Epstein Secrets

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

Attorney or State Attorney Telephone records 5-6 Videos, photographs of residence 7 Documents relating to Plaintiff Jane Doe 8 Air travel records 10 Documents relating to modeling agencies 11 Correspondence with other witnesses 14,

testimonial self-incrimination. United States v. Wujkowski The party asserting the Fifth Amendment privile

__________________________________/ PLAINTIFFS JANE DOE NOS. 2-8’ APPEAL AND OBJECTIONS TO MAGISTRATE J

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

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

testimonial and incriminatory to support the Fifth Amendment privilege against self-incrimination is a “fact dependent inquiry.” United States v. Wujkowski, 929 F.2d 981, 985 (4th Cir. 1991). It is the burden of the party asserting the privilege to “explain how the act of producing documents would pose

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

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

Defendant. ____________________________________/ JANE DOE, CASE NO.: 08- 80893-CIV-MARRA/JOHNSON Plain

6 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 wou

Defendant and the U.S. Attorney or State Attorney 1-4 Telephone records 5-6 Videos, photographs of residence 7 Documents relating to Plaintiff Jane Doe 8 Air travel records 10 Documents relating to modeling agencies I 1 Correspondence with other witnesses 14, 15, 16, 17, 19 Social networking do

ly testimonial and incriminatory to support the Fifth Amendment privilege against self-incrimination is a "fact dependent inquiry." United States'. Wujkowski, 929 F.2d 981, 985 (4th Cir. 1991). It is the burden of the party asserting the privilege to "explain how the act of producing documents would pose

F FLORIDA CASE NO.: 08-CV-80I I 9-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defend

6 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 wou

Defendant and the U.S. Attorney or State Attorney 1-4 Telephone records 5-6 Videos, photographs of residence 7 Documents relating to Plaintiff Jane Doe 8 Air travel records 10 Documents relating to modeling agencies I 1 Correspondence with other witnesses 14, 15, 16, 17, 19 Social networking do

Defendant's burden to demonstrate that the act of producing any particular responsive documents would entail testimonial self-incrimination. U.S. v. Wujkowski, 929 F.2d 981, 984 (4th Cir. 1991). In the instant case, it is evident from the requests themselves, the allegations in the various Complaints, and

(Requests 1-4), telephone records (Requests 5-6), videos and photos of Epstein's Palm Beach residence (Request 7), documents relating to Plaintiff Jane Doe (Request 8), air travel records (Request 10), documents relating to model agencies (Request 11), correspondence with other witnesses (Request 14-17,