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Corpus: 1990-03-17 – 2025-12-01

April 2015

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406

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results for “"Non-Party"”

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EFTA01078765Set 9

2015-04-0790p24,360w

DERSHOWITZ, Defendant. I MOTION TO QUASH OR FOR PROTECTIVE ORDER REGARDING SUBPOENA SERVED ON NON-PARTY JANE DOE NO. 3 Non-party Jane Doe 3, by and through undersigned counsel ... scope of the subpoena. INTRODUCTION This Court should quash the subpoena issued to non-party Jane Doe No. 3 as it is unreasonable and oppressive. The Defendant is abusing ... subpoena power in an effort to intimidate, harass and cause undue burden to a non-party. Indeed, Defendant - just days ago - publicly admitted that his goal of deposing Jane

https://www.justice.gov/epstein/files/DataSet%209/EFTA01078765.pdf

EFTA00622175Set 9

2005-02-1754p7,431w

Relevant Relationships 3 2. The Degree of Control of the Party Over the Non-Party Witness 7 3. The Compatibility of the Interests of the Party and the Non-party ... Witness in the Outcome of the litigation 9 4. The Role of the Non-Party Witness in the Litigation 10 5. Other Factors Apart from the Non-Exclusive List ... EFTA00622179 1. The Nature of the Relevant Relationships. The first LiButti factor is "the non-party witness' loyalty to the plaintiff or defendant, as the case

https://www.justice.gov/epstein/files/DataSet%209/EFTA00622175.pdf

EFTA00077108Set 9

2020-08-103p1,371w

will explain to the Court, the parties have agreed to notify all of the Non-Parties at once so that we can understand which Non-Parties object to the unsealing ... Original Parties and their staff to put together the excerpts for any Non-Party who requests them because each Non-Party will be entitled ... information (but not that of other Non-Parties). After receiving a request from a Non-Party, we anticipate it will take up to a week per Non-Party to agree

https://www.justice.gov/epstein/files/DataSet%209/EFTA00077108.pdf

EFTA00806715Set 9

2017-10-1018p3,212w

individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). NOTICE OF PRODUCTION FROM NON-PARTY TO: SIMS Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale ... Beach, FL 33401 EFTA00806715 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Notice of Production from Non-Party Page 2 2. Robert D. Critton, Esquire 303 Banyan Boulevard, Suite 400 West Palm ... Attorneys o Edwards EFTA00806716 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Notice of Production from Non-Party Page 3 COUNSEL LIST William Chester Brewer Esc Esquire Tonja Haddad Coleman Esquire

https://www.justice.gov/epstein/files/DataSet%209/EFTA00806715.pdf

EFTA00614418Set 9

2009-04-1037p6,240w

Plaintiff, v. Defendants. DEFENDANT'S, JEFFREY EPSTEIN, AMENDED OBJECTION TO PRODUCTION FROM NON-PARTY, YELLOW CAB Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), by and through his undersigned attorneys, pursuant ... Rule 1.351, Fla. R. Civ. P., hereby objects to the Notice of Production from Non-Party directed to Yellow Cab and proposed subpoena, and amends the objection to the production ... from Non-Party, Yellow Cab (all attached as Composite Exhibit "A") and as grounds set forth, would state: 1. Plaintiff, ■ in her answers to interrogatories alleges

https://www.justice.gov/epstein/files/DataSet%209/EFTA00614418.pdf

EFTA00074964Set 9

2020-06-1740p9,195w

decision in Brown, both of which fairly outline the legal process for parties and Non-Parties alike to be heard with respect to unsealing. Notably, many of the documents were ... time to accomplish is not a reason to unseal. Rather, the hundreds of interested Non-Parties together with Ms. Maxwell have every right and reason to expect that the promises ... review with respect to each document and provide notice to the Non-Parties for documents that were not 6 EFTA00074969 CaaM152-a,‘2-0743134o%PleDbtOrfiefiVM30Alle?BOMIV2eafabef746f 22 entitled

https://www.justice.gov/epstein/files/DataSet%209/EFTA00074964.pdf

EFTA00020541Set 8

2018-08-2729p10,996w

access to judicial documents was rebutted by privacy interests of parties and multiple non-parties. Motion to intervene granted; motion to unseal denied. WESTLAW © 2018 Thomson Reuters. No claim ... Headnotes (31) III Federal Civil Procedures-Particular Intervenors Members of the press and other non-parties, by motion to intervene, may seek to pursue modification of confidentiality orders that have ... action; documents at issue included range of allegations of sexual acts involving plaintiff and non-parties to litigation, some of whom were famous, identities of non-parties who either allegedly

