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

nary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 (1980). Accordingly, response

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

he claimant must [also] be 'confronted by substantial and 'real,' and not merely trifling or imaginary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 (1980). Accordingly, responses to the requests propounded upon Epstein would provide information which is protected by the privi

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

nary, hazards of incrimination.” United States v. Apfelbaum, 445 U.S. 115, 128 Case 9:08-cv-80119-KAM Docum

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

23240 Case 9:08-cv-80119-KAM Document 242 Entered on FLSD Docket 08/04/2009 Page 6 of 22 or imaginary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 (1980). When the Fifth Amendment privilege is raised as a bar to discovery, a blanket refusal to answer questions or to produce

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

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

. 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

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,