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 NO 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 NO 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 NO 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 CO MPEL ANSWERS TO PLAINTFF?S FIRST Plaintiff Jane Doe hereby this Court for an order compelling-4.1 def-7.4endant Jeffrey Epstein to answer her first set of in terrogatories or in the alternative to prove that his invocation of his Fi fth Amendment privilege is proper 2425Jane Doe has propounded interrogatories including such straightforward requests as Interrogat4.3o2.1ry12.5 No Describe financial assets that are under your control directly or indirectly including interests in corporations or other busi7.4ness entities Case Document Entered on FLSD Docket Page of CASE NO Interrogat3.7o1.5ry11.9 No Describe-4.6 which fina-4.6ncial asse ts listed in your answer to interrogatory are located out side the states of the Un ited States and where are located Interrogat3.9o1.7ry12.1 No Describe your net worth including inc-5.9o.3me and expenses for and Interrogat3.9o1.7ry12.1 No Describe any real property in which you have a total or partial interest either directly or indirectly-5.2 Interrogat3.9o1.7ry12.1 No Describe any transfer of asse ts under your control either direc-5.2t-2.4ly or indirectly to locations outside the United Stat es in and Interrogat3.7o1.5ry11.9 No Describe with specificity our travel to locations outside the states of the United states in and including your dates-5.3 of travel location to which you tr-7.1aveled and persons that accompanied in each travel Interrogat4o1.8ry12.2 No Have you heard or do you kn ow about any statement or remark verbal or written ade by or on behalf of any party to this lawsuit,-7.4 other than yourself concerning any issue in this laws-5.6ui If so state the name and address of each person who heard or read it and the date time place and subs tance of statement or remark6.2 Interrogat4o1.8ry12.2 No Do you intend to elicit te stimony of witnesses other than Plaintiff regarding statements she has ever made If so what statements do you Case Document Entered on FLSD Docket Page of CASE NO intend to produce through testimony Thr ough whic-5.9h witness do you int-8.1end to elicit such statement And for what purpose do you intend to admit such statement Interrogat4o1.8ry12.2 No State the facts upon whic-5.2h you rely for each affirmativ-5.2e-4 defense in your answer respons-4.9e to these interrogatories Epst-7.4ein has giv-5.2en the following response with only slight variations on the overbreadth objection Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 In addition to and without waiving his cons-5.3titutional privileges Defendant objects as the interrogatory is so overbroad thus seeks information that is neither relevant to the ubject ma7.2tte7.3r of the7.3 pending ac-5.6tion nor does it appear reas onably calculated to lead to the discovery of admissible evidence.-7.6 2720This Court should order Epstein to answe all of these interr ogatories or in the alternative prove that his Fi fth Amendment invocations-5.1 are va lid It is for the court not the claimant to determine hether the hazard of incrim ination is justified United States Argom8.6aniz F.2d 11th Cir A court must make a particulariz-5.6ed inquiry decid ing in connection with eac specific area that the questioning party wishes to explore whether or not the privile ge is well-founded 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 Case Document Entered on FLSD Docket Page of CASE NO district court is able to consider the questions-5.6 asked and the documents requested by the summons Id 2720Here Epstein has made boilerplate invocation of the Fifth Amendment to each and every question pr-7.5opounded by Jane Doe including-4.4 for example the question Do you intend to elicit testimony of wit nesses other than Plaintiff regarding any statements she has ever ade This obviously is not an interrogatory with Fifth Amendment implications Nor is Epstein?s claim that th interrogatory is somehow overbroad or not cal7.1c-.1ulated to lead to the discovery of admissible evidence even facially plausible 2720Epstein?s cut and paste response to the interrogatories also blatantly disregards the requirements for invoking privile ge under the Court?7.3s local rules Local rule very specifically requires the pr eparation of a privilege log with respect to all documents and oral communications among ot her things that are withheld on the basis of privilege Epstein has failed to pr epare such a log maki ng it impossible for Jane Doe to effectively challenge his generic-5.3 assertions The Local Rules do not permit this tactic and Epstein should be at a minimum promptly required to produce a privile-4.5ge all these reasons the Court should compel Epstein to answer-7.2 the interrogatories or pr-7.1ovide a particulariz ed justification for his Fifth Amendment invocation with regard to each request It should be noted that the only two ground on which Epstein can refuse to answer the interrogatories are either