Epstein Secrets

to disclosure at the instant discovery stage. See Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). According

subject to Fifth Amendment protection. See, e.g., Rajah v. Mukasey, 544 F.3d 427, 442 (2d Cir. 2008)(“Jus

ar on any issue that is or may be in the case.” Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). The corres

e not covered by the Fifth Amendment. See, e.g., Rajah v. Mukasey, 544 F.3d 427, 442 (2nd Cir. 2008) (“

o encompass any matter that bears on, or that reasonably could lead to another matter that could bear on any issue that is or may be in the case.” Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). The correspondence with the government agencies may well point Jane Doe in the direction of admissible evide

, considered by the courts to be ‘required records,’ are as a matter of law not subject to Fifth Amendment protection.” Omnibus Order at 12 (citing Rajah v. Mukasey, 544 F.3d 427, 442 (2d Cir. 2008)); In re Doe, 711 F.2d 1187, 1191 (2d Cir. 1983); In re Doe, 97 F.R.D. 640, 644-45 (S.D.N.Y. 1982)). T