Epstein Secrets

e No. 21. Epstein Page 15 Request No. 15. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Sarah Kellen, 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 Sarah Kellen, including, but not limited to, letters, notes,

r, such information is privileged pursuant to Fed. Rule 501 and §90.503, Fla. Stat. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). EFTA00222071 Case 9:08-cv-80119-KAM Document 57-3 Jane Doe No. 2'. Epstein Page 24 Entered on FLSD Docket 03/

No. 2 v. Epstein Page 15 Request No. 15. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Sarah Kellen, 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 Sarah Kellen, including, but not limited to, letters, notes,

r, such information is privileged pursuant to Fed. Rule 501 and §90.503, Fla. Stat. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). EFTA00222579 Cse 9:08-cv-80119-KAM Document 65-4 Entered on FLSD Docket 03/25/2009 Page 37 of 37 Jane Doe No.

communications between Jeffrey Epstein and Sarah Kellen, including, but not limited to, letters, notes,

No. 2 v. Epstein Page 15 Request No. 15. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Sarah Kellen, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting

r, such information is privileged pursuant to Fed. Rule 501 and §90.503, Fla. Stat. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). EFTA00067433 Cse 9:08-cv-80119-KAM Document 65-4 Entered on FLSD Docket 03/25/2009 Page 37 of 37 Jane Doe No.