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

a compelled testimonial aspect." United States v. Hubbell, 530 U.S. at 36; see also Fisher v. United State

rmation (e.g .. documents reflecting Epstein's air travel, aircraft used and flight manifests, all communications with female models, MC2 models or Jean Luc Brunel relating to or referring to females coming into the United States from other countries and his personal calendars and schedules) that could reveal

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

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

nd as well in areas that could result in criminal prosecution. See generally Hoffman v United States, 341 U.S. 479, 486 (1951) and United States v. Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000). 11. Therefore, Epstein is not required to produce any documents or responses to interrogatories. I

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

tance where "the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence, Case 9:08-cv-80119-K

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

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

n the meaning of the privilege.” United States v. Hubbell, 530 U.S. 27, 35- 36 (2000). However, in certain

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

ances where the act of producing documents in response to a subpoena or production request has a compelled testimonial aspect. See United States v. Hubbell, 530 U.S. 27, 35-36 (2000). Thus, where the existence or location of the requested documents are unknown, or where production would "implicitly aut

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

tance where "the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence EFTA00222080 Case 9:0

. 2 v. Epstein Page 19 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,

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

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

nces as here "the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence, Title 6, Chap. 13. The