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FBI VOL00009

EFTA01098622

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Case 9:08-cv-80119-KAM Document 210 Entered on FLSD Docket 07/20/2009 Page 1 of 16 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
JANE DOE NO. 2, 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
JANE DOE NO. 3, 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
JANE DOE NO. 4, 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
CASE NO: 08-CV-80232-MARRA/JOHNSON 
CASE NO: 08-CV-80380-MARRA/JOHNSON 
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Case 9:08-cv-80119-KAM Document 210 Entered on FLSD Docket 07/20/2009 Page 2 of 16 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
JANE DOE NO. 5, 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
JANE DOE NO. 6. 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
JANE DOE NO. 7, 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
CASE NO: 08-CV-80381-MARRA/JOHNSON 
CASE NO: 08-CV-80994-MARRA/JOHNSON 
CASE NO: 08-CV-80993-MARRA/JOHNSON 
2 
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Case 9:08-cv-80119-KAM Document 210 Entered on FLSD Docket 07/20/2009 Page 3 of 16 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
CASE NO: 08-CV-80811-MARRA/JOHNSON 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
JANE DOE, 
CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON 
Plaintiff, 
Vs. 
JEFFREY EPSTEIN, et al. 
Defendant. 
DOE II, 
CASE NO: 09-CV-80469-MARRA/JOHNSON 
Plaintiff 
vs. 
JEFFREY EPSTEIN, et al. 
Defendants. 
3 
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Case 9:08-cv-80119-KAM Document 210 Entered on FLSD Docket 07/20/2009 Page 4 of 16 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
JANE DOE NO. 101, 
CASE NO: 09-CV-80591-MARRA/JOHNSON 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
/ 
JANE DOE NO. 102, 
CASE NO: 09-CV-80656-MARRA/JOHNSON 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
 
/ 
PLAINTIFF JANE DOE'S MOTION TO COMPEL ANSWERS TO PLAINTFF'S FIRST 
REQUEST FOR PRODUCTION 
Plaintiff Jane Doe, hereby moves this Court for an order compelling defendant, 
Jeffrey Epstein, to answer her first request for production or, in the alternative, to prove 
that his invocation of his Fifth Amendment privilege is proper. Jane Doe also requests 
production of a privilege log. 
Jane Doe has propounded 16 requests for production, including such 
straightforward requests as requests for production of: 
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Case 9:08-cv-80119-KAM Document 210 Entered on FLSD Docket 07/20/2009 Page 5 of 16 
CASE NO: 08-CV-80119-MARRAAJOHNSON 
Request No. 1: Copies of all telephone records; 
Request No. 2: Photos of the inside of your home located at 358 El Brillo Way, 
Palm Beach, Florida, that depict the room(s) where massages took place (including 
massage table). 
Request No. 10: Correspondence between Epstein and federal prosecutors; 
Request No. 12: Personal tax returns; 
Request No. 13: Photocopies of Epstein's passport; 
Request No. 14: A statement of net worth; and 
Request No. 16: Medical records. 
In response to each and every one of these requests, Epstein has given the 
following response (with only minor variations here and there): 
Defendant is asserting his U.S. constitutional privileges. I intend to 
respond to all relevant questions 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. 
This Court should order Epstein to provide all of the requested information or, in 
the alternative, prove that his Fifth Amendment invocations are valid. It is for the court, 
not the claimant, to determine whether the hazard of incrimination is justified. United 
States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). "A court must make a 
particularized inquiry, deciding, in connection with each specific area that the 
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Case 9:08-cv-80119-KAM Document 210 Entered on FLSD Docket 07/20/2009 Page 6 of 16 
CASE NO: 08-CV-80119-MARRAMONNSON 
questioning party wishes to explore, whether or not the privilege is well-founded." Id. 
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 
district court is able to consider the questions asked and the documents requested by 
the summons." Id. 
Here Epstein has made boilerplate invocation of the Fifth Amendment to each 
and every request propounded by Jane Doe, including for example the request for 
correspondence with federal prosecutors and for production of federal tax returns. This 
obviously is not a request with Fifth Amendment implications, as the information has 
already been fully disclosed to the Government. 
For all these reasons, the Court should compel Epstein to answer the requests or 
provide a particularized justification for his Fifth Amendment invocation with regard to 
each request. 
