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d §90.503, Fla.Evid. Code. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). Interrogatory No. 9. List all items in Jeffrey Epstein's possession in Palm Beach, Florida, at any time during the period of these interrogatori
admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 6. Identify all persons who came to the St. Thomas Residence and who gave a massage or were asked to give a massage to Defendant. Answer: Defendant is asserting specific legal objections to the interrogatori
d §90.503, FIa.Evid. Code. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). Federal Rule of Evidence 401 provides that - "'Relevant evidence'" means evidence having any tendency to make the existence of any fact that is o
s who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. No. 6. Identify all persons who came to the St. Thomas Residence and who gave a massage or were asked to give a massage to Defendant. No. 7. List all the time periods during which Jeffrey Epstein was present in t
01 and §90.503, Fla. Stat. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). EFTA00222579 Cse 9:08-cv-80119-KAM Document 65-4 Entered on FLSD Docket 03/25/2009 Page 37 of 37 Jane Doe No. 2 v. Epstein Page 24 Certifi
admissible evidence. Plaintiff's Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 6. Identify all persons who came to the St. Thomas Residence and who gave a massage or were asked to give a massage to Defendant. Answer: Defendant is asserting specific legal objections to the interrogatori
01 and §90.503, Fla. Stat. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). EFTA00067433 Cse 9:08-cv-80119-KAM Document 65-4 Entered on FLSD Docket 03/25/2009 Page 37 of 37 Jane Doe No. 2 v. Epstein Page 24 Certifi
admissible evidence. Plaintiff's Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 6. Identify all persons who came to the St. Thomas Residence and who gave a massage or were asked to give a massage to Defendant. Answer: Defendant is asserting specific legal objections to the interrogatori
Entities connected to both HIPAA and the St. Thomas Residence

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSONJack Goldberger
PERSONMichael J. Pike
PERSON
Adam D. Horowitz
PERSONthe Palm Beach Residence
ORGANIZATION
United States
LOCATIONAtterbury Goldberger & Weiss
ORGANIZATIONStuart S. Mermelstein
PERSONthe Health Insurance Portability
ORGANIZATION
Jean-Luc Brunel
PERSONthe Health Insurance Portability and Accountability
ORGANIZATIONthe New Mexico Residence
ORGANIZATION
Jeffrey Marc Herman
PERSONJANE DOE NO
PERSON
Sarah Kellen
PERSONLuttier & Coleman
ORGANIZATION