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in of a crime. (DE 242, p. 18) United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). 2 Case 9:
witness against himself." (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 (I Ith Cir. 1985) (c
enuinely threatening questions.” United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). In ruling as
incriminate him in future criminal proceedings.” Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985)(citi
he privilege raised as to these requests valid, and asserted by Epstein only with reference to 'genuinely threatening questions." United States v. Goodwin, 625 F.2d 693, 701 (5 th Cir. 1980). (DE 462 at p. 10-11) Based upon the foregoing, it is clear that this court made the correct ruling relative to
provides, in relevant part, that "[n]o person ... shall be compelled in any Criminal Case to be a witness against himself." (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction i
witness, (the trial court) can conclude that the witness could 'legitimately refuse to answer essentially all relevant questions." United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. Fla. 1980)); United States v. Tsui, 646 F.2d 365, 367-68 (9th Cir. 1981). This exception is narrow and is applicable w
ut to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11 th Cir. 1985), citing Lefkowitz v. Turley, 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner, 532 U
y threatening questions" which could furnish a link in the chain of evidence needed to convict Epstein of a crime. (DE 242, p.18) United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). b. The District Court Judge Court Should Reverse or Modify The Magistrate Judge's Order (DE 242) Relative to I
put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (I Ith Cir. 1985), citing Lefkowitz v. Turley. 414 U.S. 70, 77 (1973)). The privilege is accorded "liberal construction
enuinely threatening questions.” United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). The danger Ep
incriminate him in future criminal proceedings.” Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985)(citi
tein of a crime. (DE 242, p.18) United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). 5. As detai
incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985), cit
vilege raised as to these interrogatories valid, and asserted by Epstein only with reference to "genuinely threatening questions." United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). The danger Epstein faces by being forced to testify in this instance is "substantial and real, and not merely t
ions put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future proceedings." See Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction in
s the privilege raised as to these Requests valid, and asserted by Epstein only with reference to "genuinely threatening questions? United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). In ruling as it does, the Court finds that ordering Epstein to produce the information sought, information whi
put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings? Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985)(citing 2 EFTA00592192 Case 9:08-cv-80119-KAM Document 462 Entered on FLSD Docket 02/04/2010 Page 3 o
ivilege raised as to these interrogatories valid, and asserted by Epstein only with reference to "genuinely threatening questions? United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). The danger Epstein faces by being forced to testify in this instance is "substantial and real, and not merely t
put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985)(citing Lefkowitz v. Turley, 414 U.S. 70. 77 (1973)). The privilege is accorded "liberal construction
Entities connected to both Goodwin and Edwin

Jeffrey Epstein
PERSON
United States
LOCATIONJane Doe
PERSONHubbell
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Jay Lefkowitz
PERSONApfelbaum
PERSONJack Goldberger
PERSONTurley
PERSON
Bradley Edwards
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Donald Trump
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Michael Jackson
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Julie K. Brown
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Kenneth Marra
PERSONEmmy Taylor
PERSON
George Mitchell
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Scarlett Johansson
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George W. Bush
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Sarah Kellen
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Adam D. Horowitz
PERSONthe Southern District
LOCATION