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the issues and the defenses in the litigation"). W. The information simply falls under the "highly pr
as all his passports from 2002 up through to the current date and that the government has an exact copy of same. Second, the Order presupposes that U.S. Customs and Border Patrol ("CPB") keeps a record and/or has maintained records of Epstein's travel and whereabouts from 2002 up through to the current date. Third, assuming
been found, the party whose tax return information has been requested has the burden to "provide alternative sources for this sensitive information. W. If the requested information is available from alternate sources, disclosure should not be compelled. Potential alternate sources to which the cour
as all his passports from 2002 up through to the current date and that the government has an exact copy of same. Second, the Order presupposes that U.S. Customs and Border Patrol ("CPB") keeps a record and/or has maintained records of Epstein's travel and whereabouts from 2002 up through to the current date. Third, assuming
titled by (Name) * —- “* cA.* . -a r.A' \ <'.X ' -W. »=*. Trmo> Juveroie Dtsposibdn'r>~ , ' r? « -14»
international traveler and regularly travels to and from the United States by private plane. In particular, between January 1, 2018, and the present, U.S. Customs and Border Patrol has logged approximately more than 20 flights in which Epstein was traveling to or from a foreign country. Indeed, he was arrested at Teterboro Airpo
Entities connected to both George W. Bush and U.S. Customs and Border Patrol

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
Julie K. Brown
PERSON
Department of Justice
ORGANIZATIONJack Goldberger
PERSONMaria Farmer
PERSONDarren Indyke
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Samantha Power
PERSON
Virginia Giuffre
PERSONthe Southern District
LOCATION
Scarlett Johansson
PERSON
Wilbur Ross
PERSON
Michael Jackson
PERSON
Alexander Acosta
PERSON