proof of a valid Fifth Amendment privilege or proof Case Document Entered on FLSD Docket Page of CASE NO of a valid overbreadth objec tion These are the only two objections Epstein asserted As a result any other 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 the Federal Rules of Civil Procedure or any extensions thereof shall be waived SPE-3.9CIFIC INTERRO-8.1GATORIES For the convenienc-5.5e of the court and in compliance with Local Rule party filing-4.3 motion to compel sha-4.3ll list pecific requests in succession Jane Doe?s interrogatories are as follows 1565What is the full nam-7.6e and F-4.8l1.6orida address of the person answering th-3.8ese interrogatories and if applicable the person-4.4s official position or relationship with the party to whom the in terrogatories are directed 2720Note This is the only interrogat ory Epstein answered in any way 1535Describe financial as-5.1sets that are under-7.1 your cont-7.2rol directly or indirectly including interests in corporati or other business entities Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 In addition to and without waiving his cons-5.3titutional privileges Defendant objects as the interrogatory is so overbroad thus seeks information that is neither relevant to the ubject matter of the pending ac-5.6tion nor does it appear reas onably calculated to lead to the discovery of admissible evidence.-7.6 Case Document Entered on FLSD Docket Page of CASE NO 1278.8Describe which financial assets listed in answer to in terrogatory that are located outside the states of the Unit ed States and where hey are located Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-7egarding this lawsuit howev-5er my attorneys have co-3.9unseled me that I cannot provide to any questions relevant to this and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 In addition to and without waiving his cons-5.3titutional privileges Defendant objects as the interrogatory is so overbroad thus seeks information that is neither relevant to the ubject ma7.2tte7.3r of the7.2 pending ac-5.6tion nor does it appear reas onably calculated to lead to the discovery of admissible evidence.-7.6 1785Describe y-5our net worth including inc-5.2o1me and expenses for and Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 In addition to and without waiving his cons-5.3titutional privileges Defendant objects as the interrogatory is so overbroad thus seeks information that is neither relevant to the ubject matter of the pending ac-5.6tion nor does it appear reas onably calculated to lead to the discovery of admissible evidence.-7.6 1870Describe any real property in which you hav-5.3e a total or partial ownership interest either directly or indirectly Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled Case Document Entered on FLSD Docket Page of CASE NO me that I cannot provide to any questions relevant to this and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 In addition to and without waiving his cons-5.3titutional privileges Defendant objects as the interrogatory is so overbroad thus seeks information that is neither relevant to the ubject ma7.3tte7.3r of the7.2 pending ac-5.6tion nor does it appear reas onably calculated to lead to the discovery of admissible evidence.-7.6 1608.4Describe which real proper ties listed in your answer to interrogatory are located outside the United States and where the properti es are located Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 In addition to and without waiving his cons-5.3titutional privileges Defendant objects as the interrogatory is so overbroad thus seeks information that is neither relevant to the ubject matter of the pending ac-5.6tion nor does it appear reas onably calculated to lead to the discovery of admissible evidence.-7.6 1610Describe any transfer of assets under your control either directly-4.8 or indirectly to locations outside the United Stat es in and Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this lawsuit-7 and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my Case Document Entered on FLSD Docket Page of CASE NO constitutional rights would be un reasonable and would therefore violate the Constitution In addition to and without waiving his cons-5.3titutional privileges Defendant objects as the interrogatory is so overbroad thus seeks information that is neither relevant to the ubject matter of the pending ac-5.6tion nor does it appear reas onably calculated to lead to the discovery of admissible evidence.-7.6 Describe 1695with 1700spec-5.3ificity your travel to locations out-7.4side the states of the United States in and including your dates of travel location to which you traveled and persons that accompanied you in each such travel Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by United States Constitu tion Drawing an adver se 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 In addition to and without waiving his cons-5.3titutional privileges Defendant objects as the interrogatory is so overbroad thus seeks information that is neither relevant to the ubject matter of the pending ac-5.6tion nor does it appear reas onably calculated to lead to the discovery of admissible evidence.