Epstein Secrets

nary, hazards of incrimination.” United States v. Apfelbaum, 445 U.S. 115, 128 (1980). When the Fifth Amendme

to disclosure at the instant discovery stage. See Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978).

nary, hazards of incrimination.” United States v. Apfelbaum, 445 U.S. 115, 128 (1980). When the Fifth Amendme

bear on any issue that is or may be in the case." Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978).

23240 Case 9:08-cv-80119-KAM Document 242 Entered on FLSD Docket 08/04/2009 Page 6 of 22 or imaginary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 (1980). When the Fifth Amendment privilege is raised as a bar to discovery, a blanket refusal to answer questions or to produce

ear on any issue that is or may be in the case." Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978).

17)). 'The claimant must 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). When the Fifth Amendment privilege is raised as a bar to discovery, a blanket refusal to answer questions or to produce

to disclosure at the instant discovery stage. See Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340. 352 (1978).

98 Case 9:08-cv-80119-KAM Document 242 Entered on FLSD Docket 08/04/2009 Page 6 of 22 or imaginary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 (1980). When the Fifth Amendment privilege is raised as a bar to discovery, a blanket refusal to answer questions or to produce

bear on any issue that is or may be in the case? Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978).

. The danger Epstein faces by being forced to testify in this instance is "substantial and real, and not merely trifling or imaginary" as required. Apfelbaum, 445 U.S. 128. Accordingly, finding the subject requests involve compelled statements that would furnish a link in the chain of evidence needed to

to disclosure at the instant discovery stage. See Oppenheimer Fund, Inc. I. Sanders, 437 U.S. 340, 352 (1978).