Epstein Secrets

Blau v. United States, 340 U.S. 159 (1950); SEC v Leach, 156 F.Supp.2d49!, 494 (E.D. PA. 2001). The Cou

o Plaintiffs discovery requests. United States v. Apfelbaum, 445 U.S. 115, 128 (1980). The Fifth Amendment

ate." See United States v. Neff, 315 F.2d 1235, 1239 (9th Cir.), cert denied, 447 U.S. 925 (1980); Blau v. United States, 340 U.S. 159 (1950); SEC v Leach, 156 F.Supp.2d 491,494 (E.D. PA. 2001). The Request for Production Plaintiffs claim that the "act of production doctrine" does not encompass reque

antial and 'real,' and not merely trifling or imaginary, hazard[] of incrimination" when it comes to Plaintiffs discovery requests. United States v. Apfelbaum, 445 U.S. 115, 128 (1980). (i) The Fifth Amendment and Plaintiffs' Rule 4 Appeal The Fifth Amendment serves as a guarantee against testimonial com

te." See United States v. Neff, 315 F.2d 1235, 1239 (9th Cir.), cert denied, 447 U.S. 925 (1980); Blau v. United States, 340 U.S. 159 (1950); SEC v Leach, 156 F.Supp.2d 491,494 (E.D. PA. 2001). Moreover, the act of production itself may implicitly communicate statements and, for this reason, the Fift

sult in criminal prosecution. See generally Hoffman v United States, 341 U.S. at 486; United States v. Hubbell, 530 U.S. at 36 and United States v. Apfelbaum, 445 U.S. at 128. The Court's order seems to hone in on the "required records" exception for the proposition that, as a matter of law, Epstein's pe

lau v. United States, 340 U.S. 159 (1950); SEC v Leach, 156 F.Supp.2d 491,494 (E.D. PA. 2001). Moreover

o Plaintiffs discovery requests. United States v. Apfelbaum, 445 U.S. 115, 128 (1980). The Fifth Amendment s

te." See United States v. Neff, 315 F.2d 1235, 1239 (9th Cir.), cert denied, 447 U.S. 925 (1980); Blau v. United States, 340 U.S. 159 (1950); SEC v Leach, 156 F.Supp.2d 491, 494 (E.D. PA. 2001). Add new case from my e-mail of yesterday: (Court in Englebrick v Worthington Industries Inc 670 F Supp2d 10

sult in criminal prosecution. See generally Hoffman v United States, 341 U.S. at 486; United States v. Hubbell, 530 U.S. at 36 and United States v. Apfelbaum, 445 U.S. at 128. The Court's order seems to hone in on the "required records" exception for the proposition that, as a matter of law, Epstein's pe

ccordingly, any compelled testimony that provides a "lead or clue to a source of evidence of such [a] crime" is protected by Fifth Amendment. SEC v Leach, 156 F.Supp.2d 491,494 (E.D. PA. 2001). Questions seeking "testimony" regarding names of witnesses, leads to phone or travel records, or financial

7)). "The claimant must be 'confronted by substantial and 'real,' and not merely trifling or imaginary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 (1980). Accordingly, for these reasons, Epstein's objections to the Magistrate's Order should be sustained, and this Court shoul

te." See United States v. Neff, 315 F.2d 1235, 1239 (9th Cir.), cert denied, 447 U.S. 925 (1980); Blau v. United States, 340 U.S. 159 (1950); SEC v Leach, 156 F.Supp.2d 491,494 (E.D. PA. 2001). Moreover, the act of production itself may implicitly communicate statements and, for this reason, the Fift

sult in criminal prosecution. See generally Hoffman v United States, 341 U.S. at 486; United States v. Hubbell, 530 U.S. at 36 and United States v. Apfelbaum, 445 U.S. at 128. The Court's order seems to piggyback on DE 462 (a similar order), and thus seems to hone in on the "required records" exception f