Epstein Secrets

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

tance where "the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence, Case 9:08-cv-80119-K

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

tance where "the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence EFTA00222080 Case 9:0

No. 2 v. Epstein Page 16 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. Response: Defendant is asserting

communications between Jeffrey Epstein and Nada Marcinkova, including, but not limited to, letters, notes,

nces as here "the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence, Title 6, Chap. 13. The