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in, possesses the power to move forward with its criminal prosecution against EPSTEIN. EPSTEIN entered into a Non-Prosecution Agreement ("NPA") with United States Attorney General's Office for the Federal Southern District of Florida. The terms and conditions of the NPA also entailed EPSTEIN entering into a Pl
name in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. Request No. 2. All documents referring or relating to the United States' agreement with Defendant to defer federal prosecution subject to certain conditions, including without limitation, the operative agreement between
ons who came to the New York Residence and who gave a massage or were asked to give a massage to Defendant. No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. No. 6. Identify all persons who came to the St. Thomas Residence and who gave
effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Defendant's canned objection represents a "blanket" refusal to answer questions in this civil case. See Anglada v. Sprague, 822 F.2d
admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. Answer: Defendant is asserting specific legal objections to the interrogatori
he answers cannot possibly have such tendency to incriminate. gI at 488, 399. Recognizing the breadth and magnitude of this constitutional privilege, the United States Supreme Court in discussing how a court is to analyze the application of the privilege stated — ... It is for the court to say whether his silence
admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. Answer: Defendant is asserting specific legal objections to the interrogatori
ion concerning persons, not parties to this litigation, whose privacy rights are implicated. Request No. 2. All documents referring or relating to the United States' agreement with Defendant to defer federal prosecution subject to certain conditions, including without limitation, the operative agreement between
admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. Answer: Defendant is asserting specific legal objections to the interrogatori
Entities connected to both United States and the New Mexico Residence

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Alan Dershowitz
PERSONJane Doe
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Jay Lefkowitz
PERSON
Michael Jackson
PERSON
Woody Allen
PERSON
Sarah Kellen
PERSONNadia Marcinkova
PERSON
Jean-Luc Brunel
PERSONFisher
PERSONHaley Robson
PERSONRobert D. Critton
PERSONMichael J. Pike
PERSON
Jeffrey Marc Herman
PERSON
Adam D. Horowitz
PERSONAtterbury Goldberger & Weiss
ORGANIZATION