EFTA00723218

Case 9:08-cv-80119-KAM Document 293 Entered on FLSD Docket 09/10/2009 Page 1 of 8 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-CIV-80119-MARRA/JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
Related cases: 
08-80232, 08-80380, 08-80381, 08-80994, 
08-80993, 08-80811, 08-80893, 09-80469, 
09-80591, 09-80656, 09-80802, 09-81092 
OMNIBUS ORDER 
THIS CAUSE is before the Court on Defendant's Motion for Reconsideration and/or 
Request for Rule 4 Review and Appeal of Portions of the Magistrate's Order (D.E. #282) 
and Defendant's Supplementary Brief pursuant to Magistrate's Order Requesting a More 
Particularized Showing Re: Fifth Amendment (D.E. #283). 
In this case, which has been consolidated for purposes of discovery, Plaintiffs are 
former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey 
Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have 
1 
DEFENDANT'S 
EXHIBIT 
C 
EFTA00723258

Case 9:08-cv-80119-KAM Document 293 Entered on FLSD Docket 09/10/2009 Page 2 of 8 
taken place over the course of several years in or around 2004-2005, when the girls in 
question were approximately 16 years of age. As part of this scheme, Epstein, with the 
help of his assistant, 
allegedly lured economically disadvantaged minor girls 
to his homes in Palm beach, New York and St. Thomas, with the promise of money in 
exchange for a massage. Epstein purportedly transformed the massage into a sexual 
assault. 
The three-count Complaint alleges sexual assault and battery (Count I), 
intentional infliction of emotional distress (Count II), and, coercion and enticement to sexual 
activity in violation of 18 U.S.C. §2422 (Count III). 
In 2008, Epstein entered into a Non-Prosecution Agreement with the United States 
Attorney General's Office for the Federal Southem District of Florida and the State 
Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution 
Agreement, any criminal prosecution against Epstein is deferred as long as he abides by 
the certain terms and conditions contained therein. If at any time the United States 
Attorney's Office has reason to believe Epstein is in breach of the Agreement, it need only 
provide Epstein's counsel with notice of the breach and then move forward with Epstein's 
prosecution. Accordingly, the undersigned would agree with Epstein's statement at page 
4 of its Response, that the fact there exists a Non-Prosecution Agreement does not mean 
that Epstein is free from future criminal prosecution, and that in fact, "the threat of 
prosecution is real, substantial, and present.' Id. 
On August 4, 2009, the undersigned entered an Order on Plaintiff's Motion to 
Compel as to certain requests to which Defendant Epstein was asserting a Fifth 
Amendment privilege. By the two motions referred to above Epstein is seeking 
reconsideration of a portion of the Order as it relates to Interrogatory numbers 7 and 11 
2 
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Case 9:08-cv-80119-KAM Document 293 Entered on FLSD Docket 09/10/2009 Page 3 of 8 
(D.E. #282) and pursuant to the Court's directive has submitted a more particularized 
showing as to why Epstein's Fifth Amendment privilege as to Request for Production 
Numbers 10, 11, 19 and 21 should be sustained (D.E. #283). 
The Fifth Amendment serves as a guarantee against testimonial compulsion and 
provides, in relevant part, that "frilo person...shall be compelled in any Criminal Case to be 
a witness against himself." Id. In practice, the Fifth Amendment's privilege against self-
incrimination "permits a person not to answer official questions put to him in any other 
proceeding, civil or criminal, formal or informal, where the answers might incriminate him 
in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985)(citing 
Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded "liberal construction 
in favor of the right it was intended to secure," Hoffman v. United States, 341 U.S. 479, 
486 (1951), and extends not only to answers that would in themselves support a criminal 
conviction, but extends also to those answers which would fumish a link in the chain of 
evidence needed to prosecute the claimant for a crime. Id.; Blau v. United States, 340 
U.S. 159 (1950). Thus, information is protected by the privilege not only if it would support 
a criminal conviction, but also in those instances where "the responses would merely 
'provide a lead or clue' to evidence having a tendency to incriminate." United States v. Neff, 
615 F.2d 1235, 1239 (9th Cir.), cert. denied, 447 U.S. 925 (1980). 
The Fifth Amendment's privilege against self-incrimination comes into play only in 
those instances where the witness has "reasonable cause to apprehend danger from a 
direct answer." Hoffman, 341 U.S. at 486 (citing Mason v. United States, 244 U.S. 362, 365 
(1917)). "The claimant must be 'confronted by substantial and 'real,' and not merely trifling 
or imaginary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 
3 
EFTA00723260

