3
Shared Docs
3
Same-Page
3 / 3
Mentions
David Boies, and stated that she was 16 years old when she "had the mis- fortune of meeting Jeffrey Epstein [in] New York." 7/15/19 Tr. at 72. Ms. Farmer said that Mr. Epstein "flew [her] to New Mexico" and was "inappropriate" with her. Id. She was reluctant to go into details about her experience
306 425 FEDERAL SUPPLEMENT, 3d SERIES t In short, the issue now before the Court has arisen only because Donziger unjustifi- ably has refused to comply with his discov- ery obligations. Had he done so — i.e., had he produced responsive documents as to which the
David Boies, and stated that she was 16 years old when she "had the mis- fortune of meeting Jeffrey Epstein [in] New York." 7/15/19 Tr. at 72. Ms. Farmer said that Mr. Epstein "flew [her] to New Mexico" and was "inappropriate" with her. Id. She was reluctant to go into details about her experience
306 425 FEDERAL SUPPLEMENT, 3d SERIES t In short, the issue now before the Court has arisen only because Donziger unjustifi- ably has refused to comply with his discov- ery obligations. Had he done so — i.e., had he produced responsive documents as to which the
Order, dated Feb. 16, 2021 (ECF No. 120), at 2 in Farmer v. Indyke, 19 Civ. 10475 (S.D.N.Y.); Order, date
. Donziger, No. 19-CR-561 (LAP), 2021 WL 1865376, at *4 (S.D.N.Y. May 10, 2021). The test set forth in Nixon "governs both varieties" of subpoenas. Donziger, 2021 WL 1865376, at *4. Under Nixon, the subpoena must "clear three hurdles: (1) relevancy; (2) admissibility; (3) specificity." Nixon, 418 U.S. a
Entities connected to both Maria Farmer and Donziger

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Donald Trump
PERSON
John F. Kennedy
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Joe Biden
PERSON
Julie K. Brown
PERSONMartin Weinberg
PERSON
Stephen Hawking
PERSON
New York
LOCATION
Alfredo Rodriguez
PERSON
George Mitchell
PERSON
Michael Jackson
PERSON