e and authenticate a defendant's tax-work papers. Fisher v. United States, 425 U.S. 391, 410 (1976). Jane Does 2-8 also rely extensively on U.S. v. Ghidoni, 732 F.2d 814 (11 th Cir. 1984) wherein the court directed a defendant to execute a consent directive to a foreign bank allowing the bank to releas

's 9 Case 9:08-cv-80119-KAM Document 522 Entered on FLSD Docket 04/09/2010 Page 10 of 15 accountant (Fisher) or a defendant's foreign bank (Ghidoni) where the Defendant in no way authenticates the documents nor attests to control or genuiness or even existence and, therefore, where no Fifth Ame

Epstein. Finally, Plaintiffs’ document request no. 5 seeks primarily statements for bank accounts and investment accounts. In United States v. Ghidoni, 732 F.2d 814 (11th Cir. 1984), the Eleventh Circuit held that bank account statements were not protected by the Fifth Amendment act-of-production