Epstein Secrets

2 and 13); and Epstein’s medical records from Dr. Stephen Alexander (Request 16). Each of these categories

ubbell, 530 U.S. 27, 44 (2000); United States v. Ponds, 454 F.3d 313, 325 (D.C. Cir. 2006). Thus, whil

Fisher, 425 U.S. at 410; Hubbell, 530 U.S. at 44; Ponds, 454 F.3d at 325 (D.C. Case 9:08-cv-80119-KAM D

claims, but does not prove, that he has hired Dr. Stephen Alexander as an expert witness in this case. He

very similar to those here. In United States v. Ponds, 454 F.3d 313 (D.C. Cir. 2006), federal prosecut

A Property: Parcel Number • Nana Owner: BALL, STEPHEN Name Owner 2: BA Owner Address: Property Addre

B: 51xx/1975 Age: 34 592-81-xxxx issued In Florida between 8/1/1998 and 12/2/1996 TAMARA VILLAVICENCIO DOB: 86301975 Age: 94 592-61-xxxx issued in Ponds between 8/1/1998 and 12/2/1996 Active Address(es): 410 May 2002 - Nov 2009) 964431.6568 VILLAVICENCIO FREDDY 3/18/2010 EFTA00729173 Comprehen

d, 6 r7-4 -e tt Jr. iitt_ r , Robert K. Kelner Stephen P. Anthony Brian D. Smith EFTA00617466

the government has failed to show with reasonable particularity that it knew of the existence and location of most of the subpoenaed documents ... Ponds' act of production was sufficiently testimonial to implicate his right against self-incrimination under the Fifth Amendment to the Constitution: Id