Epstein Secrets

luding alleged victims), which would necessarily thwart such individuals' rights to assert their constitutional right of privacy as guaranteed under the United States and Florida Constitutions. See generally Eisenstadt v. Baird, supra at 454-455 (the right encompasses privacy in one's sexual matters and is not lim

ing request 10 that would result in the required disclosure of communications from the Government counsel to Epstein, that notice be provided to the United States Attorney so they may intervene to protect their opinion work product, assert their rights to confidentiality under FRE 408 and 410, and assert where

08-cv-80119-KAM Document 477 Entered on FLSD Docket 02/26/2010 Page 17 of 24 Doe v. Epstein 08-CV80119 Page No. 17 Cooper v. Hallgarten & Co., 34 F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production of the requested returns in this matter, the Plaintiff must satisfy the "releva

luding alleged victims), which would necessarily thwart such individuals' rights to assert their constitutional right of privacy as guaranteed under the United States and Florida Constitutions. &2e generally Eisenstadt v. Baird, supra at 454-455 (the right encompasses privacy in ones sexual matters and is not limi

:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 25 of 37 Doe v. Epstein 08-CV80119 Page No. 25 Cooper v. Hallgarten & Co., 34 F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production of the requested returns in this matter, the Plaintiff must satisfy the "releva

c. Request Number 13 Request No. 13: A photocopy of your passport, including any supplemental pages reflecting travel to locations outside the 50 United States between 2002 and 2008, including any documents or records regarding plane tickets, hotel receipts, or transportation arrangements. Response; Defend

herwise available. Id. at *2; see also Dunkin Donuts, Inc. v. Marv's Donuts, Inc., 2001 WL 34079319 (S.D. Fla. 2001)• Cooper v. Hallgarten & Co. 34 F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production of the requested returns in this matter, the Plaintiff must satisfy the "relev

c. Request Number 13 Request No. 13: A photocopy of your passport, including any supplemental pages reflecting travel to locations outside the 50 United States between 2002 and 2008, including any documents or records regarding plane tickets, hotel receipts, or transportation arrangements. Response; Defend

herwise available. Id. at *2; see also Dunkin Donuts, Inc. v. Marv's Donuts, Inc., 2001 WL 34079319 (S.D. Fla. 2001)• Cooper v. Hallgarten & Co. 34 F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production of the requested returns in this matter, the Plaintiff must satisfy the "relev