EFTA01200390Set 9
2015-07-0651p13,320w
AMERICA,
Respondent.
OPINION AND ORDER
This cause is before the Court on various discovery related matters. In response to
Petitioners' first requests for production, the respondent Government asserted various privileges ... Discussion
District courts have "broad discretion in shaping the scope of discovery under
26(b)." Williams v. City of Dothan, 745 F.2d 1406, 1415 (11th Cir. 1984). The
Court will ... first address matters related to whether a privilege protects the submitted documents
from discovery and then turn to whether any otherwise non-privileged documents are relevant to
Petitioners' CVRA case
https://www.justice.gov/epstein/files/DataSet%209/EFTA01200390.pdf
EFTA00234871Set 9
2009-06-1941p9,427w
collection of any
judgment that she might obtain against him. Accordingly, as part of discovery in this
case, Jane Doe propounded requests for admissions by Epstein regarding whether ... other difficulty. Epstein's Resp. to RFA #23.
14. Epstein has blocked all discovery, in this and other related cases, regarding
his assets. Affidavit of Paul Cassell ... like the assertion of any privilege, stands in stark opposition to
the otherwise liberal discovery rules, and 'undermine[s] to some degree the trial
system's capacity to ascertain
https://www.justice.gov/epstein/files/DataSet%209/EFTA00234871.pdf
EFTA00731180Set 9
2010-05-2521p4,671w
negligence/breach of fiduciary duty, respectively
Response: FTC incorporates its separate response to the Discovery Guide Requests.
2. All documents relied upon in drafting the Amended Statement of Claim.
Response ... request is overly broad, vague, unduly burdensome,
and not calculated to lead to the discovery of relevant information to the extent it seeks
information not related to the Funds ... request is overly broad, vague, unduly
burdensome, and not calculated to lead to the discovery of relevant information to the extent it
seeks information not related to the Funds
https://www.justice.gov/epstein/files/DataSet%209/EFTA00731180.pdf
EFTA00604949Set 9
22p6,541w
Defendant's knowledge
regarding the matters discussed herein. Defendant has not completed his discovery or trial
preparation in this matter. Accordingly, Defendant reserves the right to revise, correct, clarify,
supplement ... this 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 ... without appropriate additional confidentiality order. Defendant expressly reserves the right
to object to further discovery on the subject matter of this Interrogatory. Subject to and without
waiving the foregoing objections
https://www.justice.gov/epstein/files/DataSet%209/EFTA00604949.pdf
EFTA00026819Set 8
2020-10-086p2,484w
October I, 2020
regarding the above-referenced case.
1. The Government Has Met Its Discovery Obligations
As an initial matter, you repeatedly assert that the Government ... discovery
obligations." (Sept. 21, 2020 Ltr. at 4; Oct. I, 2020 Ltr. at 1, 3). The Government respectfully
disagrees. The deadline for the production of Rule 16 discovery ... more than a month away. (Dkt.
25). The deadline for "initial non-electronic discovery, generally to include search warrant
applications and subpoena returns," was due on August
https://www.justice.gov/epstein/files/DataSet%208/EFTA00026819.pdf
EFTA01194855Set 9
2015-06-0530p6,125w
request to entertain
9 more argument on the six incidents and some
10 discovery motions, all of it between Mr.
11 and the Cassell people, so that's where ... that every
5 effort is being made to avoid complying with the
6 discovery obligations that Mr. has in
7 this case.
8 First he says he has documents, then ... Scott. This is not a good
16 faith effort to comply with discovery obligations.
17 This is somebody's clearly abusive tactics to avoid
18 providing discovery.
19 I would
https://www.justice.gov/epstein/files/DataSet%209/EFTA01194855.pdf
EFTA01100608Set 9
2011-04-0830p8,889w
Summary Judgment and in
support thereof states as follows:
I. INTRODUCTION
The pleadings and discovery taken to date show that there is no genuine issue as to any material
facts ... against Edwards includes Edwards's
alleged contacts with the media, his attempts to obtain discovery from high-profile persons with whom
Epstein socialized, and use of "ridiculously inflammatory" language ... each of Edwards's clients and others while they were minors. Indeed, in recent
discovery Epstein has asserted his Fifth Amendment privilege rather than answer questions about the
extent
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100608.pdf
EFTA00611358Set 9
2011-08-12138p36,797w
that motion. If it's granted, we would like to
2 take discovery on that matter, including his
3 deposition.
