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

ant must be 'confronted by substantial and 'real,' and not merely trifling or imaginary, hazards of incrimination." See generally, United States v. Apfelbaum, 445 U.S. 115, 128, 100 S.Ct. 948, 956, 63 L.Ed.2d 250 (1980)). See also, United States v. Neff, 615 F.2d 1235, 1239 (9th Cir.), cert. denied, 447 U

No. 2 v. Epstein Page 14 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. Response: Defendant is asserting

communications between Jeffrey Epstein and Haley Robson, including, but not limited to, letters, notes,

laimant must be 'confronted by substantial and 'real,' and not merely trifling or imaginary, hazards of incrimination.' generally, United States v. Apfelbaum, 445 9 EFTA00222533 Case 9:08-cv-80119-KAM Document 65 Entered on FLSD Docket 03'25'2009 Page 10 of 15 Page 10 U.S. 115, 128, 100 S.Ct. 948,

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

o Plaintiffs discovery requests. United States v. Apfelbaum, 445 U.S. 115, 128 (1980). The Fifth Amendment s