Epstein Secrets

4 -0/ 2009: Stuart S. Mermelstein, Esq. Jack Alan Goldberger, Esq. Adam D. Horowitz, Esq. Atterbu

ing on whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in

e 200 FL 33410 Fax Counsel for Plaintiff Jack Alan Goldberger, Esq. Atterbury Goldberger & 250 Aus

ing on whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny — Privilege Against Self-Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in

istrict Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D

nt 81 Entered on FLSD Docket 04)20:2009 Page 2 of 11 II. Argument in Reply A. Defendant Has Made a Blanket Assertion of the Privilege Against Self-Incrimination That Is Insufficient 1. Defendant Cannot Rely on its Blanket Objections to Interrogatories on Fifth Amendment Grounds Defendant Epstein insists t