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and it is reasonably able therefrom to respond whether it did the thing charged.” Dennis v. Begley Drug Co. of Tennessee, Inc., 53 F.R.D. 608, 609 (E.D. Tenn. 1971). As it is written, ¶ 29 is ambiguous as to whether Plaintiff claims prostitution or another criminal offense (and if so, what offense) with wh
tion’ is not limited to the situation where the defendant makes a single response to numerous questions.” United States v. Buaiz, 2008 WL 5050102 (E.D. Tenn. 2008). Rather, as here, where the defendant refuses to answer on fifth amendment grounds each and every question, such repeated assertions are fai