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ence used to prosecute Epstein for those crimes. Sheldon v. Sheldon, 193 B.R. 152, 162 (S.D.N.Y 1996). To
o Plaintiffs discovery requests. United States v. Apfelbaum, 445 U.S. 115, 128 (1980). The Fifth Amendment
0119-KAM Document 522 Entered on FLSD Docket 04/09/2010 Page 12 of 15 link in the chain of evidence used to prosecute Epstein for those crimes. Sheldon v. Sheldon, 193 B.R. 152, 162 (S.D.N.Y 1996). Answers to the interrogatories, on their face, could also provide information showing Epstein's avai
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
e to the requests would support a conviction or provide a link in the chain of evidence to support a conviction against Epstein. See M•, Sheldon v. Sheldon, 193 B.R. 152, 162 (S.D. N.Y. 1996)(the Court, in camera, determined that answers to certain deposition questions would support a conviction or pro
he claimant must [also] 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, responses to the requests propounded upon Epstein would provide information which is protected by the privi
Entities connected to both Sheldon and Apfelbaum

Jeffrey Epstein
PERSON
United States
LOCATIONHubbell
PERSONJane Doe
PERSON
Jay Lefkowitz
PERSON
Bradley Edwards
PERSON
Edwin
PERSONJack Goldberger
PERSONTurley
PERSON
Julie K. Brown
PERSON
Adam D. Horowitz
PERSON
Kenneth Marra
PERSON
Sarah Kellen
PERSON
J. Robert Oppenheimer
PERSON
Paul Cassell
PERSONMichael J. Pike
PERSON
Salt Lake City
LOCATIONMaria Farmer
PERSONGoodwin
PERSON
Stephen Hawking
PERSON