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EFTA00638232
Dataset 9
2011-10-09
1p
114w
Subject:
Fwd: EPSTEIN - Jane Doe #1 & 2's
First Request
for Production to the GOV Regarding
From:
Martin Weinberg
To:
Jeffrey Epstein <
[email protected]
-
From: Martin Weinberg To: Jeffrey Epstein <
[email protected]
- Cc: Martin Weinberg Subject: Fwd: EPSTEIN - Jane Doe #1 & 2's
First Request
for Production to the GOV Regarding Information Date: Sun, 09 Oct 2011 15:27:14 +0000 Attachments: Jane_Doe 1 _&_2 DF Here is the Edwards production requests on Govt. Martin G. Weinberg, Esq. 20 Park Plaza, Suite 1000 Boston, MA 02116 This Electronic Message contains information from the Law Office of Martin G. Weinberg, P.C., and…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00638232.pdf
EFTA00724049
Dataset 9
2008-11-19
14p
947w
…v. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S SIXTH SUPPLEMENTAL RESPONSE TO DEFENDANT'S
FIRST REQUEST
TO PRODUCE Plaintiff, JANE DOE 5, by and through her undersigned counsel, and pursuant to Federal Rules of Civil Procedure Rule 34, hereby submits her Sixth Supplemental Response to Defendant, JEFFREY EPSTEIN'S, First Set of Request for Production to Plaintiffs as follows: General Obiections 1. Plaintiff objects to Defendant's
First Request
for Production of Documents to the extent that the Requests call for the…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00724049.pdf
EFTA02728432
Dataset 11
2009-01-16
4p
401w
CLAIM ID: 26H9-2VPP UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN an Defendants. PLAINTIFF'S SUPPLEMENTAL RESPONSE TO DEFENDANTS
FIRST REQUEST
TO PRODUCE DATED JANUARY 16, 2009 Plaintifa by and through the undersigned attorney and pursuant to Rule 1.350, Florida Rules of Civil Procedure, hereby supplements her response to Defendant, JEFFREY EPSTEIN's,
First Request
to Produce dated January 16, 2009 as follows: 1. Individual and…
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02728432.pdf
EFTA02725951
Dataset 11
2013-07-19
2p
233w
…9:08-cv-80736-KAM Document 213 Entered on FLSD Docket 07/19/2013 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-C1V-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, Vs. UNITED STATES, Respondent. RESPONDENT'S NOTICE OF FILING RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT Respondent United States files its Response to Petitioners'
First Request
for Admissions to the Government. DATED: July 19, 2013 Respectfully submitted,…
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02725951.pdf
EFTA00209334
Dataset 9
2013-06-18
3p
465w
…for the filing of any relevance objections by respondent. Since lack of relevance is not an evidentiary privilege, respondent has not included any relevance objections in its Privilege Logs. Respondent respectfully requests leave of the Court to allow it to file a five-page document entitled Respondent's Relevance Objections to Petitioners'
First Request
for Production to The Government, attached as Exhibit A to this motion. CERTIFICATE OF CONFERENCE On July 30, 2013, respondent's counsel sought petitioners' position on…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209334.pdf
EFTA00157834
Dataset 9
2009-01-16
4p
468w
CLAIM ID: 26H9-2VPP UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARFtA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN and Defendants. PLAINTIFF'S SUPPLEMENTAL RESPONSE TO DEFENDANT'S
FIRST REQUEST
TO PRODUCE DATED JANUARY 16. 2009 Plaintiff, by and through the undersigned attorney and pursuant to Rule 1.350, Florida Rules of Civil Procedure, hereby supplements her response to Defendant, JEFFREY EPSTEIN's,
First Request
to Produce dated January 16, 2009 as follows: 1. Individual…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00157834.pdf
EFTA00705602
Dataset 9
2011-09-26
6p
1,432w
…2014 Order, the Court noted that, "[a]s this Court has previously indicated see DE 190, the Federal Rules of Civil Procedure govern the general course of this proceeding." DE 257 at 3. Petitioners'
first request
for production goes well beyond the "limited factual EFTA00705602 Case 9:08-cv-80736-KAM Document 260 Entered on FLSD Docket 10/06/2014 Page 2 of 6 development" permitted by the Court it its September 26, 2011 Order. Further, many of the categories…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00705602.pdf
EFTA00726470
Dataset 9
2010-02-26
13p
3,931w
Case 9:08-cv-80119-KAM Document 477-1 Entered on FLSD Docket 0226/2010 Page 1 of • • 13 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO: 08-CV-80893-MARRA/JOHNSON JANE DOE, Plaintiff vs. JEFFREY EPSTEIN, Defendant PLAINTIFF'S
FIRST REQUEST