Epstein's "cut and paste" response to the request for production also blatantly 
disregards the requirements for invoking privilege under the Court's local rules. Local 
rule 26.1.G very specifically requires the preparation of a privilege log with respect to all 
documents and oral communications (among other things) that are withheld on the 
basis of privilege. Epstein has failed to prepare such a log, making it impossible for 
Jane Doe to effectively challenge his generic assertions. Indeed, with respect to a few 
requests, Epstein has stated: "Further, the request may include information subject to 
work product or an attorney-client privilege." Of course, the whole purpose of forcing a 
defendant to prepare a privilege log is to force the defendant to decide whether or not 
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CASE NO: 08-CV-80119-MARRAMONNSON 
information is privileged. An assertion that something "may" be privileged is obviously 
woefully deficient. The Local Rules do not permit this tactic, and Epstein should be (at a 
minimum) promptly required to produce a privilege log. 
For all these reasons, the Court should compel Epstein to provide a privilege log 
and to answer the interrogatories or provide a particularized justification for his Fifth 
Amendment invocation with regard to each request. 
It should be noted that (with minor exceptions) the only grounds on which Epstein 
can refuse to answer the request for production is proof of a valid Fifth Amendment 
privilege. This the only objection Epstein has asserted (with minor exceptions). As a 
result, any other objections to production are deemed waived. 
See Local Rule 
26.1G.3.(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."). 
SPECIFIC REQUESTS FOR PRODUCTION 
For the convenience of the court — and in compliance with Local Rule 26.1 H 
(party filing motion to compel shall list specific requests in succession) — Jane Doe's 
requests for production and Epstein's objections are as follows: 
Request No. 1: Copies of all telephone records in your or your attorney's possession 
from 2002 through 2005 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.) 
Defendant is asserting his U.S. constitutional privileges. I intend to 
respond to all relevant questions 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 
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Case 9:08-cv-80119-KAM Document 210 Entered on FLSD Docket 07/20/2009 Page 8 of 16 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
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. 2: 
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 
otherwise went to your home located at 358 El Brillo Way, Palm Beach, Florida, for the 
purpose of giving you a massage. 
Defendant is asserting his U.S. constitutional privileges. I intend to 
respond to all relevant questions 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. 3: Any and all documentation in your possession that contains Plaintiff's 
name or that refers to Plaintiff, directly or indirectly, (includes e-mails, letters, message 
pads, diaries, appointment books, computer print outs). 
Defendant is asserting his U.S. constitutional privileges. I intend to 
respond to all relevant questions 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. 4: 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. 
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Case 9:08-cv-80119-KAM Document 210 Entered on FLSD Docket 07/20/2009 Page 9 of 16 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
Defendant is asserting his U.S. constitutional privileges. I intend to 
respond to all relevant questions 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. 5: Photos of the inside or your home located at 358 El Brillo Way, Palm 
Beach, Florida, that depict the room(s) where the massages too place (including 
massage table). 
Defendant is asserting his U.S. constitutional privileges. I intend to 
respond to all relevant questions 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. 6: Any and all documentation of cancelled checks or evidence of payment 
to Plaintiff of any kind and for any reason whatsoever. 
Defendant is asserting his U.S. constitutional privileges. I intend to 
respond to all relevant questions 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. 
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Case 9:08-cv-80119-KAM Document 210 
Entered on FLSD Docket 07/20/2009 Page 10 of 16 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
Request No. 7: 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. 
Defendant is asserting his U.S. constitutional privileges. I intend to 
respond to all relevant questions 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 to the terms of the deferred prosecution agreement, Federal 
Rule of Evidence 410 and 408, and § 90.410, Fla. Stat.' Further, the 
request may including information subject to work product or an attorney-
client privilege. 
Request No. 8: All financial documents evidencing asset transfers from 2005 to present 
for you personally or any company or corporation owned by you. 
Defendant is asserting his U.S. constitutional privileges. I intend to 
respond to all relevant questions 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. 
Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere 
fact that information was provided to law enforcement officials as part of plea discussions, but rather for 
other purposes. These materials are also quite clearly likely to lead to the discovery of other admissible 
evidence, as they relate to the same subject matter as this lawsuit. To the extent that Epstein relies on 
the non-prosecution agreement, nothing in that agreement bars discovery of information relevant to this 
lawsuit. 
10 
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Case 9:08-cv-80119-KAM Document 210 
Entered on FLSD Docket 07/20/2009 Page 11 of 16 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
Request No. 9: 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. 
Defendant is asserting his U.S. constitutional privileges. I intend to 
respond to all relevant questions 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 410 and 408, and § 90.410, Fla. Stat. 2 
Further, 
the request may include information subject to work product or an 
attorney-client privilege. 
Request No. 10: 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 States Attorney's office or any agents thereof). 
