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s or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead,
privilege is mistaken as to its validity.” In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making
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 the burden
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
ited 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 Defendant E
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)
s or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead,
privilege is mistaken as to its validity.” In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making
Entities connected to both Sprague and Morganroth

Jeffrey Epstein
PERSONJane Doe
PERSONHubbell
PERSONAnglada
PERSON
Kenneth Marra
PERSON
Edwin
PERSON
Jay Lefkowitz
PERSONApfelbaum
PERSONTurley
PERSON
Scarlett Johansson
PERSONEmmy Taylor
PERSON
Sarah Kellen
PERSONJack Goldberger
PERSONWujkowski
PERSONHickman
PERSONLinnea R. Johnson
PERSON
Bernie Sanders
PERSON
Alan Dershowitz
PERSONGoodwin
PERSONRobert D. Critton
PERSON