Epstein Secrets

ing frames or wall frames. Request No. 14. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Haley Robson, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 15. Any and all docume

, or (3) when the patient raises and relies on the issue of his or her mental condition in litigation as part of any claim or defense. § 90.503(4); Roberson, 884 So.2d at 980; State v. Famiglietti, 817 So.2d 901, 903 (Fla. 3d DCA 2002). The privilege does not allow the invasion of a patient's privileged

9 Page 32 of 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 fundam

on as part of any claim or defense. § 90.503(4); Roberson, 884 So.2d at 980; State v. Famiglietti, 817 So.

. As noted by the United States Supreme Court in Eisenstadt v. Baird, 405 U.S. 438, 454, 92 S.Ct. 1029, 1038

rights of privacy for victims' confidential records). 88 Roe v. Wade, 410 U.S. 113, 152 (1973). 89 Whalen v. Roe, 429 U.S. 589, 599-600 (1977). 9 Eisenstadt v. Baird, 405 U.S. 438, 453 (1972); see also Carey v. Population Servs. Int'l, 431 U.S. 678, 684-85 (1977). DAVID SCHOEN HOUSE_OVERSIGHT_017738 --

victims to present a sentencing recommendation. See Letter from Amy Baron-Evans, supra note 258 (citing S. Rep. No. 106-254, at 12 (2000) (discussing Robinson v. Maynard, 943 F.2d 1216 (10th Cir. 199]))). By 2003, however, the same passage in the Senate Judiciary Committee Report was changed to remove the c