EFTA00723218Dataset 9
2009-12-0977p19,203w
…incrimination; 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…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00723218.pdf
EFTA00018997Dataset 8
2014-10-2420p4,647w
…subpoena of that material. Matter of Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49, 51 (S.D.N.Y. 1988) (law firm could intervene and join motion to quash grand jury subpoena issued to private EFTA00019002 investigation firm). "The governing rule in these circumstances is that the possessor of the claimed privilege or right may intervene to assert it." Id. (quoting Appeal of Hughes, 633 F.2d 282, 288 (3d Cir. 1980)). See also US…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00018997.pdf
EFTA00097649Dataset 9
2014-10-2420p4,543w
…of that material. Matter of Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49, 51 (S.D.N.Y. 1988) (law firm could intervene and join motion to quash grand jury subpoena issued to private 1 EFTA00097654 investigation firm). "The governing rule in these circumstances is that the possessor of the claimed privilege or right may intervene to assert it." Id. (quoting Appeal of Hughes, 633 F.2d 282, 288 (3d Cir. 1980)). See also US…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00097649.pdf
EFTA00614418Dataset 9
2009-04-1037p6,240w
…OR TRANSFER THIS CAUSE came before the Court on Motion to Reassign and/or Transfer, and the Court having heard argument of counsel and being fully advised in these premises, it is hereby ORDERED and ADJUDGED that Defendant's Motion is hereby gamed/ denied DONE AND ORDERED at Palm Beach County Courth st Palm Beach, Florida, this day of , 2009SAGOO et -, IREml VA r e `0 • David French' . Circuit Judge Copies furnished: ROBERT D. CRITTON, JR., ESQ., and MICHAEL J…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00614418.pdf
EFTA01107348Dataset 9
8p2,699w
…S.D. Fla. 2005) ("[t]he Court, however, does find that Plaintiffs' discovery requests are overbroad on their face in that some seek financial records for a five year period."). 2. Please produce the W-2's and any other documents reflecting any income (including salary, bonuses, profit distributions, and any other form of income), including all gross and net revenue received by you directly or indirectly for the past five (5) years. Objection. This Request for Production is overbroad…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01107348.pdf
EFTA00100287Dataset 9
2014-10-2420p4,646w
…of that material. Matter of Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49, 51 (S.D.N.Y. 1988) (law firm could intervene and join motion to quash grand jury subpoena issued to private 1 EFTA00100292 investigation firm). "The governing rule in these circumstances is that the possessor of the claimed privilege or right may intervene to assert it." Id. (quoting Appeal of Hughes, 633 F.2d 282, 288 (3d Cir. 1980)). See also US…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00100287.pdf
EFTA00097331Dataset 9
2014-10-2420p4,558w
…of that material. Matter of Grand Jury Subpoena Duces Tecum Dated Feb. 18, 1988, 685 F. Supp. 49, 51 (S.D.N.Y. 1988) (law firm could intervene and join motion to quash grand jury subpoena issued to private 1 EFTA00097336 investigation firm). "The governing rule in these circumstances is that the possessor of the claimed privilege or right may intervene to assert it." Id. (quoting Appeal of Hughes, 633 F.2d 282, 288 (3d Cir. 1980)). See also US…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00097331.pdf
EFTA00622768Dataset 9
2016-06-092p614w
…Epstein objects to the Definitions, Instructions, and Document Requests as overbroad and beyond the scope permitted by the applicable rules, including but not limited to the seeking of irrelevant information, the definitions of "Agent," "Correspondence," "communication," "Defendant," "Document," "Employee," "Jeffrey Epstein," "Ghislaine Maxwell," "Person(s)," "You," and "Your," the definitions of "Relevant Period" and "relevant time frame," the phrases "relating to" and "associated with," the seeking of documents and information already in the possession of counsel for plaintiff or readily…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00622768.pdf
EFTA00105935Dataset 9
2021-03-292p259w
…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. 18-CR-224 (MN), 2021 WL 681427, at *11 (S.D.N.Y. Feb. 22, 2021). For the reasons stated in the Court's March 18, 2021 and March 29…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00105935.pdf
