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EFTA00723218
Dataset 9
2009-12-09
77p
19,203w
… c. Not relevant, material or reasonably calculated to lead to the discovery of admissible evidence; further, has the capacity to compromise the accuracy of the memories of ■ and any other witness who is permitted to view the photo and is therefore in conflict with the parties interest in a trustworthy fact-finding process; d.
Overbroad
, unduly burdensome, violation of constitutional right of privacy; and harassing; e. May allow to fabricate and tailor her testimony before her deposition occurs; and…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00723218.pdf
EFTA01581728
Dataset 10
1p
242w
… Dubin objects to the definition of "Document" as vague,
overbroad
and unduly burdensome. 5. Dubin objects to the definition of "Person" on the ground that it is vague,
overbroad
and unduly burdensome. 6. Dubin objects to the definition of "All" and "each" as vague,
overbroad
and unduly burdensome. Objections to Instructions 1. Dubin objects to each of the Instructions to the extent that they purport to impose any obligations that exceed the requirements of the New York Civil Practice Law…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01581728.pdf
EFTA01581719
Dataset 10
1p
215w
… Highbridge objects to the definition of "Document" as vague,
overbroad
and unduly burdensome. 5. Highbridge objects to the definition of "Person" on the ground that it is vague,
overbroad
and unduly burdensome. 6. Highbridge objects to the definition of "All" and "each" as vague,
overbroad
and unduly burdensome. Objections to Instructions 1. Highbridge objects to each of the Instructions to .the extent that they purport to impose any obligations that exceed the requirements of the New York Civil Practice Law…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01581719.pdf
EFTA01266114
Dataset 10
3p
682w
From:
Case Number: sub
To:
Core Tracking Number:
…Mobile- 4 Sylvan Way Parsippany, NJ 07054 metroPCS Phone: Fax: Email: Archive Records Objection Date: May 23.2019 To: Core Tracking Number: From: Case Number: sub Fax Number: Case Name: Comments: T-MOBILE IS IN RECEIPT OF YOUR LEGAL DEMAND AND RESPONDS AS FOLLOWS: The legal demand seeks records that have been archived. T-Mobile hereby objects to the legal demand as
overbroad
, unduly burdensome, not refined in scope or date range, does not permit adequate time for response and…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01266114.pdf
EFTA01331534
Dataset 10
1p
183w
…8911 Fax: (973) 292-8697 August 08.2021 T-Mobile Tracking ID: 3360122 Objection T-Mobile hereby objects to the referenced legal demand for one or more of the following reasons: a) failure of personal service; b) lack of personal jurisdiction; c) demand is facially invalid; d) demand is
overbroad
, unduly burdensome and/or not refined in scope or date range; e) demand does not provide reasonable time for response; f) demand seeks electronic records that are not readily accessible…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01331534.pdf
EFTA01326048
Dataset 10
1p
210w
…8697 March 26. 2021 T-Mobile Tracking ID: 3140320 Objection T-Mobile hereby objects to the referenced legal demand for one or more of the following reasons: a) failure of personal service; b) lack of personal jurisdiction; c) demand is facially invalid; d) demand is
overbroad
, unduly burdensome and/or not refined in scope or date range; e) demand does not provide reasonable time for response; f) demand seeks electronic records that are not readily accessible; and/or g) demand…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01326048.pdf
EFTA01626136
Dataset 10
2016-01-14
18p
4,901w
…TO THE GOVERNMENT The United States (hereinafter the "Respondent") hereby responds to Jane Doe I and Jane Doe 2's Second Request for Admissions to the Government Regarding Questions Relevant to Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Second Requestfor Admissions"), and states as follows: Objection to Requests'
Overbroad
and Unduly Burdensome Use of Petitioner-Defined "Government" The Respondent objects to the petitioners' use in ten of its numbered requests for admissions (i.e., Requests No…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01626136.pdf
EFTA00015303
Dataset 8
22p
5,018w
…R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Attorneys for Chislaine Maxwell EFTA00015303 TABLE OF CONTENTS TABLE OF CONTENTS TABLE OF AUTHORITIES ii FACTUAL BACKGROUND 1 ARGUMENT 2 I. The government's violation of the Fourth Amendment requires suppression. 2 A. The subpoena violated the Fourth Amendment because it was unconstitutionally
overbroad
. 4 B. The government's subpoena toa was an unconstitutional warrantless Fourth Amendment search 6 1. The third-party doctrine does not compel a different result. 8 C…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00015303.pdf
EFTA00072585
Dataset 9
1p
176w
…Fax: August 08. 2021 T-Mobile Tracking ID: 3360122 Objection T-Mobile hereby objects to the referenced legal demand for one or more of the following reasons: a) failure of personal service; b) lack of personal jurisdiction; c) demand is facially invalid; d) demand is
overbroad
, unduly burdensome and/or not refined in scope or date range; e) demand does not provide reasonable time for response; f) demand seeks electronic records that are not readily accessible; and/or g) demand…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00072585.pdf
EFTA00211105
Dataset 9
2016-11-04
2p
278w
Subject:
Re: Responses to Supplemental Requests for Admissions and Supplemental Request for
From:
Brad Edwards imailto:
[email protected]
)
…at 1:35 PM, Brad, The government's response to the discovery requests will not be a blanket list of objections. We should be able to provide substantive responses to some of the discovery requests. However, we continue to believe that some of the requests are
overbroad
in what they appear to seek. As we progress in our inquiries, we will let you know the specific bases for our objections. Thanks. From: Brad Edwards imailto:
