Epstein Secrets

l for Plaintiffs in Related Cases Nos. 09-80591 and 09-80656 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian A venue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 Case 9:08-cv-80119-KAM Document 342 Entered on FLSD Docket 10/06/

d testimony and information that may, directly or indirectly, furnish Plaintiff a clue or link in the chain of evidence used to prosecute him. Rudy- Glanzer v. Glanzer, 232 F.3d at 1263(the "privilege" against self-incrimination does not depend upon the likelihood, but upon the possibility of prosecution

08-801 J9, 08- 80232, 08-8038~ 08-80381, 08-80993, 08- 80994 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian A venue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 jagesq(i:llbeilsouth.net Counsel for £?.efendant Jeffrey Estein Farme

ts is considered testimonial and is protected by the Fifth Amendment. See In re Grand Jury Subpoena, 1 F.3d 87, 93 (2nd Cir. 1993); Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000)(the "privilege" against self-incrimination does not depend upon the likelihood, but upon the possibility of pro

ations with you, as well as my work product, you can answer the question. THE WITNESS: I believe that as part of the scheme to defraud investors in South Florida out of millions of dollars, claims of outrageous sums of money were made on behalf of alleged victims across the board. And the only way --

l case. In re EFTA00582836 Carp, 340 F.3d 15, 23 (1st Cir. 2003); Baxter v. Pabnigiano, 425 U.S. 308 (1976). See also Doe ex rel. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1264 (9th Cir. 2000) ("The Baxter holding is not a blanket rule that allows adverse inferences to be drawn from invocations of the p