Epstein Secrets

ntiffs request for Epstein's medical records, Dr. Stephen Alexander was hired as au expert consultant by Epstein's a

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

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

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

from the date hereof to provide the discovery subject to these Requests. The last category of documents concern Epstein's medical records from Dr. Stephen Alexander (Request 16). Epstein raises several objections to this category of Requests from relevancy concerns to privilege claims. Because Plaintiff has fail

. 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

from the date hereof to provide the discovery subject to these Requests. The last category of documents concern Epstein's medical records from Dr. Stephen Alexander (Request 16). Epstein raises several objections to this category of Requests from relevancy concerns to privilege claims. Because Plaintiff has fail

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