burden to demonstrate that the act of producing any particular responsive documents would entail testimonial self-incrimination. United States v. Wujkowski, 929 F.2d 981, 984 (4th Cir. 1991). It is not self-evident or apparent from the Plaintiff’s requests that the act of producing responsive items wo

testimonial and incriminatory to support the Fifth Amendment privilege against self-incrimination is a “fact dependent inquiry.” United States v. Wujkowski, 929 F.2d 981, 985 (4th Cir. 1991). It is the burden of the party asserting the privilege to “explain how the act of producing documents would pose

ld entail testimonial self-incrimination. U.S. v. Wujkowski, 929 F.2d 981, 984 (4th Cir. 1991). In the inst

testimonial self-incrimination. United States v. Wujkowski The party asserting the Fifth Amendment privile

s the burden of the defendant to show that the act of producing responsive documents would entail testimonial self- incrimination. United States v. Wujkowski, 929 F.2d 981, 984 (4th Cir. 1991). In many cases, the existence and location of papers are a foregone conclusion and the defendant adds little or