EFTA00175835Set 9
2008-04-1457p16,565w
Exhibit B, # a
Exhibit t(Pike, Michael) (Entered: 03/25/2009)
04/02/2009 e Defendant's MOTION to Compel Respnse to I st RTP by Jeffrey Epstein.
Responses due by 4/20/2009 (Attachments ... Exhibit # 4 Exhibit D)(Critton, Robert) (Entered: 04/02/2009)
04/02/2009 ZQ Defendant's MOTION to Compel Answers to 1st Interrogs by Jeffrey Epstein.
Responses due by 4/20/2009 (Attachments: # I Exhibit ... Unopposed MOTION for Extension of Time to File Response as to 70
Defendant's MOTION to Compel Answers to 1st Interrogs, 62 Defendant's
MOTION to Compel Respnse
https://www.justice.gov/epstein/files/DataSet%209/EFTA00175835.pdf
EFTA00175717Set 9
2008-03-0558p16,603w
EFTA00175723
CM/ECF - Live Database - flsd Page 8 of 15
•
03/26/2009)
04/02/2009 59 Defendant's MOTION to Compel Response to 1st RTP by Jeffrey Epstein.
Responses due by 4/20/2009 (Attachments ... Exhibit B, # a
Exhibit C)(Critton, Robert) (Entered: 04/02/2009)
04/02/2009 61) Defendant's MOTION to Compel Answers to 1st Interrogs by Jeffrey Epstein.
Responses due by 4/20/2009 (Attachments: # 1 Exhibit ... Unopposed MOTION for Extension of Time to File Response as to 52
Defendant's MOTION to Compel Response to 1st RTP, 6Q Defendant's
MOTION to Compel Answers
https://www.justice.gov/epstein/files/DataSet%209/EFTA00175717.pdf
EFTA01660040Set 10
2015-03-0437p25,087w
Exhibit A, # 2 Exhibit B)(Mermelstein, Stuart)
(Entered: 03/26/2009)
04/02/2009 67 Defendant's MOTION to Compel Response to 1st RTP by Jeffrey Epstein. Responses due by
4/20/2009 (Attachments: # 1 Exhibit ... Exhibit B, # 3 Exhibit C)(Critton, Robert)
(Entered: 04/02/2009)
04/02/2009 68 Defendant's MOTION to Compel Answers to 1st I nterrogs by Jeffrey Epstein. Responses due
by 4/20/2009 (Attachments ... Unopposed MOTION for Extension of Time to File Response as to 67 Defendant's MOTION to
Compel Response to 1st RTP, 68 Defendant's MOTION to Compel Answers
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01660040.pdf
EFTA00175775Set 9
2008-04-1460p17,746w
Exhibit A, # 2 Exhibit B)(Mermelstein, Stuart) (Entered: 03/27/2009)
04/0' 009 :74 Defendant's MOTION to Compel Response to 1st RTP by Jeffrey Epstein.
Responses due by 4/20/2009 (Attachments ... Exhibit , # 4 Exhibit D)(Critton, Robert) (Entered: 04/02/2009)
04/02/2009 715 Defendant's MOTION to Compel Answers to 1st Interrogs by Jeffrey Epstein.
Responses due by 4/20/2009 (Attachments: # 1 Exhibit ... Unopposed MOTION for Extension of Time to File Response as to 24
Defendant's MOTION to Compel Response to 1st RTP, 25 Defendant's
MOTION to Compel Answers
https://www.justice.gov/epstein/files/DataSet%209/EFTA00175775.pdf
EFTA00623075Set 9
2016-06-0140p11,688w
Plaintiff by and 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 ... Misc. 3d 539, 542, 858 N.Y.S.2d 591, 593 (Sup. Ct. 2008)).
CONCLUSION
Defendant's motion to compel should be denied in its entirety.
