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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,
n of Defendant's Fifth Amendment privilege is the guarantee of effective assistance of counsel by the Sixth Amendment of the U.S. Constitution. See Yarborough v. Gentry, 124 S.Ct. 1, 540 U.S. 1, 157 L.Ed.2d 1 (2003)(Sixth Amendment guarantees criminal defendants effective assistance of counsel.), on reman
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,
n of Defendant's Fifth Amendment privilege is the guarantee of effective assistance of counsel by the Sixth Amendment of the U.S. Constitution. See Yarborough v. Gentry, 124 S.Ct. 1, 540 U.S. 1, 157 L.Ed.2d 1 (2003)(Sixth Amendment guarantees criminal defendants effective assistance of counsel.), on reman
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,
assertion of the Fifth Amendment privilege is the guarantee of effective assistance of counsel by the Sixth Amendment of the U.S. Constitution. See Yarborough v. Gentry, 124 S.Ct. 1, 540 U.S. 1, 157 L.Ed.2d 1 (2003)(Sixth Amendment guarantees criminal defendants effective assistance of counsel.), on remand
Entities connected to both Ghislaine Maxwell and Yarborough

Jeffrey Epstein
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONFBI
ORGANIZATIONJane Doe
PERSON
David Rodgers
PERSON
Sarah Kellen
PERSON
George Mitchell
PERSON
Michael Jackson
PERSON
Jean-Luc Brunel
PERSON
Kenneth Marra
PERSON
Woody Allen
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSON
Harry Reid
PERSONNadia Marcinkova
PERSONHaley Robson
PERSON
Jay Lefkowitz
PERSONFisher
PERSON