EFTA00808629Set 9
2017-09-054p721w
vague and
ambiguous; the request is overly broad and seeks information that is irrelevant,
immaterial, and not reasonably calculated to lead to the discovery of admissible
evidence; information requested includes ... privacy.
3. Objection. The request is overly broad and seeks information that is irrelevant,
immaterial, and not reasonably calculated to lead to the discovery of admissible
evidence; information requested includes ... Objection. The request is overly broad and seeks information that is irrelevant,
immaterial, and not reasonably calculated to lead to the discovery of admissible
evidence; information requested includes attorney work
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808629.pdf
EFTA00085098Set 9
2019-03-0618p7,254w
headnote
Although motions to strike material
solely on ground that matter is
impertinent and immaterial are
disfavored, when material is also
1161 Courts scandalous, no such presumption
4—Making ... this headnote
Because material that is rejected or
stricken by district court as
redundant, immaterial, impertinent,
or scandalous is not relevant to 1201
performance of judicial function, it Libel ... York, NY, for
official proceedings Intervenor-Appellant Alan M. Dershowitz.
Under New York law, immaterial Marc Randazza (Jay Marshall Wolman, Las
and impertinent statements in court Vegas
https://www.justice.gov/epstein/files/DataSet%209/EFTA00085098.pdf
EFTA01143024Set 9
2011-12-0924p4,729w
source of that
income (including the payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of
admissible evidence and an unwarranted invasion ... source of that income (including the payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of
admissible evidence and an unwarranted invasion ... cases or
causes for which you provided such service.
ANSWER:
Objection. Irrelevant, immaterial and not reasonably calculated to lead to the discovery of
admissible evidence.
17. You 'claim damages
https://www.justice.gov/epstein/files/DataSet%209/EFTA01143024.pdf
EFTA01082029Set 9
2011-12-0924p4,405w
source of that
income (including the payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of
admissible evidence and an unwarranted invasion ... source of that income (including the payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of
admissible evidence and an unwarranted invasion ... cases or
causes for which you provided such service.
ANSWER:
Objection. Irrelevant, immaterial and not reasonably calculated to lead to the discovery of
admissible evidence.
17. You 'claim damages
https://www.justice.gov/epstein/files/DataSet%209/EFTA01082029.pdf
EFTA01087251Set 9
2011-12-0924p4,673w
source of that
income (including the payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of
admissible evidence and an unwarranted invasion ... source of that income (including the payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of
admissible evidence and an unwarranted invasion ... cases or
causes for which you provided such service.
ANSWER:
Objection. Irrelevant, immaterial and not reasonably calculated to lead to the discovery of
admissible evidence.
17. You 'claim damages
https://www.justice.gov/epstein/files/DataSet%209/EFTA01087251.pdf
EFTA00585352Set 9
2010-04-0521p6,736w
source of that income (including the payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the
discovery of admissible evidence and an unwarranted invasion ... source of that income (including the
payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the
discovery of
admissible evidence and an unwarranted invasion ... cases or causes for which you provided such service.
ANSWER
Objection. Irrelevant, immaterial and not reasonably calculated to lead to the
discovery of admissible evidence.
24. State each instance
https://www.justice.gov/epstein/files/DataSet%209/EFTA00585352.pdf
EFTA00175717Set 9
2008-03-0558p16,603w
U.S.C. §2255, pertaining to habeas
corpus proceedings is required to be stricken as immaterial. Rule 12(f). Plaintiff is
required to more definitely state what statutory provision she is relying ... WHEREFORE, Defendant respectfully requests that this Court dismiss Counts I and
III, strike the immaterial statutory reference, and require Plaintiff to more definitely plead
the underlying elements of her claims ... which relief can be granted. Rule 12(b)(6). Count III also contains an
Immaterial reference to 28 U.S.C. §2255, which is required to be stricken
and more definitely stated
https://www.justice.gov/epstein/files/DataSet%209/EFTA00175717.pdf
EFTA00175835Set 9
2008-04-1457p16,565w
pertaining to habeas
corpus proceedings is required to be stricken as immaterial. Rule 12(f). Plaintiff is
required to more definitely state what statutory provision she is relying on. Rule ... WHEREFORE, Defendant respectfully requests that this Court dismiss Counts I and
III, strike the immaterial statutory reference, and require Plaintiff to more definitely plead
the underlying elements of her claims ... upon which relief can be ar Rule 12031(6). Count ill also contains an
immaterial reference to 28 . 42256, which is required to be stricken
and more definitely stated.
