EFTA01660040Set 10
2015-03-0437p25,087w
Default by
Clerk Against Defendant (tp) (Entered: 06/06/2008)
06/11/2008 9 Plaintiff's MOTION to Compel Clerk to Enter Default Against Defendant, or Alternatively, for
an Enlgargement of Time to Serve ... Jack) (Entered: 06/13/2008)
06/13/2008 11 RESPONSE to Motion re 9 Plaintiff's MOTION to Compel Clerk to Enter Default Against
Defendant, or Alternatively, for an Enlgargement of Time to Serve ... Jack) (Entered: 06/20/2008)
06/24/2008 14 MEMORANDUM in Support re 9 Plaintiff's MOTION to Compel Clerk to Enter Default Against
Defendant, or Alternatively, for an Enlgargement of Time to Serve
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01660040.pdf
EFTA00723218Set 9
2009-12-0977p19,203w
Epstein's Response in Opposition to
before Your Honor on December
Inspection and to Compel Discovery, which are set for hearing
14, 2009 at 8:30 a.m. The case ... JEFFREY EPSTEIN,
Defendants.
EPSTEIN'S RESPONSE IN OPPOSITION TO MOTION FOR INSPECTION AND TO
COMPEL DISCOVERY AND MOTION FOR PROTECTIVE ORDER AND
INCORPORATED MEMORANDUM OF LAW
Defendant, JEFFREY EPSTEIN ("Epstein ... attorneys, hereby files his Response in Opposition to Plaintiffs, ("."), Motion for
Inspection and to Compel Discovery (Photographs) (the "Request") (attached as
Exhibit "A") and further moves for a protective order
https://www.justice.gov/epstein/files/DataSet%209/EFTA00723218.pdf
EFTA00623075Set 9
2016-06-0140p11,688w
Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
RESPONSE TO MOTION TO COMPEL ATTORNEY-CLIENT COMMUNICATIONS
AND ATTORNEY WORK PRODUCT MATERIALS
BOLES, SCHILLER & FLEXNER LLP
Sigrid McCawley ... through her undersigned counsel, hereby files this
response to Defendant's Motion to Compel All Attorney-Client Communications and Attorney
Work Product Placed at Issue by Plaintiff and Her Attorneys ... client's ( ) attorney-client
privilege. On September 8, 2015, Dershowitz filed a motion to compel Cassell and Edwards to
produce documents and additional responses to interrogatories. McCawley Decl., Exhibit
https://www.justice.gov/epstein/files/DataSet%209/EFTA00623075.pdf
EFTA00317211Set 9
2010-02-0437p13,297w
against testimonial compulsion and provides,
in relevant part, that "[n]o person...shall be compelled in any Criminal Case to be a witness
against himself" (DE 242, p.5); see also ... Worthington Industries Inc 670 F Supp2d 1048 (CD Cal,
2009) rejected motion to compel in helpful language:
"A valid assertion of the privilege does not require an imminent criminal prosecution ... producing documents in response to a subpoena
or production request has a compelled testimonial aspect in that it would constitute an implied
admission as to the defendant's possession
https://www.justice.gov/epstein/files/DataSet%209/EFTA00317211.pdf
EFTA01099525Set 9
2014-01-28140p21,399w
Disposition Amount:
Docket Text: & SUPPORTING LEGAL AUTHORITIES IN OPPOSITION. . .
61 MCMP - MOTION TO COMPEL
Filing Date: 10-MAY-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: BRADLEYY EDWARDS ... Party: EPSTEIN, JEFFREY
Disposition Amount:
CORRECTED EXHIBIT D AS CITED IN PLTF MOTION TO COMPEL . .
Docket Text:
64 NOH - NOTICE OF HEARING I
Filing Date: 11-MAY-2010
Filing Party ... CRITTON JR , ESQ, ROBERT DEWEESE
Disposition Amount:
5120/10 8:45 AM EPSTEIN MOTION TO COMPEL BRADLEY
Docket Text:
EDWARDS TO APPEAR FOR FOLLOWUP DEPO
65 il RESP - RESPONSE TO:
Filing
https://www.justice.gov/epstein/files/DataSet%209/EFTA01099525.pdf
EFTA01117340Set 9
2010-02-0437p13,297w
against testimonial compulsion and provides,
in relevant part, that "[n]o person...shall be compelled in any Criminal Case to be a witness
against himself" (DE 242, p.5); see also ... Worthington Industries Inc 670 F Supp2d 1048 (CD Cal,
2009) rejected motion to compel in helpful language:
"A valid assertion of the privilege does not require an imminent criminal prosecution ... producing documents in response to a subpoena
or production request has a compelled testimonial aspect in that it would constitute an implied
admission as to the defendant's possession
https://www.justice.gov/epstein/files/DataSet%209/EFTA01117340.pdf
EFTA00211776Set 9
2007-07-1026p13,262w
JEFFREY EPSTEIN
TO INTERVENE AND TO QUASH GRAND JURY SUBPOENAS
AND CROSS-MOTION TO COMPEL
UNDER SEAL
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
IN RE GRAND JURY SUBPOENAS ... JEFFREY EPSTEIN
TO INTERVENE AND TO QUASH GRAND JURY SUBPOENAS
AND CROSS-MOTION TO COMPEL
The United States of America, by and through the undersigned Assistant United States Attorney, hereby ... F.2d 1237 (9th Cir. 1989). Accordingly, the
United States asks the Court to compel the witnesses to appear before the grand jury on the next available date.
