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

951) (emphasis supplied). "[A] witness has some minimal burden to justify invocation of the privilege." In re I.M.V.. Inc. 90 F.R. 737, 739 (Bankr. E.D. Pa. 1988). The privilege must be asserted in response to a particular question, and in each instance "[i]t is for the court to decide whether a witness' sile

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

951) (emphasis supplied). "[A] witness has some minimal burden to justify invocation of the privilege." In re I.M.V.. Inc. 90 F.R. 737, 739 (Bankr. E.D. Pa. 1988). The privilege must be asserted in response to a particular question, and in each instance "[i]t is for the court to decide whether a witness' sile

Kroblin, Erika Kellerhals P.C., St. Thomas, USVI; Jeffrey B. C. Moorhead, Christiansted, USVI; Mark W. Eck

Ins. Co., 899 F. Supp. 1385, 1397 (E.D.Pa. 1995) (internal quotation marks omitted) (quoting Ne. Women's Or., Inc. v. McMonagle, 689 F. Supp. 465 (E.D. Pa. 1988), aff'd in relevant part, 868 F.2d 1342 (3d Cir. 1989). The decision to grant a new trial lies within the discretion of the district court, althoug