Epstein Secrets

arily represent those of the Company. From: Thor Brown t Sent: Monday, February 01, 2016 10:54 PM To:

inberg, Richard J" •it > Date: Tuesday, February 2, 2016 at 7:02 AM EFTA00710704 To: "Warwick, Kerry" Cc: Richard Kahn < >, Darren Indyke < .>, Stephen Alexander Subject: Re: Signed document 124 PARC MONCEAU_signed.pdf attached This is a legitimate opening offer and it is my recommendation to counter back at

s broad, it is not without limits. Washington v. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (11th C

from the date hereof to provide the discovery subject to these Requests. The last category of documents concern Epstein's medical records from Dr. Stephen Alexander (Request 16). Epstein raises several objections to this category of Requests from relevancy concerns to privilege claims. Because Plaintiff has fail

s broad, it is not without limits. Washington 1. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (11th C

from the date hereof to provide the discovery subject to these Requests. The last category of documents concern Epstein's medical records from Dr. Stephen Alexander (Request 16). Epstein raises several objections to this category of Requests from relevancy concerns to privilege claims. Because Plaintiff has fail