Epstein Secrets

ief as this Court deems just and proper. Dated: March 2, 2009 Respectfully submitted, By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERMELSTEIN & HOROWITZ, P.A. At

burden to demonstrate that the act of producing any particular responsive documents would entail testimonial self-incrimination. United States v. Wujkowski, 929 F.2d 981, 984 (4th Cir. 1991). It is not self-evident or apparent from the Plaintiff’s requests that the act of producing responsive items wo

er 24, 2009. Respectfully submitted, By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 94

testimonial self-incrimination. United States v. Wujkowski The party asserting the Fifth Amendment privile

n, and has been unable to do so. CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.A.3 Dated: September 30, 2009 Respectfully Submitted, By: Stuart S. Mermelstein (FL Bar No. 947245) /s/ Stuart S. Mermelstein [email protected] Adam D. Horowitz (FL Bar No. 376980) Case

s the burden of the defendant to show that the act of producing responsive documents would entail testimonial self- incrimination. United States v. Wujkowski, 929 F.2d 981, 984 (4th Cir. 1991). In many cases, the existence and location of papers are a foregone conclusion and the defendant adds little or

Epstein be ordered to answer interrogatories and produce responsive documents. Dated: April 20, 2009 Respectfully submitted, By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MER

testimonial and incriminatory to support the Fifth Amendment privilege against self-incrimination is a “fact dependent inquiry.” United States v. Wujkowski, 929 F.2d 981, 985 (4th Cir. 1991). It is the burden of the party asserting the privilege to “explain how the act of producing documents would pose

has been sent by fax and U.S. Mail to the following addressees this 26th day of January 2009: Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 counsel for Plaintiff Jane Doe #2 Jack Alan Goldberge

6 burden to demonstrate that the act of producing any particular responsive documents would entail testimonial self-incrimination. United States v. Wujkowski, 929 F.2d 981, 984 (4th Cir. 1991). It is not self-evident or apparent from the Plaintiff's requests that the act of producing responsive items wou

ordered to answer interrogatories and produce responsive documents. Dated: April 20, 2009 Respectfully submitted, By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERMELSTEIN & HOROWITZ, P.A. At

ly testimonial and incriminatory to support the Fifth Amendment privilege against self-incrimination is a "fact dependent inquiry." United States'. Wujkowski, 929 F.2d 981, 985 (4th Cir. 1991). It is the burden of the party asserting the privilege to "explain how the act of producing documents would pose