Epstein Secrets

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

ys to reduce any such burden. DATED: October 3, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale, Florida 33301 Telephone Facsimile Florida Bar No.: E-mail: EFTA00208644 Case 9:08-cv-80736-KAM Document 225-1 Entered o

ell). Id. The Court then noted: "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. The Court therefore reserves ruling on [the victims'] motion [for an order directing the Govern

such a responsive document. DATED: August 16, 2013 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale Florida 33301 Telephone Facsimile E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the Universi

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

ways to reduce any such burden. DATED: June 24, 2013 Respectfully Submitted, 5/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah and EFTA00615913 Case 9:08-cv-80736-KAM Document 265-1 Ent

orcement proceeding because it is not a "civil action" against the Government. To be sure, this Court has determined that convenience dictates that the Federal Rules of Civil Procedure "govern the general course of this proceeding." See DE 257 at 3. But that procedural determination does not alter the substance of this ca

ket 02/06/2015 Page 19 of 20 DATED: February 6. 2015 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER. JAFFE, WEISSING. EDWARDS FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Attorneys, or the victims This daytime business a