31
EFTA00623112
Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00623075.pdf
EFTA01070407Set 9
2009-02-1344p15,146w
portion the transcript from
Jane Doe II v. Epstein, and
Defendant's motion to compel discovery in the case of
it Court, In and For Palm
, Case No. 502008CA020614 ... indicated they would attempt to
very, with respect t
Accordingly, in granting Defendant's motion to compel disco
e the full name of A.L. (which
this interrogatory, Plaintiff should
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070407.pdf
EFTA01070501Set 9
2009-02-2332p10,787w
Circuit, In and For Palm Beach
County, State of Florida, which granted Defendant's motion to compel therein directed
3
In Bales v. Ru7zo supra, the Plaintiffs alleged a muiticount ... portion the transcript from a March 3, 2009 hearing on
Defendant's motion to compel discovery in the case of Jane Doe II v. Epstein, and
Case No. 502008CA020614 ... counsel indicated they would attempt to provide this information.
Accordingly, In granting Defendant's motion to compel discovery, with respect t
this interrogatory, Plaintiff should be required to provide
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070501.pdf
EFTA00221691Set 9
2009-01-2612p3,567w
offensive and is
apparently posed for the purpose of intimidating Plaintiff." See Defendant's Motion to
Compel directed to Plaintiff's Answers to Defendant's First Set of Interrogatories,
addressing ... Circuit, In and For Palm Beach
County, State of Florida, which granted Defendant's motion to compel therein directed
to discovery identical to interrogatory no. 18 above, and to requests ... portion the transcript from a March 3, 2009 hearing on Defendant's motion to
compel discovery in the case of Jane Doe II v. Epstein, and Case No.
502008CA020614
https://www.justice.gov/epstein/files/DataSet%209/EFTA00221691.pdf
EFTA00618132Set 9
2016-06-0615p4,066w
stating as follows:
INTRODUCTION
Plaintiff's disjointed and often confusing' Response to Defendant's Motion to Compel
Non-Privileged Documents ("Response") completely misses point. It is Plaintiff's burden ... attorney client privilege." 2016 WL 1756918, at *6. As argued in
Defendant's Motion to Compel All Attorney-Client Communications and Attorney Work
Product (Doc. # 164), Plaintiff waived her attorney ... produced.
WHEREFORE, for the foregoing reasons and those set forth in Defendant's Motion to
Compel Non-Privileged Document, Ms. Maxell requests that the relief requested therein be
granted
https://www.justice.gov/epstein/files/DataSet%209/EFTA00618132.pdf
EFTA00222171Set 9
1999-02-1910p2,165w
such showing in his
Motion to Compel to overcome this presumption. Accordingly, Defendant's Motion to Compel
must be denied in its entirety.
Defendant also seeks in Request ... should be denied.
Conclusion
Based on the foregoing, Plaintiffs respectfully request that Defendant's Motion to
Compel Response to First Request to Produce, Overrule Objections, and for an Award
https://www.justice.gov/epstein/files/DataSet%209/EFTA00222171.pdf
EFTA00727554Set 9
2009-05-216p810w
JANE DOES 2-7 MOTION FOR ENLARGEMENT
OF TIME TO RESPOND TO DEFENDANT'S MOTION TO COMPEL
AND/OR IDENTIFY JANE DOE IN THE STYLE ET AL
Plaintiffs, JANE DOES ... counsel, hereby file this
Motion for Enlargement of Time to Respond to Defendant's Motion to Compel and/or Identify
Jane Doe in the Style of this Case and Motion ... enlargement of time
until June 11, 2009 to file their response to Defendant's Motion to Compel and/or Identify Jane
Doe in the Style, et aL, and for such other
https://www.justice.gov/epstein/files/DataSet%209/EFTA00727554.pdf
EFTA00221783Set 9
2009-06-0815p3,668w
JEFFREY EPSTEIN,
Defendant.
PLAINTIFFS JANE DOES 2-7'S RESPONSE TO DEFENDANT'S MOTION TO
COMPEL AND/OR IDENTIFY PLAINTIFFS IN THE STYLE OF THIS CASE AND
MOTION TO IDENTIFY JANE ... Plaintiffs, JANE DOES 2-7, hereby serve their Response to Defendant's Motion to
Compel and/or Identify Plaintiffs in the Style of this Case and Motion to Identify Jane ... Plaintiffs Jane Does 2-7 respectfully request that (i) this Court deny
Defendant's Motion to Compel and/or Identify Plaintiffs in the Style of this Case and Motion to
Identify
https://www.justice.gov/epstein/files/DataSet%209/EFTA00221783.pdf