Epstein Secrets

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,

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

r, such information is privileged pursuant to Fed. Rule 501 and §90.503, Fla. Stat. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). EFTA00067433 Cse 9:08-cv-80119-KAM Document 65-4 Entered on FLSD Docket 03/25/2009 Page 37 of 37 Jane Doe No.

oe No. 2 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,

r, such information is privileged pursuant to Fed. Rule 501 and §90.503, Fla. Stat. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). EFTA00222071 Case 9:08-cv-80119-KAM Document 57-3 Jane Doe No. 2'. Epstein Page 24 Entered on FLSD Docket 03/

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,

r, such information is privileged pursuant to Fed. Rule 501 and §90.503, Fla. Stat. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). EFTA00222579 Cse 9:08-cv-80119-KAM Document 65-4 Entered on FLSD Docket 03/25/2009 Page 37 of 37 Jane Doe No.

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,

nformation is privileged pursuant to Rule 501, Fed.Evid., and §90.503, Fla.Evd. Code. In addition, such information is protected by the provision of the Health Insurance Portability and Accountability Act (HIPAA)." C. Grounds for Objection and Reasons for Motion The substantive basis for Defendant's objection is a claim of pr

21. QUANTITY 22. UNIT 23. UNIT PRICE 24. AMOUNT R2INYSIS0I3 Delivery/Task order under GS-25F-0131M Scanning/Document management for U.S. v. Maxwell Epstein AUSA Quote dated 3/23/2021 Estimated POP: 3/24/2021 - 5/31/2021 See Continuation Sheet(s) ((he Rower Mar Ante* Mims, Mani a Sm....) 25

this link: http:/Avww.gsa.gov/portal/content/104256. Contractors using information systems that are subject to the data security requirements under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) already are subject to the data security standards outlined below, and, therefore, only paragraphs (g), (h),

SCHEDULE OF SUPPLIESSERVICES a 21. OUANTITY 22. UNIT 23. UNIT PRICE 20. AMOUNT R2I NYSW1091 Expert Witness Services - Psychology U.S. v. Maxwell 20-CR-00330 2018R01618 Estimated POP: 3/8.12021 - 12/31/2021 POC: AUSA See Continuation Sheet(s) ( 17. 0^,,wa4,..A.“1.huila•osw, “..wunw,) 25

001359 EFTA00156700 15JA5421P00000117 Page 9 of 19 Contractors using information systems that are subject to the data security requirements under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) already are subject to the data security standards outlined below, and, therefore, only paragraphs (g), (h).