Epstein Secrets

. HIPAA regulations is (sic) purely procedural in nature and does not create a federal physician-patient or hospital-patient privilege.” Allen v. Woodford, 2007 WL 309485 *11 (E.D. Cal. 2007). Under HIPAA, health care information may be disclosed in discovery under a qualified protective order, which

Attorney or State Attorney Telephone records 5-6 Videos, photographs of residence 7 Documents relating to Plaintiff Jane Doe 8 Air travel records 10 Documents relating to modeling agencies 11 Correspondence with other witnesses 14,

Epstein's HIPAA rights should be upheld. Allen v. Woodford, 2007 WL 309485 (E.D. Cal. 2007), (p. 9)(HIPP A

EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF'S, JANE DOE, MOTION TO COMPEL RESPONSE TO PLAINTIFF'S REQUES

As to Defendant's HIPAA (Health Insurance Portability and Accountability Act) objection, as noted in the case cited in Plaintiff's motion, Allen v. Woodford, 2007 WL 309485 (E.D. Cal. 2007), (p. 9), HIPPA institutes procedural safeguards to protect the privacy of an individual's medical information and

l recording or other audio or video depiction or image of the Palm Beach Residence. Request No. 8. All documents referring or relating to Plaintiff Jane Doe No. 2, including without limitation, web pages, social networking site pages, correspondence, videotapes and audiotapes. Request No. 9. (Not at is

se (Eugene, Oregon) Testified at detention hearing (telephonic), 12/20/99 HI v. Uyesugi (Honolulu, Hawaii) Testified at trial, 5/30/00 Gal'ego v. Woodford (Oakland, California) Testified at deposition 6/8/00 Testified at trial, 12/6/00 Smith v. Equity Residential Properties Management (Atlanta, Georg

k, New York) [2nd Circuit Opinion: 938 F.2d 1535 (2nd Cir. 1991)] Testified at deposition, 5/13/90 Testified in court (trial or hearing), 5/14/90 Jane Doe v. Stuart Brown. M.D. (San Diego, California) Testified by deposition, 6/6/90 Carin Evans vs. Richard Benton, Ph.D. (Houston, Texas) Testified at