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documents that "might allow them to protect those very rights." (Id. at 15). By way of illustration, Petitioners offer the case of In re Grand Jury Subpoena Duces Tecum, where the Eighth Circuit broadly stated that "the general duty of public service calls upon government employees and agencies to favor disclosure
responsive to this request that are not otherwise protected opinion work product. No production under this request is necessary. 6. Request No. 25—Initial Disclosures under FRCP 26(a)(1) Finally, Petitioners request that the Government comply with its obligation to serve initial disclosures under Federal Rule of
documents that "might allow them to protect those very rights." (Id. at 15). By way of illustration, Petitioners offer the case of In re Grand Jury Subpoena Duces Tecum, where the Eighth Circuit broadly stated that "the general duty of public service calls upon government employees and agencies to favor disclosure
responsive to this request that are not otherwise protected opinion work product. No production under this request is necessary. 6. Request No. 25—Initial Disclosures under FRCP 26(2)(1) Finally. Petitioners request that the Government comply with its obligation to serve initial disclosures under Federal Rule of
documents that "might allow them to protect those very rights." (lcl at 15). By way of illustration, Petitioners offer the case of In re Grand Jury Subpoena Duces Tecum, where the Eighth Circuit broadly stated that "the general duty of public service calls upon government employees and agencies to favor disclosure
responsive to this request that are not otherwise protected opinion work product. No production under this request is necessary. 6. Request No. 25—Initial Disclosures under FRCP 26(a)(1) Finally, Petitioners request that the Government comply with its obligation to serve initial disclosures under Federal Rule of
documents that "might allow them to protect those very rights." (Id. at 15). By way of illustration, Petitioners offer the case of In re Grand Jury Subpoena Duces Tecum, where the Eighth Circuit broadly stated that "the general duty of public service calls upon government employees and agencies to favor disclosure
responsive to this request that are not otherwise protected opinion work product. No production under this request is necessary. 6. Request No. 25—Initial Disclosures under FRCP 26(a)(1) Finally, Petitioners request that the Government comply with its obligation to serve initial disclosures under Federal Rule of
orowitz, Adam) (Entered: 12/21/2009) 12/29/2009 443 RESPONSE/REPLY to 442 Response to Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum and Incorporated Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum Regarding Jane Doe 4 by Jeffrey Epstein. (Attachme
enior Judge Kenneth L. Ryskamp. (sh) (Entered: 04/30/2009) 05/15/2009 12 "WRONG EVENT USED, RE-DOCKETED AS ENTRY 13 " NOTICE by Jeffrey Epstein of Initial Disclosures (Brewer, William) Modified on 5/19/2009 (Is). (Entered: 05/15/2009) 05/15/2009 Initial Disclosure(s) by Jeffrey Epstein. [See Image at DE #12] (Is
Entities connected to both Subpoena Duces Tecum and Initial Disclosures

Jeffrey Epstein
PERSONthe Southern District
LOCATION
United States
LOCATIONJane Doe
PERSON
Kenneth Marra
PERSONEmmy Taylor
PERSON
George W. Bush
PERSON
Supreme Court
ORGANIZATIONthe Federal Rules of Civil
ORGANIZATION
Bradley Edwards
PERSONLeon Black
PERSON
Michael Jackson
PERSONMaria Farmer
PERSON
Paul Cassell
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSONRoy Black
PERSOND.C. Cir
ORGANIZATIONMartin Weinberg
PERSON
Southern District of New York
ORGANIZATION