[email protected]
) Sent: Friday…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211105.pdf
EFTA00603169
Dataset 9
2p
315w
…according to the documents presented to this Court, could be in excess of 10,214 pages of e-mails. At this point, the Court finds that the request is
overbroad
and not necessarily calculated to lead to admissible evidence. The purported basis for obtaining these records is to establish some type of "abuse of process" in regard to the non-prosecution agreement entered into between the government and the Plaintiff. At present, there is no pending Complaint by the Plaintiff…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00603169.pdf
EFTA00805407
Dataset 9
2018-04-06
21p
5,804w
…INTERVENE AND UNSEAL 1 EFTA00805407 Case 1:15-cv-07433-RWS Document 936 Filed 04/06/18 Page 2 of 21 TABLE OF CONTENTS TABLE OF AUTHORITIES ii PRELIMINARY STATEMENT 1 I. INTERVENORS' COVERAGE OF ALLEGATIONS AGAINST JEFFREY EPSTEIN AND GHISLAINE MAXWELL 2 II. THE
OVERBROAD
SEALING ORDER AND PRIOR ATTEMPTS TO UNSEAL 3 III. THE ORDER DENYING THE MOTIONS TO UNSEAL 6 ARGUMENT 6 I. MIAMI HERALD MEDIA HAS THE RIGHT TO INTERVENE AS A NEWS ORGANIZATION 7 II…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00805407.pdf
EFTA00211101
Dataset 9
2016-11-04
2p
522w
Subject:
RE: Responses to Supplemental Requests for Admissions and Supplemental Request for
From:
Brad Edwards
To:
Brad Edwards I
…Brad, The government's response to the discovery requests will not be a blanket list of objections. We should be able to provide substantive responses to some of the discovery requests. However, we continue to believe that some of the requests are
overbroad
in what they appear to seek. As we progress in our inquiries, we will let you know the specific bases for our objections. Thanks. From: Brad Edward Sent: Frida November 04 2016 11:37 AM To Cc…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211101.pdf
EFTA00077956
Dataset 9
2021-11-04
2p
267w
…J. NATHAN, District Judge: The Court is in receipt of the parties' proposed redactions to the parties' motions in limine, responses in opposition, replies in support, and related exhibits. As the Court indicated at today's conference, some of the parties' proposed redactions are
overbroad
considering the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). In particular, for the reasons stated at today's conference, the…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00077956.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 (
…Date: Fri, 10 Mar 2017 22:56:18 +0000 Importance: Normal Dear Paul, As an initial matter, let me assure you that you are not being stonewalled. As you know, we informed you and Brad early on that we believed that some of your supplemental discovery requests were
overbroad
and objectionable on various grounds, but that we were willing to search for and believed that we would be able to provide substantive responses to some of the requests. Indeed, after…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211042.pdf
EFTA00105935
Dataset 9
2021-03-29
2p
259w
…responding to the Court's March 29, 2021 Order. The parties agree that the redactions to pages 118 and 119 are no longer necessary. The Defendant continues to press for the redactions on pages 129-134. However, for the reasons stated in the Court's March 29, 2021 Order, the information is already part of the public record in this case and accordingly the proposed redactions are unnecessary and
overbroad
. Dkt. No. 189; see also United States v. Nejad, No…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00105935.pdf
EFTA01114413
Dataset 9
2p
372w
…according to the documents presented to this Court, could be in excess of 10,214 pages of e-mails. At this point, the Court finds that the request is
overbroad
and not necessarily calculated to lead to admissible evidence. The purported basis for obtaining these records is to establish some type of "abuse of process" in regard to the non-prosecution agreement entered into between the government and the Plaintiff. At present, there is no pending Complaint by the Plaintiff…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01114413.pdf
EFTA00211110
Dataset 9
2016-11-04
2p
477w
Subject:
RE: Responses to Supplemental Requests for Admissions and Supplemental Request for
From:
Brad Edwards [
To:
Brad Edwards
…Nov 2016 17:35:28 +0000 Importance: Normal Brad, The government's response to the discovery requests will not be a blanket list of objections. We should be able to provide substantive responses to some of the discovery requests. However, we continue to believe that some of the requests are
overbroad
in what they appear to seek. As we progress in our inquiries, we will let you know the specific bases for our objections. Thanks. From: Brad Edwards [ Sent: Friday…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211110.pdf
EFTA01114333
Dataset 9
2p
371w
…according to the documents presented to this Court, could be in excess of 10,214 pages of e-mails. At this point, the Court finds that the request is
overbroad
and not necessarily calculated to lead to admissible evidence. The purported basis for obtaining these records is to establish some type of "abuse of process" in regard to the non-prosecution agreement entered into between the government and the Plaintiff. At present, there is no pending Complaint by the Plaintiff…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01114333.pdf
EFTA01734380
Dataset 10
3p
1,054w
…2000). In addition to and without waiving his constitutional privileges, Defendant also objects as the request for production as unreasonable, vague,
overbroad
, and may seek information that is protected by attorney-client and work-product privileges and Is neither relevant to the subject matter of the pending action nor does it appear to be reasonably calculated to lead to the discovery of admissible evidence as worded. Moreover, Plaintiffs request seeks information available from other non party entities. Request No. 2…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01734380.pdf
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