-7.6 1855List each t-7.7e.7lephone number used by you or your assis-5.5t-2.7ants to call minor directly or indirectly for the purpose of sc-4.8heduling a massage to take place your house located at El Brillo Way West Palm Beach includes landlines cell phones and private jet or airplane lines For each cell phone list-7.9 the provider Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my Case Document Entered on FLSD Docket Page of CASE NO constitutional rights would be un reasonable and would therefore violate the Constitution 615List the last known name address and telephone numbers of all persons that may have any knowledge about any of the allegations in the Complaint including but not limited to friends ac quaintanc-4.9es employees or others to whom you have spok-5.4en about the subject matter which forms the basis this Complaint or who have observed such activity Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this lawsuit-7 and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 In addition to and without waiving his cons-5.3titutional privileges Defendant objects as the interrogatory is so overbroad thus seeks information that is neither relevant to the ubject matter of the pending ac-5.6tion nor does it appear reas onably calculated to lead to the discovery of admissible evidence The scope of the information is so overbroad that it also includes informati on that is attorney-client and work product privileged you heard or do you know about any statement or remark verbal or written made by or on beha lf of any party-4.7 to this lawsuit other than yourself concerning any issue in this laws-5.6uit If so state the name and address of each person wo made the s-5.1t-2.3atement or remark the name and address of each person who heard or read it and the dat-7.4e time place and substance of each statement or remark6.2 Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-7egarding this lawsuit how ever my attorneys have counseled6.5 me that I cannot provide to any questions relevant to this and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by United States Constitu tion Drawing an adver se inference under these circumstances would unconstit-7.2u1.2tionally burden my exercise of my constitutional rights would be un reasonable and would therefore violate Case Document Entered on FLSD Docket Page of CASE NO the Constitution In addition to and without waiving his cons-5.3titutional privileges Defendant objects as the interrogatory is so overbroad thus seeks information that is neither relevant to the ubject matter of the pending ac-5.6tion nor does it appear reas onably calculated to lead to the discovery of admissible evidence The scope of the information is so overbroad that it also includes informati on that is attorney-client and work product privileged you intend to elic-5it testimony of witness-5.1e1.1s other than Plaintiff regarding any statements she has ever ade If so what-7.1 statements do intend to produce through testimony Through which wit ness do you intend to elic-5.6it statement And for what purpose do ou intend to admit such statement Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this lawsuit-7 and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by United States Constitu tion Drawing an adver se 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 In addition to and without waiving his cons-5.3titutional privileges Defendant objects as the interrogatory is so overbroad thus seeks information that is neither relevant to the ubject matter of the pending ac-5.6tion nor does it appear reas onably calculated to lead to the discovery of admissible ev-5.4idence Additiona-3.7lly work-product and attorney-client you transferring or do you plan to or might you transfer money or assets of the country during the ourse of this litigation Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this lawsuit-7 and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 In addition to and without waiving his cons-5.3titutional privileges Defendant objects as the interrogatory is so overbroad Case Document Entered on FLSD Docket Page of CASE NO thus seeks information that is neither relevant to the ubject matter of the pending ac-5.6tion nor does it appear reas onably calculated to lead to the discovery of admissible evidence.-7.6 775Describe each property owned you inc-5.1l2.1uding location approximate value and whether there is a mo rtgage on the property and he amount of any such mortgage Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 In addition to and without waiving his cons-5.3titutional privileges Defendant objects as the interrogatory is so overbroad thus seeks information that is neither relevant to the ubject matter of the pending ac-5.6tion nor does it appear reas onably calculated to lead to the discovery of admissible evidence.