Epstein Secrets

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

sponsive documents 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 possibil

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

chain of evidence 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 wou

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

e the requests relate 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-

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

esponsive documents 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 possibi