Case 9:08-cv-80119-KAM Document 293 Entered on FLSD Docket 09/10/2009 Page 4 of 8 
(1980). 
When applied to documentary production, the law is well established that the Fifth 
Amendment privilege may not apply to specific documents "even though they contain 
incriminating assertions of fact or belief, because the creation of those documents was not 
'compelled' within the meaning of the privilege." United States v. Hubbell, 530 U.S. 27, 35-
36 (2000). However, in certain instances, "'the act of production' itself may implicitly 
communicate 'statements of fact.'" Id. For this reason the Fifth Amendment privilege also 
encompasses the circumstance where the act of producing documents in response to a 
subpoena or production request has a compelled testimonial aspect Id. Thus, in those 
instances where the existence and/or location of the requested documents are unknown, 
or where production would "implicitly authenticate" the requested documents, the act of 
producing responsive documents is considered testimonial and is protected by the Fifth 
Amendment. In re Grand Jury Subpoena, 1 F.3d 87, 93 (2d Cir. 1993); see also Fisher v. 
United States, 425 U.S. 391, 410 (1976)(issue expressed as whether compliance with a 
document request or subpoena "tacitly conceded" the item's authenticity, existence or 
possession by the defendant). 
MOTION FOR RECONSIDERATION AND/OR APPEAL (D.E. #282) 
Interrogatory Number 7 requests all time periods during which Epstein was present 
in the State of Florida, including for each the date he arrived and the date he departed. 
Interrogatory Number 11 requests all telephone numbers used by Epstein, including 
cellular phones and land lines in any of his residences, by stating the complete phone 
number and name of the provider. In the August 4, 2009 Order the undersigned rejected 
Epstein's assertion of the Fifth Amendment privilege as applied to these requests finding 
4 
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Case 9:08-cv-80119-KAM Document 293 Entered on FLSD Docket 09/10/2009 Page 5 of 8 
the objection 'so general and sweeping in nature" that they aamount[ed] to a blanket 
assertion of the privilege: Id. p.11. 
In the instant Motion for Reconsideration, Epstein has set forth additional facts and 
detailed reasoning successfully demonstrating how forcing him to answer these requests 
would realistically and necessarily furnish a link in the chain of evidence needed to prove 
a crime against him and would require him to provide self-incriminating evidence relative 
to this case and to the other related cases that could result in a specific hazard of self-
incrimination. In light of the additional information provided, the Court is now persuaded 
that Epstein's whereabouts and telephone numbers are crucial Issues in this case and 
other related cases and that if he is forced to reveal this information, these testimonial 
disclosures could subsequently be used to incriminate him and/or prosecute him for a 
criminal offense. See Hoffman v. United States, 341 U.S. 479, 486 (1951); United States 
v. Hubbell, 530 U.S. 27, 36 (2000). 
As such, the Court hereby vacates that portion of the August 4, 2009 Order which 
grants Plaintiff's Motion to Compel as it relates to Interrogatory Numbers 7 and 11 and 
instead denies Plaintiff's Motion in this limited respect. Accordingly, Epstein's assertion of 
his Fifth Amendment privilege as it relates to Interrogatory Numbers 7 and 11 is sustained 
and he need not provide answers to these questions. 
MORE PARTICULARIZED SHOWING (D.E. #283) 
In the August 4, 2009 Order Epstein was ordered to provide a more particularized 
showing with respect to Production Requests 10, 11, 19 and 21, so as to demonstrate why 
his Fifth Amendment privilege as applied to these requests should be sustained. Epstein 
has sustained his burden in this regard by his showing that the contested requests for 
