Epstein Secrets

s. V. PLAINTIFF IS ENTITLED TO DEFENDANT'S HEALTH CARE INFORMATION IN DISCOVERY A. Interrogatory at Issue "Interrogatory No. 8. Identify all of Jeffrey Epstein's health care providers in the past (10) ten years, including without limitation, psychologists, psychiatrists, mental health counselors, physician,

to Plaintiff's discovery requests. - 1 - EFTA00728201 Case 9:08-cv-80119-KAM Document 57 Entered on FLSD Docket 03/02/2009 Page 2 of 16 II. EPSTEIN'S BLANKET ASSERTION OF PRIVILEGE AGAINST SELF-INCRIMINATION IN RESPONSES TO INTERROGATORIES IS INSUFFICIENT Defendant's response to each and every

cceptable). While Plaintiff does not dispute that Defendant Epstein's Fifth Amendment privilege may be asserted in a

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MOTION TO COMPE

ame in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. Response: Defend

ergy communications privilege, section 39.204 abrogates the various evidentiary privileges in cases involving child abuse, abandonment or neglect." Nussbaumer v. State 882 So.2d 1067 (Fla. 2d DCA 2004). It represents a determination by the legislature that discovery of facts relating to claims of child ab

PLAINTIFF IS ENTITLED TO DEFENDANT’S HEALTH CARE INFORMATION IN DISCOVERY A. Interrogatory at Issue “Interrogatory No. 8. Identify all of Jeffrey Epstein’s health care providers in the past (10) ten years, including without limitation, psychologists, psychiatrists, mental health counselors, physician,

e, 822 F.2d 1035, 1037 (11th Cir. 1987) (rejecting a “blanket” refusal to testify as unacceptable). While Plaintiff does not dispute that Defendant Epstein’s Fifth Amendment privilege may be asserted in a civil case,3 the Fifth Amendment’s “protection must be confined to instances where the witness has

ceptable). While Plaintiff does not dispute that Defendant Epstein’s Fifth Amendment privilege may be asserted in a

t Issue “Interrogatory No. 8. Identify all of Jeffrey Epstein’s health care providers in the past (10)

rgy communications privilege, section 39.204 abrogates the various evidentiary privileges in cases involving child abuse, abandonment or neglect.” Nussbaumer v. State, 882 So.2d 1067 (Fla. 2d DCA 2004). It represents a determination by the legislature that discovery of facts relating to claims of child

s. V. PLAINTIFF IS ENTITLED TO DEFENDANT'S HEALTH CARE INFORMATION IN DISCOVERY A. Interrogatory at Issue "Interrogatory No. 8. Identify all of Jeffrey Epstein's health care providers in the past (10) ten years, including without limitation, psychologists, psychiatrists, mental health counselors, physician,

to Plaintiff's discovery requests. - 1 - EFTA00222502 Case 9:08-cv-80119-KAM Document 57 Entered on FLSD Docket 03/02/2009 Page 2 of 16 II. EPSTEIN'S BLANKET ASSERTION OF PRIVILEGE AGAINST SELF-INCRIMINATION IN RESPONSES TO INTERROGATORIES IS INSUFFICIENT Defendant's response to each and every

cceptable). While Plaintiff does not dispute that Defendant Epstein's Fifth Amendment privilege may be asserted in a

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MOTION TO COMPE

ergy communications privilege, section 39.204 abrogates the various evidentiary privileges in cases involving child abuse, abandonment or neglect." Nussbaumer v. State 882 So.2d 1067 (Fla. 2d DCA 2004). It represents a determination by the legislature that discovery of facts relating to claims of child ab