https://www.justice.gov/epstein/files/DataSet%208/EFTA00020541.pdf

EFTA00792252Set 9

2019-03-2024p4,929w

MOTION INFORMATION STATEMENT Docket Numberfs): 18-2868 Captionhum than Motion kr: Leave for Non-Party Seeking Limited Intervention to File Unredacted Motions Ex Parte, Under Seal, for in camera Review ... court's sealing orders and this Court's further direction. MOVING PARTY:1 Doe, Non-Party Limited Intervenor OPPOSING PARTY:M Plaintiff-Appellee DPktirmiff Encl.:n(4mi ElAppellmt/Petitioner ppellec/Responlent MOVING ... Docket Number(s): 18-2868 Ciaptim fuse short Wel %lotion br: Limited Intervention by Non-Party J. Doe Set forth bebss precise. complete statement of relief sought: Non-party movant

https://www.justice.gov/epstein/files/DataSet%209/EFTA00792252.pdf

EFTA00589467Set 9

2017-03-138p2,425w

Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S MOTION TO QUASH TRIAL SUBPOENA Jeffrey Epstein, a non-party to the above captioned action, has been subpoenaed to testify at the trial ... judge maintains discretion under Fed. R. Evid. 403 to control the way in which non-party claims of privilege reach the jury." BAD Servs., Inc. v. Aetna ... most significant circumstance. It should be examined, however, from the perspective of a non-party witness' loyalty to the plaintiff or defendant, as the case may be. The closer

https://www.justice.gov/epstein/files/DataSet%209/EFTA00589467.pdf

EFTA00596449Set 9

2008-08-0836p11,867w

ACTION 12 II. EDWARDS FAILS TO MEET THE REQUIREMENTS FOR DISCOVERY OF A NON-PARTY UNDER CPLR 3101(a) 14 A. The Epstein Interview Does Not Have Heightened Relevance ... reach the Shield Law privilege since Edwards does not satisfy the minimum standards for non-party disclosure under CPLR 3101(aX4) — which requires that even non-privileged evidence must have ... otherwise unobtainable from alternative sources before it may be subpoenaed from any non-party in New York. In fact, Edwards concedes in his own Florida court filings that the Epstein

https://www.justice.gov/epstein/files/DataSet%209/EFTA00596449.pdf

EFTA00307562Set 9

2011-05-2411p3,281w

STATEMENT OF RELEVANT FACTS AND PROCEDURAL HISTORY OF CASE In 2005, Plaintiffs contracted with non-parties Juan Pablo Molyneux, a resident of the State of New York, and his company ... first if complete relief can be accorded between plaintiffs and the defendant without the non-party Molyneux. "The term complete relief refers only to relief as between the persons already ... July 11, 2002). Second, the Court must determine if the non-party has sought to intervene. Id. Here Plaintiffs do not seek performance of the breached contract. Plaintiffs limit their

https://www.justice.gov/epstein/files/DataSet%209/EFTA00307562.pdf

EFTA00095531Set 9

2015-09-2923p4,052w

privacy imerems-protections of (a) plaintiff d (b) defendant Ghislaine Maxwell or icl any non-party that was su tject to sexual abuse. 4. CONFIDENTIAL information shall not be disclosed ... CONFIDENTIAL" or "HIGHLY CONFIDENTIAL— ATTORNEYS' EYES ONLY". Any such protected mMaterial produced by the non-party designated "CONFIDENTIAL" or '"'HIGHLY CONFIDENTIAL— ATTORNEYS' EYES ONLY" shall be subiect to the restrictions ... produced, disclosed, and/or provided by the Producing Party to the Receiving Party or a non-party without an obligation of confidentiality and not by inadvertence or mistake: (d) with

https://www.justice.gov/epstein/files/DataSet%209/EFTA00095531.pdf

EFTA00806733Set 9

2017-10-1018p3,230w

individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). NOTICE OF PRODUCTION FROM NON-PARTY TO: Tonja Haddad Coleman, Es uire Tonja Haddad, P.A. 315 SE 7th Street, Suite ... Beach, FL 33401 EFTA00806733 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Notice of Production from Non-Party Page 2 2. Robert D. Critton, Esquire 303 Banyan Boulevard, Suite 400 West Palm ... wards EFTA00806734 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Notice of Production from Non-Party Page 3 COUNSEL LIST William Chester Brewer, Es uire Tonja Haddad Coleman, Esquire 250 S Australian

