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enuinely threatening questions.” United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). The danger Ep
the requested discovery should not be permitted. Rossbach v. Rundle, 128 F.Supp.2d 1348, 1354 (S.D. Fla. 20
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
outweighs the likely benefit. Id. The party resisting discovery has a heavy burden of showing why the requested discovery should not be permitted. Rossbach v. Rundle, 128 F.Supp.2d 1348, 1354 (S.D. Fla. 2000) ("The onus is on the party resisting discovery to demonstrate specifically how the objected-to
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
outweighs the likely benefit. Id. The party resisting discovery has a heavy burden of showing why the requested discovery should not be permitted. Rossbach v. Rundle, 128 F.Supp.2d 1348, 1354 (S.D. Fla. 2000) ("The onus is on the party resisting discovery to demonstrate specifically how the objected-to
Entities connected to both Goodwin and Rossbach

Jeffrey Epstein
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United States
LOCATIONJane Doe
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Bradley Edwards
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Bernie Sanders
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Scarlett Johansson
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George W. Bush
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Jay Lefkowitz
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Kenneth Marra
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Hunter Biden
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J. Robert Oppenheimer
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Edwin
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