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itness against himself." (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985) (ci
quired to produce and/or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000)(the "privil
witness against himself." (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 (I Ith Cir. 1985) (c
uired to produce and/or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000)(the "privile
incriminate him in future criminal proceedings.” Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985)(citi
g required to produce or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9 Cir. 2000). Accordingly,
might incriminate him Case 9:08-cv-80119-KAM Document 480 Entered on FLSD Docket 03/04/2010 Page 2 of 10 - 3 in future criminal proceedings.” Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985)(citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded “liberal construction i
elate solely to Defendant’s net worth and are “unrelated to Defendant’s inducement of minors to sexual activity,” ring hollow. See 1 Rudy-Glanzer v. Glanzer, 232 F.3d at 1263 (the “privilege” against self-incrimination does Case 9:08-cv-80119-KAM Document 480 Entered on FLSD Docket 03/04/2010 Page 7
provides, in relevant part, that "[n]o person ... shall be compelled in any Criminal Case to be a witness against himself." (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley. 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction
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
provides, in relevant part, that "[tic) person...shall be compelled in any Criminal Case to be a witness against himself." (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction in
nts is considered testimonial and is protected by the Fifth Amendment. ao in re Grand Jury Subpoena, 1 F.3d 87, 93 (2nd Cir. 1993); Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000Xthe "privilege" against self-incrimination does not depend upon the likelihood, but upon the possibility of pro
nd provides, in relevant part, that "[n]o person...shall be compelled in any Criminal Case to be a witness against himself" (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 ( 1 1 th Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded liberal constructi
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. 2000Xthe "privilege" against self-incrimination does not depend upon the likelihood, but upon the possibility of pros
put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings? Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985)(citing 2 EFTA00592192 Case 9:08-cv-80119-KAM Document 462 Entered on FLSD Docket 02/04/2010 Page 3 o
e having a tendency to Incriminate Epstein and would threaten to invade his privilege against being required to produce or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9"' Cir. 2000). Accordingly, finding the sought after information would result in testimonial disclosures that would communica
criminate him 2 EFTA00728617 Case 9:08-cv-80119-KAM Document 480 Entered on FLSD Docket 03/04/2010 Page 3 of 10 in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985)(citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded "liberal construction
elate solely to Defendant's net worth and are "unrelated to Defendant's inducement of minors to sexual activity,"' ring hollow. See Rudy-Glanzer v. Glanzer, 232 F.3d at 1263 (the "privilege" against self-incrimination does ' See Plaintiffs' Mtn. (D.E. #333), p.7. 7 EFTA00728622 Case 9:08-cv-80119-KA
Entities connected to both Edwin and Glanzer

Jeffrey Epstein
PERSON
Jay Lefkowitz
PERSONHubbell
PERSONJane Doe
PERSONApfelbaum
PERSONTurley
PERSONJack Goldberger
PERSON
United States
LOCATION
Rudy Giuliani
PERSON
Adam D. Horowitz
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONMichael J. Pike
PERSON
Sarah Kellen
PERSON
Paul Cassell
PERSONKatherine W. Ezell
PERSONIsidro Manuel Garcia
PERSONSpencer Kuvin
PERSONMermelstein & Horowitz
ORGANIZATIONRobert C. Josefsberg
PERSON