FOR PRODUCTION TO DEFENDANT COMES NOW the Plaintiff, JANE DOE, by and through her undersigned counsel, pursuant to Fed.R.Civ.P. 34 and S.D. Fla. 26.10., and requests the Defendant, Jeffrey…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00726470.pdf
EFTA00016132
Dataset 8
2019-07-26
4p
1,296w
…the Southern District of New York New York, New York 10007 Re: United States v. Jeffrey Epstein, No. I 9-cr-00490 Defendant's
First Request
for Discovery Dear We represent Jeffrey Epstein in the above-referenced matter. We write to request the preservation and production of several important categories of documents. The following request and future requests' encompass not only documents and information in your office's possession, custody, or control, but also documents that the government has the…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00016132.pdf
EFTA00604972
Dataset 9
2010-03-10
9p
1,640w
…self-incrimination. See, e.g., No. EFTA00604972 Case 9:08-cv-80119-KAM Document 486 Entered on FLSD Docket 03/10/2010 Page 2 of 7 CASE NO: 08-CV-80119-MARRA/JOHNSON 9:08-CV-80893, Motion to Compel Answers to Plaintiffs
First Request
for Production, Dkt. #97 (listing discovery requests blocked by Fifth Amendment invocations). Because Epstein has been unwilling to answer questions, Jane Doe has been forced to search for other means of discovery. She understands, on…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00604972.pdf
EFTA00299879
Dataset 9
2010-04-15
12p
2,279w
…Employee Status EFTA00299886 7. Copies of Permanent Resident Cards 8. Island Grounds Sick/Vacation/Personal Days Alain Gifford vs. L.S1 -Correspondence -Operating File -Demand for Arbitration -American Arbitration Associates -Preliminary Hearing Schedule Order -American Arbitration Invoices -Complainant's
First Request
for Production of Documents -Complainant's First Set of Interrogatories to Respondent -Letter and Proposed Notice of Deposition sent to Att. Carty (March 2, 2010) -Respondents Opposition To Claimants Motion to Dismiss -March 1, 2010 Order -Notice of Deposition…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00299879.pdf
EFTA00221691
Dataset 9
2009-01-26
12p
3,567w
…Rules 7.1 and 26.1 H (S.D. Fla. 2008). In support of his motion, Defendant states: Introduction Prior to the filing of this motion, counsel for Defendant and counsel for Plaintiff corresponded with each other and were able to resolve some of the discovery issues related to Defendant's
First Request
to Produce and Plaintiffs Response thereto. By letter, dated March 3, 2009, the Plaintiff agreed to withdraw her "General Objections" set forth in her response. As well…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00221691.pdf
EFTA00596695
Dataset 9
2010-11-05
1p
209w
…et al. v. Jeepers, Inc. Second Production in Response to Financial Trust Company, Inc.'s and Jeepers, Inc.'s
First Request
for Production of Documents Dear Mr. Susman: Please find enclosed a CD containing documents that are bates stamped DBZCO_FTC0001605 - DISZCO_FTC0003774. All of the aforementioned documents should be treated as confidential and subject to the terms of the Confidentiality Agreement and Order that Hannah Sholl of Paul, Weiss, Rifkin, Wharton & Garrison LLP sent you via email on October…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00596695.pdf
EFTA01139610
Dataset 9
2014-10-24
11p
3,228w
…pretends that this point can be easily established in other ways. But the Government has refused to admit basic facts surrounding the strength of its case. The victims'
first request
for admission to the Government asked for an admission that the U.S. Attorney's Office's and the FBI's "investigation into Jeffrey Epstein developed a case for a federal prosecution against Epstein for many federal sex offenses." Victims' Req. for Admission #1. Rather than simply admit this point…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01139610.pdf
EFTA00210758
Dataset 9
2015-01-29
80p
24,607w
…the proposed amended complaint go beyond the victims' existing pleadings. See, e.g., Exhibit 3. We don't see any good faith basis for you to withhold consent to the victims'
first request
to amend their petition to conform to the evidence. We hope that you will consent. 2. Motion to Add Two New Parties. A separate question is presented by Jane Doe No. I and Jane Doe No. 2's request to add two new parties into the case…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00210758.pdf
EFTA00210193
Dataset 9
2015-06-26
2p
727w
Subject:
RE: two questions: (I) certification re completion of 2013 production; (2) procedures for
From:
(USAFLS)" <1 [=.
