Case Document Entered on FLSD Docket Page of Identify with respect to person When referring to a person to identify means to give to the extent known the persons full name present or last known address and when referring to a natural person additionally the present or last known place of employment Once a person has been identified in accordance with this subparagraph only the name of the person need be listed in response to subsequent discovery requesting the identification of that person Identify with respect to documents When referring to documents to identify means to give to the extent known the i type of documents ii general subject matter i date of the document and iv author addressee and recipient Parties The terms plaintiff and defendant as well as a partys full or abbreviated name or a pronoun referring to a party means the party and where applicable its officers directors employees partners corporate parent subsidiaries or affiliates This definition is not intended to impose a discovery obligation on any person who is not a party to the litigation Person The term person is defined as any natural person or any business legal or governmental entity or association Concerning The term concerning means relating to referring to describing evidencing or constituting All/Each The terms all and each shall be construed as all and each And/Or The connectives and and or shall be construed either disjunctively or conjunctively as necessary to bring within the scope of the discovery request all responses that might otherwise be construed to be outside of its scope Number The use of the singular form of any word includes the plural and vice versa Refer/Relate to Refer or relate to means to make a statement about discuss describe reflect constitute identify deal with consist of establish comprise list evidence substantiate or in any way pertain in whole to in part to the subject As used herein the singular shall include the plural the plural shall include the singular and the masculine feminine and neuter shall include each of the other genders DOCUMENTS REQUESTED Copies of all telephone records in your or your attorneys possession from that in any way relate to you including all phone Jines owned by you or that were used to contact girls for the purposes of scheduling massages for you Case Document Entered on FLSD Docket Page of All massage appointment books diaries computer calendars or scheduling entries scheduling books or any other wdting or correspondence that contains the names of any of the girls that were called contacted scheduled or who otherwise went to your home located at El Brillo Way Palm Beach Florida for the purpose of giving you a massage Any and all documentation in your possession that contains Plaintiffs name or that refers to Plaintiff directly or indirectly includes emails letters message pads diaries appointment books computer print outs Any and all photos videos downloaded digital prints or any other visual depiction of Plaintiff or of any other known or suspected minor females introduced to you directly or indirectly by Plaintiff Photos of the inside of your home located at El Brillo Way Palm Beach Florida that depict the room where the massages took place including massage table Any and all documentation of cancelled checks or evidence of payment to Plaintiff of any kind and for any reason whatsoever All discovery information obtained by you or your attorneys as a result of the exchange of discovery in the State criminal case against you or the Federal investigation against you All financial documents evidencing asset transfers from to the present for you personally or any company or corporation owned by you Any documents or other evidentiary materials provided to local state or federal law enforcement investigators or local state or federal prosecutors investigating your sexual activities with minors Case Document Entered on FLSD Docket Page of All correspondence between you or your attorneys and state or federal law enforcement or prosecutors includes but is not limited to letters to and from the State Attorneys office or any agents thereof Any and all documents reflecting your current net worth Personal tax returns for all years from through the present A photocopy of your passport including any supplemental pages reflecting travel to locations outside the United States between and including any documents or records regarding plane tickets hotel receipts or transportation arrangements A sworn statement of your net worth including a detailed financial statement depicting all current assets and liabilities All financial statements or affidavits produced by you for any reason to any person company entity or corporation since All medical records of Defendant Epstein from Dr Stephan Alexander CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided via United States mail to the following addressees this 2.3day of March Robert Critton Jr Esquire Michael Pike Esquire Burman Critton Luttier Coleman LLP North Flagler Drive Suite West Palm Beach Florida rcrit bclclaw.com mpike bclclaw.com Case Document Entered on FLSD Docket Page of Jack Alan Goldberger Esquire Atterbury Goldberger Weiss P.A Australian A venue South Suite West Palm Beach Florida jagesq bellsouth.net Michael Tein Esquire Lewis Tein P.L Grand Avenue Suite Coconut Grove Florida tein lewistein.com By Respectfully Submitted THE LAW OFFICE OF BRAD EDWARDS ASSOCIATES LLC Brad Edwards Esquire Attorney for Plaintiff Florida Bar No Harrison Street Suite Hollywood Florida Telephone Facsimile E-Mail be bradedwardslaw.com Paul Cassell Attorney for Plaintiff Pro Hae Vice Salt Lake City UT Telephone Facsimile E-Mail cassellp law.utah.edu Case Document Entered on FLSD Docket Page of JANE DOE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV MARRA/JOHNSON Plaintiff JEFFREY EPSTEIN Defendant DEFENDANTS RESPONSE OBJECTIONS TO PLAINTIFFS FIRST REQUEST FOR PRODUCTION