https://www.justice.gov/epstein/files/DataSet%209/EFTA00806733.pdf

EFTA00594020Set 9

2015-12-2715p3,787w

Jeffrey Epstein 12/18/2015 Order to Seal Documents 12/1612015 Motion to Strike AND FOR SANCTIONS Non-Party 12)1612015 Request to Produce Pasty: MAW( Edwaids.Braeley J Fla/noff Cassell. Paul ... DENIAL OF HIS MOTION TO OUASH SUBPOENA DUCES TECUM/GRANTED 1 2 11/04/2015 Order on Non-Party Jeffrey Es Motion to Cvash Subpoena/ Denied 2 11/04/2015 Requital to Produce Patty: MAWR ... November 7. 2015 e 9:00AM 2 10/27/2015 Reply /CONSOLIDATED REPLY IN SUPPORT OF NON-PARTY JANE DOE 53 NO. 31 AND BOIES. SCHILLER & FLEXNER LLPs MOT ht p:/ www.clerk

https://www.justice.gov/epstein/files/DataSet%209/EFTA00594020.pdf

EFTA00084609Set 9

2020-08-103p1,371w

https://www.justice.gov/epstein/files/DataSet%209/EFTA00084609.pdf

EFTA00590248Set 9

2015-05-1538p9,499w

DERSHOWITZ, Defendant / Counterclaim Plaintiff. DEFENDANT / COUNTERCLAIM PLAINTIFF ALAN DERSHOWITZ'S MEMORANDUM IN OPPOSITION TO NON-PARTY BOLES, SCHILLER & FLEXNER LLP'S MOTION TO OUASH OR FOR PROTECTIVE ORDER Defendant / Counterclaim ... Quash or for Protective Order Regarding Subpoena (the "Motion to Quash") filed by non-party Boies, Schiller & Flexner LLP ("BSF'). Dershowitz also refers the Court to his memorandum in opposition ... should be quashed in its entirety because it "seeks entirely privileged documents from a non-party law firm of communications with a non-party client that are not subject

https://www.justice.gov/epstein/files/DataSet%209/EFTA00590248.pdf

EFTA00075024Set 9

2006-10-2331p8,486w

thus far, and because the first five motions contain the names of various other Non-Parties, Maxwell contends in her objection that the Court cannot unseal any of the first ... five motions or their related docket entries until each Non-Party is separately noticed in the order that their name appears on the Non-Party list ... Order that the Court would be "amenable to unsealing portions of documents mentioning non-parties rather than waiting to unseal the entirety of a given document until all non-parties

https://www.justice.gov/epstein/files/DataSet%209/EFTA00075024.pdf

EFTA00075004Set 9

2020-06-1020p5,220w

However, unsealing of these Sealed Items would be premature at this time because multiple Non-Party Does are referenced in these items, as described in the accompanying memorandum ... Court's clarification of its March 31, 2020 Order, DE 1053, ("the Protocol"), Non-Parties Does 1 and 2 have been served with the approved Notice and, pursuant ... Protocol, additional Non-Parties will be notified prior to any unsealing of the selected Sealed Materials. Does I and 2 did not respond to the Notice. The absence

https://www.justice.gov/epstein/files/DataSet%209/EFTA00075004.pdf

EFTA00791869Set 9

2019-03-1527p6,343w

discovery into the sexual and other private acts and history of the parties and non-parties based on Ms. representations about the relevance of the discovery ... access to the discovery in court filings against Ms. Maxwell's and the non-parties' compelling interests. This is an extraordinary case. Ms. for more than a decade has actively ... expedition she then used the discovery process to coerce Ms. Maxwell and dozens of non-parties to disclose to her highly sensitive, embarrassing and confidential information about their personal lives

https://www.justice.gov/epstein/files/DataSet%209/EFTA00791869.pdf

EFTA00022960Set 8

2020-06-1020p5,494w

However, unsealing of these Sealed Items would be premature at this time because multiple Non-Party Does are referenced in these items, as described in the accompanying memorandum ... Court's clarification of its March 31, 2020 Order, DE 1053, ("the Protocol"), Non-Parties Does I and 2 have been served with the approved Notice and, pursuant ... Protocol, additional Non-Parties will be notified prior to any unsealing of the selected Sealed Materials. Does 1 and 2 did not respond to the Notice. The absence

https://www.justice.gov/epstein/files/DataSet%208/EFTA00022960.pdf