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1.81 MB

Extraction Summary

3
People
3
Organizations
1
Locations
1
Events
2
Relationships
3
Quotes

Document Information

Type: Legal motion (motion to compel production of documents)
File Size: 1.81 MB
Summary

This document is page 5 of a 'Motion to Compel Production of Documents' in the case of Bradley Edwards vs. Alan Dershowitz (Case No. CACE 15-000072), filed in federal court on March 24, 2015. The text details a dispute over discovery delays, noting that on February 11, 2015, Dershowitz's legal team (specifically a paralegal from Cole, Scott & Kissane) promised documents that were then retracted by an attorney. By February 23, 2015, Dershowitz had produced zero documents, offering only 'evasive' standard responses objecting to requests for the 'absolute proof' he referenced in a sworn declaration.

People (3)

Name Role Context
Bradley Edwards Plaintiff
Party filing the motion against Dershowitz.
Alan M. Dershowitz Defendant
Accused of failing to produce discovery documents; quoted as claiming 'absolute proof' in a sworn declaration.
Cassell Counsel/Plaintiff Side
Mentioned alongside Edwards regarding counsel sending emails.

Organizations (3)

Name Type Context
Cole, Scott & Kissane
Law firm representing Dershowitz; a paralegal from this firm confirmed a production date that was later disavowed.
FLSD
Florida Southern District Court (Docket location).
House Oversight
Referenced in the footer stamp (HOUSE_OVERSIGHT_014095).

Timeline (1 events)

2015-02-23
Deadline set by Dershowitz's attorney for document production; Dershowitz responded but produced no documents.
N/A
Alan Dershowitz

Locations (1)

Location Context
Implied by FLSD (Southern District of Florida) and CACE case number format.

Relationships (2)

Bradley Edwards Adversarial Alan M. Dershowitz
Edwards, Bradley vs. Dershowitz (Case Title)
Alan M. Dershowitz Legal Representation Cole, Scott & Kissane
Paralegal for Cole, Scott & Kissane communicated on behalf of Dershowitz regarding production.

Key Quotes (3)

"any and all 'absolute proof' as described in paragraph 8 of the sworn declaration of Alan M. Dershowitz."
Source
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Quote #1
"Dershowitz produced no documents whatsoever."
Source
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Quote #2
"Defendant responds that he will produce all responsive, non-privileged documents currently in his possession, custody or control."
Source
HOUSE_OVERSIGHT_014095.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,941 characters)

Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 12 of 34
Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Plaintiffs’ Motion to Compel Production of Documents
any and all ‘absolute proof’ as described in paragraph 8 of the sworn declaration of Alan M.
Dershowitz.”
On February 11, 2015, counsel for Edwards and Cassell sent an email to counsel for
Dershowitz, noting that discovery production was past due and inquiring as to whether a motion
to compel would be necessary. That same day, a paralegal for Cole, Scott & Kissane confirmed
that appropriate production would be made by the end of the week. Shortly after, an attorney for
Dershowitz disavowed that commitment, and indicated that Dershowitz would make his
productions by February 23, 2015.
On February 23, 2015 – 45 days after the discovery requests had been served –
Dershowitz responded. With regard to the request for production of documents, Dershowitz
produced no documents whatsoever. Instead, he made a vague commitment to produce
unspecified documents at some unspecified time in the future. Illustrative of Dershowitz’s
failure to make any substantive production is the following request for production and
Dershowitz’s answer:
9. Copies of any and all “absolute proof” as described in paragraph 8 of
the sworn Declaration of Alan M. Dershowitz.
RESPONSE: Defendant objects to this Document Request to the extent
that Plaintiffs seek to alter or shift any burdens of proof as a matter of law in this
action. Subject to and without waiving the foregoing specific objections and
General Objections, Defendant responds that he will produce all responsive, non-
privileged documents currently in his possession, custody or control.
Dershowitz made the same evasive response – “Defendant responds that he will produce”
unspecified “non-privileged documents” – to multiple discovery requests. See Dershowitz
5
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