Epstein File EFTA00222075: Brunel, Jean-Luc Brunel and Graham (DS9)

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Epstein File EFTA00222075: Brunel, Jean-Luc Brunel and Graham (DS9)

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This document is Jeffrey Epstein's response to a plaintiff's motion to compel answers to interrogatories and production of documents, dated in response to a March 2, 2009 motion. The response includes a memorandum of law asserting privilege protections, citing case law regarding privilege assertion and the risk of waiver. The document references grand jury matters and discusses legal privilege doctrine but does not provide substantive factual details in the available excerpts.

👤 Named in This Document

Jeffrey Epstein Jean-Luc Brunel Lindsey Graham Carson Ben Carson Sarah Kellen

🔑 Evidence Keywords

recruit plea agreement sexual assault painting MC2 coercion text messages enticement massage table sexual misconduct involuntary 16 years old+22 more

📋 Key Excerpts15

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Excerpt 1

EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES, and RESPONSES TO 1st and 2nd PRODUCTION OF DOCUMENTS, AND INCORPORATED **MEMORANDUM**

Excerpt 2

OF LAW Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, serves his response and supporting **memorandum** of law to Plaintiff's Motion

Excerpt 3

to Compel Answers to Interrogatories and Production of Documents, and Incorporated **Memorandum** of Law In Support, dated March 2, 2009.