5 
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Case 9:08-cv-80119-KAM Document 293 Entered on FLSD Docket 09/10/2009 Page 6 of 8 
production seeking detailed information relating to Epstein's air travel, aircraft used and 
flight manifests, all communications with female models, MC2 models or Jean Luc Brunel 
relating or referring to females coming into the United States from other countries and his 
personal calendars and schedules, could reveal the availability to him and/or use by him 
of interstate facilities and thus would constitute a link in the chain of evidence that could 
potentially expose him to the dangers of self-incrimination. 
In this and the other civil actions, Plaintiffs allege that Epstein violated certain 
federal and state criminal statutes in an attempt to make claims against Epstein ranging 
from sexual battery to intentional infliction of emotional distress. The lynchpin for the 
exercise of federal criminal jurisdiction under 18 U.S.C. §2422(b), which figures in some 
of the Complaints filed, is "the use of any facility or means of interstate or foreign 
commerce" and the analogous essential element of 18 U.S.C. §2423((b), which also 
figures in some of the Complaints, is "travel[s] in interstate commerce or travels into the 
United States or 
travels in foreign commerce." Accordingly, requiring Epstein to provide 
responses to the subject production requests would in essence be compelling him to 
provide assertions of fact, thereby admitting that such documents existed and further 
admitting that the documents in his possession or control were authentic. In re Grand Jury 
Subpoena, 1 F.3d 87, 93 (2d Cir. 1993)(noting that in those instances where the existence 
and/or location of the requested documents are unknown, or where production would 
"implicitly authenticate' the requested documents, the act of producing responsive 
documents is considered testimonial and is protected by the Fifth Amendment). 
In summary, the Court finds that the danger Epstein faces by being forced to 
respond and produce documents relative to Production Requests 10, 11, 19 and 21 is 
6 
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Case 9:08-cv-80119-KAM Document 293 Entered on FLSD Docket 09/10/2009 Page 7 of 8 
substantial and real and therefore the assertion of his Fifth Amendment privilege relative 
to these requests Is sustained and Plaintiff's Motion to Compel as it relates to these 
requests is denied. 
In accordance with the above and foregoing, it is hereby 
ORDERED AND ADJUDGED as follows: 
(1) 
Defendant's Motion for Reconsideration and/or Request for Rule 4 Review 
and Appeal of Portions of the Magistrate's Order (D.E. #282) is GRANTED. The 
undesigned has reconsidered the August 4, 2009 relative to Interrogatory Numbers 7 and 
11 and finds Epstein's assertion of his Fifth Amendment privilege as to these requests 
valid. Accordingly, that portion of the August 4, 2009 Order which grants Plaintiffs Motion 
to Compel as it relates to Interrogatory Numbers 7 and 11 is hereby VACATED. Instead, 
Plaintiff's Motion to Compel as it relates to Interrogatory Numbers 7 and 11 is denied. 
Accordingly, Epstein's assertion of his Fifth Amendment privilege as it relates to these 
interrogatories is sustained and he need not provide answers to these questions; and 
(2) 
Defendant's Supplementary Brief pursuant to Magistrate's Order Requesting 
a More Particularized Showing Re: Fifth Amendment (D.E. #283) is GRANTED. Because 
the Court finds the danger Epstein faces by being forced to respond and produce 
documents relative to Production Requests 10, 11, 19 and 21 is substantial and real, his 
assertion of his Fifth Amendment privilege relative to these requests is sustained and 
Plaintiffs Motion to Compel as it relates to these requests is denied. 
DONE AND ORDERED this September 9, 2009, in Chambers, at West Palm Beach, 
7 
EFTA00723264

