Epstein Secrets

nformation is privileged pursuant to Rule 501, Fed.Evid., 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 pr

admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 5. Identify all persons who came to the New Mexico 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

r, such information is privileged pursuant to Fed. Rule 501 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.

admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 5. Identify all persons who came to the New Mexico 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

r, such information is privileged pursuant to Fed. Rule 501 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.

admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 5. Identify all persons who came to the New Mexico 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