataSet%208/EFTA00022960.pdf
EFTA00075004Set 9
2020-06-1020p5,220w
that should not be
submitted to courts because of their potential for abuse.
3. Annoyance, embarrassment, oppression, undue burden ("CI-3").
Materials that cause annoyance, embarrassment, oppression or undue burden ... party (CI-1).
Prevention of the abuse of court records and files (CI-2). Annoyance,
embarrassment, oppression, undue burden (CI-3). Preserving the
fundamental rights of suspects or others under ... party or non-party, Prevention of the abuse of court records and files,
Annoyance, embarrassment, oppression, undue burden, Preserving the fundamental rights of
suspects or others under criminal investigation
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075004.pdf
EFTA00158017Set 9
2009-11-06187p19,717w
that?
4 A. She got annoyed.
5 Q. What do you mean, "she got annoyed?"
6 A. She got annoyed and she told me that she had
7 found ... know -- I'm not understanding
9 what you mean when you said, "she got annoyed."
10 A. She got annoyed with the people that were
11 there. And at that ... Maybe 14, going on 15.
18 Q. So your daughter says she's annoyed with
19 school. What's your reaction to that? What was your
20 reaction
https://www.justice.gov/epstein/files/DataSet%209/EFTA00158017.pdf
EFTA01107639Set 9
2013-01-0914p2,871w
grant protective orders "for good cause shown" and "to protect a party from
annoyance embarrassment, oppression, or undue burden or expense that justice
requires." FI.A. R.Civ ... bears the burden of showing the requisite "good cause," as well as the alleged
"annoyance, embarrassment, oppression, or undue burden." See Sabol v. Bennett 672
So.2d ... Protective Order.
and wholly disregards the requirement that he properly establish the alleged
annoyance,
embarrassment, oppression, or undue burden. Edwards asserts impermissible
one-word.
conclusory objections in support
https://www.justice.gov/epstein/files/DataSet%209/EFTA01107639.pdf
EFTA00812184Set 9
102p54,227w
flows , stock accts, structures. sales Etc) and
me and each time with my many annoying calls to you made immediately afterwards that she was
g y !! No one was hired ... flows , stock accts, structures. sales Etc) and
me and each time with my many annoying calls to you made immediately afterwards that she was
g y !! No one was hired ... apollo. (1031 exchange blown etc) at this time
as I recall you got quite annoyed, and agressive and initiated the" talking out of the both sides of your
mouth " tiddy
https://www.justice.gov/epstein/files/DataSet%209/EFTA00812184.pdf
EFTA00838368Set 9
2018-04-0867p54,266w
flows , stock accts, structures. sales Etc) and me. and each time with my
many annoying calls to you made immediately afterwards that she was g y !! No one was hired ... flows , stock accts, structures. sales Etc) and me. and each time with my
many annoying calls to you made immediately afterwards that she was g y !! No one was hired ... apollo. (1031
exchange blown etc) at this time
as I recall you got quite annoyed, and agressive and initiated the" talking out of the both sides of your mouth "
tiddy
https://www.justice.gov/epstein/files/DataSet%209/EFTA00838368.pdf
EFTA00023557Set 8
2009-12-0467p24,313w
beyond that an inquiry
9 is intended for no other purpose except to
10 annoy, harass, and embarrass.
I1 MR. LUTTIER: With all due respect, I
12 disagree ... /Cl/Documents%20and%20SettingsfProduction/Desktop "120Vol.%208.ixt[12/11/2009 6:15:58 PM]
EFTA00023561
12 annoy, embarrass, and harass the witness.
13 MR. LUTTIER: It's, it's not intended ... annoying. I believe the degree of frequency
15 is absolutely relevant in the case.
16 MR. SCAROLA: To what -- to which element?
17 MR. LUTTIER: Arguable -- well --
18 MR. SCAROLA
https://www.justice.gov/epstein/files/DataSet%208/EFTA00023557.pdf
EFTA00595377Set 9
2013-03-1117p3,664w
raised in our motion for
16 protective order were on the grounds of annoyance,
17 embarrassment, oppression, undue burden. We've only
18 raised issues as delineated in Rule ... issuance of protective order
4 only to protect a party or person from annoyance,
5 embarrassment, oppression or undue burden or
6 expense.'" It does not refer to privilege ... challenging 12:11 days 3:23,24 4:13,14,23
12:8,10
annoyance 6:16 7:4 CIRCUIT 1:1,1 6:6 filing
https://www.justice.gov/epstein/files/DataSet%209/EFTA00595377.pdf
EFTA02323447Set 11
2011-07-292p268w
workers, so that
makes it easy, but he can be ve=y annoying. Maybe he will step it up since JE called ... wrote:
>» I agree... Is he being annoying?
>»
>» On Jul 29, 2011, at 5:01PM, wrote:
>>» Unbelievable.
>>»
>>» On Jul 29, 2011, at 4:52 PM wrote:
>>»
»>» Penn has not showed ... annoying.
