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n the meaning of the privilege.” United States v. Hubbell, 530 U.S. 27, 35-36 (2000). However, in certain i
to lead to the discovery of admissible evidence. Dunbar v. United States, 502 F.2d 206 (5th Cir. 1974). U
ances where the act of producing documents in response to a subpoena or production request has a compelled testimonial aspect. See 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 aut
discoverable, even if not admissible at trial, so long as the information is reasonably calculated to lead to the discovery of admissible evidence. Dunbar v. United States, 502 F.2d 206 (5th Cir. 1974). Under Fed. R. Civ. P., 26(b)(1) a court may limit discovery of relevant material if it determines
ng assertions of fact or belief, because the creation of those documents was not 'compelled' within the meaning of the privilege." United States v. Hubbell, 530 U.S. 27, 35-36 (2000). However, in certain instances, "'the act of production' itself may implicitly communicate 'statements of fact.' Id. For
discoverable, even if not admissible at trial, so long as the information is reasonably calculated to lead to the discovery of admissible evidence. Dunbar v. United States, 502 F.2d 206 (5th Cir. 1974). Under Fed. R. Civ. P., 26(b)(1) a court may limit discovery of relevant material if It determines
Entities connected to both Hubbell and Dunbar

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
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Adam D. Horowitz
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Jay Lefkowitz
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Bradley Edwards
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