Epstein Secrets

ould not be entitled to compel pre-trial production of any of this information. See Fed. R. Cr. P. 16(b)(l)(A), (C), and 16(b)(2); United States v. Argomaniz, 925 F.2d 1349, 1355-56 (11th Cir. 1991) (explaining act-of-production privilege). Thus, absent a stay of this civil action, the USAO would receive

ered on FLSD Docket 08/12/2008 Page 3 of 13 "agreed to defer federal prosecution in favor of prosecution by the State of Florida .... " See In re. Jane Doe, Case No. 08-80736-CIV-Marra/Johnson (S.D. Fla.) (DE 14), Deel. of AUSA Villafana, 07/09/08, ,i 5, attached hereto as Exhibit "A" (emphasis added).

of incrimination is justified. United States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). “A court

pel shall list specific requests in succession) – Jane Doe’s requests for admission are as follows: 1. Yo

ment invocations are valid. It is for the court, not the claimant, to determine whether the hazard of incrimination is justified. United States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). “A court must make a particularized inquiry, deciding, in connection with each specific area that the Case

the convenience of the court – and in compliance with Local Rule 26.1 H (party filing motion to compel shall list specific requests in succession) – Jane Doe’s requests for production and Epstein’s objections are as follows: Request No. 1: Copies of all telephone records in your or your attorney’s possess

ment invocations are valid. It is for the court, not the claimant, to determine whether the hazard of incrimination is justified. United States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). “A court must make a particularized inquiry, deciding, in connection with each specific area that the quest

the convenience of the court – and in compliance with Local Rule 26.1 H (party filing motion to compel shall list specific requests in succession) – Jane Doe’s requests for admission are as follows: 1. Your net worth is greater than $10 million. 2. Your net worth is greater than $50 million. 3.

ment invocations are valid. It is for the court, not the claimant, to determine whether the hazard of incrimination is justified. United States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). “A court must make a particularized inquiry, deciding, in connection with each specific area that the Case

the convenience of the court – and in compliance with Local Rule 26.1 H (party filing motion to compel shall list specific requests in succession) – Jane Doe’s requests for production and Epstein’s objections are as follows: Request No. 1: Copies of all telephone records in your or your attorney’s possess

ment invocations are valid. It is for the court, not the claimant, to determine whether the hazard of incrimination is justified. United States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). “A court must make a particularized inquiry, deciding, in connection with each specific area that the quest

the convenience of the court – and in compliance with Local Rule 26.1 H (party filing motion to compel shall list specific requests in succession) – Jane Doe’s requests for admission are as follows: 1. Your net worth is greater than $10 million. 2. Your net worth is greater than $50 million. 3.

ion, and he exercised that right. He was given every opportunity to substantiate his claims of privilege before the Magistrate Judge. See U.S. v. Argomaniz 1 Nothing in Defendant’s Motion indicates that he seeks to submit in camera evidence that

FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPS

It is for the Court, not the claimant, to determine whether the hazard of incrimination justifies invocation of the privilege. See United States'. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). "A court must make a particularized inquiry, deciding, in connection with each specific area that the 9 EFT

ions asked and the documents requested .. . ." Id. Here Epstein has made sweeping generalizations about the applicability of the Fifth Amendment to Jane Doe's specific discovery requests. But in his motion, he has merely cobbled together a few grandiose quotations about general Fifth Amendment principles