The document is a reply memorandum filed by the plaintiff's counsel in support of a motion to compel defendant Jeffrey Epstein to answer interrogatories and produce documents. The plaintiff argues against Epstein's blanket assertion of the Fifth Amendment privilege and other objections to discovery requests. The memorandum addresses various legal arguments, including the insufficiency of Epstein's privilege claims, the potential for adverse inferences in civil cases, and the relevance of health care information. The plaintiff requests an order compelling Epstein to comply with discovery requests.
documents/EFTA00221721.pdf
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