Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CV-80119-MARRA-JOHNSON JANE DOE NO Plaintiff JEFFREY EPSTEIN Defendant DEFENDANT JEFFREY EPSTEINS RESPONSE OBJECTIONS TO PLAINTIFFS AMENDED FIRST REQUEST FOR PRODUCTION Defendant JEFFREY EPSTEIN by and through his undersigned counsel serves his responses and objections to Plaintiffs Amended First Request For Production To Defendant dated December Request No The list provided to you by the U.S Attorney of individuals whom the U.S Attorney was prepared to name in an Indictment as victims of an offense by Mr Epstein enumerated in U.S.C Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference A Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Request No All documents referring or relating to the United States agreement with Defendant to defer federal prosecution subject to certain conditions including without limitation the operative agreement between Defendant and the United States and all amendments revisions and supplements thereto Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Request No All documents referring or relating to Defendants agreement with the State of Florida on his plea of guilty to violations of Florida Criminal Statutes including without limitation the operative plea agreement and any amendments revisions and supplements thereto Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page4 information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Whatever public documents exist are in the State Court file and equally accessible to Plaintiff Request No.4 All documents obtained in discovery or investigation relating to either the Florida Criminal Case or the Federal Criminal Case including without limitation documents obtained from any federal state or local law enforcement agency the State Attorneys office and the United States Attorneys office Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Request No seeks documents that are attorney-client and work product privileged in that it seeks all documents obtained in discovery or investigation relating either to the Florida Criminal Case or the Federal Criminal Case In addition such documents are privileged and confidential as they are the subject of a pending investigation Request No All telephone records and other documents reflecting telephone calls made by or to Defendant including without limitation telephone logs and message pads Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Defendant objects as the request is overbroad and seeks information that is neither relevant to the subject matter of the pending action nor does it appear reasonably calculated to lead to the discovery of admissible evidence Plaintiffs complaint alleges a time period of in or about Plaintiffs request seeks information for a time period of January until present regarding any and all telephone records and other documents reflecting any and all telephone calls made to or by Defendant As phrased the request includes attorney-client and work product privileged information as well as records and documents of calls having absolutely no relationship to any of the allegations in this action Request No All telephone records and other documents reflecting telephone calls made by or to Defendant including without limitation telephone logs and message pads reflecting telephone calls made by or to employees Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page7 documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition as defined by Plaintiff in paragraph of her request the term employee is overly broad and encompasses information that is neither relevant to the subject matter of the pending action nor does it appear reasonably calculated to lead to the discovery of admissible evidence Further the request seeks information pertaining to person who are not parties to this action and whose privacy rights are implicated Request No All surveillance videos slides film videotape digital recording or other audio or video depiction or image of the Palm Beach Residence Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page8 Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Plaintiffs complaint alleges a time period of in or about Plaintiffs request seeks information for a time period of January until present regarding all surveillance videos etc or image of the Palm Beach Residence Request No All documents referring or relating to Plaintiff Jane Doe No including without limitation web pages social networking site pages correspondence videotapes and audiotapes Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot sel,ect authenticate and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page9 Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential Request No All statements taken transcribed or recorded from any person referring or relating to Defendants sexual conduct massages given to Defendant or any issue in these cases Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential Request No All documents referring to or relating to air travel and aircraft used by Defendant including without limitation flight logs and flight manifests Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential Plaintiffs complaint alleges a time period of in or about Plaintiffs request seeks documents for a Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page time period of January until present regarding air travel and aircraft used by Defendant Request No Any and all documents referring to or relating to modeling agencies including but not limited to documents relating to or reflecting communications with female models Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Plaintiffs complaint alleges a time period of in or about Plaintiffs request has no time limitation Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page Request No All photographs videotapes digital images and other documents depicting or showing females who at the time thereof were under the age of which were taken or created by or for Defendant and not intended for sale commercially to the public Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Plaintiffs complaint alleges a time period of in or about Plaintiffs request has no time limitation Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page Request No All photographs and painting of females which were displayed in any of Defendants homes or residences in the time frame of these requests including without limitation