EFTA01660040Set 10
2015-03-0437p25,087w
Default by
Clerk Against Defendant (tp) (Entered: 06/06/2008)
06/11/2008 9 Plaintiff's MOTION to Compel Clerk to Enter Default Against Defendant, or Alternatively, for
an Enlgargement of Time to Serve ... Goldberger. Jack) (Entered: 06/13/2008)
06/13/2008 11 RESPONSE to Motion re 9 Plaintiff's MOTION to Compel Clerk to Enter Default Against
Defendant, or Alternatively, for an Enlgargement of Time ... Goldberger, Jack) (Entered: 06/20/2008)
06/24/2008 14 MEMORANDUM in Support re 9 Plaintiff's MOTION to Compel Clerk to Enter Default Against
Defendant, or Alternatively, for an Enlgargement of Time
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01660040.pdf
EFTA00091353Set 9
2014-12-3024p10,201w
liability or resolution of dispositive motions.
Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will
Defendant move for a Protective Order with ... liability or resolution of dispositive motions.
Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will
12
EFTA00091364
Defendant move for a Protective ... liability or resolution of dispositive motions.
Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will
Defendant move for a Protective Order with
https://www.justice.gov/epstein/files/DataSet%209/EFTA00091353.pdf
EFTA00623075Set 9
2016-06-0140p11,688w
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
RESPONSE TO MOTION TO COMPEL ATTORNEY-CLIENT COMMUNICATIONS
AND ATTORNEY WORK PRODUCT MATERIALS
BOLES, SCHILLER & FLEXNER LLP
Sigrid McCawley ... 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 and Her Attorneys ... their client's ( ) attorney-client
privilege. On September 8, 2015, Dershowitz filed a motion to compel Cassell and Edwards to
produce documents and additional responses to interrogatories. McCawley Decl., Exhibit
https://www.justice.gov/epstein/files/DataSet%209/EFTA00623075.pdf
EFTA00723218Set 9
2009-12-0977p19,203w
minor
(Interrogatory No. 15). See August 4, 2009 Order on Plaintiff's Motion to Compel
Answers to Interrogatories and Production of Documents. See Infra for Attachments.
9. If the Fifth ... real, substantial and present!" See August 4, 2009 Order on Plaintiff's Motion to
Compel Answers to Interrogatories and Production of Documents at 4 (attached as
Exhibit "B") and September ... JEFFREY EPSTEIN,
Defendant.
ORDER
THIS CAUSE is before the Court on Plaintiff's Motion to Compel Answers to
Interrogatories and Production of Documents (D.E. #57). For the following reasons said
https://www.justice.gov/epstein/files/DataSet%209/EFTA00723218.pdf
EFTA00601808Set 9
2012-01-247p1,945w
DISMISS [DE 129]
AND RESPONDENT'S RESPONSE IN OPPOSITION
TO PETITIONERS' PROTECTIVE MOTION TO COMPEL [DE 130]
Respondent, by and through its undersigned counsel, hereby files this Reply to Petitioner ... Respondent's Motion to Dismiss [DE129] and Response in Opposition to
Petitioners' Protective Motion to Compel [DE 130]. For the following reasons and the reasons set
forth in Respondent ... Dismiss for Lack
of Subject Matter Jurisdiction and, similarly, deny the Petitioners' Protective Motion to Compel.
In both their Response to the Motion to Stay Discovery and their Motion
https://www.justice.gov/epstein/files/DataSet%209/EFTA00601808.pdf
EFTA00221691Set 9
2009-01-2612p3,567w
JOHNSON
JANE DOE NO. 2
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO.
2, TO RESPOND TO DEFENDANT'S FIRST REQUEST TO PRODUCE ... come to an agreement.
Also, Defendant has filed simultaneously with this motion a Motion To Compel
directed to certain of Plaintiff's Answers to Defendant's First Set of Interrogatories ... addresses identical discovery issues. Both motions
should be determined at the same time.
