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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:
668, 669 (I Ith Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accor
enuinely threatening questions.” United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). In ruling as
Docket 02/04/2010 Page 2 of 14 3 Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is acco
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
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 in favor of the right and extends not only to answers that would support a
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
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.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth Amendment privilege is also ava
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
l, 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 in favor of the right it was intended to secure," Hoffman v. United State
enuinely threatening questions.” United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). The danger Ep
.2d 668, 669 (11th Cir. 1985)(citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is acco
tein of a crime. (DE 242, p.18) United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). 5. As detai
d 668, 669 (11th Cir. 1985), citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). Thus, information is pr
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
nformal, 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 favor of the right and extends not only to answers that would support a
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
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 of 14 Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction in favor of the right it was intended to secure," Hoffman v. United States
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
al, 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 in favor of the right it was intended to secure," Hoffman v. United State
Entities connected to both Goodwin and Turley

Jeffrey Epstein
PERSON
United States
LOCATIONJane Doe
PERSONHubbell
PERSON
Jay Lefkowitz
PERSON
Department of Justice
ORGANIZATIONApfelbaum
PERSON
Donald Trump
PERSON
Edwin
PERSON
Julie K. Brown
PERSON
Michael Jackson
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONEmmy Taylor
PERSONThe New York Post
ORGANIZATIONLeon Black
PERSON
Scarlett Johansson
PERSON
Joe Biden
PERSON
Supreme Court
ORGANIZATION
George Mitchell
PERSON