Epstein Secrets

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

are unknown; or (2) where production would "implicitly authenticate" the documents. In re Grand Jury Subpoena 1 F.3d 87, 93 (2d Cir. 1993); see also Fisher v. United States, 425 U.S. 391, 410 (1976) (issue expressed as whether compliance with a document request or subpoena "tacitly conceded" the item's

ating; rather, if anything, it is their contents, which are not protected by the Fifth Amendment privilege so long as they were created voluntarily. Fisher 425 U.S. at 410; see also In `Plaintiff concedes that the act of producing items in response to request no. 9, concerning witness statements, and r

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

are unknown; or (2) where production would "implicitly authenticate" the documents. In re Grand Jury Subpoena 1 F.3d 87, 93 (2d Cir. 1993); see also Fisher v. United States, 425 U.S. 391, 410 (1976) (issue expressed as whether compliance with a document request or subpoena "tacitly conceded" the item's

ating; rather, if anything, it is their contents, which are not protected by the Fifth Amendment privilege so long as they were created voluntarily. Fisher 425 U.S. at 410; see also In `Plaintiff concedes that the act of producing items in response to request no. 9, concerning witness statements, and r

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

f 22 documents is considered testimonial and is protected by the Fifth Amendment. In re Grand Jury Subpoena, 1 F.3d 87, 93 (2d Cir. 1993); see also Fisher v. United States, 425 U.S. 391, 410 (1976)(issue expressed as whether compliance with a document request or subpoena "tacitly conceded" the item's

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

nsive documents is considered testimonial and is protected by the Fifth Amendment. In re Grand Jury Subpoena 1 F.3d 87, 93 (2d Cir. 1993); see also Fisher v. United States, 425 U.S. 391, 410 (1976)(issue expressed as whether compliance with a document request or subpoena "tacitly conceded" the item's

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

sive documents is considered testimonial and is protected by the Fifth Amendment. In re Grand Jury Subpoena, 1 F.3d 87, 93 (2d Cir. 1993); see also Fisher v. United States, 425 U.S. 391, 410 (1976)(issue expressed as whether compliance with a document request or subpoena "tacitly conceded" the item's