EFTA00603608Set 9
2015-01-06129p34,335w
information).
In sum, Plaintiffs' objections to Interrogatory Nos. 13 and 21 and to Document Request
Nos ... Exhibit A, Responses to Interrogatory Nos. 13, 21; Exhibit C, Responses to Document Request
Nos ... evidence
Accordingly, Plaintiffs' relevancy and/or admissibility objections to Interrogatory Nos.
13 & 21 and Document Request Nos
https://www.justice.gov/epstein/files/DataSet%209/EFTA00603608.pdf
EFTA01079203Set 9
2016-01-1260p13,979w
being sexually trafficked by convicted sex offender Jeffrey Epstein. See
Exhibit 6, Request nos. 2, 3, 4 and 10. Defendant's unreasonable subpoena even includes a
demand for this ... privacy and intimidate and harass the party).
Defendant also has a number of requests (Request nos. 2, 3, 4, 10 and 19) that seek
"photographs" and "videos" of this ... party and the Court should preclude this type
of discovery set forth in Request Nos. 2, 3, 4, 10, 15, 16, 19 and 21. See Citimortgage, Inc. v.
Davis
https://www.justice.gov/epstein/files/DataSet%209/EFTA01079203.pdf
EFTA01078765Set 9
2015-04-0790p24,360w
being sexually trafficked by convicted sex offender Jeffrey Epstein. See
Exhibit 6, Request nos. 2, 3, 4 and 10. Defendant's unreasonable subpoena even includes a
demand for this ... privacy and intimidate and harass the party).
Defendant also has a number of requests (Request nos. 2, 3, 4, 10 and 19) that seek
"photographs" and "videos" of this ... party and the Court should preclude this type
of discovery set forth in Request Nos. 2, 3, 4, 10, 15, 16, 19 and 21. See Citimortgage, Inc. v.
Davis
https://www.justice.gov/epstein/files/DataSet%209/EFTA01078765.pdf
EFTA01078855Set 9
2015-04-0790p24,394w
being sexually trafficked by convicted sex offender Jeffrey Epstein. See
Exhibit 6, Request nos. 2, 3, 4 and 10. Defendant's unreasonable subpoena even includes a
demand for this ... privacy and intimidate and harass the party).
Defendant also has a number of requests (Request nos. 2, 3, 4, 10 and 19) that seek
"photographs" and "videos" of this ... party and the Court should preclude this type
of discovery set forth in Request Nos. 2, 3, 4, 10, 15, 16, 19 and 21. See Citimortgage, Inc. v.
Davis
https://www.justice.gov/epstein/files/DataSet%209/EFTA01078855.pdf
EFTA00728201Set 9
2009-03-0253p14,628w
response to the following requests would compel testimonial self-
incrimination:
Types of Documents Requested Request Nos.
Agreements with the U.S. Attorney 1-4
and State Attorney, and documents
exchanged between ... producing items in response to request no. 9, concerning witness
statements, and request nos. 12-13, concerning photographs or images of females, may implicate the
Fifth Amendment.
-5-
EFTA00728205
Case ... Create a Privilege in Discovery
Defendant objects to Document Request nos. 1-5, which seek the Defendant's agreements
with the U.S. Attorney and State Attorney, and documents exchanged with
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728201.pdf
EFTA00222502Set 9
2009-03-0216p3,973w
response to the following requests would compel testimonial self-
incrimination:
Types of Documents Requested Request Nos.
Agreements with the U.S. Attorney 1-4
and State Attorney, and documents
exchanged between ... producing items in response to request no. 9, concerning witness
statements, and request nos. 12-13, concerning photographs or images of females, may implicate the
Fifth Amendment.
-5-
EFTA00222506
Case ... Create a Privilege in Discovery
Defendant objects to Document Request nos. 1-5, which seek the Defendant's agreements
with the U.S. Attorney and State Attorney, and documents exchanged with
https://www.justice.gov/epstein/files/DataSet%209/EFTA00222502.pdf
EFTA00221691Set 9
2009-01-2612p3,567w
entitled to the documents requested for each of the years
2002-2007.
Production Requests Nos. 10, 11, 17, & 18
10. All photographs, movies, dvds, and videotapes in which you performed ... better response
specifically indicating whether the items requested in each of the production requests
nos. 10, 11, 17, and 18 - (1) exist or do not exist ... discovery sought regarding any
photos, movies, dvds, and videotapes as decscribed in requests nos. 10 and 11, and
Plaintiff's sexual activity with males, as described in nos
https://www.justice.gov/epstein/files/DataSet%209/EFTA00221691.pdf
EFTA00207838Set 9
2010-07-0625p6,150w
HELD IN CONTEMPT FOR FAILING TO PRODUCE
STATE DISCOVERY AND STATE CORRESPONDENCE RESPONSIVE TO
REQUESTS NOS. 7, 9, AND 10
9
EFTA00207846
CASE NO: 08-CV-80119-MARRA/JOHNSON
As noted ... matter for him to have simply said that and not appeal the ruling on Requests
Nos. 7 and 9 (and to a large extent 10). To the contrary, however, Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00207838.pdf
EFTA01078617Set 9
2015-04-09148p40,118w
firm seeking information that is not relevant to the
underlying action. For example, Request nos. 2, 3, 5, 6, 7, 10, 14, 17, 19, and 20 specifically
reference either ... abused as a minor
child and writings related to her experience. See Exhibit 6, Request nos. 1, 8, 9, 10, 11, 13, 16,
19 and 20. Defendant also demands that ... being sexually trafficked by convicted sex offender,
Jeffrey Epstein. See Exhibit 6, Request nos. 4, 5, 11 and 13. Defendant also demands that the
law firm produce information relating
https://www.justice.gov/epstein/files/DataSet%209/EFTA01078617.pdf
EFTA01070533Set 9
2009-07-2041p13,997w
interrogatories
overlap.
1, 2, 4, 5, and 19,
Motion To Compel Responses to Production Requests Nos. 23.
and Answers to Interrogatories Nos. 2.18, and
Production Request No. 1
documentation
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070533.pdf
EFTA01070451Set 9
2009-07-2050p15,294w
requests and Interrogatories because the discovery Issues
overlap.
PAotIon To Compel Responses to Production Requests Nos. 1, 2, 4, 5, and 19,
and Answers to Interrogatories Nos
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070451.pdf
EFTA00723743Set 9
2010-01-1515p4,666w
Town objects to producing any responsive
documents of the type objected to in Request Nos. 2, 15 and 16, supra. Subject
to and notwithstanding its objections, the Town Police Department ... Town objects to producing any responsive
documents of the type objected to in Request Nos. 2, 15 and 16, supra. Subject
to and notwithstanding its objections, the Town Police Department
https://www.justice.gov/epstein/files/DataSet%209/EFTA00723743.pdf
EFTA01076133Set 9
2009-10-2625p7,430w
Town objects to producing any responsive
documents of the type objected to in Request Nos. 2, 15 and 16, supra. Subject
to and notwithstanding its objections, the Town Police Department ... Town objects to producing any responsive
documents of the type objected to in Request Nos. 2, 15 and 16, supra. Subject
to and notwithstanding its objections, the Town Police Department
https://www.justice.gov/epstein/files/DataSet%209/EFTA01076133.pdf
EFTA00723218Set 9
2009-12-0977p19,203w
Motion, that the act of
producing items in response to Production Request Nos. 9, 12-13 and responding to
Interrogatory No. 9, may implicate the Fifth Amendment. Finally, the Court
https://www.justice.gov/epstein/files/DataSet%209/EFTA00723218.pdf
EFTA00593382Set 9
2015-11-022p334w
Granted in part, as follows:
a. The Motion to Quash is Granted as to Requests Nos. 9, 17, 18, 20, and 23. The
Motion is denied as to the remaining
https://www.justice.gov/epstein/files/DataSet%209/EFTA00593382.pdf