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falling within the exception of §39.204. D. Third Party Privacy Rights Are Not a Basis to Deny Discovery The right to privacy discussed in Eisenstadt v. Baird, 405 U.S. 438, 454 (1972), has nothing to do with the discovery issues in this case. Eisenstadt concerns the distribution of a contracepti
very The right to privacy discussed in Eisenstadt v. Baird, 405 U.S. 438, 454 (1972), has nothing to do with the discovery issues in this case. Eisenstadt concerns the distribution of a contraceptive device. Yet Defendant relies entirely on Eisenstadt in contending that third party privacy rights pro
”, and “only as to genuinely threatening questions should [the witness’s] silence be sustained.” Goodwin, 625 F.2d at 701 (quoting United States v. Melchor Moreno, 536 F.2d 1042, 1049 (5th Cir. 1976)). Defendant further asserts that Plaintiff’s interrogatories requesting that he identify employees may lea
9 Page 32 of 37 Jane Doe No. 2 v. Epstein Page 32 parties are implicated. See specified requests. As noted by the United States Supreme Court in Eisenstadt v. Baird, 405 U.S. 438,454, 92 S.Ct. 1029, 1038, at fn. 10 (1972): In Stanley, 394 U.S., at 564, 89 S.Ct., at 1247, the Court stated:'(A)lso fundam
a particularized inquiry, evaluating whether the privilege applies with respect to each specific area that the questioning party wishes to explore. Melchor Moreno. 536 F.2d at 1049. The witness may be totally excused from testifying only if the court finds that he could legitimately refuse to answer essential
hing to do with the discovery issues in this case. Eisenstadt concerns the distribution of a contraceptive device. Yet Defendant relies entirely on Eisenstadt in contending that third party privacy rights provide a basis for Defendant to object to discovery in this case. The vague argument and unsupported
ry", and "only as to genuinely threatening questions should [the witness's] silence be sustained." Goodwin, 625 F.2d at 701 (quoting United States'. Melchor Moreno, 536 F.2d 1042, 1049 (5th Cir. 1976)). Defendant further asserts that Plaintiff's interrogatories requesting that he identify employees may lead t
Entities connected to both Eisenstadt and Melchor Moreno

Jeffrey Epstein
PERSON
United States
LOCATIONJack Goldberger
PERSONHubbell
PERSON
Adam D. Horowitz
PERSONJane Doe
PERSONBaird
PERSON
Sarah Kellen
PERSONSecond Circuit
ORGANIZATIONGoodwin
PERSON
Alan Dershowitz
PERSON
United States District Court
ORGANIZATION
Jay Lefkowitz
PERSONthe Florida Supreme Court
ORGANIZATION
Harry Reid
PERSONStuart S. Mermelstein
PERSON
Edwin
PERSONthe First District
LOCATIONShaktman
PERSONMichael J. Pike
PERSON