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Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 13 of 34 Edwards, Bradley vs. Dershowitz Case No.: CACE 15-000072 Plaintiffs’ Motion to Compel Production of Documents Response to Requests for Production 1, 2, 3, 4, 5, 6, 9, 10, 13, 14, 15, 16, 19, 20, 21, 22, and 23. To permit the Court to review the extent of Dershowitz’s evasions, a copy of his responses is attached to this pleading as Exhibit A. In short, despite having had 45 days to gather materials that allegedly provide “absolute proof” that he has never even met Jane Doe No. 3 — and despite having told numerous media sources that he had already collected such information — Dershowitz has produced none of these documents to Edwards and Cassell. He has also made blanket assertions of a variety of privileges, but has produced no privilege logs. CONCLUSION Accordingly, Edwards and Cassell request: 1. That Dershowitz be directed to produce all materials covered by the discovery requests forthwith; 2. That Dershowitz be held to have waived any and all otherwise applicable privileges as a consequence of his failure to timely file a privilege log; and 3. That Dershowitz be ordered to pay reasonable costs and attorneys’ fees associated with the need to file this motion to compel. CERTIFICATE OF GOOD FAITH EFFORT TO RESOLVE Plaintiffs have attempted in good faith to resolve the discovery issues presented in this motion (and others) as evidenced by the letter attached as Exhibit B. The Defendant has failed to respond as of the time of the filing of this motion. HOUSE_OVERSIGHT_014096