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o Fifth Amendment protection. See, e.g., Rajah v. Mukasey, 544 F.3d 427, 442 (2d Cir. 2008)(“Just as a taxp
ubbell, 530 U.S. 27, 44 (2000); United States v. Ponds, 454 F.3d 313, 325 (D.C. Cir. 2006). Thus, whil
Fisher, 425 U.S. at 410; Hubbell, 530 U.S. at 44; Ponds, 454 F.3d at 325 (D.C. Case 9:08-cv-80119-KAM D
red by the Fifth Amendment. See, e.g., Rajah v. Mukasey, 544 F.3d 427, 442 (2nd Cir. 2008) (“. . . a taxp
very similar to those here. In United States v. Ponds, 454 F.3d 313 (D.C. Cir. 2006), federal prosecut
red by the courts to be ‘required records,’ are as a matter of law not subject to Fifth Amendment protection.” Omnibus Order at 12 (citing Rajah v. Mukasey, 544 F.3d 427, 442 (2d Cir. 2008)); In re Doe, 711 F.2d 1187, 1191 (2d Cir. 1983); In re Doe, 97 F.R.D. 640, 644-45 (S.D.N.Y. 1982)). Third, the m
2004). The D.C. Circuit has recently refused to extend the act of production doctrine on facts very similar to those here. In United States v. Ponds, 454 F.3d 313 (D.C. Cir. 2006), federal prosecutors sought information about possible crimes committed by a defense attorney in the course of repre
Entities connected to both Mukasey and Ponds

Jeffrey Epstein
PERSON
United States
LOCATION
Jay Lefkowitz
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Alexander Acosta
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Ken Starr
PERSONJane Doe
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George W. Bush
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Bradley Edwards
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Stephen Hawking
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New York City
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Ghislaine Maxwell
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Rajah
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Bernie Sanders
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J. Robert Oppenheimer
PERSONOppenheimer Fund, Inc.
ORGANIZATIONJack Goldberger
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Adam D. Horowitz
PERSONMichael J. Pike
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