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ust 16, 2010. See Edwards Dec. at ¶ 6-7. 17. Maxwell was not the only important witness to lie to avoid deposition by Edwards in the Jane Doe case. Jean Luc Brunel did so as well. Upon review of message pads police took from Epstein's home, many were discovered to be from Jean Luc Brunel, a French citizen and
ssage pads police took from Epstein's home, many were discovered to be from Jean Luc Brunel, a French citizen and one of Epstein's closest friends. Brunel left messages for Epstein that were taken by Epstein's staff such as "Ile has a teacher for you how to speak Russian. She is 2x8 years old not blon
deposition by Edwards in the Jane Doe case. Jean Luc Brunel did so as well. Upon review of message pads poli
e court must then "weigh and determine (the) disputed issues of facts on a Rule 12(b)(5) motion." Cranford v. United States, 359 F.Supp.2d 981, 984 (E.D. Cal. 2005). An evidentiary hearing is the proper vehicle for resolving this particular factual dispute. See Blair v. City of Worcester, 522 F.3d 105, 1
. 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
purely procedural in nature and does not create a federal physician-patient or hospital-patient privilege." Allen v. Woodford 2007 WL 309485 *I I (E.D. Cal. 2007). Under HIPAA, health care information may be disclosed in discovery under a qualified protective order, which prohibits using or disclosing
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
(Health Insurance Portability and Accountability Act) objection, as noted in the case cited in Plaintiffs motion Allen v. Woodford, 2007 WL 309485 (E.D. Cal. 2007), (p. 9), HIPPA institutes procedural safeguards to protect the privacy of an individual's medical information and history. In the context of
Entities connected to both Jean-Luc Brunel and E.D. Cal

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
Bradley Edwards
PERSON
Marc Rich
PERSONLeon Black
PERSONJane Doe
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSON
United States
LOCATION
Woody Allen
PERSON
Scarlett Johansson
PERSON
New York
LOCATION
Julie K. Brown
PERSONSouthern District
LOCATION
Wales
LOCATION
Wilbur Ross
PERSONGerald Lefcourt
PERSON