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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
s 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 a massage or were asked to give a massage to Defendant. No. 7. List all the time periods during which Jeffrey Epstein was present in t
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. Plaintiff's Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 6. Identify all persons who came to the St. Thomas 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. Plaintiff's Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 6. Identify all persons who came to the St. Thomas 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 St. Thomas Residence

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Alan Dershowitz
PERSONJack Goldberger
PERSON
Sarah Kellen
PERSONJane Doe
PERSON
Kenneth Marra
PERSONthe Southern District
LOCATIONNadia Marcinkova
PERSON
Jay Lefkowitz
PERSON
Jean-Luc Brunel
PERSON
Jeffrey Marc Herman
PERSON
Adam D. Horowitz
PERSONFisher
PERSONMichael J. Pike
PERSON
Hogan
PERSONStuart S. Mermelstein
PERSONJANE DOE NO
PERSONAtterbury Goldberger & Weiss
ORGANIZATION