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"Compel Production"
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EFTA00211068
Dataset 9
2017-03-08
2p
776w
Subject:
RE: Motion to Compel and S.J. Briefing Schedule
From:
Paul Cassell <I
To:
"Brad Edwards
…conduct a search of the e- mail accounts of Special Agents ..." Given the nature of the materials that we are seeking, it appears that the U.S. Attorney's Office is intent on not locating the materials that we are seeking. We intend to file a motion to
compel production
of these materials on or about Tuesday, March 14 — making all of these points clearly for Judge Marra, so that he can draw his own conclusions about what is happening…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211068.pdf
EFTA00211046
Dataset 9
2017-03-10
3p
936w
Subject:
RE: Motion to Compel and S.J. Briefing Schedule
From:
Paul Cassell <I
To:
"Brad Edwards (r>, "
…conduct a search of the e- mail accounts of Special Agents Given the nature of the materials that we are seeking, it appears that the U.S. Attorney's Office is intent on not locating the materials that we are seeking. We intend to file a motion to
compel production
of these materials on or about Tuesday, March 14 — making all of these points clearly for Judge Marra, so that he can draw his own conclusions about what is happening…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211046.pdf
EFTA00211076
Dataset 9
2017-03-08
3p
1,013w
Subject:
RE: Motion to Compel and S.J. Briefing Schedule
From:
vnrarana, HIRI lvf drle C. (IJJArL3)
To:
"N
…a search of the e-mail accounts of Special Agents r" • •" " Given the nature of the materials that we are seeking, it appears that the U.S. Attorney's Office is intent on not locating the materials that we are seeking. We intend to file a motion to
compel production
of these materials on or about Tuesday, March 14 — making all of these points clearly for Judge Marra, so that he can draw his own conclusions about what is happening…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211076.pdf
EFTA00211062
Dataset 9
2017-03-08
3p
991w
Subject:
RE: Motion to Compel and S.J. Briefing Schedule
From:
' (USAFLS)"
To:
M" INICSAFLS)" c > ' (USAFLS)"
…a search of the e-mail accounts of Special Agents and ..." Given the nature of the materials that we are seeking, it appears that the U.S. Attorney's Office is intent on not locating the materials that we are seeking. We intend to file a motion to
compel production
of these materials on or about Tuesday, March 14 — making all of these points clearly for Judge Marra, so that he can draw his own conclusions about what is happening…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211062.pdf
EFTA00211070
Dataset 9
2017-03-08
3p
944w
Subject:
Re: Motion to Compel and S.J. Briefing Schedule
…conduct a search of the e-mail accounts of Special Agents Given the nature of the materials that we are seeking, it appears that the U.S. Attorney's Office is intent on not locating the materials that we are seeking. We intend to file a motion to
compel production
of these materials on or about Tuesday, March 14 — making all of these points clearly for Judge Marra, so that he can draw his own conclusions about what is happening…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211070.pdf
EFTA00211079
Dataset 9
2017-03-08
2p
797w
Subject:
Fwd: Motion to Compel and S.J. Briefing Schedule
From:
Paul Cassel
…conduct a search of the e-mail accounts of Special Agents Given the nature of the materials that we are seeking, it appears that the U.S. Attorney's Office is intent on not locating the materials that we are seeking. We intend to file a motion to
compel production
of these materials on or about Tuesday, March 14 — making all of these points clearly for Judge Marra, so that he can draw his own conclusions about what is happening…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211079.pdf
EFTA00211073
Dataset 9
2017-03-08
3p
822w
Subject:
RE: Motion to Compel and S.J. Briefing Schedule
…the FBI to conduct a search of the e-mail accounts Given the nature of the materials that we are seeking, it appears that the U.S. Attorney's Office is intent on not locating the materials that we are seeking. We intend to file a motion to
