EFTA01081604Set 9
2015-01-0734p8,230w
control.
Dershowitz made the same evasive response — "Defendant responds that he will produce"
unspecified "non-privileged documents" — to multiple discovery requests. See Dershowitz
5
EFTA01081615
Case ... located or obtained
up to the date of service of the responses. Additional responsive, non-privileged documents may
be ascertained or identified subsequently, and Defendant reserves the right to rely ... without waiving the General Objections, Defendant responds that he will produce
all responsive, non-privileged documents currently in his possession, custody or control relating
to the sole occasion on which
https://www.justice.gov/epstein/files/DataSet%209/EFTA01081604.pdf
EFTA00618132Set 9
2016-06-0615p4,066w
Defendant.
X
DEFENDANT'S REPLY IN SUPPORT OF
MOTION TO COMPEL NON-PRIVILEGED DOCUMENTS
Laura A. Menninger
Jeffrey S. Pagliuca
HADDON, MORGAN, AND FOREMAN. P.C.
East 101h Avenue
Denver ... Ghislaine Maxwell ("Ms. Maxwell") files this Reply In Support of her Motion
to Compel Non-Privileged Documents contained on Plaintiff's Privilege Log, stating as follows:
INTRODUCTION
Plaintiff's disjointed ... often confusing' Response to Defendant's Motion to Compel
Non-Privileged Documents ("Response") completely misses point. It is Plaintiff's burden to
establish that any privilege exists with respect
https://www.justice.gov/epstein/files/DataSet%209/EFTA00618132.pdf
EFTA00808645Set 9
2018-03-056p1,349w
Defendants.
RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR COURT TO DECLARE
RELEVANCE AND NON-PRIVILEGED NATURE OF DOCUMENTS AND REQUEST
FOR ADDITIONAL LIMITED DISCOVERY, EVIDENTIARY HEARING, AND
APPOINTMENT ... this Response
in Opposition to Epstein's Motion for Court to Declare Relevance and Non-Privileged Nature of
Documents and Request for Additional Limited Discovery, Evidentiary Hearing, and Appointment ... 502009CA040800XXXXMBAG
Response in Opposition to Epstein's Motion for Court to Declare Relevance and Non-Privileged
Nature of Documents and Request for Additional Limited Discovery, Evidentiary Hearing, and
Appointment
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808645.pdf
EFTA00788035Set 9
2018-09-2745p10,024w
supposed to get those because they were produced back to
19 Fowler White as non-privileged documents. There was only
20 approximately 6,400 documents which remain ... status
3 of a case with his client, is going to discuss the
4 non-privileged materials that have been turned over, the
5 21,000 pages of non-privileged ... boxes
9 contained all of the documents, privileged and
10 non-privileged, there are really three ways that I can
11 envision anyway, and I'm purely guessing
https://www.justice.gov/epstein/files/DataSet%209/EFTA00788035.pdf
EFTA00793499Set 9
2018-10-13165p32,130w
believe that it was a waiver of the privilege. He gave you
non-privileged communication, and he's not going to share with you privileged
communications.
r Epstein Depo ... believe that it
14 was a waiver of the privilege. He gave you
15 non-privileged communication, and he's not
16 going to share with you privileged
17 communications ... documents existed. We, in fact, produced
2 the only responsive non-privileged
3 documents.
4 I will note for the record,
5 Mr. Scarola, that we did all of that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793499.pdf
EFTA00804162Set 9
2018-08-1479p14,540w
believe that it
10 was waiver of the privilege. He gave you
11 non-privileged communication, and he's not
12 going to share with you privileged
13 communications ... identified where no
19 documents existed. We, in fact, produced
20 the only responsive non-privileged
21 documents.
22 I will note for the record,
23 Mr. Scarola, that ... under the Florida rules of Civil
16 Procedure, and we have produced all
17 non-privileged documents.
18 BY MR. SCAROLA:
19 Q And I am entitled to know whether
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804162.pdf
EFTA00793401Set 9
2018-10-2497p18,954w
believe that it
14 was a waiver of the privilege. He gave you
15 non-privileged communication, and he's not
16 going to share with you privileged
17 communications ... documents existed. We, in fact, produced
2 the only responsive non-privileged
3 documents.
4 I will note for the record,
5 Mr. Scarola, that we did all of that ... under the Florida Rules of Civil
23 Procedure, and we have produced all
24 non-privileged documents.
