EFTA00589735Dataset 9
2017-09-256p1,563w
…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 in this case; and a Motion in Limine. Forcing Epstein to provide and argue proper responses to all of these items, as well as prepare for argument on his motions; motions which include a request to compel answers to four separate sets of Interrogatories and Requests to Produce, especially when Epstein is unreachable 4…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00589735.pdf
EFTA00586084Dataset 9
2017-09-256p1,570w
…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 in this case; and a Motion in Limine. Forcing Epstein to provide and argue proper responses to all of these items, as well as prepare for argument on his motions; motions which include a request to compel answers to four separate sets of Interrogatories and Requests to Produce, especially when Epstein is unreachable 4…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00586084.pdf
EFTA00601557Dataset 9
2017-09-256p1,442w
…criminal defense counsels; three motions directed to Epstein's Motion for Summary Judgment; objections to 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 in this case; and a Motion in Limine. Forcing Epstein to research these issues, draft, file, and argue proper responses to all of these items, as well as prepare for hearing on his motions; motions which…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00601557.pdf
EFTA00584754Dataset 9
2017-09-256p1,568w
…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 in this case; and a Motion in Limine. Forcing Epstein to provide and argue proper responses to all of these items, as well as prepare for argument on his motions; motions which include a request to compel answers to four separate sets of Interrogatories and Requests to Produce, especially when Epstein is unreachable 4…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00584754.pdf
EFTA01111222Dataset 9
2013-05-1718p5,126w
…asserted the Fifth Amendment in response to every question/re quest propounded by Edwards where an answer, if provided, could conceivably "furnish a link in the chain of evidence needed to prosecute the claimant." Accordingly, if the Cour t's May 17, 2013 Order is compelling Epstein to provide a privilege log with respect to his Const itutional Privileges it is, in essence, forcing Epstein to waive this privilege. See United States v. Doe, 465 U.S. 605, 612 (1984)…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01111222.pdf
EFTA01112365Dataset 9
2013-05-179p2,220w
…therefore, properly asserted the Fifth Amendment in response to every question/request propounded by Edwards where an answer, if provided, could conceivably "furnish a link in the chain of evidence needed to prosecute the claimant." 6 EFTA01112370 Accordingly, if the Court's Order is compelling Epstein to provide a privilege log with respect to his Constitutional Privilege it is, in essence, forcing Epstein to waive this privilege. See United States v. Doe, 465 U.S. 605, 612 (1984); People v…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112365.pdf