Epstein Secrets

as an Exhibit by Plaintiff's counsel at Detective Recarey's deposition as well as certain message pads Pla

t marked as an Exhibit by Plaintiff's counsel at Detective Recarey's deposition as well as certain message pads Pla

is already in hand? Sic also Exhibits "D-1" and "D-2" and "E," a copy of the 89-page incident report marked as an Exhibit by Plaintiff's counsel at Detective Recarey's deposition as well as certain message pads Plaintiff claims was pulled from the residence at 358 Brillo Way. EFTA00317225 Case 9:08-cv-80119-KAM

ested documents, as to their authenticity, and as to the defendant's selection of them as meeting the requests for production. ate United States v. Hubbell, 530 U.S. 27, 35-36 (2000). Thus, where the existence or location of the requested documents are unknown, or where production would "implicitly auth

tz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by the f

ershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by the f

each, FL 33401 Telephone: Facsimile: CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July , 2007, the foregoing document and the Declaration of Joseph Recarey will be served via hand delivery on Attorney Roy Black, counsel for Jeffrey Epstein. The same documents will be served on William Richey, counsel fo

(4th Cir. 1991) (Fifth Amendment does not protect the contents of voluntarily prepared documents, whether business or personal); United States v. Hubbell , 167 F.3d 552, 567 (D.C. Cir. 1999) (same), aff'd on other grounds , 530 U.S. 27 (2000); In re Grand Jury Proceedings , 759 F.2d 1418, 1419 (9th Ci

tz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by the f

ershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by the f

500 South Australian Avenue, Suite 400 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July , 2007, the foregoing document and the Declaration of Joseph Recarey will be served via hand delivery on Attorney Roy Black, counsel for Jeffrey Epstein. The same documents will be served on William Richey, counsel fo

3 (4th Cir. 1991) (Fifth Amendment does not protect the contents of voluntarily prepared documents, whether business or personal); United States I Hubbell , 167 F.3d 552, 567 (D.C. Cir. 1999) (same), aff'd on other grounds , 530 U.S. 27 (2000); In re Grand Jury Proceedings , 759 F.2d 1418, 1419 (9th Ci

rt marked as an Exhibit by Plaintiffs counsel at Detective Recarey's deposition as well as certain message pads Pla

y in hand? See also Exhibits "D-1" and "D-2" and "E," a copy of the 89-page incident report marked as an Exhibit by Plaintiffs counsel at Detective Recarey's deposition as well as certain message pads Plaintiff claims was pulled from the residence at 358 Brillo Way. Case 9:08-cv-80119-KAM Document

ested documents, as to their authenticity, and as to the defendant's selection of them as meeting the requests for production. See United States v. Hubbell, 530 U.S. 27, 35-36 (2000). Thus, where the existence or location of the requested documents are unknown, or where production would "implicitly auth

ers were his private papers. As set forth in the Recarey Affidavit, one of the computers was in an area th

rily compiled [a] document, no compulsion in present and the contents of the document are not privileged." Id. at 612 n.10. See also United States I Hubbell , 530 U.S. 27, 35-36 (2000) (It is a "settled proposition that a person may be required to produce specific documents even though they contain incr