Epstein Secrets

orking sites, and e-mails. Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 18. Any and all docume

unications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, t

ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,

Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 9 of 37 Jane Doe No. 2 v. Epstein Page 9 can be used at trial. !g; Pillsbury Company v. Conboy, 495 U.S. 248, 103 S.Ct. 608 (1983). See also, Hubbell, supra, quoted above as to what is encompassed by the phrase "in any criminal case

orking sites, and e-mails. Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 18. Any and all docume

unications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, t

ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,

Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 9 of 37 Jane Doe No. 2 v. Epstein Page 9 can be used at trial. Id; Pillsbury Company v. Conbov 495 U.S. 248, 103 S.Ct. 608 (1983). See also, Hubbell, supra, quoted above as to what is encompassed by the phrase "in any criminal case"

No. 2 v. Epstein Page 17 Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting

munications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes,

ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,

d be used in anyway to convict the witness of a crime or could aid in the development of other incriminating evidence that can be used at trial. Id; Pillsbury Company v. Conboy, 495 U.S. 248, 103 S.Ct. 608 (1983). Certainly, if the USAO decides to prosecute EPSTEIN for an alleged violation of the NPA, it would u