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ted information only if it "clearly appears" to the court that the witness was mistaken in his invocation of the privilege." (Emphasis added). In re Keller Financial Svcs., supra at 399, ciSgr Hoffman at 486. 12 EFTA00067394 Case 9:08-cv-80119-KAM Document 65 Entered on FLSD Docket 03/25/2009 Pag
cend any difficulties that the exercise of the privilege may impose on society in the detection and prosecution of a crime." Id., at 490; and In re Keller Financial Svcs. of Flan Inc. 259 B.R. 391, 399 (M.D. Fla. 2000). The privilege not only extends to answers that would in themselves support a conviction under a cr
nscend any difficulties that the exercise of the privilege may impose on society in the detection and prosecution of a crime." Id, at 490; and In re Keller Financial Svcs. of Fla., Inc., 259 B.R. 391, 399 (M.D. Fla. 2000). The privilege not only extends to answers that would in themselves support a con
in any criminal case" contained in the Fifth Amendment. As noted, the Fifth Amendment privilege against self-incrimination is broad. Hoffman; In re Keller Financial Svcs., supra. To deny a witness the right to invoke the privilege, the judge must be perfectly clear, from a careful consideration of all the circumstan
ted information only if it "clearly appears" to the court that the witness was mistaken in his invocation of the privilege." (Emphasis added). In re Keller Financial Svcs., supra at 399, ciSgr Hoffman at 486. 12 EFTA00222536 Case 9:08-cv-80119-KAM Document 65 Entered on FLSD Docket 03/25/2009 Pag
cend any difficulties that the exercise of the privilege may impose on society in the detection and prosecution of a crime." Id., at 490; and In re Keller Financial Svcs. of Flan Inc. 259 B.R. 391, 399 (M.D. Fla. 2000). The privilege not only extends to answers that would in themselves support a conviction under a cr
AYRAIN09 PaKO PS 4 24 C.M.A. v. Epstein, et al. Page 13 that the witness was mistaken in his invocation of the privilege." (Emphasis added). In re Keller Financial Svcs., supra at 399, .gr Hoffman, at 486. In the instant case, the privilege applies as Defendant EPSTEIN "has reasonable cause to appr
cend any difficulties that the exercise of the privilege may impose on society in the detection and prosecution of a crime." Id., at 490; and In re Keller Financial Svcs. of Fla.. Inc., 259 B.R. 391, 399 (M.D. Fla. 2000). The privilege not only extends to answers that would in themselves support a conviction under a
Entities connected to both Keller and Keller Financial Svcs

Jeffrey Epstein
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Ghislaine Maxwell
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Alan Dershowitz
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Kenneth Marra
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ORGANIZATIONJane Doe
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Jay Lefkowitz
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