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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
d 668, 669 (11th Cir. 1985), citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). Thus, information is pr
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
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.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth Amendment privilege is also ava
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
.2d 668, 669 (11th Cir. 1985)(citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accor
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
nformal, 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 favor of the right and extends not only to answers that would support a
Entities connected to both Jean-Luc Brunel and Turley

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Marc Rich
PERSONLeon Black
PERSON
Donald Trump
PERSONJane Doe
PERSON
Bill Clinton
PERSON
Joe Biden
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
United States
LOCATION
George W. Bush
PERSONMaria Farmer
PERSON
Paul Cassell
PERSON
Woody Allen
PERSONthe Southern District
LOCATION
Jes Staley
PERSON