HOUSE_OVERSIGHT_014100.jpg

1.62 MB

Extraction Summary

2
People
2
Organizations
0
Locations
1
Events
1
Relationships
3
Quotes

Document Information

Type: Legal filing (response/objections to document requests)
File Size: 1.62 MB
Summary

This page contains the 'General Objections' section of a legal filing (Case 9:08-cv-80736-KAM) entered in the Southern District of Florida in 2015. The Defendant outlines five standard objections regarding the production of documents, citing relevance, admissibility, timing of discovery, attorney-client privilege, and undue burden. The document bears a House Oversight Committee bates stamp.

People (2)

Name Role Context
Defendant Legal Party
The party objecting to the document requests (likely Jeffrey Epstein based on case number context, though not explici...
Plaintiffs Legal Party
The party propounding the document requests.

Organizations (2)

Name Type Context
FLSD
United States District Court for the Southern District of Florida (implied by docket header).
House Oversight Committee
Indicated by the Bates stamp 'HOUSE_OVERSIGHT'.

Timeline (1 events)

2015-03-24
Document entered on FLSD Docket
Florida Southern District Court

Relationships (1)

Plaintiffs Legal Adversaries Defendant
Document discusses 'Document Request propounded by Plaintiffs' and 'Defendant further reserves the right to object'.

Key Quotes (3)

"Defendant objects to each Document Request to the extent that it calls for documents protected by the attorney-client privilege, the work-product doctrine, or any other applicable privilege or protection."
Source
HOUSE_OVERSIGHT_014100.jpg
Quote #1
"Defendant generally objects to the Document Requests as unduly burdensome and oppressive"
Source
HOUSE_OVERSIGHT_014100.jpg
Quote #2
"Defendant does not concede that any information requested is relevant to this action or admissible at trial."
Source
HOUSE_OVERSIGHT_014100.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,834 characters)

Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 17 of
34
any Document Request propounded by Plaintiffs. Defendant further reserves the right to object
to the admission in evidence of any and all information made available in response to the
Document Requests on any ground, including, but not limited to, the ground that it is irrelevant
and immaterial to the issues in this action.
GENERAL OBJECTIONS
1. The General Objections and statements in this section apply to each of
Defendant’s responses to the Document Requests set forth below and are not necessarily
repeated in response to each individual Document Request.
2. By responding to the Document Requests, Defendant does not concede that any
information requested is relevant to this action or admissible at trial. Defendant expressly
reserves the right to object to further discovery on the subject matter of any of these Document
Requests.
3. Defendant’s responses set forth below include only documents located or obtained
up to the date of service of the responses. Additional responsive, non-privileged documents may
be ascertained or identified subsequently, and Defendant reserves the right to rely on such
documents throughout this litigation and at trial.
4. Defendant objects to each Document Request to the extent that it calls for
documents protected by the attorney-client privilege, the work-product doctrine, or any other
applicable privilege or protection. By responding to any Document Request, Defendant does not
waive any applicable privilege as to that Document Request or as to any other present or future
discovery request.
5. Defendant generally objects to the Document Requests as unduly burdensome and
oppressive to the extent that they ask Defendant to provide information that is beyond
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HOUSE_OVERSIGHT_014100

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