UNITED DISTRICT COURT SOUTHE-3.4RN DISTRICT OF FLORIDA JANE CAS-3.5E NO 93-CIV-MARRA/JOHNSON Plaintiff Vs JEFFREY EPST-4.5EIN et al Defendant Related Cases PLAINTIFF-5.2 JANE REPL-5.2Y TO DE FENDANT?S RESPONSE DE TO MOTION TO COMPE6.9L.7 ANSWERS TO PLAINTFF?S FIRST REQUE-3.6S1.4T FOR ADMISSIONS Plaintiff Jane Doe hereby files her repl to defendant Jeffrey Epstein?s response DE in consolidated case no to her motion to compel answers to her first request for admissions Epstein sh ould be compelled to provide the requested information because it is not properly subj ect to a Fifth Amendment invocation explained in Jane Doe?s opening submission Doe will stand on her opening s-5.1ubmission but br iefly replies to Epst-7.5ein?s response with regard to one subjec Epstein?s current net worth Requests Nos and Your net worth is greater than million.-8.1 Your net worth is greater than million.-8.1 Case Document Entered on FLSD Docket Page of CASE NO Your net worth is greater than million Your net worth is greater than million Your net worth is greater than billion You c-5u1.2rrently have he ability to post a bond of million to satis-5f-2.2y a judgment in this case without fi nancial or other difficulty Respon-5.4se In response Defendant asserts hi U.S constitutional privileges-5.3 specified herein I intend to respond to all relevant-7.5 discov-5.3e.9ry regarding this-5.3 lawsuit however my attorneys have couns eled me that I cannot provide answers to any dis-5.2c-.2overy relevant to this lawsuit and I must accept this-5.2 advice risk waiv-5.4ing Fifth Amendment rights as guaranteed by the Untied States Constitution and my Sixth Amendment right to effective representation.-7.4 Accordingly I assert my federal consti tutional rights under the Fifth Sixth and Fourteenth Amendments as guar anteed by the United States Constitution Drawing an adverse inference und er these circumstances would unconstitutionally burden my exercise my constitutional rights would be unreasonable and would therefore violate the Constitution to Epstein?s Respon-4.7se Epstein argues that disclosing information about current financial status is somehow incrim inating The reasons for thi7.2s0 claim are obscure because Epstein relies on sealed subm issions DE and DE that Jane Doe not had the opportunity-5.2 to review Of course because these doc-4.9u1.3ments are sealed Jane Doe has no of determining one way or ot-7.2her whether Epstein?s-5 assertions are true Jane Doe therefor respectfully asks t-7he Court to make its determination of the is-5.5sue mindf ul of the fact that it is proceeding without the benefit an adversarial presentat ion from Jane Doe the Court concludes-5.1 that the materi als in DE and DE do demons-5.9trate that Epstein would incriminat himself by discussing his current net worth then the Court should consider-7.7 the information in de ciding whether to grant Jane Doe?s motion for Preliminary Injunction Restraining Fra udulent Transfer of Assets DE for Case Document Entered on FLSD Docket Page of CASE NO reasons that Jane Doe explains in her conc-5.3urrently-filed Notice that Additional of Epstein?s Fraudulent Asset-7.2 Transfers Will Be Filed shortly and Motion Consideration by the Court of Materials in DE and DE in Deter-7.7m-2.7ining Motion for Appointment of a Receiv-5.3er In any event it appears far-fetched that answering Jane Doe?s requests for admissions-5.3 about net worth woul be incrim-7.4inating The abov-5.4e-lis-5.4ted questions ask a current snapshot of Epstein?s current net wealth They do not ask for how Epstein-3.7 obtained that net wealth what sorts of asse transfers underlie that net wealth or other questions that could even conceivably provide a bas-5.7is for criminal prosecution-3.5.-6.8 For example if Epstein admits that he has a net worth of more than billion that does not provide a link to any crime It is not a in the United States to have immense wealth Similarly if Epstein were to admit that he could easily post a million bond secure any judgment i7n1 this case that admi ssion would not be relevant to any possible criminal prosecution 2210Accordingly Epstein should be com pelled to answer these requests for admission about his c-5.5u.7rrent net wo rth as well as all of the other requests Jane Doe propounded CONCLUS-2.3ION all these reasons the Court should co mpel Epstein to answer the requests-5.5 for admission Jane Doe has propounded DATED October Case Document Entered on FLSD Docket Page of CASE NO 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 E-Mail 110cassellp law.utah.edu CERTIFICATE OF SERVICE HEREBY CERTIF-4.3Y t-7.3hat on October I e-3.6l2.5ectronically filed the foreg-3.6o1.5ing 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-6.9her authorized manner fo 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
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