Request for records of communication regarding allegations; Defendant claims privilege and irrelevance.
This legal document is a response by a Defendant to document requests in the case *Jane Doe No. 1 v. United States* (Case 9:08-cv-80736). The Defendant objects to providing travel records from 1998-2007, limiting the scope to 1999-2002 based on Jane Doe #3's allegations that she was Epstein's 'sex slave' during that period before escaping to Australia. The Defendant also objects to producing communications with Jeffrey Epstein from late 2014 to 2015 regarding the sexual misconduct allegations, claiming attorney-client privilege and lack of relevance.
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