4 THE COURT: All right. Thank ... motion. As far as I
17 know, there's been no attempt to conduct discovery;
18 no request for admissions; no document production;
19 nothing in the ordinary ... could have, if you wanted to, asked for the
7 opportunity to conduct discovery or send out
8 discovery requests and get them to either admit or
9 deny certain
https://www.justice.gov/epstein/files/DataSet%209/EFTA00611358.pdf
EFTA00222162Set 9
2009-05-069p1,992w
with whom
they had sexual contact.' Plaintiffs properly objected to these interrogatories in that discovery on
Plaintiffs also object to Interrogatory nos. 19, 20, and 21, served on each ... victim is substantially limited in federal court, "courts should
presumptively issue protective orders barring discovery unless the party seeking discovery makes a
showing that the evidence sought to be discovered ... facts and theories of
the particular case and cannot be obtained except through discovery." See Fed. R. Evid. 412,
Advisory Committee Notes to 1994 Amendments, subdivision (c). Defendant has made
https://www.justice.gov/epstein/files/DataSet%209/EFTA00222162.pdf
EFTA00222134Set 9
1997-10-108p5,067w
trial, if it would lead to
Marjorie A. RU2ZO, and Exec., Inc., etc., Re- discovery of relevant evidence. West's F.S.A. RCP
spondents. Rule ... Procedure
. oker.‘e rl t s So. Zd 2'B t• no 307A11Depositions and Discovery
Plaintiffs brought action against alleged house of \ann. 307All(A) Discovery in General
prostitution ... Spriggs & Johnson, Tallahassee, for Peti-
307A Pretrial Procedure tioners.
307AI:I Depositions and Discovery
307A11(A) Discovery in General Mark S. Peters of Amari, Theriac & Eisenmenger,
307Ak31 k. Relevancy
https://www.justice.gov/epstein/files/DataSet%209/EFTA00222134.pdf
EFTA01176822Set 9
2012-05-1712p2,426w
other
written, recorded, computerized, electronic or graphic matters, copies, excerpts or summaries of
documents ("Discovery Material") produced by any party or non-party in the Proceeding.
3. Any party ... party that produces Discovery Material in this Proceeding may
designate as "Confidential" any Discovery Material that it believes in good faith contains
confidential and/or proprietary information. All Discovery Material ... designated shall be
referred to in this Confidentiality Order as "Confidential Discovery Material" and shall be
handled in strict accordance with the terms of this Confidentiality Order.
4. To designate
https://www.justice.gov/epstein/files/DataSet%209/EFTA01176822.pdf
EFTA00076383Set 9
2016-04-2178p17,141w
Defendant's Motion to Compel Responses to Defendant's First Set of
Discovery Responses to Plaintiff
• 139 — Plaintiff's Brief in Support of the Privilege Claimed for In Camera
Submission ... Criminal Procedure 16 ("Rule 16")
and pursuant to any other disclosure obligations (collectively,
the "Discovery"), which contain sensitive, confidential, or
personal identifying information;
WHEREAS, the Government seeks to protect sensitive ... applied for the entry of
this Order;
IT HEREBY IS ORDERED:
1. The Discovery disclosed to the defendant
("Defendant") and/or to the defendant's criminal defense
attorneys ("Defense Counsel") during
https://www.justice.gov/epstein/files/DataSet%209/EFTA00076383.pdf
EFTA01660040Set 10
2015-03-0437p25,087w
West Palm
Beach Division before Judge Kenneth A. Marra., Amended Pleadings due by 12/1/2008.
Discovery due by 8/3/2009. Motions due by 8/31/2009. ORDER REFERRING CASE to
Magistrate Judge Linnea ... Johnson for Discovery Proceedings. ORDER REFERRING CASE to
Mediation. 15 days to appoint mediator. Signed by Judge Kenneth A. Marra on 9/29/08. (ir)
(Entered: 09/30/2008)
10/06/2008 46 Defendant's MOTION ... Deposition of Jane Doe No. 3,
Motion to Consolidate Cases for Purposes of Discovery, and Incorporated Memorandum of
Law in Support by Jane Doe. (Attachments: # 1 Exhibit A, # 2 Exhibit
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01660040.pdf
EFTA00776366Set 9
2009-05-2255p11,193w
young women should not have to undergo what we
21 think would be abusive discovery, and I would
22 like to just present that to the Court --
23 THE COURT ... clients were raped
24 by somebody else, we're not objecting to that
25 discovery --
EFTA00776369
5
1 THE COURT: Well, I wasn't aware that you
2 were ... objecting to that aspect of discovery.
3 Thank you for that clarification.
4 MR. BERGER: -- and the nature of the
5 consensual sexual activities and whether they
6 received money
https://www.justice.gov/epstein/files/DataSet%209/EFTA00776366.pdf
EFTA01115274Set 9
2009-01-069p2,164w
lack of
subject matter jurisdiction, are hereby preserved.
II. DUTIES OF LEAD COUNSEL
7. Discovery in All Actions shall proceed as follows as to that party:
8. Subject to paragraphs ... Securities Action and
Consolidated Actions:
(a) Sign any consolidated class action complaint, motions, briefs, discovery
requests, objections, or notices on behalf of all plaintiffs or those plaintiffs filing the particular ... plaintiffs.
(c) Brief and argue motions on behalf of plaintiffs.
(d) Initiate and conduct discovery consistent with Section VI below.
(e) Speak on behalf of plaintiffs at any pretrial conference
https://www.justice.gov/epstein/files/DataSet%209/EFTA01115274.pdf