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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
mation is privileged pursuant to Rule 501, Fed. Evid., and §90.503, FIa.Evid. Code. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). Federal Rule of Evidence 401 provides that - "'Relevant evidence'" means evidence having any tendency to make the existence of any fa
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,
mation is privileged pursuant to Rule 501, Fed. Evid., and §90.503, FIa.Evid. Code. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HI PAA). Interrogatory No. 9. List all items in Jeffrey Epstein's possession in Palm Beach, Florida, at any time during the period of these
communications between Jeffrey Epstein and Nada Marcinkova, including, but not limited to, letters, notes,
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
mation is privileged pursuant to Rule 501, Fed. Evid., and §90.503, FIa.Evid. Code. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HI PAA). Interrogatory No. 9. List all items in Jeffrey Epstein's possession in Palm Beach, Florida, at any time during the period of these
Entities connected to both Nadia Marcinkova and the Health Insurance Portability and Accountability

Jeffrey Epstein
PERSON
Sarah Kellen
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONJane Doe
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSONthe Southern District
LOCATION
Jean-Luc Brunel
PERSON
Jay Lefkowitz
PERSONHaley Robson
PERSONMichael J. Pike
PERSON
Adam D. Horowitz
PERSON
Jeffrey Marc Herman
PERSONStuart S. Mermelstein
PERSONFisher
PERSONAtterbury Goldberger & Weiss
ORGANIZATIONU.S. Mail
ORGANIZATIONJANE DOE NO
PERSON