Epstein Secrets

er questions or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987).

privilege is mistaken as to its validity.” In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making

1980). When the Fifth Amendment privilege is raised as a bar to discovery, a blanket refusal to answer questions or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead, the privilege must be asserted in response to a particular question, and in each instance

ified and to require him to answer if it clearly appears to the court that the witness asserting the privilege is mistaken as to its validity.” In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making this Case 9:08-cv-80119-KAM Document 480 Entered on FLSD Docket 03/04/2010 Page 3 of 10 4 de

d by the United States Constitution. Defendant’s canned objection represents a “blanket” refusal to answer questions in this civil case. See Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987) (rejecting a “blanket” refusal to testify as unacceptable). While Plaintiff does not dispute that

ied and to require him to answer if it clearly appears to the Court that the witness asserting the privilege is mistaken as to its validity.” In re Morganroth, 718 F.2d 161, 166-167 (6th Cir. 1983)

er questions or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987).

privilege is mistaken as to its validity.” In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making

80). When the Fifth Amendment privilege is raised as a bar to discovery, a blanket refusal to answer questions or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead, the privilege must be asserted in response to a particular question, and in each instanc

ied and to require him to answer if it clearly appears to the court that the witness asserting the privilege is mistaken as to its validity." In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making this determination the judge is instructed to view the facts and evidence presented on a case- by-c

80). When the Fifth Amendment privilege is raised as a bar to discovery, a blanket refusal to answer questions or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead, the privilege must be asserted in response to a particular question, and in each instanc

ied and to require him to answer if it clearly appears to the court that the witness asserting the privilege is mistaken as to its validity." In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making this determination the judge is instructed to view the facts and evidence presented on a case- 3

ranteed by the United States Constitution. Defendant's canned objection represents a "blanket" refusal to answer questions in this civil case. See Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987) (rejecting a "blanket" refusal to testify as unacceptable). While Plaintiff does not dispute that D

fied and to require him to answer if it clearly appears to the Court that the witness asserting the privilege is mistaken as to its validity." In re Morganroth, 718 F.2d 161, 166-167 (6th Cir. 1983) Accordingly, Plaintiff deviates where necessary from the format set forth in S.D.Fla.L.R. 26.1(H)(2) in the

80). When the Fifth Amendment privilege is raised as a bar to discovery, a blanket refusal to answer questions or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead, the privilege must be asserted in response to a particular question, and in each instanc

ied and to require him to answer if it clearly appears to the court that the witness asserting the privilege is mistaken as to its validity." In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making this 3 EFTA00728618 Case 9:08-cv-80119-KAM Document 480 Entered on FLSD Docket 03/04/2010 Page 4

ranteed by the United States Constitution. Defendant's canned objection represents a "blanket" refusal to answer questions in this civil case. See Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987) (rejecting a "blanket" refusal to testify as unacceptable). While Plaintiff does not dispute that D

fied and to require him to answer if it clearly appears to the Court that the witness asserting the privilege is mistaken as to its validity." In re Morganroth, 718 F.2d 161, 166-167 (6th Cir. 1983) Accordingly, Plaintiff deviates where necessary from the format set forth in S.D.Fla.L.R. 26.1(H)(2) in the

80). When the Fifth Amendment privilege is raised as a bar to discovery, a blanket refusal to answer questions or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead, the privilege must be asserted in response to a particular question, and in each instanc

ied and to require him to answer if it clearly appears to the court that the witness asserting the privilege is mistaken as to its validity." In re Morganroth, 718 F.2d 161, 166.67 (6th Cir. 1983). In making this determination the judge is instructed to view the facts and evidence presented on a case-by-ca