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ned counsel, to file this motion to compel the Government to provide answers to certain requests for admission and requests for production involving Alan Dershowitz or, in the alternative, to properly assert privilege over these discovery requests. On April 11, 2015, the victims sent a Second Request for Admiss
ne of Jeffrey Epstein's defense attorneys, Alan Dershowitz, the Government refused to provide any information, asserting that any information about Dershowitz was irrelevant to this case and, in some instances, was privileged from production. Following discussions between counsel for the victims and the G
r admission and requests for production involving Alan Dershowitz or, in the alternative, to properly a
07) (internal quotations omitted). The Federal Rules of Civil Procedure are broadly written and "strongly favor full discovery whenever possible." Farnsworth I Procter and Gamble Co., 758 F.2d 1545, 1547 (11th Cir.1985). Thus, as this Court has previously ruled in this case, the bottom line is that "[d]is
lead to the discovery of the admissible evidence; protected by privacy rights 11420-11426 08/24/2009 Attorneys at RRA Bradley Edwards Serving Alan Dershowitz Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect
lead to the discovery of the admissible evidence; protected by privacy rights 20201-20204 08/24/2009 Attorneys at RRA Bradley Edwards Serving Dershowitz Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect
/2009 Attorneys at RRA Bradley Edwards Serving Alan Dershowitz Work product; attorney/client priv
Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION protected by privacy rights 06118-06146 09/15/2009 Seth Lehrman Bradley Edwards Farnsworth v. Marys case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evid
lead to the discovery of the admissible evidence; protected by privacy rights 11420-11426 08/24/2009 Attorneys at RRA Bradley Edwards Serving Alan Dershowitz Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect
lead to the discovery of the admissible evidence; protected by privacy rights 20201-20204 08/24/2009 Attorneys at RRA Bradley Edwards Serving Dershowitz Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect
/2009 Attorneys at RRA Bradley Edwards Serving Alan Dershowitz Work product; attorney/client priv
Fistos & Lehrman BATES DATE LQ FROM DESCRIPTION OBJECTION protected by privacy rights 06118-06146 09/15/2009 Seth Lehrman Bradley Edwards Farnsworth v. Macys case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evid
Entities connected to both Alan Dershowitz and Farnsworth

Jeffrey Epstein
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Paul Cassell
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONRobert D. Critton
PERSONMaria Farmer
PERSON
Les Wexner
PERSONScott Rothstein
PERSON
Alfredo Rodriguez
PERSON
Jean-Luc Brunel
PERSON
David Rodgers
PERSON
Michael Reiter
PERSONLarry Visoski
PERSONEmmy Taylor
PERSON