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orking sites, and e-mails. Request No. 16. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Nada Marcinkova, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 17. Any and all docume
communications between Jeffrey Epstein and Nada Marcinkova, including, but not limited to, letters, notes, t
37 Jane Doe No. 2 v. Epstein Page 32 parties are implicated. See specified requests. As noted by the United States Supreme Court in Eisenstadt v. Baird, 405 U.S. 438,454, 92 S.Ct. 1029, 1038, at fn. 10 (1972): In Stanley, 394 U.S., at 564, 89 S.Ct., at 1247, the Court stated:'(A)lso fundamental is
rights to assert their constitutional right of privacy as guaranteed under the United States and Florida Constitutions. See generally Eisenstadt v. Baird, supra at 454-455 (The right encompasses privacy in one's sexual matters and is not limited to the marital relationship.). Ill. Conclusion Under
uting the enterprise included a group of individuals associated in fact. These individuals include Defendants, Jeffrey Epstein and Sarah Kellen, and Nadia Marcinkova, as well as other persons unknown at this time. 44. The criminal enterprise had a definite structure. The enterprise operated together on a contin
nts, Jeffrey Epstein and Sarah Kellen, and Nadia Marcinkova, as well as other persons unknown at this time.
Defendants, Jeffrey Epstein and Sarah Kellen, and Nadia Marcinkova, as well as other persons unknown at
lection to affirm. Hendricks v. Stark, 99 Fla. 277, 285, 126 So. 293, 296-97 (Fla. 1930) (internal quotation omitted); see, e.g., United States v. Baird, 218 F.3d 221, 230-31 (3d Cir. 2000) (recognizing that "quIntil the party who has the power of avoidance elects to exercise it, the contract remains
uting the enterprise included a group of individuals associated in fact. These individuals include Defendants, Jeffrey Epstein and Sarah Kellen, and Nadia Marcinkova, as well as other persons unknown at this time. 44. The criminal enterprise had a definite structure. The enterprise operated together on a contin
nts, Jeffrey Epstein and Sarah Kellen, and Nadia Marcinkova, as well as other persons unknown at this time.
Defendants, Jeffrey Epstein and Sarah Kellen, and Nadia Marcinkova, as well as other persons unknown at
lection to affirm. Hendricks v. Stark, 99 Fla. 277, 285, 126 So. 293, 296-97 (Fla. 1930) (internal quotation omitted); see, e.g., United States v. Baird, 218 F.3d 221, 230-31 (3d Cir. 2000) (recognizing that "quIntil the party who has the power of avoidance elects to exercise it, the contract remains
uting the enterprise included a group of individuals associated in fact. These individuals include Defendants, Jeffrey Epstein and Sarah Kellen, and Nadia Marcinkova, as well as other persons unknown at this time. 44. The criminal enterprise had a definite structure. The enterprise operated together on a contin
nts, Jeffrey Epstein and Sarah Kellen, and Nadia Marcinkova, as well as other persons unknown at this time.
Defendants, Jeffrey Epstein and Sarah Kellen, and Nadia Marcinkova, as well as other persons unknown at
lection to affirm. Hendricks v. Stark, 99 Fla. 277, 285, 126 So. 293, 296-97 (Fla. 1930) (internal quotation omitted); see, e.g., United States v. Baird, 218 F.3d 221, 230-31 (3d Cir. 2000) (recognizing that "'[u]ntil the party who has the power of avoidance elects to exercise it, the contract remain
rsons constituting the enterprise included a group of individuals associated in fact. These individuals include Defendants, Jeffrey Epstein and and Nadia Marcinkova, as well as other persons unknown at this time. 44. The criminal enterprise had a definite structure. The enterprise operated together on a contin
clude Defendants, Jeffrey Epstein and and Nadia Marcinkova, as well as other persons unknown at this time.
uals include Defendants, Jeffrey Epstein and and Nadia Marcinkova, as well as other persons unknown at
lection to affirm. Hendricks v. Stark, 99 Fla. 277, 285, 126 So. 293, 296-97 (Fla. 1930) (internal quotation omitted); see, e.g., United States v. Baird, 218 F.3d 221, 230-31 (3d Cir. 2000) (recognizing that "lujntil the party who has the power of avoidance elects to exercise it, the contract remains
orking sites, and e-mails. Request No. 16. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Nada Marcinkova, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 17. Any and all docume
communications between Jeffrey Epstein and Nada Marcinkova, including, but not limited to, letters, notes, t
37 Jane Doe No. 2 v. Epstein Page 32 parties are implicated. See specified requests. As noted by the United States Supreme Court in Eisenstadt v. Baird, 405 U.S. 438, 454, 92 S.Ct. 1029, 1038, at fn. 10 (1972): In Stanley 394 U.S., at 564, 89 S.Ct., at 1247, the Court stated:'(A)Iso fundamental is
latonnailon Sawing and Privacy Policy. and the Nadia IOU and kit. . prepared by: 904 Authorized by:,
FirstBankPR000593 EFTA_00124073 EFTA01269277 J. Efain Virgin Islands Foundation, Me. d/b/a Enhanced Education Unanimous Wtitten Consent of the Baird ofTnistees Page 3 IN WITNESS WI-IEREOF. each of the undersigned has executed this Consent for the purpose of giving his consent thereto and approv
Entities connected to both Nadia Marcinkova and Baird

Jeffrey Epstein
PERSON
Sarah Kellen
PERSON
Ghislaine Maxwell
PERSONLarry Visoski
PERSON
United States
LOCATION
Lesley Groff
PERSON
George W. Bush
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Kenneth Marra
PERSON
Marc Rich
PERSONJack Goldberger
PERSONLeon Black
PERSONMaria Farmer
PERSONthe Southern District
LOCATION
A. Marie Villafana
PERSON
Donald Trump
PERSON
Virginia Giuffre
PERSON