EFTA00622835Dataset 9
2015-01-0610p2,506w
… On September 8, 2015, Dershowitz file a motion to compel Plaintiffs' production of documents and complete responses to interrogatories (the "Motion to Compel"). Among other arguments raised in his briefs in support of the Motion to Compel, Dershowitz asserted that: • Plaintiffs have waived the attorney-client privilege belonging to by bringing this defamation action against Dershowitz and placing at issue both 2 EFTA00622836 the veracity of allegations against Dershowitz and Plaintiffs' investigation into those allegations. • herself has waived the attorney…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00622835.pdf
EFTA01116468Dataset 9
2015-09-1091p29,281w
…However, Edwards and Cassell are not the triers of fact who have authority to decide what is relevant, permissible, and proper discovery, through their own self-serving definition of "responsiveness." As set forth in Dershowitz's Motion to Compel, Plaintiffs' interrogatory responses and document production are incomplete, with no date certain as to when they will be completed. Moreover, Plaintiffs have asserted objections that have been waived or lack a sufficient basis in law or fact. SUMMARY OF REPLY ARGUMENT…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01116468.pdf
EFTA00593012Dataset 9
2015-12-092p264w
…and the Court having heard argument, reviewed the pleadings and exhibits and being otherwise fully advised in the premises, it is hereby, ORDERED AND ADJUGED that I. Defendant/Counterclaim Plaintiffs Motion to Compel Plaintiffs Production of Documents and complete responses to interrogatories is hereby denied. Pre March 2014 communication are protected by the work product privilege and the witness has not waived the communications that were protected by the attorney-client privilege. Also, there was no waiver by the Plaintiffs…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00593012.pdf
EFTA00590326Dataset 9
2015-11-033p370w
…ALAN M. DERSHOWITZ'S MOTION TO COMPEL PLAINTIFFS' PRODUCTION OF DOCUMENTS & COMPLETE RESPONSES TO INTERROGATORIES; • DEFENDANT/COUNTERCLAIM PLAINTIFF ALAN M. DERSHOWITZ'S MOTION FOR FINDING OF WAIVER BASED ON PLAINTIFFS' FAILURE TO PROVIDE A PRIVILEGE LOG OR, IN THE ALTERNATIVE, TO COMPEL PLAINTIFFS TO PROVIDE AN ITEMIZED PRIVILEGE LOG Movant counsel certifies that A) I have made a good faith attempt to agree or to narrow the issues on the Motions noticed has been made with opposing counsel, to no…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00590326.pdf
EFTA01196965Dataset 9
2015-10-223p286w
…2015, at 9:30 ■. or as soon thereafter as counsel may be heard, the following: DEFENDANT/COUNTERCLAIM PLAINTIFF ALAN M. DERSHOWITZ'S MOTION TO COMPEL PLAINTIFFS' PRODUCTION OF DOCUMENTS & COMPLETE RESPONSES TO INTERROGATORIES Movant counsel certifies that a bona fide effort to agree or to narrow the issues on the Motions noticed has been made with opposing counsel, to no avail. PLEASE GOVERN YOURSELVES ACCORDINGLY. EFTA01196965 Respectfully submitted, /s/ Thomas E. Scott Thomas E. Scott, Esq. Florida Bar No…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01196965.pdf
EFTA00593337Dataset 9
2015-10-214p425w
…the following: DEFENDANT/COUNTERCLAIM PLAINTIFF ALAN M. DERSHOWITZ'S MOTION FOR FINDING OF WAIVER BASED ON PLAINTIFFS' FAILURE TO PROVIDE A PRIVILEGE LOG OR, IN THE ALTERNATIVE, TO COMPEL PLAINTIFFS TO PROVIDE AN ITEMIZED PRIVILEGE LOG Movant counsel certifies that A) I have made a good faith attempt to agree or to narrow the issues on the Motions noticed has been made with opposing counsel, to no avail; and B) the issues before the Court may be heard and resolved…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00593337.pdf
EFTA00603608Dataset 9
2015-01-06129p34,335w
…EDWARDS and PAUL G. CASSELL, Plaintiffs/Counterclaim Defendants, vs. ALAN M. DERSHOWITZ, Defendant/Counterclaim Plaintiff. DEFENDANT/COUNTERCLAIM PLAINTIFF ALAN M. DERSHOWITZ'S MOTION TO COMPEL PLAINTIFFS' PRODUCTION OF DOCUMENTS & COMPLETE RESPONSES TO INTERROGATORIES Defendant/Counterclaim Plaintiff ALAN M. DERSHOWITZ ("Dershowitz") respectfully moves this Court for entry of an Order that (a) overrules the objections asserted by Plaintiffs BRADLEY J. EDWARDS ("Edwards") and PAUL G. CASSELL ("Cassell") in response to Dershowitz's First Set of Document Requests and First Set of…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00603608.pdf
EFTA00222162Dataset 9
2009-05-069p1,992w
…EXPENSES Plaintiffs, JANE DOES 2-7, by and through their undersigned counsel, hereby file this Memorandum in Opposition to Epstein's Motion to Compel Plaintiffs to Answer First Set of Interrogatories and for an Award of Reasonable Expenses, and state as follows: I. Introduction Defendant Epstein served an Interrogatory (# 18) seeking to unearth explicit information on every bit of possible sexual conduct and activity in chronological order which each Jane Doe might have engaged in since age 10, including the…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00222162.pdf
EFTA01157164Dataset 9
2015-02-116p1,385w
…Edwards") with, among other things, certain discovery requests, including without limitation a First Set of Document Requests and a First Set of Interrogatories, each dated February 11, 2015, and a Motion to Compel Plaintiffs' Production of Documents & Complete Responses to Interrogatories, dated September 8, 2015; and WHEREAS, Edwards contends that in responding to said discovery requests Edwards would be required produce and disclose documents and information produced or obtained by Edwards, either as counsel or litigant, to or from Epstein…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01157164.pdf