Epstein Secrets

2 and 13); and Epstein’s medical records from Dr. Stephen Alexander (Request 16). Each of these categories

nary, hazards of incrimination.” United States v. Apfelbaum, 445 U.S. 115, 128 (1980). When the Fifth Amendme

All medical records of Defendant Epstein from Dr. Stephan Alexander. Response: Defendant is asserting sp

o Plaintiffs discovery requests. United States v. Apfelbaum, 445 U.S. 115, 128 (1980). The Fifth Amendment s

and 13); and Epstein's medical records from Dr. Stephen Alexander (Request 16). Each of these categories

17)). 'The claimant must be 'confronted by substantial and 'real,' and not merely trifling or imaginary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 (1980). When the Fifth Amendment privilege is raised as a bar to discovery, a blanket refusal to answer questions or to produce

and 13); and Epstein's medical records from Dr. Stephen Alexander (Request 16). Each of these categories

. The danger Epstein faces by being forced to testify in this instance is "substantial and real, and not merely trifling or imaginary" as required. Apfelbaum, 445 U.S. 128. Accordingly, finding the subject requests involve compelled statements that would furnish a link in the chain of evidence needed to