Epstein Secrets

/25/2009 Page 1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, V. JEFFREY EPSTEIN, Defendant. I -------------- DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES, and RESPONSES TO 1st and 2

se protections meaningless in attempting Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 2 of 37 Jane Doe No. 2 v. Epstein Page2 to assert and argue the factual basis for the additional objections and privileges. See part II.A. herein. I. Defendant EPSTEIN has proper

ntains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach, FL." Id, ,I?. "Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas." Id, ,

name in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. Request No. 2.

JEFFREY EPSTEIN, Defendant. I -------------- DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWE

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

PLAINTIFF IS ENTITLED TO DEFENDANT’S HEALTH CARE INFORMATION IN DISCOVERY A. Interrogatory at Issue “Interrogatory No. 8. Identify all of Jeffrey Epstein’s health care providers in the past (10) ten years, including without limitation, psychologists, psychiatrists, mental health counselors, physician,

e, 822 F.2d 1035, 1037 (11th Cir. 1987) (rejecting a “blanket” refusal to testify as unacceptable). While Plaintiff does not dispute that Defendant Epstein’s Fifth Amendment privilege may be asserted in a civil case,3 the Fifth Amendment’s “protection must be confined to instances where the witness has

ceptable). While Plaintiff does not dispute that Defendant Epstein’s Fifth Amendment privilege may be asserted in a

t Issue “Interrogatory No. 8. Identify all of Jeffrey Epstein’s health care providers in the past (10)

. 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

09-80802, 09-81092 --------------~/ DEFENDANT, JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF'S, JANE DOE,

d on FLSD Docket 10/06/2009 Page 2 of 23 Doe v. Epstein 08-CV80119 Page No. 2 herein. Portions of DE 28

nsuming. Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander. Response: Defendan

uant to Florida Statute 796.09 Against Defendant, Jeffrey Epstein". Erie R.Co. v. Tompkins, 58 S.Ct. 817

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

da, October 16, 1987. 24. Kalt JP, Dietz PE, Cox JE Jr.: Economics and the Environment: New Challeng

torney, Milwaukee County, Wisconsin, in State v. Jeffrey L. Dahmer (serial murders of men) Consultant to

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