Epstein Secrets

n FLSD Docket 03/02/2009 Page 15 of 16 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] s/ Adam D. Horowitz - 16

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

burden to demonstrate that the act of producing any particular responsive documents would entail testimonial self-incrimination. United States v. Wujkowski, 929 F.2d 981, 984 (4th Cir. 1991). It is not self-evident or apparent from the Plaintiff’s requests that the act of producing responsive items wo

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

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

testimonial self-incrimination. United States v. Wujkowski The party asserting the Fifth Amendment privile

d on FLSD Docket 09/30/2009 Page 8 of 9 9 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Bradley James Edwards [email protected] Isidro Manuel

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

s the burden of the defendant to show that the act of producing responsive documents would entail testimonial self- incrimination. United States v. Wujkowski, 929 F.2d 981, 984 (4th Cir. 1991). In many cases, the existence and location of papers are a foregone conclusion and the defendant adds little or

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

ed on FLSD Docket 04/20/2009 Page 10 of 11 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] s/ Stuart S. Mermelstein

testimonial and incriminatory to support the Fifth Amendment privilege against self-incrimination is a “fact dependent inquiry.” United States v. Wujkowski, 929 F.2d 981, 985 (4th Cir. 1991). It is the burden of the party asserting the privilege to “explain how the act of producing documents would pose

egan approaching the State Attorney's Office, applying pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by t

f attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.

papers that are not business documents, we now rule that it does not." (internal EFTA00211789 citation and quotations omitted)); United States v. Wujkowski , 929 F.2d 981 (4th Cir. 1991); In re Sealed Case , 877 F.2d 83, 84 (D.C. Cir. 1989) (Fifth Amendment privilege "does not cover the contents of any

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

Entered on FLSD Docket 04/20/2009 Page 11 of 11 SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] s/ Stuart S. Mermelstein EFTA00221731

ly testimonial and incriminatory to support the Fifth Amendment privilege against self-incrimination is a "fact dependent inquiry." United States'. Wujkowski, 929 F.2d 981, 985 (4th Cir. 1991). It is the burden of the party asserting the privilege to "explain how the act of producing documents would pose

egan approaching the State Attorney's Office, applying pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by t

f attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz.

te papers that are not business documents, we now rule that it does not." (internal EFTA00223005 citation and quotations omitted)); United States, Wujkowski , 929 F.2d 981 (4th Cir. 1991); In re Sealed Case , 877 F.2d 83, 84 (D.C. Cir. 1989) (Fifth Amendment privilege "does not cover the contents of any

ct Court, Southern District of Florida Jack Alan Goldberger Es . Robert D. Critton, Esq. s/ Adam D. Horowit

6 burden to demonstrate that the act of producing any particular responsive documents would entail testimonial self-incrimination. United States v. Wujkowski, 929 F.2d 981, 984 (4th Cir. 1991). It is not self-evident or apparent from the Plaintiff's requests that the act of producing responsive items wou