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ubbell, 530 U.S. 27, 44 (2000); United States v. Ponds, 454 F.3d 313, 325 (D.C. Cir. 2006). Thus, whil
Fisher, 425 U.S. at 410; Hubbell, 530 U.S. at 44; Ponds, 454 F.3d at 325 (D.C. Case 9:08-cv-80119-KAM D
prosecution. In each of these motions Plaintiff Jane Doe seeks to compel answers to certain requests for a
is known to the government or is a foregone conclusion. Fisher, 425 U.S. at 410; United States v. Hubbell, 530 U.S. 27, 44 (2000); United States v. Ponds, 454 F.3d 313, 325 (D.C. Cir. 2006). Thus, while the Fifth Amendment covers situations where the act of producing documents has “communicative aspe
OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN,
very similar to those here. In United States v. Ponds, 454 F.3d 313 (D.C. Cir. 2006), federal prosecut
not require any mind to pick and choose. Indeed, Jane Doe’s request is significantly narrower that other req
2004). The D.C. Circuit has recently refused to extend the act of production doctrine on facts very similar to those here. In United States v. Ponds, 454 F.3d 313 (D.C. Cir. 2006), federal prosecutors sought information about possible crimes committed by a defense attorney in the course of repre
notice that more than 90 days had elapsed since the filing of her motion (dkt. #453). On February 4, 2010, the magistrate judge granted in part Jane Doe’s motion to compel, specifically ruling that Epstein had to produce the discovery provided to him by state and federal prosecutors, his recent tax re
Entities connected to both Ponds and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
United States
LOCATIONMaria Farmer
PERSONRobert D. Critton
PERSON
George W. Bush
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSON
Ghislaine Maxwell
PERSON
Salt Lake City
LOCATION
Alexander Acosta
PERSONRobert C. Josefsberg
PERSONKatherine W. Ezell
PERSONRichard Horace Willits
PERSONJack Patrick Hill
PERSON
Jay Lefkowitz
PERSONStuart S. Mermelstein
PERSON