Epstein Secrets

s to Interrogatories on Fifth Amendment Grounds Defendant Epstein insists that he has not asserted a "blanket privi

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. REPLY MEMORANDUM IN SUPPORT

9 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80I I 9-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. REPLY MEMORANDUM IN SUPPORT OF MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND PRODUCTION OF DOCUMENTS Plaintiff, by and through unde

elf-Incrimination That Is Insufficient 1. Defendant Cannot Rely on its Blanket Objections to Interrogatories on Fifth Amendment Grounds Defendant Epstein insists that he has not asserted a "blanket privilege" to discovery under the Fifth Amendment, even though he has repeated the identical objection t

anket, all-encompassing assertion by a witness or party that the production of documents would be testimonial and incriminating: To begin with, in Hubei!, the incriminatory nature of the production of the document sought was obvious. The respondent was already incarcerated as a result of one investi

Wean) Inurnational ln,, :bard of Directors The Jeffrey Epstein Project for Brain Development in Critically-Ill

Inurnational ln,, :bard of Directors The Jeffrey Epstein Project for Brain Development in Critically-Ill

Wean) Inurnational ln,, :bard of Directors The Jeffrey Epstein Project for Brain Development in Critica

r of Child Neurology Mass General Moss% Whllont Chiefof Child Neurology Mall Center for Aforphoinetrit Analysts Director Advisory Board David II. Hubei, MD Nobel IMMO( on Physiology or Medicine John FrorsUln Enders Barra Uniurrstty Professor Sir George Martin, CBE AIRS:mhos, founding President

To: From: Sent: Subject: Jeffrey Epstein Fri 8/14/2009 4:29:09 PM Fwd: Forwarded message From: Valentino Braitenberg Date: Wed, Aug 12, 2009 at 11:49 AM Subject: Re: To: Jeffrey Eps

To: From: Sent: Subject: Jeffrey Epstein Fri 8/14/2009 4:29:09 PM Fwd: Forwarded mess

To: From: Sent: Subject: Jeffrey Epstein Fri 8/14/2009 4:29:09 PM Fwd: Forwar

cortex of mammals in complete agreement with the known facts of cortical anatomy and sufficient to explain all the miraculous effects discovered by Hubei and Wiesel, but not explained by them. Besides these results (1), (2), (3) which were original (and in part even shocking) because of the unusual d

To: From: Jeffrey Epstein Sent Wed 8/26/2009 6:09:59 PM Subject Fwd: Forwarded message From: Valentino Braitenberg Date: Wed, Aug 12, 2009 at 11:49 AM Subject: Re:

To: From: Jeffrey Epstein Sent Wed 8/26/2009 6:09:59 PM Subject Fwd:

To: From: Jeffrey Epstein Sent Wed 8/26/2009 6:09:59 PM Subject

cortex of mammals in complete agreement with the known facts of cortical anatomy and sufficient to explain all the miraculous effects discovered by Hubei and Wiesel, but not explained by them. Besides these results (1), (2), (3) which were original (and in part even shocking) because of the unusual d

From: MARK TRAMO < Sent: Tuesday, April 2, 2019 5:08 PM To: Jeffrey Epstein Subject: To JEE Had a blast with Robert last week, and Spring Quarter star=ing now - have to tell you that -150 UCLA undergrads signed up for my

nt: Tuesday, April 2, 2019 5:08 PM To: Jeffrey Epstein Subject: To JEE Had a blast with Robert last w

MO < Sent: Tuesday, April 2, 2019 5:08 PM To: Jeffrey Epstein Subject: To JEE Had a blast with Rober

was nuts to suggest a research program on the cognitive neuroscie=ce of music when none existed. It took you and some NSci hall-of-fame beli=vers - Hubei, the Gaz,Kiang - and a Harvard Provost's Award for Educat=onal Innovation from Harvey Fineberg to nurture the maverick, feed the bea=t, and make it