>>>»
>»» Sent from Story's iPhone
>>>»
>>>»
>»» On Jul 29, 2011, at 4:51 PM, > wrote:
>>>»
>>»» Ok. Going over things with JE. Did penn ever show? Je just called
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02323447.pdf
EFTA00076383Set 9
2016-04-2178p17,141w
that the material concerns personal
24 matters that, if released, might lead to annoyance or
25 embarrassment, that the material was abusively filed or is
SOUTHERN DISTRICT REPORTERS ... argument that the material
4 constitutes personal information which might lead to annoyance
5 or embarrassment if unsealed, Ms. Maxwell proffers little more
6 than her ipsi dixit; she provides ... trafficking of
12 young girls, the Court finds that any minor embarrassment or
13 annoyance resulting from disclosure of Ms. Maxwell's mostly
14 nontestimony about behavior that has been
https://www.justice.gov/epstein/files/DataSet%209/EFTA00076383.pdf
EFTA00075477Set 9
2020-08-2074p15,469w
that the material concerns personal
24 matters that, if released, might lead to annoyance or
25 embarrassment, that the material was abusively filed or is
SOUTHERN DISTRICT REPORTERS ... argument that the material
4 constitutes personal information which might lead to annoyance
5 or embarrassment if unsealed, Ms. Maxwell proffers little more
6 than her ipsi dixit; she provides ... trafficking of
12 young girls, the Court finds that any minor embarrassment or
13 annoyance resulting from disclosure of Ms. Maxwell's mostly
14 nontestimony about behavior that has been
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075477.pdf
EFTA00074941Set 9
2020-07-2317p3,908w
that the material concerns personal
24 matters that, if released, might lead to annoyance or
25 embarrassment, that the material was abusively filed or is
SOUTHERN DISTRICT REPORTERS, P.C.
EFTA00074943 ... argument that the material
4 constitutes personal information which might lead to annoyance
5 or embarrassment if unsealed, Ms. Maxwell proffers little more
6 than her ipsi dixit; she provides ... trafficking of
12 young girls, the Court finds that any minor embarrassment or
13 annoyance resulting from disclosure of Ms. Maxwell's mostly
14 nontestimony about behavior that has been
https://www.justice.gov/epstein/files/DataSet%209/EFTA00074941.pdf
EFTA00514416Set 9
2016-08-0818p2,432w
Sender:
Partici ants: , (
), Self (
Someone is annoyed with me
iMessage
2016-08-10 01:39:23 (UTC) [11
Sender:
Partici ants: ),
), Scl1(
Someone is annoyed with me
EFTA00514424
iMessage ... Sender: )
Participants: , (
), Self ( )
Someone is annoyed with me
iMessage
2016-08-10 01:39:31 UTC 1
Sender: ( )
Partici ants:
), Self (
I covered her sofa
iMessage
https://www.justice.gov/epstein/files/DataSet%209/EFTA00514416.pdf
EFTA00516308Set 9
2018-09-1719p2,769w
Sender:
Participants: ( ), Self ( e:jeeitunes@gmail.com )
Sony a little
Annoying
I know your time is valuable
iMessage
2018-09-17 20:27:53 UTC [8
Sender:
Participants: ( ), Self ( e:jeeitunes@gmail.com )
Sony ... little
Annoying
I know your time is valuable
iMessage
2018-09-17 20:27:53 UTC [9
Sender:
Participants: ( ), Self ( e:jeeitunes@gmail.com )
Sony a little
Annoying
I know your time
https://www.justice.gov/epstein/files/DataSet%209/EFTA00516308.pdf
EFTA00221676Set 9
2008-09-2910p2,202w
deposition by Epstein's attorney more than once would be unduly
traumatizing, burdensome, annoying, harassing and, most importantly, unnecessary. There is no
-1-
EFTA00221676
Case ... good cause, issue an
order to protect a party or person from annoyance, embarrassment, oppression or undue burden or
expense."
The federal rules expressly recognize that a party should ... contrary to
judicial economy and efficiency, and would serve only to unduly harass, annoy and burden her.
Defendant's counsel has offered no reason whatsoever why Jane
https://www.justice.gov/epstein/files/DataSet%209/EFTA00221676.pdf
EFTA02323625Set 11
2011-07-292p467w
workers, so that makes it easy,
» but =e can be very annoying. Maybe he will step it up since JE called ... Story Cowles =rote:
>>»
> » I agree... Is he being annoying?
>>>»
>»» On Jul 29, 2011, at 5:01PM,note:
>>>»
>>»» Unbelievable.
EFTA_R1_01238587
EFTA02323625
>>>>»
>>»» On Jul 29, 2011, at 452 PM, =rote ... Penn has not showed yet.
>>>»» So annoying.
>>>>>>>
>»>>» Sent from Story's iPhone
>>>>>»
>>>>>»
>>>»» On Jul 29, 2011, at 4:51 PM, wrote:
>>>>>»
>>>>»» Ok. Going over things with JE. Did penn ever
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02323625.pdf