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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
incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985), cit
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
ut to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11 th Cir. 1985), citing Lefkowitz v. Turley, 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner, 532 U
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
incriminate him in future criminal proceedings.” Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985)(citi
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
ions put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future proceedings." See Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction in
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
put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985), citing Lefkowitz v. Turlev 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner, 532 U.S
. 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
put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price 778 F.2d 668, 669 (11i' Cir. 1985), citing Lefkowitz v. Turley 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner 532 U.S.
Entities connected to both Jean-Luc Brunel and Edwin

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Marc Rich
PERSONJane Doe
PERSON
Donald Trump
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
United States
LOCATION
George W. Bush
PERSONMaria Farmer
PERSON
Paul Cassell
PERSON
Woody Allen
PERSON
Richard Kahn
PERSONthe Southern District
LOCATION
Sarah Kellen
PERSON
Jes Staley
PERSON
George Mitchell
PERSON
Palm Beach
LOCATION