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laintiffs also allege that Epstein "sexually assaulted" them, and that Epstein "maintains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach, FL." They further allege "Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted girls in Fl
ested documents, as to their authenticity, and as to the defendant's selection of them as meeting the requests for production. ate United States v. Hubbell, 530 U.S. 27, 35-36 (2000). Thus, where the existence or location of the requested documents are unknown, or where production would "implicitly auth
that Epstein "sexually assaulted" her. ¶12 Plaintiff also alleges that EPSTEIN "maintains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach, FL." Id, ¶7. "Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted girls in Florida, New Yo
tance where "the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence EFTA00222080 Case 9:0
16, and 37, upon information and belief, Defendant displayed a myriad of photographs of underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set
e act of production where, as here, it involves a self-incriminating testimonial communication or "a compelled testimonial aspect." United States v, Hubbell, 530 U.S. 27, 120 S.Ct. 2037 (2000)• Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence, Title 6, Chap. 13. The Privilege Against
Entities connected to both New Mexico and Hubbell

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONJane Doe
PERSONthe Southern District
LOCATIONJack Goldberger
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
New York
LOCATION
Marc Rich
PERSON
Donald Trump
PERSON
Palm Beach
LOCATION
Scarlett Johansson
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSONLeon Black
PERSON
Bill Clinton
PERSON
Paul Cassell
PERSON
Prince Andrew
PERSON