Motion To Compel Responses to Nos. 1, 10, 11. 17, & 18
Production Request No. 1
1. Individual
https://www.justice.gov/epstein/files/DataSet%209/EFTA00221691.pdf
EFTA00586084Set 9
2017-09-256p1,570w
Court on
September 25, 2017; to wit: his Omnibus Motion in Limine; a Motion to Compel discovery
related to Edwards's Privilege Log; a Motion to Compel responses to Discovery ... Motion to
Compel answers to questions posed to Edwards in his depositions. Edwards filed the following
motions on September 25, 2017, to which undersigned cannot possibly respond in three ... every single one of Epstein's
damages Interrogatories to Edwards; four bare-bones Motions to Compel responses to four sets
of unidentified discovery responses, some predating undersigned's involvement
https://www.justice.gov/epstein/files/DataSet%209/EFTA00586084.pdf
EFTA00207488Set 9
2010-06-102p473w
Reconsideration re [559] Defendant's MOTION for Reconsideration re
[555] Order on Motion to Compel, Order on Motion for Contempt Defendant's Motion for
Modification and Reconsideration of the Magistrate ... with
Incorporated Objections aDefendant's MOTION for Reconsideration re [555] Order on Motion to
Compel, Order on Motion for Contempt Defendant's Motion for Modification and
Reconsideration of the Magistrate ... Order Dated June 1, 2010 with Incorporated Objections a,
[555] Order on Motion to Compel, Order on Motion for Contempt or Alternative Rule 4 Appeal
by Jeffrey Epstein. (Attachments
https://www.justice.gov/epstein/files/DataSet%209/EFTA00207488.pdf
EFTA00075477Set 9
2020-08-2074p15,469w
sexual activity, invoking her constitutional right to privacy. In
response, plaintiff filed a motion to compel, telling the court "we have a protective
order in place, and that assures ... Document 40, 08/20/2020, 2913550, Page38 of 74
In response to Ms. Maxwell's motion to compel the production of
documents, App. pp 132-38, plaintiff submitted the "law enforcement materials ... district court denied Ms. Maxwell's motion to compel. App. p
1873. To this day, the district court in this case has not turned over the materials to
Ms. Maxwell
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075477.pdf
EFTA00808583Set 9
2018-07-267p1,054w
EDWARDS, individually, and
individually,
Defendants.
RESPONSE IN OPPOSITION TO DEFENDANT JEFFREY EPSTEIN'S MOTION TO
COMPEL COUNTER-PLAINTIFF BRADLEY J. EDWARDS TO IDENTIFY BATES
NUMBERS OF DOCUMENTS PRODUCED
Bradley ... undersigned counsel, hereby files this
Response in Opposition to Defendant Jeffrey Epstein's Motion to Compel Edwards to Identify
Bates Numbers of Documents Produced thereto, and as grounds therefor states ... EFTA00808583
Edwards adv. Epstein
Case No. 502009CA040800XXXXMBAG
Response in Opposition to Epstein's Motion to Compel Identification of Bates Number.
relitigate waived discovery issues in order to continue wasting Court
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808583.pdf
EFTA01111310Set 9
2010-04-128p1,826w
SCOTT ROTHSTEIN, individually, and
BRADLEY J. EDWARDS, individually,
Defendants/Counter-Plaintiffs.
PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL
AND AMEND PROTECTIVE ORDER
Plaintiff, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel ... privilege.
EFTA01111310
Epstein v. Rothstein and Edwards
Case No. 502009CA040800XXXXMB/Div. AG
Epstein's Motion to Compel and Amend Protective Order
3. Although Edwards did not object to producing all documents ... EFTA01111311
Epstein v. Rothstein and Edwards
Case No. 502009CA040800XXXXMB/Div. AG
Epstein's Motion to Compel and Amend Protective Order
a) U.S. Attorney's office;
b) State of Florida Attorney
https://www.justice.gov/epstein/files/DataSet%209/EFTA01111310.pdf
EFTA01070533Set 9
2009-07-2041p13,997w
Most Cited
The Circuit Court, Brevard
dis- Cases
J., granted in part defendants' motion to compel
Evidence of plaintiffs' past prostitution and their
covery. Plaintiffs filed petition for writ ... Activity In Case 9:08-cv-80811-KAM C.M.A. v. Epstein et al Motion to Compel
This is an automatic e-mail message generated by the CM/ECF system. Please ... Filer; Jeffrey Epstein
Document Number: 54
Docket Text:
by Jeffrey Epstein.
