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. 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
t seeks information concerning persons, not parties to this litigation, whose privacy rights are implicated. Whatever public documents exist are in the State Court file and equally accessible to Plaintiff. Request No.4. All documents obtained in discovery or investigation relating to either the Florida Crimi
o blocked because Epstein's co-conspirators (i.e., also took the Fifth on every question posed. Other important witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12. Because of the difficulty of obtaining discovery from Epstein and his co-conspirators, Edwards was forced to pursue other
ant witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12. Because of the difficu
portant witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12. Because of the difficu
relevance, burdensomeness, and attorney-client and other privileges regarding the Razorback Creditors' subpoena. Instead, these issues are left to the State Court judge presiding over their case to decide. I. BACKGROUND The procedural background surrounding the Razorback Creditor's motion is important to t
No. 21 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
t seeks information concerning persons, not parties to this litigation, whose privacy rights are implicated. Whatever public documents exist are in the State Court file and equally accessible to Plaintiff. Request No.4. All documents obtained in discovery or investigation relating to either the Florida Crimi
. 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
t seeks information concerning persons, not parties to this litigation, whose privacy rights are implicated. Whatever public documents exist are in the State Court file and equally accessible to Plaintiff. Request No.4. All documents obtained in discovery or investigation relating to either the Florida Crimi
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
. 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,
t seeks information concerning persons, not parties to this litigation, whose privacy rights are implicated. Whatever public documents exist are in the State Court file and equally accessible to Plaintiff. Request No.4. All documents obtained in discovery or investigation relating to either the Florida Crimi
Entities connected to both Jean-Luc Brunel and the State Court

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSONJane Doe
PERSON
Bill Clinton
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSON
United States
LOCATIONMaria Farmer
PERSON
Paul Cassell
PERSONthe Southern District
LOCATION
Palm Beach
LOCATION
Scarlett Johansson
PERSON
Sarah Kellen
PERSON
Virginia Giuffre
PERSON
David Rodgers
PERSON
Department of Justice
ORGANIZATION