Epstein Secrets

Epstein 08-CV80119 Page No. 10 2 See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4th DCA 1983); Mall

effort to defeat collection of any judgment that Jane Doe and other plaintiffs may obtain." (DE 485, p.l 9

occurrence of the assaults alleged and still maintain the safe harbor of the 5 Amendment.2 See Ohio v. Reiner, 532 U.S. 17(1991). 2 See DeLisi v. Bankers Ins. Company. 436 So.2d 1099 (Fla. 4th DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to

ocket entries. Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 4 of 37 Doe v. Epstein 08-CV80119 Page No. 4 (a) Jane Doe Plaintiff, Jane Doe's Motion to Compel is filed at DE (194). Defendant's Response in Opposition is filed at DE (339), and the arguments set forth t

ledge and deny. 2. As to the allegations in paragraphs 2, Defendant asserts his Fifth Amendment privilege against self-incrimination. See Delisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4th DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to

levard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 [email protected] [email protected] Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300

ivilege against self-incrimination. See Delisi v. Bankers Ins. Company. 436 So.2d 1099 (Fla. 4th DCA 1983); Mal

[email protected] Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger &