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ear on any issue that is or may be in the case." Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978).
OBBIE M. MCKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OP COUNSEL ED RICCI SPECIAL CONSUMER JUSTICE COUNSEL Dear Judge Hafele: Enclosed, please find Jeffrey Epstein's Response in Opposition to ll's Motion for Inspection and to Compel Discovery, which are set for hearing be
rum, From Beirut to Kabul, and a segment for The Oppenheimer Report. She is a contributor to The Huffington Po
suffered psychologi- cal ills after being paid to give him sexually-charged massages at his Palm Beach mansion when they were as young as 14. • Hafele told Epstein's at- torneys they couldn't go on a fishing expedition. The medical records, he said, can't be sought until the women are asked whet
orum, From Beirut to Kabul, and a segment for The Oppenheimer Report. She is a contributor to The Huffington Po
they suffered psychologi- cal ills after being paid to give him sexually-charged massages at his Palm Beach mansion when they were as‘young as 14. - Hafele told Epstein’s.at- .torneys they couldn’t go on a fishing expedition. The _ medical records, he said, can’t be sought until the women are asked whet
rum, From Beirut to Kabul, and a segment for The Oppenheimer Report She is a contributor to The Buffington Pos
en claim Epstein, now 57, is responsible for . their emotional distress, his attorneys can explore the impact of other events. Medical records; Hafele said, are a better source of information than a person% memory. Attorney Louis Silver, who represents the Presi- dential Women Health Center,
Entities connected to both J. Robert Oppenheimer and Donald W. Hafele

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