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,

(Health Insurance Portability and Accountability Act) objection, as noted in the case cited in Plaintiffs 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 history. In the context of

l counsel also handled Jane Doe's case against Epstein. 15. While working on that case and others like it, Edwards learned through deposition that Ghislaine Maxwell was involved in managing Epstein's affairs and companies. See Edwards Dec. at 114. 16. , Alfredo Rodriguez, also testified that Maxwell took phot

Ghislaine Maxwell was involved in managing Epstein's affairs and companies. See Edwards Dec. at 114. 16. , Alfredo Rodriguez, also testified that Maxwell took photos of girls without the girls' knowledge, kept the images on her computer, knew the names of the underage girls and their respective phone

like it, Edwards learned through deposition that Ghislaine Maxwell was involved in managing Epstein's affair

e court must then "weigh and determine (the) disputed issues of facts on a Rule 12(b)(5) motion." Cranford v. United States, 359 F.Supp.2d 981, 984 (E.D. Cal. 2005). An evidentiary hearing is the proper vehicle for resolving this particular factual dispute. See Blair v. City of Worcester, 522 F.3d 105, 1

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,

purely procedural in nature and does not create a federal physician-patient or hospital-patient privilege." Allen v. Woodford 2007 WL 309485 *I I (E.D. Cal. 2007). Under HIPAA, health care information may be disclosed in discovery under a qualified protective order, which prohibits using or disclosing