Epstein Secrets

905 MARCONI AVE RONKONKOMA. NY 11779 P. 631.205.1200 F. 631.205.1211 CLAIMFOX.COM CLAIMFO, CONSIDER I T DONE 1-Jul-20 US Attorney's Office Southern District of New York AUSA Alex Rossmiller 1 St. Andrew's Plaza, New York 10007 Request Reference ID: ---- ClaimFox Reference No: 42561447 To Whom It May C

e been disclosed to you from records whose privacy is protected from disclosure by federal and state law including, as applicable, 45 CFP Part 160 (HIPAA), 42 CFP Part 2 (alcohol and drug treatment) and other state laws. The applicable law or laws may prohibit you from making any further disclosure wi

9:08-cv-80119-KAM Document 185 Entered on FLSD Docket 07/02/2009 Page 6 of 6 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. Robert D. ritton Es . Bradley James Edwards Isidro Manuel Garcia [email protected] Jack Patrick

erapy records. 3. Accordingly, the parties request the entry of the attached Stipulated HIPAA Protective Order to protect Plaintiffs' rights under HIPAA and allow Defendant to receive discovery of protected healthcare information under HIPAA. 3 EFTA00727599 Case 9:08-cv-80119-KAM Document 185 E

:08-cv-80119-KAM Document 57 Entered on FLSD Docket 03/02/2009 Page 16 of 16 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger Es . Robert D. Critton, Esq. s/ Adam D. Horowitz -16- EFTA00728216 Case 9:08-cv-80119-KAM Document 57-2 Enter

and §90.503, Fla.Evd. Code. In addition, such information is protected by the provision of the Health Insurance Portability and Accountability Act (HIPAA)." C. Grounds for Objection and Reasons for Motion The substantive basis for Defendant's objection is a claim of privilege under state law, Flori

deral Criminal Case" shall mean that certain grand jury proceeding and investigation identified as Grand Jury No. 07-103 (WPB), U.S. District Court, Southern District of Florida. o. The name, "Jane Doe No. 2", shall mean the individual who is the Plaintiff in this case, whose name has been provided to Defendant

01 and §90.503, Fla. Stat. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). EFTA00728988 Case 9:08-cv-80119-KAM Document 57-3 Entered on FLSD Docket 03/02/2009 Page 10 of 24 Jane Doe No. 2 v. Epstein Page 10 Consti

9:08-cv-80119-KAM Document 266 Entered on FLSD Docket 08)1412009 Page 9 of 9 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldber er Es . Robert D. Critton, Es . Bradley James Edwards Isidro Manuel Garcia Jack Patrick Hill Katherine Warthen Eze

s Order. Plaintiffs have otherwise worked cooperatively with Defendant in providing relevant discovery. Plaintiffs' counsel initiated a draft of a HIPAA compliant protective order, which was stipulated by the parties and entered by the Court on July 2, 2009. Additionally, Plaintiffs have provided De

from RHB; finalize Motion for Extension on CMA; prepare Order on 0.60 hr $75.00 Extension; scan and pdf Motion and Order; file electronically with Southern District Clerk; receipt of e-mail from Clerk print attachment 03/16/2009 MJP Telephone conference with J. Hill, Esq. 0.10 hr $30.00 03/16/2009 RDC Pr

e with Robert Critton regarding status; various issues Continue draft of Responses to Plaintiffs Motion to Compel (Jane Doe 2-5) Legal research re: HIPAA, Federal Rule 408, 410, Florida Statute 90.410; case law in Plaintiffs motion Conference with MJP re: signing Motions; scan and pdf Doe #2 through

:08-cv-80119-KAM Document 57 Entered on FLSD Docket 03/02/2009 Page 16 of 16 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldber er, Es . Robert D. Critton, Esq. s/ Adam D. Horowitz -16- EFTA00222517

and §90.503, Fla.Evd. Code. In addition, such information is protected by the provision of the Health Insurance Portability and Accountability Act (HIPAA)." C. Grounds for Objection and Reasons for Motion The substantive basis for Defendant's objection is a claim of privilege under state law, Flori