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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 HOUSE_OVERSIGHT_014095