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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 26 of 43 becomes relevant. Epstein does not appear to have even bothered to first collect responsive documents before asserting a Fifth Amendment claim. For example, during his deposition, Epstein took the Fifth rather than answer a question about whether he had produced a privilege log. Epstein Depo. Tr. at 228. Under the Federal Rules of Civil Procedure, Epstein is required to produce a privilege log for the communications he is withholding. Fed. R. Civ. P. 45(e)(2)(A) provides that “[a] person withholding subpoenaed information under a claim that it is privileged . .. must describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.” Epstein should have provided this log at the time of his deposition so that he could be questioned about it. He certainly should produce a log immediately, if he hopes to sustain his claim. The “general rule” in this Court is that a “blanket refusal to produce records or to testify is simply insufficient to support a Fifth Amendment claim.” United States v, Kowalik, 809 F. Supp. 1571, 1577 (S.D. Fla. 1992), aff'd, 12 F.3d 218 (11th Cir. 1993), and aff'd, 12 F.3d 218 (11th Cir, 1993), Instead, a witness who has been subpoenaed to produce documents “must present himself with his records for questioning, and as to each question and each record elect to raise or not to raise the defense.” Jd. (discussing taxpayer’s refusal to respond to IRS summons). In addition, the Court's local rules require the production of a privilege log whenever materials are withheld on the basis of privilege. See Local 26.1(e)(2)(C) (“This rule requires preparation ofa privilege log with respect to all documents, electronically stored information, things and oral communications withheld on the basis of a claim of privilege -. . .except [attorney-client communications or work product materials created after the lawsuit].”).