ivilege are tested by refusing to answer specific questions. Davis , 636 F.2d at 1039. See also Nguyen I Excel Corp. , 197 F.3d 200 (5th Cir. 1999); Clarke I American Commerce Nat. Bank , 974 F.2d 127 (9th Cir. 1992); United States I White , 950 F.2d 426, 430 (7th Cir. 1991). In his motion, Epstein has pr