Epstein Secrets

ntial conflicts of interest that the Justice Department discussed or determined existed for the USAO SDFL, as well as any referral that was made to Main Justice or to any other District, including any documents that were transmitted to any other District regarding the conflict and regarding what was to be i

initial disclosures required by the Federal Rules of Civil Procedure, including Rule 26(a)(1). Respondents object because the Court's finding that the Federal Rules of Civil Procedure "govern the general course of this proceeding," does not mean that all requirements governing 4 EFTA00705605 Case 9:08-cv-80736-KAM Do

ntial conflicts of interest that the Justice Department discussed or determined existed for the USAO SDFL, as well as any referral that was made to Main Justice or to any other District, including any documents that EFTA00208640 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 3

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

ntial conflicts of interest that the Justice Department discussed or determined existed for the USAO SDFL, as well as any referral that was made to Main Justice or to any other District, including any documents that were transmitted to any other District regarding the conflict and regarding what was to be i

ly to this case. D.E. 99 at 11 ("Because the Court will allow this limited factual development, it is unnecessary to decide here whether the CVRA or the Federal Rules of Civil Procedure provide discovery rights in this context."). Petitioners cannot obtain initial disclosures under Rule 26(a)(1) by simply incorporating it

lose to persons associated with the victims. 21 EFTA00210160 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 22 of 51 Main Justice or to any other District, including any documents that were transmitted to any other District regarding the conflict and regarding what was to be in

26(a)(1). Although Petitioners have already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation d

ntial conflicts of interest that the Justice Department discussed or determined existed for the USAO SDFL, as well as any referral that was made to Main Justice or to any other District, including any documents that EFTA00615901 Case 9:08-cv-80736-KAM Document 265-1 Entered on FLSD Docket 10/20/2014 Page 3

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

IDENTIAL - PURSUANT TO FED. R.CON(F IDENTIAL DB-SDNY-0022405 EFTA_OOPOI31 EFTA01296799 Page 75 2015 U.S. Dist. LEXIS 87203, * that was made to Main Justice or to any other District, including any documents that were transmitted to any other District regarding the conflict and regarding what was to be i

76 2015 U.S. Dist. LEXIS 87203, * already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation

sociated with the victims. 21 EFTA_R1_01293456 EFTA02335918 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 22 of 51 Main Justice or to any other District, including any documents that were transmitted to any other District regarding the conflict and regarding what was to be in

26(a)(1). Although Petitioners have already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation d

ntial conflicts of interest that the Justice Department discussed or determined existed for the USAO SDFL, as well as any referral that was made to Main Justice or to any other District, including any documents that EFTA00081148 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 3

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

lose to persons associated with the victims. 21 EFTA00086465 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 22 of 51 Main Justice or to any other District, including any documents that were transmitted to any other District regarding the conflict and regarding what was to be in

26(a)(1). Although Petitioners have already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation d

lose to persons associated with the victims. 21 EFTA01657772 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 22 of 51 Main Justice or to any other District, including any documents that were transmitted to any other District regarding the conflict and regarding what was to be in

26(a)(1). Although Petitioners have already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation d