EFTA00067398

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 21 of 37 
Jane Doe No. 2 v. Epstein 
Page 8 
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. 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 2004 — 
2005." Plaintiffs request seeks information for a time period of January 1, 2003 
until present regarding "all surveillance videos, etc., or image of the Palm Beach 
Residence." 
Request No. 8. All documents referring or relating to Plaintiff Jane Doe No. 2, 
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 select, authenticate, and produce 
documents relevant to this lawsuit and I must accept this advice or risk losing my 
EFTA00067418

dase 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 22 of 37 
Jane Doe No. 2 v. Epstein 
Page 9 
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. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
Request No. 9. All statements taken, transcribed or recorded from any person 
referring or relating to Defendant's 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. 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 
EFTA00067419

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 23 of 37 
Jane Doe No. 2 v. Epstein 
Page 10 
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. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
Request No. 10. 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 410 and 
408, and §90.410, 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 2004 — 2005." Plaintiff's request seeks documents for a 
EFTA00067420

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 24 of 37 
Jane Doe No. 2 v. Epstein 
Page 11 
time period of January 1, 2003 until present regarding air travel and aircraft used 
by Defendant. 
Request No. 11. 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 410 and 
408, and §90.410, 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 2004 — 
2005." Plaintiffs request has no time limitation. 
EFTA00067421

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 25 of 37 
Jane Doe No. 2 v. Epstein 
Page 12 
Request No. 12. 
All photographs, videotapes, digital images and other 
documents depicting or showing females who, at the time thereof, were under 
the age of 21, 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 410 and 
408, and §90.410, 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. Plaintiff's complaint alleges a time period of "in or about 2004 — 
2005." Plaintiffs request has no time limitation. 
EFTA00067422

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 26 of 37 
Jane Doe No. 2 v. Epstein 
Page 13 
Request No. 13. All photographs and painting of females which were displayed 
in any of Defendant's homes or residences in the time frame of these requests, 
including without limitation, photographs in standing or sifting 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 410 and 
408, and §90.410, 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 2004 — 
2005." Plaintiff's request has no time limitation. 
EFTA00067423

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 27 of 37 
Jane Doe No. 2 v. Epstein 
Page 14 
Request No. 14. 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 410 and 
408, and §90.410, 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 2004 —
2005." Plaintiffs request has no time limitation. 
EFTA00067424

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 28 of 37 
Jane Doe No. 2 v. Epstein 
Page 15 
Request No. 15. 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 410 and 
408, and §90.410, 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 2004 — 
2005." Plaintiffs request has no time limitation. 
EFTA00067425

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 29 of 37 
Jane Doe No. 2 v. Epstein 
Page 16 
Request No. 16. 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 410 and 
408, and §90.410, 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 2004 — 
2005." Plaintiffs request has no time limitation. 
EFTA00067426

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 30 of 37 
Jane Doe No. 2 v. Epstein 
Page 17 
Request No. 17. 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 410 and 
408, and §90.410, 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 2004 —
2005." Plaintiffs request has no time limitation. 
EFTA00067427

Cse 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 31 of 37 
Jane Doe No. 2 v. Epstein 
Page 18 
Request No. 18. 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.com and MySpace.com. 
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 410 and 
408, and §90.410, 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 2004 — 
2005." Plaintiffs request seeks documents and photographs for a time period of 
January 1, 2003 until present. 
EFTA00067428

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 32 of 37 
Jane Doe No. 2 v. Epstein 
Page 19 
Request No. 19. 
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 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 410 and 
408, and §90.410, 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 2004 — 
EFTA00067429

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 33 of 37 
Jane Doe No. 2 v. Epstein 
Page 20 
2005." In addition, the request seeks documents pertaining to females who are 
not non-parties, and who possess privacy rights. 
Request No. 20. Any and all documents referring or relating to gifts or loans to 
females under the age of 21, 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 410 and 
408, and §90.410, 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 2004 — 
2005." Plaintiffs request has no time limitation. 
EFTA00067430

Cse 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 34 of 37 
Jane Doe No. 2 v. Epstein 
Page 21 
Request No. 21. Any and all personal calendars or schedules of or for Jeffrey 
Epstein from January 1, 2003 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 410 and 
408, and §90.410, 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 2004 — 
2005." In addition, the request encompasses attorney-client privileged material. 
Request No. 22. All documents written by Jeffrey Epstein consisting of personal 
thoughts, feelings or descriptions of events, incidents or occurrences in 
Defendant's life, including without limitation, any diaries of Jeffrey Epstein. 
EFTA00067431

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 35 of 37 
Jane Doe No. 2 v. Epstein 
Page 22 
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 410 and 
408, and §90.410, 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 2004 - 
2005." 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. 23. All documents referring to or relating to Jeffrey Epstein's 
purchase or consumption of prescription medicine. 
EFTA00067432

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 36 of 37 
Jane Doe No. 2 v. Epstein 
Page 23 
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 410 and 
408, and §90.410, 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. Plaintiff's complaint alleges a time period of "in or about 2004 — 
2005." Defendant's 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 501 and §90.503, Fla. Stat. In addition, such 
information is protected by the provisions of the Health Insurance Portability and 
Accountability Act (HIPAA). 
EFTA00067433

Cse 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 37 of 37 
Jane Doe No. 2 v. Epstein 
Page 24 
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, 2009. 
Adam D. Horowitz, Esq. 
Jeffrey Marc Herman, Esq. 
Stuart S. Mermelstein, Es. 
Counsel for Plaintiff Jane Doe #2 
Jack Alan Goldberger 
Atterbury Goldberger & Weiss, P.A. 
Co-Counsel for Defendant Jeffrey 
Epstein 
Respectfu 
By: 
ROBERT 
Florida B. No. 
MICHAEL 
Florida Bar 
JR., ESQ. 
BURMAN, CRITTON, LUTTIER & 
COLEMAN 
(Co-counse or e en an e rey pstein) 
EFTA00067434