Count
https://www.justice.gov/epstein/files/DataSet%209/EFTA00175835.pdf
EFTA00802139Set 9
2010-04-0521p6,734w
source of that income (including the payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the
discovery of admissible evidence and an unwarranted invasion ... source of that income (including the
payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the
discovery of
admissible evidence and an unwarranted invasion ... cases or causes for which you provided such service.
ANSWER
Objection. Irrelevant, immaterial and not reasonably calculated to lead to the
discovery of admissible evidence.
24. State each instance
https://www.justice.gov/epstein/files/DataSet%209/EFTA00802139.pdf
EFTA00585373Set 9
2010-04-0521p6,735w
source of that income (including the payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the
discovery of admissible evidence and an unwarranted invasion ... source of that income (including the
payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the
discovery of
admissible evidence and an unwarranted invasion ... cases or causes for which you provided such service.
ANSWER
Objection. Irrelevant, immaterial and not reasonably calculated to lead to the
discovery of admissible evidence.
24. State each instance
https://www.justice.gov/epstein/files/DataSet%209/EFTA00585373.pdf
EFTA00800173Set 9
2010-04-0519p6,165w
source of that income (including the payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the
discovery of
admissible evidence and an unwarranted invasion ... source of that income (including the payor
of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the
discovery of
admissible evidence and an unwarranted invasion ... cases or causes for which you provided such service.
ANSWER
Objection. Irrelevant, immaterial and not reasonably calculated to lead to the
discovery of admissible evidence.
24. State each instance
https://www.justice.gov/epstein/files/DataSet%209/EFTA00800173.pdf
EFTA00802391Set 9
2010-04-0520p6,559w
source of that income (including the payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the
discovery of admissible evidence and an unwarranted invasion ... source of that income (including the
payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the
discovery of
admissible evidence and an unwarranted invasion ... cases or causes for which you provided such service.
ANSWER
Objection. Irrelevant, immaterial and not reasonably calculated to lead to the
discovery of admissible evidence.
24. State each instance
https://www.justice.gov/epstein/files/DataSet%209/EFTA00802391.pdf
EFTA00175775Set 9
2008-04-1460p17,746w
pertaining to habeas
corpus proceedings is required to be stricken as immaterial. Rule 12(f). Plaintiff is
required to more definitely state what statutory provision she is relying on. Rule ... WHEREFORE, Defendant respectfully requests that this Court dismiss Counts I and
III, strike the immaterial statutory reference, and require Plaintiff to more definitely plead
the underlying elements of her claims ... which relief can be qr Rule 12(b)(6). Count Ill also contains an
immaterial reference to 28 . 42255. which is required to be stricken
and more definitely stated.
Count
https://www.justice.gov/epstein/files/DataSet%209/EFTA00175775.pdf
EFTA00799381Set 9
2010-04-0521p6,732w
source of that income (including the payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the
discovery of admissible evidence and an unwarranted invasion ... source of that income (including the
payor of the same).
ANSWER:
Objection. Irrelevant, immaterial, not reasonably calculated to lead to the
discovery of
admissible evidence and an unwarranted invasion ... cases or causes for which you provided such service.
ANSWER
Objection. Irrelevant, immaterial and not reasonably calculated to lead to the
discovery of admissible evidence.
24. State each instance
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799381.pdf
EFTA00801426Set 9
2011-04-1434p9,651w
further re-pleading would be futile.
