Skip to main content
Skip to content
Case File
efta-efta00209334DOJ Data Set 9Other

UNITED STATES DISTRICT COURT

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 OF AMERICA, Respondent. RESPONDENT'S MOTION FOR LEAVE OF COURT TO FILE RELEVANCE OBJECTIONS TO PETITIONERS' FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT Respondent, by and through its undersigned counsel, files its Motion for Leave of Court to File Relevance Objections to Petitioners' First Request for Production to The Government, and state: I. On June 18, 2013, this Court entered its Omnibus Order, where it directed the respondent, within thirty (30) days of the entry date to (a) file answers to all outstanding requests for admissions in the open court file; (b) produce responsive documents in response to all outstanding requests for production of documents encompassing any documentary material exchanged by or between the federal government and persons or entities outside the federal government (including without limitat

Date
Unknown
Source
DOJ Data Set 9
Reference
EFTA 00209334
Pages
3
Persons
3
Integrity

Summary

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 OF AMERICA, Respondent. RESPONDENT'S MOTION FOR LEAVE OF COURT TO FILE RELEVANCE OBJECTIONS TO PETITIONERS' FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT Respondent, by and through its undersigned counsel, files its Motion for Leave of Court to File Relevance Objections to Petitioners' First Request for Production to The Government, and state: I. On June 18, 2013, this Court entered its Omnibus Order, where it directed the respondent, within thirty (30) days of the entry date to (a) file answers to all outstanding requests for admissions in the open court file; (b) produce responsive documents in response to all outstanding requests for production of documents encompassing any documentary material exchanged by or between the federal government and persons or entities outside the federal government (including without limitat

Tags

eftadataset-9vol00009

Ask AI About This Document

0Share
PostReddit

Extracted Text (OCR)

EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
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 OF AMERICA, Respondent. RESPONDENT'S MOTION FOR LEAVE OF COURT TO FILE RELEVANCE OBJECTIONS TO PETITIONERS' FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT Respondent, by and through its undersigned counsel, files its Motion for Leave of Court to File Relevance Objections to Petitioners' First Request for Production to The Government, and state: I. On June 18, 2013, this Court entered its Omnibus Order, where it directed the respondent, within thirty (30) days of the entry date to (a) file answers to all outstanding requests for admissions in the open court file; (b) produce responsive documents in response to all outstanding requests for production of documents encompassing any documentary material exchanged by or between the federal government and persons or entities outside the federal government (including without limitation all correspondence generated by or between the federal government and Epstein's attorneys); and (c) produce all other responsive documents in response to all outstanding requests for production of documents. D.E. 190 at 2. 2. With regard to any claims of privilege asserted in connection with the production of materials other than communications generated between the federal government and outside persons and entities, the Court directed the government to file and serve, in the public portion of EFTA00209334 the court file, a privilege log; and submit all responsive documents withheld on claim of privilege to the court for in camera inspection by submitting the same for filing with the court under seal. D.E. 190 at 2, ¶ 3(c)(i) and (ii). 3. The Court's Omnibus Order did not provide 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 the instant motion. Petitioners stated that they oppose the motion. DATED: July 19, 2013 Respectfully submitted, WILFREDO A. FERRER UNITED STATES ATTORNEY By: ATTORNEY FOR RESPONDENT CERTIFICATE OF SERVICE 2 EFTA00209335 I HEREBY CERTIFY that on August 2, 2013, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. ___5/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney SERVICE LIST Jane Does 1 and 2 I. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ISM Paul G. Cassell Attorneys for Jane Doe # 1 and Jane Doe # 2 3 EFTA00209336

Related Documents (6)

DOJ Data Set 9OtherUnknown

Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 1 of 10

Case 9:08-cv-80736-KAM Document 324 Entered on FLSD Docket 04/07/2015 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:08-CV-80736-ICAM JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. ORDER DENYING PETITIONERS' MOTION TO JOIN UNDER RULE 21 AND MOTION TO AMEND UNDER RULE 15 This cause is before the Court on Jane Doe 3 and Jane Doe 4's Corrected Motion Pursuant to Rule 21 for Joinder in Action ("Rule 21 Motion") (DE 280), and Jane Doe 1 and Jane Doe 2's Protective Motion Pursuant to Rule 15 to Amend Their Pleadings to Conform to Existing Evidence and to Add Jane Doe 3 and Jane Doe 4 as Petitioners ("Rule 15 Motion") (DE 311). Both motions are ripe for review. For the following reasons, the Court concludes that they should be denied. I. Background This is an action by two unnamed petitioners, Jane Doe 1 and Jane Doe 2, seeking to prosecute a claim under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 377

10p
House OversightOtherNov 11, 2025

Jane Doe victims contest Alan Dershowitz’s motion for limited intervention, alleging he hides truth about sexual molestation claims

The passage provides a concrete legal filing that references specific parties (Alan Dershowitz, multiple Jane Does) and a motion for limited intervention, suggesting a potential avenue for further dis Dershowitz filed a motion for limited intervention in a civil case (9:08‑80736‑Civ‑Marra/Johnson). He claims an affidavit from Jane Doe #3 disproves her allegations, but the filing says no evidence w

1p
DOJ Data Set 10OtherUnknown

EFTA01308033

23p
DOJ Data Set 9OtherUnknown

Farmer, Jaffe, Weissing,

Farmer, Jaffe, Weissing, Edwards, Fistos £t Lehrman, P.L. 'Ovid Pam ftoisl pet WWW.PATITTOJUSTKE.COM 425 North Andrews Avenue • Suite 2 Fort Lauderdale, Florida 33301 4 00 "ti e 6.‘ tk i r atire CalkAllfle alvdtr aIINNEV rar ,NYTTENNINIP PITNEY 'OWES 02 !F $003 , 50 0 000i3V, wit JAN 2i 2,2!3 .a4P En M ZIP t20-12E 3330 Dexter Lee A. Marie Villafatia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 EFTA00191396 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, 1. UNITED STATES, Respondent. SEALED DOCUMENT EFTA00191397 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, UNITED STATES, Respondent. SEALED DOCUMENT MOTION TO SEAL Petitioners Jane Doc No. 1 and Jane Doe No. 2, joined by movants Jane Doe No. 3 and Jane Doe No. 4, move to file the attached pleading and supporti

71p
DOJ Data Set 9OtherUnknown

Case 9:08-cv-80736-KAM Document 312 Entered on FLSD Docket 02/23/2015 Page 1 of 3

3p
DOJ Data Set 9OtherUnknown

Ca_4ate.24h24/43134.01FrietibtOrtlefifitin0a0le28013,8111$2eafiabef146f 22

Ca_4ate.24h24/43134.01FrietibtOrtlefifitin0a0le28013,8111$2eafiabef146f 22 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealinu Sealed Materials Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue EFTA00074964 Ca_QatIgt24743tictoWneDbtOrfiefiVIMOXIle?BOWERKVaffizte12401 22 Introduction This Court asked the parties to brief three issues: "(a) the weight of presumption of public access that should be afforded to an item, (b) the identification and weight of any countervailing interests supporting continued sealing/redaction of the item, and (c) whether the countervailing interests rebut the presumption of public access to the item." DE 1044 at 1. Plaintiff and the Miami Herald's responses improperly afford the highest level of presumption to discovery dispute documents, deny that any co

40p

Forum Discussions

This document was digitized, indexed, and cross-referenced with 1,400+ persons in the Epstein files. 100% free, ad-free, and independent.

Annotations powered by Hypothesis. Select any text on this page to annotate or highlight it.