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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
mation is privileged pursuant to Rule 501, Fed. Evid., and §90.503, FIa.Evid. Code. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HI PAA). Interrogatory No. 9. List all items in Jeffrey Epstein's possession in Palm Beach, Florida, at any time during the period of these
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,
mation is privileged pursuant to Rule 501, Fed. Evid., and §90.503, FIa.Evid. Code. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). Federal Rule of Evidence 401 provides that - "'Relevant evidence'" means evidence having any tendency to make the existence of any fa
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,
mation is privileged pursuant to Rule 501, Fed. Evid., and §90.503, FIa.Evid. Code. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HI PAA). Interrogatory No. 9. List all items in Jeffrey Epstein's possession in Palm Beach, Florida, at any time during the period of these
Entities connected to both Ghislaine Maxwell and the Health Insurance Portability and Accountability

Jeffrey Epstein
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONJane Doe
PERSON
Sarah Kellen
PERSON
Jean-Luc Brunel
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSONNadia Marcinkova
PERSONHaley Robson
PERSON
Jay Lefkowitz
PERSONFisher
PERSONFeldman
PERSONMichael J. Pike
PERSON
Jeffrey Marc Herman
PERSON
Keller
PERSON
Adam D. Horowitz
PERSONU.S. Mail
ORGANIZATION
Hogan
PERSON