Epstein's counsel
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211776.pdf
EFTA00208185Set 9
2012-05-0822p5,666w
BRADLEY J. EDWARDS, individually,
Defendants/Counter-Plaintiffs.
ORDER ON PLAINTIFF JEFFREY EPSTEIN'S
MOTION TO COMPEL AND AMEND PROTECTIVE ORDER
THIS MATTER came before the Court on PlaintiffJeffrey Epstein's Motion ... Compel and
Amend Protective Order in the above-styled case. This Court having reviewed the Motion, having
heard argument of counsel, and being otherwise fully advised in the premises ... hereby
ORDERED AND ADJUDGED as follows: The Motion seeks to Compel a Request to
Produce and to modify this Court's prior Protective Order in regard to specific requests
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208185.pdf
EFTA00222442Set 9
2010-02-0424p7,883w
support, Epstein states:
I. Procedural Background
Plaintiffs Motion to Compel is filed at DE (194). Defendant's Response in Opposition is
filed at DE (339), and the arguments set forth ... guarantee against testimonial compulsion and provides,
in relevant part, that "[tic) person...shall be compelled in any Criminal Case to be a witness
against himself." (DE 242, p.5); see also ... producing documents in response to a subpoena or production request has a compelled
testimonial aspect. See United States v. Hubbell, 530 U.S. 27, 35-36 (2000). Thus, where the
existence
https://www.justice.gov/epstein/files/DataSet%209/EFTA00222442.pdf
EFTA00211439Set 9
2016-05-2225p16,498w
future please select the proper event. (Is)
(Entered: 08/20/2008)
08/21/2008 26 ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER. Signed by Judge Kenneth A.
Marra on 8/21/08. (ir) (Entered: 08/21/2008)
08/22/2008 ... Stay by Jane Doe. (Edwards, Bradley) (Entered: 12/05/2011)
12/05/2011 130 MOTION Protective Motion to Compel Jane Doe #1 and Jane Doe #2 Protective Motion to
Compel by Jane Doe. (Attachments ... Response/Reply as to 128 Motion for
Miscellaneous Relief, 127 Response/Reply (Other), 130 Motion to Compel, 129
Respon e/Re I Other) by United States of America. (Attachments: # 1 Text of Proposed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211439.pdf
EFTA00800218Set 9
2019-02-2535p19,674w
event. (Is) (Entered: 08/20/2008)
08/21/2008 26 ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER. Signed by Judge
Kenneth A. Marra on 8/21/08. (ir) (Entered: 08/21/2008)
08/22/2008 22 TRANSCRIPT of Hearing held ... Stay by Jane Doe. (Edwards, Bradley) (Entered: 12/05/2011)
12/05/2011 130 MOTION Protective Motion to Compel Jane Doe #1 and Jane Doe #2 Protective Motion
to Compel by Jane Doe. (Attachments ... Motion
for Miscellaneous Relief, 122 Response/Reply (Other),1,1Q Motion to Compel, i22
Response/Reply (Other) by United States of America. (Attachments: # 1 Text of Proposed
Order)(Lee, Dexter) (Entered: 12/15/2011
https://www.justice.gov/epstein/files/DataSet%209/EFTA00800218.pdf
EFTA01116869Set 9
81p40,653w
nothing of value, because the creditors (in the
child's stead) could not compel the trustee to make (and thus the
trustee would be unlikely to make) any distributions. Thus ... interest
that protects the trust assets against creditors' claims. Because the
beneficiary could not compel trust distributions, neither can the
beneficiary's creditors.'
C. Traditional Rules Regarding Creditors' Rights ... however, that the beneficiary of a discretionary trust can never
compel distributions. Under some circumstances a trustee's refusal to make distributions
under a wholly discretionary standard might be considered
https://www.justice.gov/epstein/files/DataSet%209/EFTA01116869.pdf
EFTA00091353Set 9
2014-12-3024p10,201w
resolution of dispositive motions.
Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will
Defendant move for a Protective Order with regard ... resolution of dispositive motions.
Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will
12
EFTA00091364
Defendant move for a Protective Order with ... resolution of dispositive motions.
Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will
Defendant move for a Protective Order with regard
https://www.justice.gov/epstein/files/DataSet%209/EFTA00091353.pdf