Epstein Secrets

he following individuals from 1999 — resent: Emmy Taylor, Eva Dubin, Glen Dubin, Jean Luc Brunel, and DO

ssages. 7 EFTA00605866 DOCUMENT REOUEST NO. 6 All documents relating to communications with any of the following individuals from 1999 — resent: Emmy Taylor, Eva Dubin, Glen Dubin, Jean Luc Brunel, and DOCUMENT REQUEST NO. 7 All video tapes, audio tapes, photographs or any other print or electronic med

ntiff, by and through her undersigned counsel, hereby propounds Plaintiff's First Request for Production of Documents pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure to the Defendant Ghislaine Maxwell. The responses are due at the offices of Boies, Schiller & Flexner LLP, 401 East Las Olas Boulevard, S

606504 Jeffrey Epstein EXIJIBIT A 10. All Documents relating to, and all media depicting, any of the following individuals from 1999 — present: Emmy Taylor, Eva Dubin, Glen Dubin, Alan Dcrshowitz, Jean Luc Brunel, (a/k/a and or any females under the age of 18. (a/k/a 11. All Documents relating to

following individuals from 1999 — present: Emmy Taylor, Eva Dubin, Glen Dubin, Alan Dcrshowitz, Jean Lu

slaine Maxwell, Defendant. NOTICE OF SERVICE OF RULE 45 SUBPOENA DUCES TECUM UPON JEFFREY EPSTEIN PLEASE TAKE NOTICE THAT, pursuant to Rule 45 of the Federal Rules of Civil Procedure, Plaintiff, hereby provides Notice of Service of Subpoena upon Jeffrey Epstein. A copy of the Subpoena is attached to this Notice as Exh

opposing parties and their counsel." Hickman I. Taylor, 329 U.S. 495, 510 (1947). The privilege is codi

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

y opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510, 67 S. Ct. 385, 91 L. Ed. 451

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

opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codi

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

opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codi

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

opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codi

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

ion.' United States' Nobles, 422 U.S. 225, 238 (1975). The work-product doctrine applies in civil and criminal litigation. Id. at 236. In Hickman' Taylor, the Supreme Court described the policy behind the doctrine protecting the opinion work-product of lawyers. The Court explained that a lawyer is bou

rs. III. PETITIONERS HAVE NO RIGHT TO DISCOVERY UNDER THE FEDERAL RULES OF CIVIL PROCEDURE Petitioners argue they arc entitled to discovery under the Federal Rules of Civil Procedure, but they point to no particular rule, or case, which provides that such a discovery rights exists. Instead, petitioners seize upon the g