Epstein Secrets

effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Defendant's canned objection represents a "blanket" refusal to answer questions in this civil case. See Anglada v. Sprague, 822 F.2d

ents that are attorney-client and work product privileged in that it seeks "all documents obtained in discovery or investigation relating either to the Florida Criminal Case or the Federal Criminal Case ... ." In addition, such documents are privileged and confidential as they are the subject of a pending investigation.

ion concerning persons, not parties to this litigation, whose privacy rights are implicated. Request No. 2. All documents referring or relating to the United States' agreement with Defendant to defer federal prosecution subject to certain conditions, including without limitation, the operative agreement between

ents that are attorney-client and work product privileged in that it seeks "all documents obtained in discovery or investigation relating either to the Florida Criminal Case or the Federal Criminal Case ... ." In addition, such documents are privileged and confidential as they are the subject of a pending investigation.

he answers cannot possibly have such tendency to incriminate. gI at 488, 399. Recognizing the breadth and magnitude of this constitutional privilege, the United States Supreme Court in discussing how a court is to analyze the application of the privilege stated — ... It is for the court to say whether his silence

ents that are attorney-client and work product privileged in that it seeks "all documents obtained in discovery or investigation relating either to the Florida Criminal Case or the Federal Criminal Case ... ." In addition, such documents are privileged and confidential as they are the subject of a pending investigation.

ion concerning persons, not parties to this litigation, whose privacy rights are implicated. Request No. 2. All documents referring or relating to the United States' agreement with Defendant to defer federal prosecution subject to certain conditions, including without limitation, the operative agreement between

ents that are attorney-client and work product privileged in that it seeks "all documents obtained in discovery or investigation relating either to the Florida Criminal Case or the Federal Criminal Case ... ." In addition, such documents are privileged and confidential as they are the subject of a pending investigation.