Epstein Secrets

Docket 03/15/2010 Page 7 of 12 Page No. 7 disclosure in an affidavit by the requested party of net worth, wealth, and income. Id. at 331-32. See Barton v. Cascade Regional Blood Services, 2007 WL 2288035 (W.D.Wash. 2007)("Tax returns are confidential communications between the taxpayer and the gover

reasonably calculated to lead to the discovery of admissible evidence. Moreover, the request here is more broad in nature than the requests made by Jane Doe seeking only personal tax returns (i.e., this request here seeks or may seek production of information related not only to Epstein's personal tax re

ted not only to Epstein's personal tax returns but also to any alleged tax returns filed by any businesses in which Epstein has an interest in - and Jane Doe 2-8's Request for Production attached as Exhibit "A" does not define what tax returns they seek). Although page 3 of DE 426 seems to connote Plaintiff

hering the information through deposition or disclosure in an affidavit by the requested party of net worth, wealth, and income. Id. at 331-32. See Barton v. Cascade Regional Blood Services, 2007 WL 2288035 (W.D.Wash. 2007)("Tax returns are confidential communications between the taxpayer and the gover

des Epstein's counsel's views on the limits and inapplicability of certain elements of 18 U.S.C. §2255, one of the principal causes of action in the Jane Doe cases. This opinion work product should not be disclosed when it was incorporated into heartland plea negotiations that are accorded protection und

hering the information through deposition or disclosure in an affidavit by the requested party of net worth, wealth, and income. Id. at 331-32. See Barton v. Cascade Regional Blood Services, 2007 WL 2288035 (W.D.Wash. 2007)("Tax returns are confidential communications between the taxpayer and the gover

ocket entries. Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 4 of 37 Doe v. Epstein 08-CV80119 Page No. 4 (a) Jane Doe Plaintiff, Jane Doe's Motion to Compel is filed at DE (194). Defendant's Response in Opposition is filed at DE (339), and the arguments set forth t

hering the information through deposition or disclosure in an affidavit by the requested party of net worth, wealth, and income. Id. at 331-32. ke. Barton v. Cascade Regional Blood Services, 2007 WL 2288035 (W.D.Wash. 2007)("Tax returns are confidential communications between the taxpayer and the gover

des Epstein's counsel's views on the limits and inapplicability of certain elements of 18 U.S.C. §2255, one of the principal causes of action in the Jane Doe cases. This opinion work product should not be disclosed when it was incorporated into heartland plea negotiations that are accorded protection und

United States I Demaree, 459 F.3d 791, 794 (7th Cir.2006), petition for cert. filed,No. co, 06-837 (U.S. Dec. 11, 2006); see also United States Barton, 455 F.3d 649, 655 n. 4 (6th Cir.2 . But in a case decided after Booker, we "recognize[d] that 'retrospective application of the Guidelines impli

ages of a prepubescent fe- male known as Jane Doe. Images of this young girl had been found on several individuals' computers and were labeled with Jane Doe's actual name. NCMEC analysts used this information to locate the girl in Indianapolis, Indiana. Law enforcement officials interviewed Jane Doe. Sh