Epstein Secrets

communications with female models, MC2 models or Jean Luc Brunel relating to or referring to females coming into t

cations between Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming

tween Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into the

nications with female models, MC2 models or Jean Luc Brunel relating to or referring to females coming into t

tein of a crime. (DE 242, p.18) United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). 5. As detai

o. 2 v. Epstein Page 22 Request No. 19. Any and all documents reflecting or consisting of communications between Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into the United States from other countries to pursue a career in modeling, including, but not limited to,

tween Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into th

s between Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into th

witness, (the trial court) can conclude that the witness could 'legitimately refuse to answer essentially all relevant questions." United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. Fla. 1980)); United States v. Tsui, 646 F.2d 365, 367-68 (9th Cir. 1981). This exception is narrow and is applicable w

king detailed information relating to Epstein's air travel, aircraft used and flight manifests, all communications with female models, MC2 models or Jean Luc Brunel relating or referring to females coming into the United States from other countries and his personal calendars and schedules, could reveal the avai

ations with female models, MC2 models or Jean Luc Brunel relating or referring to females coming into the

unications with female models, MC2 models or Jean Luc Brunel relating or referring to females coming into the

vilege raised as to these interrogatories valid, and asserted by Epstein only with reference to "genuinely threatening questions." United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). The danger Epstein faces by being forced to testify in this instance is "substantial and real, and not merely t

o. 2 v. Epstein Page 22 Request No. 19. Any and all documents reflecting or consisting of communications between Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into the United States from other countries to pursue a career in modeling, including, but not limited to,

tween Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into th

s between Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into th

witness, (the trial court) can conclude that the witness could 'legitimately refuse to answer essentially all relevant questions." United States v. Goodwin 625 F.2d 693, 701 (5th Cir. Fla. 1980)); United States v. Tsui, 646 F.2d 365, 367-68 (9th Cir. 1981). This exception is narrow and is applicable wh