inal message From: Richard Kahn a =br> Date:11/17/2014 4:04 PM (GMT-04:00) To: Patrick Adams Cc: Daphne Wallace ann =odriquez =ob Petersen =on Sprague a>, =hip Harris -c >, Bill =eeper >, Mark =anzin Subject: Re: Telephone call - November 7, 2014 good afternoon hope friday visit went well mr e

:57 AM EST To: =/b>Richard Kahn < >, =ob Petersen a, =ill Leeper , =ichael Malo </=iv> Cc: Daphne Wallace < , ann =odriquez =ob Petersen =on Sprague , =hip Harris Bill =eeper Mark =anzin a> Good morning Richard, Friday's visit went well. We were able to document all needed plant =ata and its

s or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead,

not of itself establish the hazard of incrimination.” Id. A “blanket refusal” to provide testimony or information is unacceptable. See Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). A witness bears the burden of justifying the invocation of the privilege. In re J.M.V., Inc. Epstein fall

s or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead,

the Fifth Amendment privilege is raised as a bar to discovery, a blanket refusal to answer questions or to produce documents is improper. Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead, the privilege must be asserted in response to a particular question, and in each instance the burden

ould be a surprise to you, based 24 upon at least what you —your impression is from 25 Justin; is that correct? Page 172 1 COURT REPORTER: And Sprague? 2 THE WITNESS: I don't know his last name — 3 MR. CRITTON: S-p-r-a-g-u-e, I believe. 4 That's how I've seen it answered in 5 interrogatories.

plaintiff or defendant, the nature of the action, and the date and court in which such suit was filed. I was involved in a custody proceeding with Sprague. 15. List all dates you allege you were at Mr. Epstein's home in Florida, include date, time arrived and left, the name(s) of anyone who went with

d not say "no" to Epstein. Jane Doc made a conscious decision not to have intercourse or oral sex with Epstein. Jane Doe's sexual experiences with Sprague during that same time period demonstrate that she chose to engage in those acts with him, but would not do the same with Epstein. For the same reas

7/6/2010 Benz, Devon 58.00 Current JANE DOE JEFFREY EPSTEIN Case: 08-80893CIV-MARRA/JOHNSON Southern Ref: Doe v. Epstein 2010009677 7/8/2010 Sprague, Justin 255.88 Current JANE DOE JEFFREY EPSTEIN Case: 08.80893CIV-MARRNJOHNSON Southern Ref: Doe v. Epstein 2010009678 7/1/2010 Special., MS,

:06:49 AM EST To: =/b>Richard Kahn =atrick Adams =/div> Cc: Bob Petersen =ill Leeper =ichael Malo , Daphne =allace < =odriquez" S ' ' =on Sprague < , =Mark Banzin" Mr. =ahn: We =ppreciate your patience with this; the confluence of the end of our =SVI project and the holiday interruption (Th

ited States Constitution. Defendant’s canned objection represents a “blanket” refusal to answer questions in this civil case. See Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987) (rejecting a “blanket” refusal to testify as unacceptable). While Plaintiff does not dispute that Defendant E

n-top:0px;margin-right:0px;margin-bottom:0px;margin-left:=px">From: Bob Peters=n To: Richar= Kahn <javascript:_e(%7B%7D,'cvml > > </=pan> Cc: =on Sprague aspan> Subject: LSJ Intake Service and Meeting Request <=pan style="font-family:-webkit-system-font,Helvetica Neue,Helvetica,sans=serif;color:rgb