Epstein Secrets

8, 101, 210, 240, 253-56, 278, 280 Manhattan, Inc., 74 Manigault, Omarosa, 109 Mar-a-Lago, 4, 69, 99, 106, 159, 189, 193-94, 210, 228, 248-49 Marcus, Bernie, 309 Mattis, James, 4, 21, 103, 109, 188, 264-65, 288, 296, 304-5 May, Theresa, 258 McCain, John, 112, 306 McCarthy, Joe, 73 McConnell, Mitch, 32, 11

, 159-67, 170-72, 224 Sandberg, Sheryl, 187, 236 Sanders, Bernie, 5 Sanders, Sarah Huckabee, 229 Sater,

olf, 127 HNA Group, 269 Hogan, Hulk, 22, 308 HOUSE_OVERSIGHT_020127 Homeland Security Department, 63, 86, 133, 218, 285, 288 Hoover, J. Edgar, 219 Hubbell, Webster, 97 Hull, Cordell, 105 Hussein, Saddam, 27 Hutchison, Kay Bailey, 81 IBM, 88 Icahn, Carl, 20, 141, 211 Iger, Bob, 88, 238 immigration

or may be in the case." Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). Discovery is not limi

n the meaning of the privilege.” United States v. Hubbell, 530 U.S. 27, 35-36 (2000). However, in certain i

may be in the case.” Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). The correspondence w

actions of the defendant. Thus, United States v. Hubbell, 530 U.S. 27 (2000), rejected the Government’s a

nt discovery stage. See Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). Accordingly, Epstein

n the meaning of the privilege.” United States v. Hubbell, 530 U.S. 27, 35-36 (2000). However, in certain i

t bears on, or that reasonably could lead to another matter that could bear on any issue that is or may be in the case.” Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). The correspondence with the government agencies may well point Jane Doe in the direction of admissible evidence, and th

t patterns 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.”

t discovery stage. See Oppenheimer Fund, Inc. I. Sanders, 437 U.S. 340, 352 (1978). Accordingly, Epstein

tion does not extend to documents whose existence is known to the government or is a foregone conclusion. Fisher, 425 U.S. at 410; United States 1. Hubbell, 530 U.S. 27, 44 (2000); United States I. Ponds, 454 F.3d 313, 325 (D.C. Cir. 2006). Thus, while the Fifth Amendment covers situations where the ac

t discovery stage. See Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340. 352 (1978). Accordingly, Epstein

ing assertions of fact or belief, because the creation of those documents was not 'compelled' within the meaning of the privilege? United States v. Hubbell, 530 U.S. 27, 35-36 (2000). However, in certain instances, "'the act of production' itself may implicitly communicate 'statements of fact."' Id. Fo

hat bears on, or that reasonably could lead to another matter that could bear on any issue that is or may be in the case." Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). Discovery is not limited to the issues raised by the pleadings because 'discovery itself is designed to help define and

ances where the act of producing documents in response to a subpoena or production request has a compelled testimonial aspect. 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 aut

that bears on, or that reasonably could lead to another matter that could bear on any issue that is or may be in the case? Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). Discovery is not limited to the issues raised by the pleadings because "discovery itself is designed to help define and

ng assertions of fact or belief, because the creation of those documents was not 'compelled' within the meaning of the privilege." United States v. Hubbell, 530 U.S. 27, 35-36 (2000). However, in certain instances, "'the act of production' itself may implicitly communicate 'statements of fact.' Id. For