Accordingly, Epstein's objection to responding to these requests on the basis of his Fifth Amendment Right against self incrimination is upheld and Plaintiffs Motion is denied. As noted previously, the Fifth Amendment privilege against self incrimination is accorded "liberal construction," Hoffman, 341 U.S. at 4

nc. . Boulevard Burgers Corporation, 52 A.D. 3d 1150, 861 N.Y.S. 2d 808 (N.Y.S.C., Appellate Division, June 26, 2008). Defendant first argues that Plaintiffs Motion is defective because the Plaintiff did not timely file the Affidavit of Service. However, a delay in filing proof of service under CPLR 308 is mere

Accordingly, Epstein's objection to responding to these requests on the basis of his Fifth Amendment Right against self incrimination is upheld and Plaintiffs Motion is denied. As noted previously, the Fifth Amendment privilege against self incrimination is accorded liberal construction," Hoffman, 341 U.S. at 48

ogatories wherein she lists certain witness that may have knowledge regarding the facts and allegations alleged in her complaint. See page three of Plaintiffs Motion wherein she acknowledges that she allegedly brought two of the other Plaintiffs in related cases to Defendant's home. In particular, the response t