This document is a Motion to Compel Answers to Plaintiff's First Request for Production filed by Plaintiff Jane Doe against Defendant Jeffrey Epstein in the United States District Court, Southern District of Florida (Case No. 08-CV-80119-MARRA/JOHNSON). The motion argues that Epstein has improperly asserted blanket Fifth Amendment privileges in response to sixteen specific requests for production of documents, including telephone records, appointment books, financial records, and correspondence. The Plaintiff requests the Court to order Epstein to answer the requests, provide a particularized justification for his Fifth Amendment invocations, and produce a privilege log.
This legal document is a motion filed on January 12, 2023, by John M. Leventhal, attorney for the defendant-appellant, requesting a one-month extension to file an appellate brief, moving the deadline from January 30 to February 28, 2023. The justification for the extension is the difficulty in communicating with the client, who is incarcerated in Tallahassee, Florida, and the need for more time to complete the work. The motion notes that the opposing counsel, Assistant U.S. Attorney Andrew Rohrbach, does not object to the request.
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