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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
ons who came to the New York Residence and who gave a massage or were asked to give a massage to Defendant. No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. No. 6. Identify all persons who came to the St. Thomas Residence and who gave
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,
admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. Answer: Defendant is asserting specific legal objections to the interrogatori
communications between Jeffrey Epstein and Haley Robson, including, but not limited to, letters, notes,
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
admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. Answer: Defendant is asserting specific legal objections to the interrogatori
Entities connected to both Haley Robson and the New Mexico Residence

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Alan Dershowitz
PERSONJack Goldberger
PERSON
Michael Jackson
PERSON
Sarah Kellen
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Woody Allen
PERSONthe Southern District
LOCATIONNadia Marcinkova
PERSON
Jay Lefkowitz
PERSON
Jean-Luc Brunel
PERSONRobert D. Critton
PERSON
Jeffrey Marc Herman
PERSON
Adam D. Horowitz
PERSONFisher
PERSONMichael J. Pike
PERSONStuart S. Mermelstein
PERSON