Epstein Secrets

nsive documents is considered testimonial and is protected by the Fifth Amendment. In re Grand Jury Subpoena 1 F.3d 87, 93 (2d Cir. 1993); see also Fisher v. United States, 425 U.S. 391, 410 (1976)(issue expressed as whether compliance with a document request or subpoena "tacitly conceded" the item's

ses are less specific in nature. 4 EFTA00592194 Case 9:08-cv-80119-KAM Document 462 Entered on FLSD Docket 02/04/2010 Page 5 of 14 REQUESTS FOR ADMISSIONS The Admission Requests at issue herein, Request Numbers 1-9 and 21-23, all essentially seek admissions relating to the same general subject matter,

Amendment privilege against self-incrimination does not extend to documents whose existence is known to the government or is a foregone conclusion. Fisher, 425 U.S. at 410; United States 1. Hubbell, 530 U.S. 27, 44 (2000); United States I. Ponds, 454 F.3d 313, 325 (D.C. Cir. 2006). Thus, while the Fif

ses are less specific in nature. 4 EFTA00222431 Case 9:08-cv-80119-KAM Document 462 Entered on FLSD Docket 02/04/2010 Page 5 of 14 REQUESTS FOR ADMISSIONS The Admission Requests at issue herein, Request Numbers 1-9 and 21-23, all essentially seek admissions relating to the same general subject matter,

y representative, and not from the Government, to avoid any bias. As you know, Judge Starr has requested a meeting with Assistant Attorney General Fisher to address what we believe is the unprecedented nature of the section 2255 component of the Agreement. We are hopeful that this meeting will take p

n JANE DOE #1 and JANE DOE #2, Petitioners, 1. UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Doe #1 and Jane Doe #2's First Request for Admissions to