Defendant's MOTION to Compel Response to 1st RTP and 1st Interrogs
Exhibit A, # (2) Exhibit B, # (3) Exhibit
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070533.pdf
EFTA00600871Set 9
2009-09-016p2,429w
mediation/It
Emails re case law, statutes, and predicate offenses, Motion for protective order,
Motion to compel discovery, Motion to compel deposition, availability for hearing,
Right to attend depositions
https://www.justice.gov/epstein/files/DataSet%209/EFTA00600871.pdf
EFTA00088032Set 9
2019-11-199p2,750w
Government to comply with its disclosure
obligations" in order to justify a motion to compel. United States v. Minaya, 395 F. Supp. 2d 28,
34 (S.D.N.Y. 2005).
B. BradylGiglio
Under ... particularized showing that
materials exist requiring disclosure" in order to sustain a motion to compel. United States v.
Juliano, No. 99 Cr. 1197, 2000 WL 640644, at *2 (S.D.N.Y ... disclose." Gov't Opp. at 21-22. The Court cannot grant a motion to compel the Government to
produce a report that, at the time of this order, does
https://www.justice.gov/epstein/files/DataSet%209/EFTA00088032.pdf
EFTA00805158Set 9
2018-01-0531p6,526w
hearing preliminarily
addressing the non-disclosed trial exhibit, Edwards made an ore terms motion to compel
production of all other settlement agreements. (12/5/17 Tr. 230:21-23.)2
This Court ... entered by the employer in other cases. The federal court denied the
plaintiffs motion to compel noting the strong public policy "weigh[ing] in favor of keeping such
documents protected ... Yellow
Freight Sys., Inc., 132 F.R.D. 548, 554-55 (ED. Ca. 1990) (denying motion to compel production
of documents containing information about confidential settlement discussions); Bottaro v. Hatton
Assocs
https://www.justice.gov/epstein/files/DataSet%209/EFTA00805158.pdf
EFTA00211073Set 9
2017-03-083p822w
Subject: RE: Motion to Compel and S.J. Briefing Schedule
Date: Wed, 08 Mar 2017 20:27:41 +0000
Importance: Normal
Let's talk at 6pm. me aid then ... line.
Sent: Wednesday, March 08, 2017 3:25 PM
Subject: Re: Motion to Compel and S.J. Briefing Schedule
6:00pm is fine for me.
Sent from my iPhone ... here late.
Sent: Wednesday, March 08, 2017 3:16 PM
Subject: RE: Motion to Compel and S.J. Briefing Schedule
I have a conference call at 5pm. It should be over
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211073.pdf
EFTA00809157Set 9
2018-02-073p541w
individually,
Defendants/Counter-Plaintiff.
ORDER DENYING EDWARDS' MOTION FOR PROTECTIVE
ORDER AND GRANTING EPSTEIN'S MOTION TO COMPEL E.W. TO
ANSWER QUESTIONS RELATING TO THE CRIMES VICTIMS'
RIGHTS ACT AND TO REOPEN ... Response in Opposition to Edward?
Motion for Protective Order and Epsteiris Motion to Compel E.W. to Answer Questions Relating
to the Crime Victim? Rights Act and to Reopen Deposition ... Edwards
January 12, 2018, Response in Opposition to Epstein's Motion to Compel E.W. to Answer
Questions Relating to the Crime Victim? Rights Act and to Reopen Discovery
https://www.justice.gov/epstein/files/DataSet%209/EFTA00809157.pdf