Epstein Secrets

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

incriminate him in future criminal proceedings.” Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985)(citi

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

itness against himself." (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985) (ci

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

put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings? Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985)(citing 2 EFTA00592192 Case 9:08-cv-80119-KAM Document 462 Entered on FLSD Docket 02/04/2010 Page 3 o