Case 9:08-cv-80119-KAM Document 293 Entered on FLSD Docket 09/10/2009 Page 8 of 8 
Florida. 
"Inacen.--,
LINNEA R. JO MESON 
UNITED STATES MAGISTRATE JUDGE 
CC: 
The Honorable Kenneth A. Marra 
All Counsel of Record 
8 
EFTA00723265

IN THE CIRCUIT COURT OF THE 
15TH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY 
FLORIDA 
CASE NO: 
S02008CA037319XXXXMB AB 
Plaintiffs, 
vs. 
JEFFREY EPSTEIN, 
Defendants. 
AMENDED COMPLAINT 
Plaintiff, JANE DOE 
brings this Complaint against Defendants, JEFFREY 
EPSTEIN, and states as follows: 
Parties, Jurisdiction and Venue 
1. 
brings this Complaint under a fictitious name to protect her identity, because the 
Complaint makes sensitive allegations of sexual assault and abuse that she suffered while a 
minor. 
2. 
II. is a citizen and resident of the State of Florida. She is currently over the age of 
18 and otherwise :tit furls. 
3. 
Defendant, Jeffrey Epstein, is currently incarcerated in Palm Beach County, is a 
citizen and resident of Palm Beach County, Florida, has MI intent to stay in Palm Beach County 
after his incarceration and is otherwise suijuris. 
4. 
Defendant, 
Mil is a citizen and resident of the State of New York and 
otherwise sui juris. 
EFTA00723266

5. 
This is an action for damages in excess of Fifteen Thousand Dollars (815,000), 
exclusive of interest and costs. 
6. 
Venue is proper in this Court under section 47.011, Florida Statutes, because the 
causes of action brought herein accrued in Palm Beach County, Florida, and one or more 
Defendants reside in Palm Beach County, Florida. 
Factual Allegations 
7. 
At all relevant times, Defendant, Jeffrey Epstein, was an adult male. Mr. Epstein is a 
financier and money manager with a secret clientele limited exclusively to billionaires. He is a 
man of tremendous wealth, power and influence. Before confinement, he maintained homes in 
New York, New Mexico, St. Thomas, U.S. Virgin Islands, and Palm Beach, Florida. The 
allegations herein concern Mr. Epstein's conduct while at his lavish estate in Palm Beach. 
8. 
Upon information and belief, Mr. Epstein has a sexual preference and obsession for 
minor girls. He engaged in a plan, scheme, and/or enterprise wherein he gained access to 
primarily economically disadvantaged minor girls in his Palm Beach home and sexually 
assaulted the girls, or coerced or attempted to coerce the girls to engage in prostitution, and then 
gave them money. 
9. 
In or about 2005, It 
then 15 years old, fell victim to Mr. Epstein's trap described 
above, at Mr. Epstein's Palm Beach estate. 
10. 
Upon information and belief, Mr. Epstein carried out this scheme/enterprise and 
assaulted girls in Florida, New York and on his private island, known as Little St. James, in St. 
Thomas, U.S. Virgin Islands. 
11. 
Integral conspirators in Mr. Epstein's Florida scheme/enterprise were Defendant; 
MIMI 
an assistant of Mr. Epstein from New York City, New York; an
 a 
Page 2 of 7 
EFTA00723267

