Epstein Secrets

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

Docket 02/04/2010 Page 2 of 14 3 Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is acco

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

d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accor

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

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 of 14 Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction in favor of the right it was intended to secure," Hoffman v. United States