expenditure by you or on your behalf which expenditure is alleged as an element of damages RESPONSE Objection this request seeks documents and information protected by the attorney/client privilege and work product privilege as well as documents that are irrelevant and/or duplicative of other requests As to subsections a and Epstein objects as the information is confidential and protected by attorney/client privilege and also asserts his Fifth Amendment privilege However Epstein will be producing invoices in redacted form which contain substantially the same information requested in subsections a and In addition subsection is unduly burdensome as it would require Epstein to cull through thousands of documents to determine which if any documents are responsive Epstein also asserts his U.S constitutional privileges under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would u:1constitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution Epstein asserts his Fifth Amendment privilege against self-incrimination See Delisi Bankers Ins Company So.2d Fla th DCA Malloy Hogan S.Ct the Fifth Amendments Self-Incrimination Clause applies to the states through the Due Process Clause of the Fourteenth Amendment it would be incongruous to have different standards determine the validity of a claim of privilege based on the same feared prosecution depending on whether the claim was asserted in state or federal court Without waiving the foregoing objections Epstein will produce responsive documents in redacted form pursuant to the Agreed Order entered on May The undersigned will produce additional documents the week of May Any and all prescriptions for correctives lenses issued to you within the past five years RESPONSE Documents responsive to this request have already been produced to Edwards Certificate of Service I HEREBY CERTIFY that a true co of the foregoing was sent by fax and U.S Vlail to the following addressees on this l.Ct ay of Farmer Jr Esq Farer Jaffe Weissing Edwards Fistos Lehrman PL Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Andrews Avenue Suite Fort _auderdale FL fax Attorneys for Defendant Jack Scarola Esq Suite West Palm Beach FL Fax Co-Counsel for Defendant Jeffrey Epstein Law Offices of Marc Nurik Searcy Denney Scarola Barnhart Ship:ey P.A Counsel to Scott Rothstein One East Broward Boulevard Suite Fort Lauderdale FL Palm Beach Lakes Blvd Wes Palm Beach FL Attorneys for Defendant Edwards BURMAN CRITTON LUTTIER COLEMAN LLP Banyan Bo vard Suite West Palm ch FL 4:Fax 1J I By ir obe Critton Jr Florida Bar Michael Pike Florida Bar Counsel for Defendant Jeffrey Epstein
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