To:
Paul Cassell <I
…2, 3, or 4. I will double-check on Supplemental Discovery Request numbers 3, 4, and 6, and let you know by June 30, 2015. I will have a certification on the petitioners'
First Request
for Production and
First Request
for Admission by June 30, 2015. I am in the middle of several other projects right now. Thank you. From: Paul Catcall (mato Sent: Thursd June 25, 2015 4:14 PM To: USAFLS Cc: . (USAFLS); (USAFLS); Brad Edwards ( Subject: RE…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00210193.pdf
EFTA01202952
Dataset 9
2014-10-20
17p
4,679w
…strong case against Epstein is a critical starting point for the victims' case. The victims' need for information is also demonstrating by the Government's refusal to admit basic facts surrounding the strength of its case. The victims'
first request
for admission to the Government asked it to admit that the U.S. Attorney's Office and the FBI's "investigation into Jeffrey Epstein developed a case for a federal prosecution against Epstein for many federal sex offenses." Victims' Req…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01202952.pdf
EFTA00210999
Dataset 9
2015-06-30
5p
2,219w
Subject:
RE: thanks very much ...
From:
Paul Cassell
…which we believe may be responsive, but believe that, if there is responsive information, it would likely be located in those documents. EFTA00210999 On the issue of the certification regarding the petitioners'
First Request
for Production to The Government Regarding Information Relevant to Their Pending Action Concern (sic) The Crime Victims Rights Act (October 3, 2011), and petitioners' Supplemental Request for Production to The Government Regarding New Information Concerning Investigation of Handling of Epstein Non-Prosecution Agreement (June 24, 2013)…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00210999.pdf
EFTA00727279
Dataset 9
2009-09-28
3p
500w
…Records reviewed: Plaintiff's First Amended Complaint Civil RICO Case Statement Plaintiff's Answers to Defendant's First Interrogatories Correspondence of United States Attorney, Southern District of Florida PkiintifEs Supplemental Response to Defendant's
First Request
to Produce Number 7 Defendant's Reply to Plaintiff's Response in Opposition to Motion to Compel Interrogatories • Multiple police/court records Court records o Phone 1 Police/court records o 08/18/09 Review, annotate and highlight records 6 hr 08/19/09…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00727279.pdf
EFTA00727282
Dataset 9
2009-09-03
7p
1,235w
Subject:
/14:N VO% GPiI
…09 Review, annotate and highlight records 5 min Total hours 50 min Rate: $400/hour $333.00 69L9-ZZC-LOtb OW 'II8H '3 lalel-loN BZI.:Ol• 60 OZ PO EFTA00727284 Records reviewed: First Amended Complaint Answers to Interrogatories Amended Answer to Interrogatory #13 Answers to
First Request
to Produce Answers to Expert Interrogatories Various police reports Photographs Various police reports o Various police reports o Various police reports o 08/12/09 Review, annotate and highlight records 08/13…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00727282.pdf
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