and other Jane Does. Ms. 
NM Ms 
and other Jane Does recruited girls ostensibly to give a wealthy man a 
platonic massage for monetary compensation in his Palm Beach mansion. Under Mr. Epstein's 
plan/enterprise, Ms. rwas 
contacted shortly before or soon after Mr. Epstein was at his 
Palm Beach residence. Mr. Epstein, or Ms. i 
or someone on their behalf, directed Ms. 
NMand others to bring one or more underage girls to Mr. Epstein's residence. Upon 
information and belief, economically-disadvantaged, underage girls from Loxahatchee and 
surrounding areas were specifically targeted because they were easier to entice by the money 
being offered (generally $200 to $300 per "massage" session) and these girls were perceived as 
less likely to complain to authorities or have credibility if allegations of improper conduct were 
made. This was pivitol to Mr. Epstein's plan/enterprise. 
12. 
Mr. Epstein's plan, scheme, and/or enterprise had a particular pattern and method. 
Upon arrival at Mr. Epstein's mansion, the underage girls would be introduced to Ms. ME 
who in turn gathered the victim's personal information, including her name and telephone 
number. The girls would then be brought up a flight of stairs to a bedroom that contained, 
among other furnishings, a massage table. Photographs of nude women lined the stairway hall 
and bedroom. Ms. 
would then leave the girl alone in this room, whereupon Mr. Epstein 
would enter wearing only a toweL Mr. Epstein would then remove his towel, lay down naked on 
the massage table, and direct the girl to remove her clothes. He then would perform one or more 
lewd, lascivious and sexual acts, including masturbation, touching the girl's vagina with a 
vibrator, or digitally penetrating the girl's vagina, and coerce or attempt to coerce the girl to 
engage in lewd acts and/or prostitution. 
Page 3 of 7 
EFTA00723268

Facts Specific tea. 
13. 
Consistent with the foregoing plan, scheme, and/or enterprise..., then 15 years of 
age, was recruited to give Mr. Epstein a massage for monetary compensation. Int. was brought 
by taxi with another girl 15 years of age to Mr. Epstein's mansion in Palm Beach. S. and the 
other girl were brought into the kitchen of the home and led up the flight of stairs to a large 
bathroom containing a massage table. Upon arriving in the bathroom, a young woman, on 
information and belief, Ms...4 
exited a sauna wearing only a towel, placed a tube of lotion 
on the counter and stated, "I guess you will need this more than I will." 
14. 
Several minutes later, Mr. Epstein came into the bathroom and shut the door behind 
him, told both girls to remove their clothes and undressed himself. Mr. Epstein then placed a 
small washcloth over his genitals and asked both girls to rub lotion on his naked body. At some 
point Mrs  stein told the
 15 year old girl to leave the room, leaving.. alone with Mr.
11stein. Mr. Epstein then began to masturbate while.. was massaging him. 
15. 
At this point, Mr. Epstein specifically asked s. 
her age, to which.. honestly 
advised she was 15 years old. 
16. 
Mr. Epstein took his free hand and began to touch 
between her legs and in her 
genitals while simultaneously masturbating himself. s.
 told Mr. Epstein to stop, but he 
continued to rub.. between her legs in her genital area. Mr. Epstein then ejactulated and told
s
. she could get dressed. 
17. 
s.
 was then allowed to get dressed, leave the room and go back down the stairs and 
into the kitchen. Mr. Epstein gave the other 15 year old girl money and told s.
 that this girl 
"had her money" and then left. 5.  was given $200 by the other 15 year old girl. 
Page 4 of 7 
EFTA00723269

18. 
As a result of this encounter with Mr. Epstein, the 15 year old.. 
experienced 
confusion, shame, humiliation and embarrassment, and the assault sent her life into a downward 
spiral. 
COUNT I 
Sexual Battery against Defendant Epstein 
19. 
Plaintiff.. repeats and realleges paragraphs 1 through 18 above. 
20. 
This is a count for sexual battery against Defendant, Mr. Epstein. 
21. 
Mr. Epstein sexually battered.. at a time when she was 15 years old. 
22. 
During this incident Epstein exploited his natural authority and trust as an adult with a 
minor. 
23. 
Plaintiff..., because of her age at the time of this incident, did not have the legal 
ability to consent to the sexual acts as described above. 
24. 
Mr. Epstein's actions amounted to a harmful, unapproved and intentional touching of 
25. 
Epstein inflicted harmful or offensive contact on 
with the intent to cause such 
contact, alternatively,.. had the apprehension that such contact was imminent. 
26. 
Plaintiff is in need of therapy and counseling, so that she can deal with the shame 
associated with this incident. 
27. 
As a direct and proximate result of Mr. Epstein's assault on.., she has suffered and 
will continue to suffer severe and permanent traumatic injuries, including mental, psychological 
and emotional damages. 
WHEREFORE, Plaintiff,.., demands judgment against Defendant, Jeffrey Epstein, for 
compensatory damages, costs, and such other and further relief as this Court deems just and 
proper. 
Page 5 of 7 
EFTA00723270

