Epstein Secrets

. 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

and §90.503, Fla.Evd. Code. In addition, such information is protected by the provision of the Health Insurance Portability and Accountability Act (HIPAA)." C. Grounds for Objection and Reasons for Motion The substantive basis for Defendant's objection is a claim of privilege under state law, Flori

. 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

01 and §90.503, Fla. Stat. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). EFTA00728988 Case 9:08-cv-80119-KAM Document 57-3 Entered on FLSD Docket 03/02/2009 Page 10 of 24 Jane Doe No. 2 v. Epstein Page 10 Consti

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

01 and §90.503, Fla. Stat. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). EFTA00222071 Case 9:08-cv-80119-KAM Document 57-3 Jane Doe No. 2'. Epstein Page 24 Entered on FLSD Docket 03/02/2009 Page 24 of 24 Certifi

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

d §90.503, FIa.Evid. Code. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). Federal Rule of Evidence 401 provides that - "'Relevant evidence'" means evidence having any tendency to make the existence of any fact that is o

. 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

01 and §90.503, Fla. Stat. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). EFTA00222579 Cse 9:08-cv-80119-KAM Document 65-4 Entered on FLSD Docket 03/25/2009 Page 37 of 37 Jane Doe No. 2 v. Epstein Page 24 Certifi

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,

01 and §90.503, Fla. Stat. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). EFTA00067433 Cse 9:08-cv-80119-KAM Document 65-4 Entered on FLSD Docket 03/25/2009 Page 37 of 37 Jane Doe No. 2 v. Epstein Page 24 Certifi