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o Plaintiffs discovery requests. United States v. Apfelbaum, 445 U.S. 115, 128 (1980). The Fifth Amendment
th is in fact the evidence demanded"); People v. Defore, 242 N.Y. 13, 27 (1926) ("A defendant is 'protect
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
1973) (the person complying with the subpoena "implicitly testifies that the evidence he brings forth is in fact the evidence demanded"); People v. Defore, 242 N.Y. 13, 27 (1926) ("A defendant is 'protected from producing his documents in response to a Subpoena duces tecum, for his production of them i
nary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 (1980). Accordingly, response
th is in fact the evidence demanded"); People v. Defore, 242 N.Y. 13, 27 (1926) ("A defendant is 'protect
Entities connected to both Apfelbaum and Defore

Jeffrey Epstein
PERSONHubbell
PERSONJane Doe
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Jay Lefkowitz
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Edwin
PERSONTurley
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United States
LOCATIONJack Goldberger
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Adam D. Horowitz
PERSONMichael J. Pike
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Sarah Kellen
PERSONGoodwin
PERSONKatherine W. Ezell
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Paul Cassell
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Bradley Edwards
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LOCATIONIsidro Manuel Garcia
PERSONRobert C. Josefsberg
PERSONSpencer Kuvin
PERSONMermelstein & Horowitz
ORGANIZATION