COUNT II 
Intentional and/or Reckless Infliction of Emotional Distress against 
Defendants Epstein 
28. 
Plaintiff 
repeats and realleges paragraphs 1 through 18 above. 
29. 
This is a count for intentional infliction of emotional distress against Defendant, Mr. 
Epstein. 
30. 
The conduct of Defendant Mr. Epstein in subjecting 
to Mr. Epstein's actions as 
described above was intentional or reckless. 
31. 
The conduct of Defendant, Mr. Epstein in subjecting 
to Mr. Epstein's conduct 
• described above was outrageous, going beyond all bounds of decency. 
32. 
The conduct of Defendant Mr. Epstein, in subjecting 
to Mr. Epstein's conduct 
described above, caused ■ 
severe emotional distress. Defendant knew or had reason to how 
that their intentional and outrageous conduct would cause emotional trauma and damage to 5 
33. 
As a direct and proximate result of Defendant's intentional and/or reckless conduct, 
suffered and will continue to suffer severe mental anguish and pain. 
WHEREFORE, Plaintiff 5 
demands judgment against Defendant, Jeffrey Epstein, for 
compensatory damages, costs, attorney's fees, and such other and further relief as this Court 
deems just and proper. Further, Plaintiff reserves the right to amend this Complaint to add a 
claim for punitive damages pursuant to Florida Law. 
JURY TRIAL DEMAND 
Plaintiff demands a jury trial in this action. 
Page 6 of 7 
EFTA00723271

CER111.1CATE OF SERVICE 
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by U. S. 
Mail, postage prepaid, this 
day of April, 2009 to Jack A. Goldberger, Esq./Bruce E. Reinhart, 
Esq., 250 Australian Ave, Ste 1400, WPB, FL 334101; Robert D. Critton, Jr., Michael J. Pike, 515 
North Flagler Drive, Suite 400, West Palm Beach, FL 33401. 
LEOPOLD-KUV1N, PA. 
2925 PGA Boulevard 
Suite 200 
ens, FL 33410 
BY: 
SPENCER T. KUVIN, Esq. 
Florida Bar No.: 089737 
Page 7 of 7 
EFTA00723272

IN THE COURT OF THE FIFTEENTH 
JUDICIAL CIRCUIT, IN AND FOR 
PALM BEACH COUNTY, FLORIDA 
CASE NO. 502008CA037319XWMB AB 
Plaintiff, 
• 
CQ1~ 
Ikt.friCt..(ve:O ift."21 
it..!14C.4 
v. 
74.4! I 7:* 
JEFF 
Y E 
EIN, 
SlIm1O,4 n. SOCK 
LER 
C
CUrr 
Defendants. 
IR
EPSTEIN'S OBJECTIONS TOM REQUEST FOR ENTRY UPON LAND, MOTION 
FOR PROTECTIVE ORDER AND INCORPORATED MEMORANDUM OF LAW 
Defendant, JEFFREY EPSTEIN ("Epstein"), objects to Plaintiffs, S. (s"), 
Request for Entry Upon Land ("Request") (attached as Exhibit A), moves for a 
protective order pursuant to Fla. R. Civ. P. 1.280(c), and states: 
I. 
Introduction 
1. 
On August 13, 2009, served her Request seeking to: 
Inspect the entire property located at [358 El Brillo Way], 
including but not limited to the driveway, the interior of the 
house, each and every room in the house, the massage 
table, the backyard, the swimming area and all other areas 
located on said property. 
2. 
asserts the inspection will take approximately 4 hours: She also states 
the inspection will be attended by an unspecified number of lawyers, a videographer, 
members of the "video team," a photographer, members of the "photography team" and 
various "other persons to assist in the process" (i.e. a "cast of thousands" a/k/a Cecil B. 
DeVille). See Request ¶3. 
EFTA00723273