Defendant is asserting his U.S. constitutional privileges. I intend to 
respond to all relevant questions 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, 
2 Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere 
fact of plea discussions, but rather for other purposes. These materials are also likely to lead to the 
discovery of other admissible evidence. 
To the extent that Epstein relies on the non-prosecution 
agreement. nothing in that agreement bars discovery of information relevant to this lawsuit. 
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Case 9:08-cv-80119-KAM Document 210 
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CASE NO: 08-CV-80119-MARRAMONNSON 
Fed. Rule of Evidence 410 and 408, and § 90.410, Fla. Stat. 3 
Further, 
the request may include information subject to work product or an 
attorney-client privilege. 
Request No. 11: Any and all documents reflecting your current net worth. 
Defendant is asserting his U.S. constitutional privileges. I intend to 
respond to all relevant questions 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. 12: Personal tax returns for all years from 2002 through the present. 
Defendant is asserting his U.S. constitutional privileges. I intend to 
respond to all relevant questions 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. 13: A photocopy of your passport, including any supplemental pages 
reflecting travel to locations outside the 50 United States between 2002 and 2008, 
including any documents or records regarding plane tickets, hotel receipts, or 
transportation arrangements. 
3 Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere 
fact of correspondence in connection with plea discussions, but rather for other purposes. These 
materials are also likely to lead to the discovery of other admissible evidence. To the extent that Epstein 
relies on the non-prosecution agreement, nothing in that agreement bars discovery of information relevant 
to this lawsuit. 
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CASE NO: 08-CV-80119-MARRAMONNSON 
Defendant is asserting his U.S. constitutional privileges. I intend to 
respond to all relevant questions 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.4
Request No. 14: A sworn statement of your net worth (including a detailed financial 
statement depicting all current assets and liabilities). 
Defendant is asserting his U.S. constitutional privileges. I intend to respond to all 
relevant questions 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. 15: All financial statements or affidavits produced by you for any reason, 
to any person, company, entity or corporation since 2005. 
Defendant is asserting his U.S. constitutional privileges. I intend to 
respond to all relevant questions 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 
4 Jane Doe believes that Epstein used overseas travel as a means of obtaining underage girls for sexual 
purposes and for avoiding criminal prosecution for such activities. Also. providing a copy of a passport is 
hardly 'burdensome." Also, given the fact that Epstein is likely to have used the services of a travel agent 
or another intermediary, it should not be difficult for him to provide evidence of his overseas travels from 
such intermediaries. 
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CASE NO: 08-CV-80119-MARRAMONNSON 
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. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander. 
Defendant is asserting his U.S. constitutional privileges. I intend to 
respond to all relevant questions 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. 
CONCLUSION 
For all these reasons, the Court should compel Epstein to answer the request for 
production, or provide a particularized justification for his Fifth Amendment invocation 
with regard to each request. Epstein should also be required to provide a privilege log. 
Counsel for Jane Doe have conferred with opposing counsel on the issues raised in this 
motion, and no resolution was possible. 
DATED July 20, 2009 
Respectfully Submitted, 
s/ Bradley J. Edwards 
Bradley J. Edwards 
ROTHSTEIN ROSENFELDT ADLER 
Las Olas City Centre 
401 East Las Olas Blvd., Suite 1650 
Fort Lauderdale, Florida 33301 
Telephone (954) 522-3456 
Facsimile (954) 527-8663 
Florida il
r N 
E-mail: 
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CASE NO: 08-CV-80119-MARRA/JOHNSON 
and 
Paul G. Cassell 
Pro Hac Vice 
332 S. 1400 E. 
Salt Lake City, UT 84112 
Telephone: 801-585-5202 
Facsimile: 
801-585-6833 
E-Mail: 
cassellp@law.utah.edu 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on July 20, 2009, I electronically 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 parties on the attached Service List in the 
manner specified, either via transmission of Notices of Electronic Filing generated by 
CM/ECF or in some other authorized manner for those parties who are not authorized to 
receive electronically filed Notices of Electronic Filing. 
s/ Bradley J. Edwards 
Bradley J. Edwards 
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CASE NO: 08-CV-80119-MARRA/JOHNSON 
SERVICE LIST 
Jane Doe v. Jeffrey Epstein 
United States District Court, Southern District of Florida 
Jack Alan Goldber er Esq. 
Robert D. Critton, Esq. 
Isidro Manual Garcia 
isidroqarcia(abellsouth.net 
Jack Patrick Hill 
Katherine Warthen Ezell 
Michael James Pike 
Paul G. Cassell 
Richard Horace Willits 
Robert C. Josefsbera 
A 
m D. H r wiz 
Stuart S. Mermelstein 
William J. Ber er 
16 
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