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n the meaning of the privilege.” United States v. Hubbell, 530 U.S. 27, 35-36 (2000). However, in certain i
s or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead,
ting assertions of fact or belief, because the creation of those documents was not ‘compelled’ within the meaning of the privilege.” United States v. Hubbell, 530 U.S. 27, 35-36 (2000). However, in certain instances, “‘the act of production’ itself may implicitly communicate ‘statements of fact.’” Id. For
the Fifth Amendment privilege is raised as a bar to discovery, a blanket refusal to answer questions or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead, the privilege must be asserted in response to a particular question, and in each instance the burden
ng assertions of fact or belief because the creation of those documents was not ‘compelled’ within the meaning of the privilege.” United States v. Hubbell, 530 U.S. 27, 35-36 (2000). Accordingly, a party cannot avoid discovery merely because demanded documents contain incriminating evidence, “whether
ited States Constitution. Defendant’s canned objection represents a “blanket” refusal to answer questions in this civil case. See Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987) (rejecting a “blanket” refusal to testify as unacceptable). While Plaintiff does not dispute that Defendant E
n the meaning of the privilege.” United States v. Hubbell, 530 U.S. 27, 35-36 (2000). However, in certain i
s or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead,
Entities connected to both Hubbell and Sprague

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
Adam D. Horowitz
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Jay Lefkowitz
PERSONApfelbaum
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Bradley Edwards
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Edwin
PERSONTurley
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Sarah Kellen
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Kenneth Marra
PERSONStuart S. Mermelstein
PERSONSecond Circuit
ORGANIZATIONMermelstein & Horowitz
ORGANIZATION
Alan Dershowitz
PERSON
Scarlett Johansson
PERSONRobert D. Critton
PERSONGoodwin
PERSONMorganroth
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Rudy Giuliani
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