-7.6 775Describe with specific-5.2it the amount of money available to you in cash or that can be readily-5.5 liquidated as such Include the bank financial ins-5.2t-2.4itution holding company or other location of this money and the name of the account Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 In addition to and without waiving his cons-5.3titutional privileges Defendant objects as the interrogatory is so overbroad thus seeks information that is neither relevant to the ubject matter of the pending ac-5.6tion nor does it appear reas onably calculated to lead to the discovery of admissible evidence.-7.6 Case Document Entered on FLSD Docket Page of CASE NO 1025State with as much specific-5.1ity as pos when you met the Plaintiff-7.6,-2.6 and including in your answer the following a the circumstances and location of how and where you met describe the nature of your relationship describe how many occasions was with at your residence loca ted at El Brillo in Palm Beach Florida Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 830Provide the names addresses and phone numbers of a ll your current accountants financial planners or money anagers ha-4.5ndling or assisting in the handling of your money or assets Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this lawsuit-7 and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 In addition to and without waiving his cons-5.3titutional privileges Defendant objects as the interrogatory is so overbroad thus seeks information that is neither relevant to the ubject matter of the pending ac-5.6tion nor does it appear reas onably calculated to lead to the discovery of admissible evidence.-7.6 you ev-5.2er ask the Plaintiff to i7n1tr oduce you to minor females and/or to bring minor females to your house in Palm Be ach Florida and if so when did this occur and what was asked by you to do and what did yo tell her about the reason for her to bring these other minor girl7.2s Case Document Entered on FLSD Docket Page of CASE NO Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 you ever engage in activity of any ki nd whatsoever with the Plaintiff and inc-5.6l1.6uding in your answer wh at type of sexual activ-5.4i-3.2ty took place where it took place and the dates or general timefr ame w7.1hen this activity occurred Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by United States Constitu tion Drawing an adver se 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 1205Were there parameters or in structions by you to the Pl aintiff as to the types girls to bring to your Palm Beach,-7.7 Flor ida house including age range what they would be asked to do body type or socio-economic bac-5.4kground Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this lawsuit-7 and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 Case Document Entered on FLSD Docket Page of CASE NO 1235Describe any words or actions that you made to assure the Plaintiff that sexual activity with you was proper or appropriate Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-5.1sert my federal const-7.3i2.1tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 1328.4Describe what age yo thought the Plainti ff was when you first had sexual ac-5tivity with her including your reasons for that belief Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this lawsuit-7 and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 1330State the facts upon which you rely for each affirmative defense in your answer Defendant is asserting specific legal objections to the interrogatories well as his U.S constitutional privilege I i7.1n1.1tend to respond to all relevant questions r-6.9egarding this lawsuit howev-4.9er my attorneys have counseled me that I cannot provide to any questions relevant to this and I must-7.5 accept this advic-5.3e risk losing my Sixth Amendment right to effective representation Accordingly I as-4.8sert my federal const-7.6i1.8tutional rights under the Fifth Sixth and Fourteenth Amendment as guaranteed by United States Constitu tion Drawing an adver se 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 In addition to and without waiving his cons-5.3titutional privileges Defendant objects as the interrogatory is so overbroad Case Document Entered on FLSD Docket Page of CASE NO thus seeks information that is neither relevant to the ubject matter of the pending ac-5.6tion nor does it appear reas onably calculated to lead to the discovery of admissible evidence No answer been filed so not applicable CONCLUS-2.7ION all these reasons the Court should compel Epstein to answer-7.2 the interrogatories or pr-7.1ovide a particulariz ed justification for his Fifth Amendment invocation with regard to each request Epst ein should also be r-7.5e.7quired to produce a privilege log Couns-5el for Jane Doe hav conferred with oppos ing c-4.9ounsel on the issues rais-5.5ed in this motion and no resolution was pos-5.5sible DATED July Respectfully 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 and Salt 2720Lake 2720City Telephone:-7.7 Facsimile:-7.7 cassellp law.utah.edu Case Document Entered on FLSD Docket Page of CASE NO 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 NO 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
