Epstein Secrets

o Plaintiffs discovery requests. United States v. Apfelbaum, 445 U.S. 115, 128 (1980). The Fifth Amendment

liance with a subpoena to produce one's papers); Couch v. United States, 409 U.S. 322, 344-46 (1973) (th

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

privilege reaches ... the compulsion of responses which are also communications, for example, compliance with a subpoena to produce one's papers); Couch v. United States, 409 U.S. 322, 344-46 (1973) (the person complying with the subpoena "implicitly testifies that the evidence he brings forth is in

nary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 (1980). Accordingly, response

pliance with a subpoena to produce one's papers); Couch v. United States, 409 U.S. 322, 344-46 (1973) (t