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Case 9:08-cv-80119-KAM Document 477-1 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO: 08-CV-80893-MARRA/JOHNSON 
JANE DOE, 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
PLAINTIFF'S FIRST REQUEST FOR PRODUCTION TO DEFENDANT 
COMES NOW the Plaintiff, JANE DOE, by and through her undersigned counsel, 
pursuant to Fed.R.Civ.P. 34 and S.D. Fla. 26.10., and requests the Defendant, Jeffrey Epstein, to 
produce the original or best copy of the items listed hereinbelow, at the offices of the Plaintiffs 
undersigned counsel, for inspection and/or copying within thirty (30) days of service. 
PRELIMINARY STATEMENT 
I. 
These requests for production are deemed continuing. Pursuant to Rule 26(e) of 
the Federal Rules of Civil Procedure and applicable law, if any information sought by said 
requests for production is not learned until after they are answered, or if any answers for any 
reason should later become incorrect, there shall be a continuing duty on the party answering 
said requests to supplement or change answers previously submitted. 
DEFINITIONS AND INSTRUCTIONS 
1. 
Communication. The term "communication" means the transmittal of information (in 
the form of facts, ideas, inquiries or otherwise). 
2. 
Document. The term "document" is defined to be synonymous in meaning and equal in 
scope to the usage of this term in Federal Rule of Civil Procedure 34(a), including, without 
limitation, electronic or computerized data compilations. A draft or non-identical copy is a 
separate document within the meaning of this term. 
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3. 
Identify (with respect to person). When referring to a person, "to identify" means to 
give, to the extent known, the person's 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. 
4. 
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, (iii) 
date of the document; and (iv) author(s), addressee(s) and recipient(s). 
5. 
Parties. The terms "plaintiff' and "defendant" as, well as a party's 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. 
6. 
Person. The term "person" is defined as any natural person or any business, legal or 
governmental entity or association. 
7. 
Concerning. 
The term "concerning" means relating to, referring to, describing, 
evidencing or constituting. 
8. 
All/Each. The terms "all" and "each" shall be construed as all and each. 
9. 
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. 
10. 
Number. The use of the singular form of any word includes the plural and vice versa. 
11. 
Refer/Relate to. "Refer" or "relate to" means to make a statement about, discuss, 
describe, reflect, constitute, identify, deal with, consist 
establish, comprise, list, evidence, 
substantiate or in any way pertain, in whole to in part, to the subject. 
12. 
As used herein the singular shall include the plural, the plural shall ;Delude the singular, 
and the masculine, feminine and neuter shall include each of the other genders. 
DOCUMENTS REQUESTED 
1. 
Copies of all telephone records in your or your attorneys' possession from 2002 —
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). 
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2. 
All massage appointment books, diaries, computer calendars or scheduling 
entries, 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. 
3. 
Any and all documentation in your possession that contains Plaintiff's name or 
that refers to Plaintiff, directly or indirectly, (includes emails, letters, message pads, diaries, 
appointment books, computer print outs). 
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. 
5. 
Photos of the inside of your home located at 358 El Brillo Way, Palm Beach, 
Florida, that depict the room(s) where the massages took place (including massage table). 
6. 
Any and all documentation of cancelled checks or evidence of payment to 
Plaintiff of any kind and for any reason whatsoever. 
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. 
8. 
All financial documents evidencing asset transfers from 2005 to the present for 
you personally or any company or corporation owned by you. 
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. 
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10. 
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 
Attorney's office or any agents thereof). 
11. 
Any and all documents reflecting your current net worth. 
12. 
Personal tax returns for all years from 2002 through the present. 
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. 
14. 
A sworn statement of your net worth (including a detailed financial statement 
depicting all current assets and liabilities). 
15. 
All financial statements or affidavits produced by you for any reason, to any 
person, company, entity or corporation since 2005. 
16. 
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 Th day of March, 2009. 
Robert D. Critton, Jr., Esquire 
Michael J. Pike, Esquire 
urman. Critton, Luther & Coleman, LLP 
aim Beach, Florida 33401 
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Jack Alan Goldberger, Esquire 
Atterbury, Goldberger & Weiss, P.A. 
West Palm Beach, Florida 33401 
Michael R. Tein, Esquire 
Lewis Tein P.L. 
Coconut Grove, Florida 33133 
Respectfully Submitted, 
THE LAW OFFICE OF BRAD EDWARDS & 
ASSOCIATES, LLC 
By: 
Brad Edwards, Esquire 
Attorney for Plaintiff 
Florida Bar No. 542075 
IME
MS
Hollywood, Florida 33020 
Telephone: 
Facsimile: 
E-Mail: 
Paul G. Cassell 
Attorney for Plaintiff 
Pro Hac Vice 
Salt Lake City UT 84112 
Telephone: 
Facsimile: 
E-Mail: 
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6 PI d 
JANE DOE, 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CIV- 80893 - MARRA/JOHNSON 
Plaintiff, 
v. 
JEFFREY EPSTEIN, 
Defendant. 
DEFENDANT'S RESPONSE & OBJECTIONS TO PLAINTIFF'S 
FIRST REQUEST FOR PRODUCTION (dated 03/23/09) 
Defendant, JEFFREY EPSTEIN, ('EPSTEIN"), by and through his undersigned 
attorneys, pursuant to Fed.R.Civ.P., 34, and S.D. Fla. 26.1.G., serves his response to 
Plaintiff JANE DOE's First Request For Production, dated March 23, 2009. 
Request No. 1: 
Copies of all telephone records in your or your attorneys' 
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.) 
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. 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 
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otherwise went to your home located at 358 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. 3: 
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. 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. 
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. 
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Request No. 5: 
Photos of the inside of your home located at 358 El Brillo Way, 
Palm Beach, Florida, that depict the room(s) 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. 6: 
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 attomeys 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. 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. 
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 
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pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence 
410 and 408, and §90.410, Fla. Stat. Further, the request may include information 
subject to work product or an attorney-client privilege. 
Request No. 8: 
All financial documents evidencing asset transfers from 2005 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. 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. 
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 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 State Attorney's office or any agents thereof). 
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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 may include information 
subject to work product or an attorney-client privilege. 
Request No. 11: 
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. 12: 
Personal tax returns for all years from 2002 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. 13: 
A photocopy of your passport, including any supplemental pages 
reflecting travel to locations outside the 50 United States between 2020 and 2008, 
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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. 14: 
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. 15: 
All financial statements or affidavits produced by you for any 
reason, to any person, company, entity or corporation since 2005. 
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. 
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Request No. 16: 
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 the f regoing has been sent via U.S. 
Mail and facsimile to the following addressees this 
day of May, 2009. 
Brad Edwards, Esq. 
h tein Rosenfeldt Adler 
Fort Lauderdale. FL 33301 
Phone: 
Fax: 
Counsel for Plaintiff 
Paul G. Cassell, Esq. 
Pro Hac Vice 
t
.
Salt Lake Cit , UT 84112 
Fax 
Co-counsel for Plaintif 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger & Weiss, P.A. 
st Palm Beach, FL 33401-5012 
 
 Fax 
Co- ounse or e en ant Jeffrey Epstein 
Respectfully subm 
RITTON, JR., ESQ. 
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Jane Doe v. Epstein, et al. 
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Florida Bar No. 
BURMAN, CRITTON, LUTTIER & COLEMAN 
ach, FL 33401 
Phone 
Fax 
(Counsel for Defendant Jeffrey Epstein) 
EFTA00726482