compel production
of these materials on or about Tuesday, March 14 — making all of these points clearly for Judge Marra, so that he can draw his own conclusions about what is happening…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211073.pdf
EFTA00211065
Dataset 9
2017-03-08
3p
932w
Subject:
RE: Motion to Compel and S.J. Briefing Schedule
From:
' (USAFLS)"
To:
>, ' (USAFLS)"
…e-mail accounts of Special Agents Nesbitt Kuyrkendall and Jason Richards ..." Given the nature of the materials that we are seeking, it appears that the U.S. Attorney's Office is intent on not locating the materials that we are seeking. We intend to file a motion to
compel production
of these materials on or about Tuesday, March 14 — making all of these points clearly for Judge Marra, so that he can draw his own conclusions about what is happening…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211065.pdf
EFTA00211042
Dataset 9
2017-03-10
4p
1,923w
Subject:
RE: Motion to Compel and S.J. Briefing Schedule
From:
' (l'SAFLS)".cl
To:
Paul "Brad Edwards (
…search of the e- mail accounts of Special Agents and Jason Given the nature of the materials that we are seeking, it appears that the U.S. Attorney's Office is intent on not locating the materials that we are seeking. We intend to file a motion to
compel production
of these materials on or about Tuesday, March 14 — making all of these points clearly for Judge Marra, so that he can draw his own conclusions about what is happening…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211042.pdf
EFTA00207115
Dataset 9
2010-03-10
2p
331w
Subject:
Activity in Case 9:08-cv-80119-ICAM Doe v. Epstein Motion to Compel
From:
'
…Notice of Electronic Filing The following transaction was entered by Edwards, Bradley on 3/10/2010 at 5:41 PM EST and filed on 3/10/2010 Case Name: Doe v. Epstein Case Number: 9:08-cv-80119-KAM Filer: Jane Doe Document Number:486 Docket Text: Plaintiff's MOTION to
Compel Production
ofFBI Records by Jane Doe. Responses due by 3/29/2010 (Attachments: # (1) Text of Proposed Order)(Edwards, Bradley) 9:08-cv-80119-KAM Notice has been…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00207115.pdf
EFTA00207097
Dataset 9
2010-03-17
2p
292w
Subject:
Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Motion to Compel
From:
"
[email protected]
" <
[email protected]
>
To:
"flsd_cmecf
[email protected]
" <flsd_cmecf
[email protected]
>
…Florida Notice of Electronic Filing The following transaction was entered by Horowitz, Adam on 3/17/2010 at 11:44AM EDT and filed on 3/17/2010 Case Name: Doe I. Epstein Case Number: 9:08-cv-80119-KAM Filer: Jane Doe Document Number: 489 Docket Text: Plaintiff's MOTION to
Compel Production
of Jane Doe Nos. 2-7's Sworn Statements to FBI investigators and Incorporated Memorandum of Law by Jane Doe. Responses due by 4/5/2010 (Attachments: #…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00207097.pdf
EFTA01734801
Dataset 10
2016-09-06
8p
2,140w
…Epstein," she has reneged on that promise, forcing Ms. Maxwell to file yet another motion to
compel production
of relevant, discoverable information in Plaintiff's possession. Plaintiff's refusal to produce the document is groundless and the Court should order production of the document forthwith and sanction Plaintiff for her conduct. STATEMENT OF CONFERRAL The undersigned has conferred extensively with Plaintiff's counsel on this issue by telephone and email, as demonstrated in the correspondence attached hereto in Menninger Decl…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01734801.pdf
EFTA00205314
Dataset 9
2013-03-29
2p
277w
…Ruling Denying Government's Motion to Stay (DE 179); and Jane Doe #1 and Jane Doe #2's Motion to
Compel Production
of Court-Ordered Discovery and fora Prompt Ruling on the Motion (DE 183). The Court recognizes that the government's motion to dismiss (DE 119) and motion to stay discovery pending ruling upon the motion to dismiss (DE 121) have been pending for an extended period of time. The Court apologizes to the parties for not having resolved…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00205314.pdf
EFTA00208682
Dataset 9
2013-08-16
70p
20,257w