EFTA01081945Dataset 9
2011-09-2624p7,771w
Case 9:08-cv-80736-KAM Document 205-4 Entered on FLSD Docket 07/05/2013 Page 1 of 24 Appendix D EFTA01081945 Case 9:08-cv-80736-KAM Document 205-4 Entered on FLSD Docket 07/05/2013 Page 2 of 24 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. RESPONDENT'S SEALED MOTION TO STAY DISCOVERY PENDING RULING UPON RESPONDENT…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01081945.pdf
EFTA00020298Dataset 8
2021-04-279p2,731w
…on a certain subject, the requests are so overbroad that issuance of the Rule 17(c) subpoena would be improper. As set forth in the subpoena, the term "communications" encompasses "all forms of correspondence, including regular mail, email, text message, memorandum, or other written communication of information of any kind." The use of the terms "all" and "any" "do not evince specificity." United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00020298.pdf
EFTA00015859Dataset 8
2021-04-276p1,662w
…In any event, the argument is too speculative to meet the standard set forth in Nixon. To begin with, the request appears to be overbroad; under Rule 17(c), the moving party must show that all of the requested material is relevant. Cf. United States v. Pena, No. 15-CR-551 (MN), 2016 WL 8735699, at *2 (S.D.N.Y. Feb. 12, 2016). It appears from the briefing that the diary includes entries from before Minor Victim-2's…
https://www.justice.gov/epstein/files/DataSet%208/EFTA00015859.pdf
EFTA00603608Dataset 9
2015-01-06129p34,335w
…3. In response to Request No. 30, which seeks "[a]ll Documents Concerning Your retainer agreement with Jane Doe #3," Plaintiffs objected on the basis that the request seeks "information not reasonably calculated to lead to the discovery of admissible evidence, attorney- client privilege, work-product doctrine, overly burdensome, overbroad, vague, harassing." Exhibit D, Supplemental Responses, Req. No. 30. Plaintiffs' objections are not well-taken. As an initial matter, the terms of Plaintiffs' engagement by Jane Doe No. 3 are…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00603608.pdf
EFTA00222162Dataset 9
2009-05-069p1,992w
…information regarding all men other than Epstein with whom the Plaintiffs have had sexual activity, interrogatory nos. 19-21 are at least limited to criminal conduct. Nonetheless, these interrogatories are overbroad and unnecessarily infringe on the Plaintiffs' privacy interests, particularly since they seek identity and contact information of men other than Epstein whom Plaintiffs claim committed sexual crimes against them. As discussed infra discovery on a victim in a case of this nature is tempered by Fed.R.Evid., 412…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00222162.pdf
EFTA00104703Dataset 9
2021-04-276p1,661w
…In any event, the argument is too speculative to meet the standard set forth in Nixon. To begin with, the request appears to be overbroad; under Rule 17(c), the moving party must show that all of the requested material is relevant. Cf. United States v. Pena, No. 15-CR-551 (MN), 2016 WL 8735699, at *2 (S.D.N.Y. Feb. 12, 2016). It appears from the briefing that the diary includes entries from before Minor Victim-Ts first…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00104703.pdf
EFTA00103815Dataset 9
2021-04-279p2,731w
…on a certain subject, the requests are so overbroad that issuance of the Rule 17(c) subpoena would be improper. As set forth in the subpoena, the term "communications" encompasses "all forms of correspondence, including regular mail, email, text message, memorandum, or other written communication of information of any kind." The use of the terms "all" and "any" "do not evince specificity." United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00103815.pdf
EFTA00076468Dataset 9
2018-06-1320p6,187w
…CR 523 (CM), 2009 WL 484436, at •2 (S.D.N.Y. Feb. 24, 2009) (McMahon, J.) (quashing subpoena for investigative file as overbroad because although part of the investigative file "may be relevant to the case at bar," the "the bulk of materials sought by defendant would be inadmissible"). In an explanatory parenthetical, Defendants suggest that another court found a "subpoena was `sufficiently specified' because the recipient could 'easily' locate the evidence." (Defs.' Opp'n, at 27 (quoting United…
https://www.justice.gov/epstein/files/DataSet%209/EFTA00076468.pdf