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Request 12, which seeks "any" submission to the Epstein Victims' Compensation Program made by BSF, fails
dum, or other written communication of information of any kind." The use of the terms "all" and "any" "do not evince specificity." United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y. Mar. 16, 2021). Here, the requests do not identify specific lawyers or employees of BSF whose
Request 12, which seeks "any" submission to the Epstein Victims' Compensation Program made by BSF, fails
dum, or other written communication of information of any kind." The use of the terms "all" and "any" "do not evince specificity." United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y. Mar. 16, 2021). Here, the requests do not identify specific lawyers or employees of BSF whose
Request 12, which seeks "any" submission to the Epstein Victims' Compensation Program made by BSF, fails
dum, or other written communication of information of any kind." The use of the terms "all" and "any" "do not evince specificity." United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y. Mar. 16, 2021). Here, the requests do not identify specific lawyers or employees of BSF whose
dum, or other written communication of information of any kind." The use of the terms "all" and "any" "do not evince specificity." United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y. Mar. 16, 2021). Here, the requests do not identify specific lawyers or employees of BSF whose
Page: EFTA00020300 →Request 12, which seeks "any" submission to the Epstein Victims' Compensation Program made by BSF, fails
Page: EFTA00020303 →Entities connected to both Jeffrey Epstein and Tagliaferro

Marc Rich
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Lawrence Krauss
PERSON
Sarah Ferguson
PERSON
David Boies
PERSON
Audrey Strauss
PERSON
Chris Tucker
PERSONSecond Circuit
ORGANIZATIONReyes
PERSON
Alison J. Nathan
PERSON
Barneys New York
ORGANIZATION
Cynthia Nixon
PERSON
Brady
PERSON
Aguilar
PERSON
Giglio
PERSON
ALISON J. NATHAN
ORGANIZATION
Michael Avenatti
PERSONSkelos
PERSON