Epstein Secrets

2 and 13); and Epstein’s medical records from Dr. Stephen Alexander (Request 16). Each of these categories of reques

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

ntiffs request for Epstein's medical records, Dr. Stephen Alexander was hired as au expert consultant by Epstein's a

mpelled testimonial aspect. See United States v. Hubbell, 530 U.S. 27, 35-36 (2000). Thus, where the exis

All medical records of Defendant Epstein from Dr. Stephan Alexander. Defendant is asserting his U.S. constitutiona

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

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

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

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

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