Epstein Secrets

ert C. Josefsberg [email protected] Adam D. Horowitz [email protected] Stuart S. Mermelstein [email protected] William J. Berger [email protected] Case 9:08-cv-80119-KAM Document 346 Entered on FLSD Docket 10/13/2009 Page 7 of 7

cular, the examiner proposes to ask Jane Doe about her previous “medical, . . . legal, social, criminal, [and] academic” background.” Affidavit of Ryan Hall, Attachment “D” to Defendant Epstein’s Motion to Compel Independent Medical Examination, [DE 301-4] Case 9:08-CV-80119- KAM. In addition, the exami

ot reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01930 09/05/2009 Bradley J. Edwards William J. Berger Client info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evide

asonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05927 09/18/2009 Bradley Edwards Amy Swan Ryan Hall Psychiatrist Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evide

ot reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01930 09/05/2009 Bradley J. Edwards William J. Berger Client info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evide

asonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05927 09/18/2009 Bradley Edwards Amy Swan Ryan Hall Psychiatrist Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evide