UNITED DISTRICT COURT SOUTHE-3.4RN DISTRICT OF FLORIDA JANE NO CASE NO 80119-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 JANE NO CASE NO 80232-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 JANE NO CASE NO 80380-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 Case Document Entered on FLSD Docket Page of CASE JANE NO CASE NO 80381-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 JANE NO CASE NO 80994-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 JANE NO CASE NO 80993-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 Case Document Entered on FLSD Docket Page of CASE CASE NO 80811-MARRA/JOHNSON C.M.A Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 JANE CAS-3.5E NO 93-CIV-MARRA/JOHNSON Plaintiff Vs JEFFREY EPST-4.5EIN et al Defendant DOE CASE NO 80469-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-4.5EIN et al Defendants-5.6.-2.8 Case Document Entered on FLSD Docket Page of CASE JANE DOE NO CASE NO 80591-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 JANE DOE NO CASE NO 80656-MARRA/JOHNSON Plaintiff vs JEFFREY EPST-5.1EIN Defendant-8.1 PLAINTIFF JANE MOTION TO COMPEL ANSWERS TO PLAINTFF?S FIRST REQUEST FOR ADMISSIONS TO D7.2E2FENDANT Plaintiff Jane Doe hereby this Court for an order compelling-4.1 def-7.4endant Jeffrey Epstein to answer her first requests for admissions or in the alternative to prove that his invocation of his Fifth Amendment privilege is proper Doe has propounded requests for adm ission to Epstein,-7.6 including such straightforward requests as 760Your net worth is gr eater than billion Case Document Entered on FLSD Docket Page of CASE 580You own or control directly or indi rectly real estate property in foreign countries 709You are moving s-5.4i1.8gnificant financ-5.4ial asse ts o-3.8v.1erseas outside of the territorial reach of the U.S and Florida Courts 595You currently have the ability to pos a bond of million to satisfy a judgment in this case without fi nancial or other difficulty response to each and every one of these questions Epstein has given the following response response Defendant asserts hi U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorne ys have counseled me that I cannot provide answers to any discov-4.9e1.3ry relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Am endments as guaranteed by the United States Constitution Drawing an adv-5.4erse inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be un reasonable and would therefore violate the Constitution 2690This Court should order Epstein to answe all of the requests for admission or in the alternative prove that hi Fifth Amendment invocations ar valid It is for the court not the claimant to determine whether the hazard of incriminatio is justifie-4.1d United-4.7 States Argom8.5a1.7niz F.2d 11th Cir A court must make a particulariz-5.3ed inquiry-5.3 deciding,-7.5 in c-5.3onnect ion with each s-4.9p-3.7ecific area that the questioning party wishes to explore whet her or not the priv ilege is well-founded Id Typically t-8h.4is done in an proceeding wherein he person asserting the privilege given the opportunity to substantiate clai ms of the privilege and the Case Document Entered on FLSD Docket Page of CASE district court is able to consider the ques tions asked and the doc-5.3uments requested by the summons Id 2570Here Epstein has made boilerplate invo cation of the Fifth Amendment to each and every question pr-7.6opounded by Jane Doe incl uding for example a request that he admit that his net worth is more than million It is not appa-4.4rent how a-4.4d.6mitting net worth is incriminating in the circumstanc es of this case In any event the Fifth Amendment does operate in th is fashion It is Epstein obligation to explain his claims on a question-by-question basis Id The only is-5.7sue before the Court is Epstein?s-4.8 Fifth Amendment privilege Ep-3.7stein has only asserted a Fifth Amen dment objection to pr-7.4oduction As a result-7.1 any other-6.9 objections to production are deemed waived See Local Rule a Any ground for an objection not stated in an objection within the time provided by Federal-8.3 Rules of Civil Procedure or any ext ensions thereof shall be waived SPE-3.2CIFIC FOR ADMISSION For the convenience of the court and in complianc-5.3e with Local Rule party filing-4.2 motion to compel sh-4.2all list spe-4.2c ific reque-4.2sts in succ-5.4ession Jane requests for admission are as follows Your net worth is greater than million.