HOUSE_OVERSIGHT_013387.jpg
1.4 MB
Extraction Summary
5
People
2
Organizations
1
Locations
2
Events
3
Relationships
2
Quotes
Document Information
Type:
Legal motion / brief (page 18)
File Size:
1.4 MB
Summary
This document is page 18 of a legal filing (Bates HOUSE_OVERSIGHT_013387) arguing for the dismissal of Epstein's claims against a party named Edwards. It lists specific unanswered discovery questions regarding physical contact with individuals identified as L.M., Jane Doe, and E.W., and cites Florida case law to argue that Epstein's refusal to answer these questions violates discovery rules and deprives Edwards of a fair defense.
People (5)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Plaintiff/Party to lawsuit |
Accused of refusing to answer discovery questions and blocking full and fair discovery.
|
| Edwards | Defendant/Party to lawsuit |
Argues he is being deprived of understanding evidence and the opportunity to conduct third-party discovery due to Eps...
|
| L.M. | Complainant |
Filed a complaint in September 2008.
|
| Jane Doe | Subject of inquiry |
Referenced in a federal complaint; subject of questions regarding physical contact.
|
| E.W. | Claimant/Subject of inquiry |
Subject of questions regarding physical contact and the value of a claim against a party.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Florida 4th District Court of Appeal |
Cited in legal precedent (McFadden v. State).
|
|
| House Oversight Committee |
Referenced in Bates stamp 'HOUSE_OVERSIGHT'.
|
Locations (1)
| Location | Context |
|---|---|
|
Implied by legal citations (Fla.2006, Fla. 4th Dist. Ct. App.).
|
Relationships (3)
Document discusses 'Epstein's claims against Edwards' and requests dismissal.
Questions regarding L.M.'s complaint filed in 2008.
Questions asking if physical contact occurred with E.W.
Key Quotes (2)
"Epstein's refusal to answer these and literally every other substantive question put to him in discovery has deprived Edwards of even a basic understanding of the evidence alleged to support claims against him."Source
HOUSE_OVERSIGHT_013387.jpg
Quote #1
"Epstein has repeatedly blocked 'full and fair discovery,' requiring dismissal of his claim against Edwards."Source
HOUSE_OVERSIGHT_013387.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (1,648 characters)
• "Is there anything in L.M.'s Complaint that was filed against you in September of 2008 which you contend to be false?"
• "I would like to know whether you ever had any physical contact with the person referred to as Jane Doe in that [federal] complaint?"
• "Did you ever have any physical contact with E.W.?"
• "What is the actual value that you contend the claim of E.W. against you has?"
The matters addressed in these questions are the central focus of Epstein's claims against Edwards. Epstein's refusal to answer these and literally every other substantive question put to him in discovery has deprived Edwards of even a basic understanding of the evidence alleged to support claims against him. Moreover, by not offering any explanation of his allegations, Epstein is depriving Edwards of any opportunity to conduct third party discovery and opportunity to challenge Epstein's allegations.
It is the clear law that "the chief purpose of our discovery rules is to assist the truth-finding function of our justice system and to avoid trial by surprise or ambush," Scipio v. State, 928 So.2d 1138 (Fla.2006), and "full and fair discovery is essential to these important goals," McFadden v. State, 15 So.3d 755, 757 (Fla. 4th Dist. Ct. App. 2009). Accordingly, it is important for the Court to insure "not only compliance with the technical provisions of the discovery rules, but also adherence to the purpose and spirit of those rules in both the criminal and civil context." McFadden, 15 So.3d at 757. Epstein has repeatedly blocked "full and fair discovery," requiring dismissal of his claim against Edwards.
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HOUSE_OVERSIGHT_013387
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