photographs in standing or sitting frames or wall frames Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Plaintiffs complaint alleges a time period of in or about Plaintiffs request has no time limitation Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page Request No Any and all documents consisting of referring or relating to communications between Jeffrey Epstein and Haley Robson including but not limited to letters notes text messages messages on social networking sites and e-mails Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Plaintiffs complaint alleges a time period of in or about Plaintiffs request has no time limitation Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page Request No Any and all documents consisting of referring or relating to communications between Jeffrey Epstein and Sarah Kellen including but not limited to letters notes text messages messages on social networking sites and e-mails Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Plaintiffs complaint alleges a time period of in or about Plaintiffs request has no time limitation Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page Request No Any and all documents consisting of referring or relating to communications between Jeffrey Epstein and Nada Marcinkova including but not limited to letters notes text messages messages on social networking sites and e-mails Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Plaintiffs complaint alleges a time period of in or about Plaintiffs request has no time limitation Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page Request No Any and all documents consisting of referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell including but not limited to letters notes text messages messages on social networking sites and e-mails Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Plaintiffs complaint alleges a time period of in or about Plaintiffs request has no time limitation Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page Request No Any and all documents and photographs placed by Defendant at any time in the period of these requests on a social networking website including without limitation Facebook.corn and MySpace.corn Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Plaintiffs complaint alleges a time period of in or about Plaintiffs request seeks documents and photographs for a time period of January until present Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page Request No Any and all documents reflecting or consisting of communications between Jeffrey Epstein and MC2 Models or Jean-Luc Brunel relating or referring to females coming into the United States from other countries to pursue a career in modeling including but not limited to letters notes and mails Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Plaintiffs complaint alleges a time period of in or about Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page In addition the request seeks documents pertaining to females who are not non-parties and who possess privacy rights Request No Any and all documents referring or relating to gifts or loans to females under the age of including but not limited to notes receipts and car rental agreements Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Plaintiffs complaint alleges a time period of in or about Plaintiffs request has no time limitation Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page Request No Any and all personal calendars or schedules of or for Jeffrey Epstein from January to the present Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Plaintiffs complaint alleges a time period of in or about In addition the request encompasses attorney-client privileged material Request No All documents written by Jeffrey Epstein consisting of personal thoughts feelings or descriptions of events incidents or occurrences in Defendants life including without limitation any diaries of Jeffrey Epstein Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Plaintiffs complaint alleges a time period of in or about On its fact the request goes beyond the scope of allowable discovery and is meant to harass embarrass and overburden the Defendant Further the request is so overly broad that it includes attorney-client and work product privileged materials Request No All documents referring to or relating to Jeffrey Epsteins purchase or consumption of prescription medicine Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page Response Defendant is asserting specific legal objections to the production request as well as his U.S constitutional privileges I intend to produce all relevant documents regarding this lawsuit however my attorneys have counseled me that at the present time I cannot select authenticate and produce documents 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 Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the information sought is privileged and confidential and inadmissible pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request is overly broad work product attorney-client privileged and confidential In addition the request seeks information concerning persons not parties to this litigation whose privacy rights are implicated Plaintiffs complaint alleges a time period of in or about Defendants medical condition is not at issue in this action Such a request is meant to harass and embarrass Defendant Further such information is privileged pursuant to Fed Rule and Fla Stat In addition such information is protected by the provisions of the Health Insurance Portability and Accountability Act HIPAA Case Document Entered on FLSD Docket Page of Jane Doe No Epstei Page Certificate of Service WE HEREBY CERTIFY that a true copy of the foregoing has been sent via U.S Mail and facsimile to the following addressees this 26th day of January Adam Horowitz Esq Jeffrey Marc Herman Esq Stuart Mermelstein Esq Biscayne Boulevard Suite Miami FL Fax ahorowitz hermanlaw.com jherman hermanlaw.com lrivera hermanlaw.com Counsel for Plaintiff Jane Doe Jack Alan Goldberger Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Fax jagesq bellsouth.net Co-Counsel for Defendant Jeffrey Epstein By ROBERT CRITTON JR ESQ Florida No rcrit bclclaw.com MICHAEL PIKE ESQ Florida Bar moike bclclaw.com BURMAN CRITTON LUTTIER COLEMAN Flagler Drive Suite West Palm Beach FL Fax Co-counsel for Defendant Jeffrey Epstein
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