25
Palm Beach Reporting Service, Inc. 561-471-2995
EFTA00793473
Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793401.pdf
EFTA00799200Set 9
2018-09-1220p4,843w
bankruptcy court, Epstein's
Circuit Court Motion for Court to Declare Relevance
and Non-Privileged Nature of Documents and
Appointment of Special Master and Supplement
thereto, Epstein's Response ... Documents Containing
Privileged Materials, and Epstein's Motion for Court
to Declare Relevant and Non-Privileged Nature of
Documents, for purposes of drafting Sworn
Declaration of Fact of Scott ... Supplemental Response to J. Epstein's Motion for
Court to Declare Relevance and Non-Privileged
Nature of Documents, and Request for Additional
Limited Discovery, Evidentiary Hearing, and
Appointment of Special
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799200.pdf
EFTA00799180Set 9
2018-08-1420p4,715w
bankruptcy court, Epstein's
Circuit Court Motion for Court to Declare Relevance
and Non-Privileged Nature of Documents and
Appointment of Special Master and Supplement
thereto, Epstein's Response ... Documents Containing
Privileged Materials, and Epstein's Motion for Court
to Declare Relevant and Non-Privileged Nature of
Documents, for purposes of drafting Sworn
Declaration of Fact of Scott ... Supplemental Response to J. Epstein's Motion for
Court to Declare Relevance and Non-Privileged
Nature of Documents, and Request for Additional
Limited Discovery, Evidentiary Hearing, and
Appointment of Special
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799180.pdf
EFTA00800960Set 9
2018-08-1418p4,570w
bankruptcy court, Epstein's
Circuit Court Motion for Court to Declare Relevance
and Non-Privileged Nature of Documents and
Appointment of Special Master and Supplement
thereto, Epstein's Response ... Documents Containing
Privileged Materials, and Epstein's Motion for Court
to Declare Relevant and Non-Privileged Nature of
Documents, for purposes of drafting Sworn
Declaration of Fact of Scott ... Supplemental Response to J. Epstein's Motion for
Court to Declare Relevance and Non-Privileged
Nature of Documents, and Request for Additional
Limited Discovery, Evidentiary Hearing, and
Appointment of Special
https://www.justice.gov/epstein/files/DataSet%209/EFTA00800960.pdf
EFTA00808704Set 9
2018-11-1315p4,769w
03/06/18 Edwards' Response to Epstein's Motion for Court to Declare
Relevance and Non-Privileged Nature of Documents, etc.
¶ 5 - "In his Notice of Filing Appendix, Epstein, through counsel, includes ... 04/04/18 Epstein's Supplement to Motion for Court to Declare Relevance
and Non-Privilege Nature of Documents
Page 2 - Preface
"Now that the appellate court has made this time available
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808704.pdf
EFTA01194924Set 9
2p1,309w
take this opportunity to inform you of our practice regarding
the sharing of non-privileged information with other members. Our global
practice ranks among the largest and most prestigious ... staff practicing in over 50 offices around the world. We share with other
members non-privileged information about our practice and clients for
research, practice management, training, administrative and other ... place among all members. If you
have any concerns about this sharing of non-privileged information that relates
to you, please promptly notify us so that we can address your
https://www.justice.gov/epstein/files/DataSet%209/EFTA01194924.pdf
EFTA00083400Set 9
2020-07-082p327w
Subject: FW: Maxwell Investigation - Friendly Subpoena to Real Estate Attorney
Approved. Friendly subpoena for non-privileged documents related to a real estate transaction.
From:
Sent: Tuesday, July ... assistance. She requested via email the formality of a subpoena before providing us non-privileged
documents from her file. As such, we do not need PSEU's approval ... proposed subpoena is attached to this email. In short, we are seeking any non-privileged documents
and records regarding the purchase of Maxwell's New Hampshire property. These records
https://www.justice.gov/epstein/files/DataSet%209/EFTA00083400.pdf
EFTA01626136Set 10
2016-01-1418p4,901w
provides, in pertinent part, that "(p)arties may obtain discovery
regarding any non-privileged matter that is relevant to any party's claim or defense—
including the existence, description, nature ... provides, in pertinent part, that Ipiarties may obtain discovery
regarding any non-privileged matter that is relevant to any party's claim or defense—
including the existence, description, nature, custody ... provides, in pertinent part, that "[p]arties may obtain discovery
regarding any non-privileged matter that is relevant to any party's claim or defense—
including the existence, description, nature
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01626136.pdf