Epstein Secrets

fs' allegations are without any factual basis and know such assertions to be false and untrue. 3. Defendant agrees with Plaintiff's assertion that the Palm Beach Police Department (PBPD) executed a search warrant at EPSTEIN's Palm Beach mansion on October 25, 2005. See '1!4 Plaintiffs' motion. 4. Defendant's atto

e act of production where, as here, it involves a self-incriminating testimonial communication or "a compelled testimonial aspect." United States v. Hubbell, 530 U.S. 27, 120 S.Ct. 2037 (2000); Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence, Title 6, Chap. 13. The Privilege Against

rmation from both the Palm Beach Police Department and the State Attorneys' file. In fact, as argued infra, Mr. Edwards has certain information from the Palm Beach Police Department, which resulted from various alleged "trash pulls" from a residence on Palm Beach (e.g., certain notepads). Finally, at the deposition

ested documents, as to their authenticity, and as to the defendant's selection of them as meeting the requests for production. See United States v. Hubbell, 530 U.S. 27, 35-36 (2000). Thus, where the existence or location of the requested documents are unknown, or where production would "implicitly auth

evidence, documents, statements, information, dvds, cds and ALL other information provided to Defendant Epstein, or his attorneys, in discovery by the Palm Beach State Attorney's Office, the Palm Beach Police Department, The FBI or the U.S. Attorney's Office. Response: Defendant is asserting specific legal objecti

rious facts have asked whether the government was aware of the documents' existence apart from any actions of the defendant. Thus, United States v. Hubbell, 530 U.S. 27 (2000), rejected the Government's argument that it was a foregone conclusion that the defendant possessed "ordinary business records."