The FAC also repeats a laundry list of immaterial, impertinent and scandalous allegations
about Epstein which were contained in the Complaint and should ... Florida, referred to herein as
the "Prior Proceedings," are scandalous, harassing, and entirely immaterial to Plaintiff's claim.
All of the allegations relating to the Prior Proceedings should be stricken ... court may strike from a pleading ... any ... immaterial, impertinent, or
scandalous matter." Anderson v. Davis Polk & Wardwell LLP, 850 F. Supp. 2d 392, 416
(S.D.N.Y. 2012). "An allegation is impertinent
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801426.pdf
EFTA00092308Set 9
2019-03-0626p5,904w
internal quotation marks and brackets omitted).
6
EFTA00092313
defense or any redundant, immaterial, impertinent, or scandalous
matter . . . on its own,"4 the Florida District Court (Kenneth A. Marra,
Judge ... strike such
material from the filings on the grounds that it is "redundant,
immaterial, impertinent, or scandalous."42 Because such rejected or
stricken material is not "relevant to the performance ... motions to strike
material solely "on the ground that the matter is impertinent and immaterial" are
disfavored, when material is also "scandalous," no such presumption applies. Cf.
Lipsky v. Commonwealth
https://www.justice.gov/epstein/files/DataSet%209/EFTA00092308.pdf
EFTA02728376Set 11
2009-01-167p1,160w
documentation relative to the
Plaintiffs earnings for the current year.
ANSWER
Objection. Irrelevant, immaterial and not reasonably calculated to lead to the
discovery of admissible information
2. All hills/expenses from ... videotapes in which you performed sexual acts or
simulated sexual acts.
ANSWER
Objection, irrelevant, Immaterial and not reasonably calculated to lead to the
discovery of admissible evidence. Notwithstanding same, none ... simulated sexual acts in exchange for money or other consideration.
ANSWER
Objection, Irrelevant, immaterial and not reasonably calculated to lead to the
discovery of admissible evidence. Notwithstanding same, none
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02728376.pdf
EFTA00585420Set 9
2017-09-1525p7,884w
Accordingly, a
motion in limine is proper to exclude any irrelevant and immaterial evidence when its probative
value is outweighed by prejudice. Devoe v. Western Auto Supply ... Epstein Plead or any Alleged Criminal Investigation(s).
Since it is inadmissible, irrelevant, and immaterial to this suit, Epstein requests that
Edwards be precluded from using any pleading, testimony, remarks ... deflect
attention away from the glaring deficiencies in his case in chief with immaterial and irrelevant
depiction of Mr. Epstein as someone culpable of numerous federal criminal offenses involving
sexual
https://www.justice.gov/epstein/files/DataSet%209/EFTA00585420.pdf
EFTA00590248Set 9
2015-05-1538p9,499w
Joinder Motion by Plaintiffs on behalf of Jane Doe No. 3, are "immaterial and
impertinent" to the issues in dispute in the Federal Action, and were "unnecessary" to resolving ... strike from a pleading an insufficient defense or any
redundant, immaterial, impertinent, or scandalous matter." Fed. R. Civ. P. 12(0.
Petitioners' Rule 21 Motion consists of relatively little argumentation ... details regarding
with whom and where the Jane Does engaged in sexual activities are immaterial and impertinent
to this central claim (i.e., that they were known victims of Mr. Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00590248.pdf
EFTA01297717Set 10
2018-05-3147p7,403w
lapse. letter dated, Maritime Rules. Federal Arbitration Act, arbitration
provision, failure to comply, aforementioned, immaterial. mandatory•, binding. jointly. naming• dispute arising, delivery.
confirm, waived
LexisNexisit licadnotes
Contracts Law > Contract Conditions ... mechanical breakdown. such as a lapse in time in naming of the arbitrator, is immaterial to the
enforcement of arbitration agreements.
Admiralty Law > Arbitration > Federal Arbitration Act
Admiralty Law > Maritime ... mechanical breakdown," such as "a lapse in time in naming of the arbitrator? is immaterial). This is in notable contrast
to other sections of the Construction Agreement. such as Section
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01297717.pdf