Epstein Secrets

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

g required to produce or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9 Cir. 2000). Accordingly,

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

quired to produce and/or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000)(the "privil

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

e having a tendency to Incriminate Epstein and would threaten to invade his privilege against being required to produce or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9"' Cir. 2000). Accordingly, finding the sought after information would result in testimonial disclosures that would communica