claimant, to determine whether the hazard of incrimination Is justified. United States v. Argomaniz, 925 F.2d 1349, 1355 (11th Clr. 1991). court must make a particularized inquiry, deciding, in connection with each specific area that the questioning party wishes to explore, whether or not the privilege Is well-founded." Id. Typically this is done in an in camera proceeding wherein the person asserting the privilege is given the opportunity "to substantiate his claims of the privilege and the district court is able to consider the questions asked and the documents requested by the summons: Id. 3. Here Epstein has made boilerplate invocation of the Fifth Amendment to each and every request propounded by L.M.. That hardly suffices to carry his burden providing that his assertion of the Fifth Amendment is appropriate. 4. As part of this particularized inquiry, Epstein should also be required to produce a privilege log of the items over which he is asserting privilege. SPECIFIC REQUESTS FOR PRODUCTION 5. For the convenience of the court , L.M.'s two specific requests for production and Epstein's objections are reprinted, followed by analysis as to why his assertion of privilege is improper. Request No. 1. The ENTIRE FILE (including all discovery) provided to you by the State Attorney's Office, and/or Palm Beach County Police Department and/or U.S. Attorney's Office and/or the Federal Bureau of Investigation relating to the Defendant. JEFFREY EPSTEIN. Response: Defendant is asserting specific legal objections including but not limited to relying on certain U.S. constitutional privileges in declining at present to respond to this request for production based on advice from my EFTA_R1_00012325 EFTA01734380