Epstein Secrets

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

burden to demonstrate that the act of producing any particular responsive documents would entail testimonial self-incrimination. United States v. Wujkowski, 929 F.2d 981, 984 (4th Cir. 1991). It is not self-evident or apparent from the Plaintiff’s requests that the act of producing responsive items wo

not of itself establish the hazard of incrimination.” Id. A “blanket refusal” to provide testimony or information is unacceptable. See Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). A witness bears the burden of justifying the invocation of the privilege. In re J.M.V., Inc. Epstein fall

s the burden of the defendant to show that the act of producing responsive documents would entail testimonial self- incrimination. United States v. Wujkowski, 929 F.2d 981, 984 (4th Cir. 1991). In many cases, the existence and location of papers are a foregone conclusion and the defendant adds little or

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

ld entail testimonial self-incrimination. U.S. v. Wujkowski, 929 F.2d 981, 984 (4th Cir. 1991). In the inst