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 1 of 70 EXHIBIT A PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS EFTA00208682 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 2 of 70 PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS Key to Objections (linking to Victims' Motion to
Compel Production
of Docments that Are Not Prig ileged Objection Abbreviation General Objections -- Inadequate Privilege Log Inadequate Log Failure…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208682.pdf
EFTA01081295
Dataset 9
2013-09-03
13p
3,614w
…balancing has not been done, the Privacy Act applies and precludes disclosure by the government. CONCLUSION The government has validly asserted privileges that preclude disclosure of the requested 11 EFTA01081305 Case 9:08-cv-80736-KAM Document 229 Entered on FLSD Docket 09/03/2013 Page 12 of 13 documents to petitioners. Therefore, petitioners' motion to
compel production
should be denied. DATED: September 3, 2013 Respectfully submitted, WILFREDO A. FERRER UNITED STATES ATTORNEY By: s/ Dexter A. Lee DEXTER A…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01081295.pdf
EFTA01142189
Dataset 9
2013-09-03
13p
3,647w
…balancing has not been done, the Privacy Act applies and precludes disclosure by the government. CONCLUSION The government has validly asserted privileges that preclude disclosure of the requested 11 EFTA01142199 Case 9:08-cv-80736-KAM Document 229 Entered on FLSD Docket 09/03/2013 Page 12 of 13 documents to petitioners. Therefore, petitioners' motion to
compel production
should be denied. DATED: September 3, 2013 Respectfully submitted, WILFREDO A. FERRER UNITED STATES ATTORNEY By: s/ Dexter A. Lee DEXTER A…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01142189.pdf
EFTA01116468
Dataset 9
2015-09-10
91p
29,281w
…to the Response filed by Plaintiffs/Counterclaim Defendants' BRADLEY J. EDWARDS ("Edwards") and PAUL G. CASSELL ("Cassell") (together, "Plaintiffs") in opposition to Dershowitz's Motion to
Compel Production
of Documents and Complete Responses to Interrogatories (the "Motion to Compel"),I INTRODUCTION At the outset of their Response, Plaintiffs spend several pages attempting to document at At issue are Plaintiffs/Counterclaim Defendants' discovery responses and objections in Dershowitz's Motion to Compel, as well as Edwards's Objection to Request No…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01116468.pdf
EFTA01079793
Dataset 9
2013-08-16
70p
20,254w
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 1 of 70 EXHIBIT A PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS EFTA01079793 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 2 of 70 PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS Key to Objections (linking to Victims' Motion to
Compel Production
of Docments that Are Not Prig ileged Objection Abbreviation General Objections -- Inadequate Privilege Log Inadequate Log Failure…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01079793.pdf
EFTA00647347
Dataset 9
2012-08-01
2p
731w
Subject:
RE: Friday's Hearing
From:
"Tonja Haddad Coleman"
…15:33:24 +0000 Attachments: Motion to Compel Re Privilege Log.pdf; 2).pdf Mr. Scarola- Because you seemed so certain in your email to my office yesterday that you have no outstanding discovery issues, I reviewed both the Motion to
Compel Production
of Documents and the Order regarding same that was entered by the Court on May 7, 2012; the one for which you requested clarification. I am attaching copies of each for your review. It seems very clear…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00647347.pdf
EFTA00205252
Dataset 9
2013-03-29
2p
277w
…Ruling Denying Government's Motion to Stay (DE 179); and Jane Doe #1 and Jane Doe #2's Motion to
Compel Production
of Court-Ordered Discovery and fora Prompt Ruling on the Motion (DE 183). The Court recognizes that the government's motion to dismiss (DE 119) and motion to stay discovery pending ruling upon the motion to dismiss (DE 121) have been pending for an extended period of time. The Court apologizes to the parties for not having resolved…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00205252.pdf
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