dated Defendant JEFFREY EPSTEIN EPSTEIN by and through his undersigned attorneys pursuant to Fed.R.Civ.P and S.D Fla serves his response to Plaintiff JANE DOEs First Request For Production dated March Request No Copies of all telephone records in your or your attorneys possession from through that in any way relate to you including all phone lines owned by you or that were used to contact girls for the purposes of scheduling massages for you Response Defendant asserts 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 Request No All massage appointment books diaries computer calendars or scheduling entities scheduling books or any other writing or correspondence that contains the names of any of the girls that were called contacted scheduled or who Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page otherwise went to your home located at El Brillo Way Palm Beach Florida for the purpose of giving you a massage Response Defendant asserts 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 Request No Any and all documentation in your possession that contains Plaintiffs name or that refers to Plaintiff directly or indirectly includes e-mails letters message pads diaries appointment books computer print outs Response Defendant asserts 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 Request No Any and all photos videos downloaded digital prints or any other visual depiction of Plaintiff or of any other known or suspected minor females introduced to you directly or indirectly by Plaintiff Response Defendant asserts 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 Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page Request No Photos of the inside of your home located at El Brillo Way Palm Beach Florida that depict the room where the massages took place including massage table Response Defendant asserts 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 Request No Any and all documentation of cancelled checks or evidence of payment to Plaintiff of any kind and for any reason whatsoever Response Defendant asserts 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 Request No All discovery information obtained by you or your attorneys as a result of the exchange of discovery in the State criminal case against you or the Federal investigation against you 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 Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page4 pursuant to the terms of the deferred prosecution agreement Fed Rule of Evidence and and Fla Stat Further the request may include information subject to work product or an attorney-client privilege Request No All financial documents evidencing asset transfers from to the present for you personally or any company or corporation owned by you 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 Request No Any documents or other evidentiary materials provided to local state or federal law enforcement investigators or local state or federal prosecutors investigating your sexual activities with minors 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 may include information subject to work product or an attorney-client privilege Request No All correspondence between you and your attorneys and state or federal law enforcement or prosecutors includes but not limited to letters to and from the State Attorneys office or any agents thereof Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al 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 may include information subject to work product or an attorney-client privilege Request No Any and all documents reflecting your current net worth Response Defendant asserts 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 Request No Personal tax returns for all years from through the present Response Defendant asserts 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 overly broad Request No A photocopy of your passport including any supplemental pages reflecting travel to locations outside the United States between and Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page including any documents or records regarding plane tickets hotel receipts or transportation arrangements Response Defendant asserts 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 protections and privileges the scope of information is so overbroad that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence compiling such information over a six year period would be unduly burdensome and time consuming Request No A sworn statement of your net worth including a detailed financial statement depicting all current assets and liabilities Response Defendant asserts 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 Request No All financial statements or affidavits produced by you for any reason to any person company entity or corporation since Response Defendant asserts 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 overly broad Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page Request No All medical records of Defendant Epstein from Dr Stephan Alexander 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 Certificate of Service WE HEREBY CERTIFY that a true copy of regoing has been sent via U.S Mail and facsimile to the following addressees this clay of May Brad Edwards Esq Rothstein Rosenfeldt Adler East Las Olas Boulevard Suite Fort Lauderdale FL Fax bedwards rra-law.com Counsel for Plaintiff Paul Cassell Esq Pro Hae Vice South Room Salt Lake City UT Fax cassellp law.utah.edu Co-counsel for Plaintiff Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Fax jagesg bellsouth.net Co-Counsel for Defendant Jeffrey Epstein Respectfully By ROBERT RITTON JR ESQ Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page Florida Bar No rcrit bclclaw.com BURMAN CRITTON LUTTIER COLEMAN Flagler Drive Suite West Palm Beach FL Phone Fax Counsel for Defendant Jeffrey Epstein
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