-8.1 Your net worth is greater than million.-8.1 Your net worth is greater than million Your net worth is greater than million Your net worth is greater than billion Case Document Entered on FLSD Docket Page of CASE Since being inc-5.4a.8rcerated you have dire ctly or indirectly through the services or assistance of other persons conveyed money or assets in an attempt to insulate or protect your money or assets from being captured in any civil lawsuits filed against you You own or control7,-2.4 directly or indi rectly real estate property in the Caribbean You own or control directly-5.2 or i ndirec-5.1t-2.3ly real estate property in foreign countries In the years you have transfe rred assets and/or oney and/or financial instruments to countri7.5es outside the United States You have provided financial support to the modeling agency MC2 You have committed a ssault against Plaintiff a minor You committed ba6.3ttery against Plaintiff You digitally penetrated Plaintiff when she was a minor You offered Plaintiff more money contingent upon her hav-5.7ing sex with or giving you oral You intended to harm Plaintiff hen you committed these sexual acts-5.6 against You k-4.9new Plaintiff was under he age of when you sexually touched and fondled You intend to hire investigators to intimidate and harass Plaintiff during this-5.4 litigation You were engaged in he act of traffi7.5cking minors across state or country borders for the purposes of sex or pr ostitution between and the present Case Document Entered on FLSD Docket Page of CASE You coerced Plaintiff into being a prostitute and remaining in prostitution You are guilty of the follo wing offenses against Jane Doe Procuring a minor for the purpose of prostitution as defined in F.S Battery as defined by Florida Statutes Sex5.6u1.8al Battery You are moving signific-5.5ant financial assets overseas outside of the direct territorial reach of the U.S and Florida Courts You are making asset transfers with the intent to defeat judgment that might be entered against you in this or similar cases You currently have the ability to post a bond of million to satisfy a judgment in this case without fi nancial or other difficulty CONCLUS-2.3ION all these reasons the Court should co mpel Epstein to answer the requests-5.5 for admission or provide a particularized just ification for his Fifth Amendment invocation-8.9 with regar-7.3d to each request Counsel fo Jane Doe have c-5.2o-4nferred with oppos-5.2ing counsel on the issues raised in this mo tion and no resolution was possible DATED July 2720Respectfully Submitted Bradley Edwards Bradley Edwards ROTHST-5.3EIN ROSENFELDT Las Olas City Centre East Las Olas Blvd Suite Fort Lauderdale Florida Telephone Facsimile Florida No E-mail bedwards rra-law.com Case Document Entered on FLSD Docket Page of CASE and Salt 2720Lake 2720City Telephone:-7.7 Facsimile:-7.7 cassellp law.utah.edu CERTIFICATE OF SERVICE HEREBY CERTIFY that on I electr-6.6onically filed the foregoing document with the Clerk of the Court using CM/ECF I also certify that the foregoing document is being served this day on all part ies on the attached Service List in the manner specified either via transmission of Notices of Electronic Filing generated by CM/ECF or in some ot-7her authorized manner for those parties who are not authorized receive electronically filed Notices of Electronic Filing Bradley Edwards Bradley Edwards Case Document Entered on FLSD Docket Page of CASE SERVICE LIST Jane Doe Jeffrey10.8 Epstein United States District Court Southern District of Florida Jack Alan Goldberger-7.5 Esq Jgoldberger agwpa.c-5.1o1.1m Robert Critton Esq rcritton bclcla-4.3w.com Isidro Manual Garcia isidrogarcia bells-5.2outh.net Jack Patrick Hill iph searc-5.7y-.7law.com Katherine Warthen Ezell KEzell podhurst.com Michael James Pike MPike bclclaw.com Paul Cassell cassellp Richard Ho-4.5race Willits-5.7 lawyerswillits aol.com Robert Josefsberg rjosefsberg podhurst.com Adam Horowitz ahorowitz-5.6 5sexabus-5.6eattorney.com Stuart Mermelstein-4.1 ssm sexabuseattorney.com William Berger wberger rra-law.com Case Document Entered on FLSD Docket Page of