I
I
 
v. Epstein 
Case No. 502008CA0371CXXMB AB 
Epstein's Objections to 
equest and Motion for Protective Order 
Page 2 of 22 
3. 
Epstein objects to the Request on the following grounds: 
a. Violation of the Due Process Clause of the Fifth and Fourteenth 
Amendments in that this Court is being asked to authorize a 
general search and seizure by a private party of the entirety of the 
Epstein's private residence, including an intrusive 4 — hour 
videotaping (i.e. it is being asked to authorize a search and seizure 
by private parties that it could not authorize if requested by the 
Government), all in violation of Epstein's right to privacy and due 
process; 
b. Risks compromising the defendant's Fourth Amendment right to the 
extent that the video — or testimony about the view — was provided, 
voluntarily or via subpoena to any state or federal law enforcement 
or prosecutorial authority 
c. Violation of the Fifth Amendment protection against self-
incrimination; 
d. Not relevant, material or reasonably calculated to lead to the 
discovery of admissible evidence; further, has the capacity to 
compromise the accuracy of the memories of El and any other 
witness who is permitted to attend or view the photo/video results of 
the inspection and is therefore in conflict with the parties interest in 
a trustworthy fact-finding process; 
EFTA00723274

v. Epstein 
Case No. 502008CA03a12XXXXMB AB 
Epstein's Objections to= Request and Motion for Protective Order 
Page 3 of 22 
e. Overbroad; 
f. Unduly burdensome; 
g. Violation of constitutional right of privacy; 
h. Harassing; 
4. 
Reading 
Request, one would think 
intention is to shoot a reality 
television show. But this is not reality TV; this is a lawsuit. The scope of 
Request 
is absolutely absurd and the Court should prohibit the requested inspection or, in the 
alternative, substantially limit the inspection, order that it only occur after El and all 
other witnesses have been deposed, and subject any photographs or video to a 
protective order precluding any dissemination to any third parties. 
II. 
Permitting the Requested Inspection Would Be Akin to an Illegal Search 
and Seizure Prohibited by the Fourth Amendment 
essentially asks the Court to order a warrantless search and seizure of 
Epstein's residence. The inspection is analogous to a search as IN seeks to enter 
Epstein's residence, inspect (i.e. search) the residence without limit, photograph (i.e. 
seize) images of the residence, all because El claims she was sexually abused by 
Epstein. 
6. 
The Fourth Amendment to the United States Constitution provides: 
The right of the people to be secure in their persons, houses, 
papers, and effects, against unreasonable searches and 
seizures, shall not be violated, and no Warrants shall issue, 
but upon probable cause, supported by Oath or affirmation, 
and particularly describing the place to be searched, and the 
persons or things to be seized. 
EFTA00723275

lg. 
v. Epstein 
Case No. 502008CA0Vals9XXXXMB AB 
Epstein's Objections lee Request and Motion for Protective Order 
Page 4 of 22 
7. 
Further, the Florida Constitution, Article I, § 12 provides in pertinent part: 
The right of the people to be secure in their persons, houses, 
papers and effects against unreasonable searches and 
seizures, and against the unreasonable interception of 
private communications by any means, shall not be violated. 
No warrant shall be issued except upon probable cause, 
supported by affidavit, particularly describing the place or 
places to be searched, the person or persons, thing or things 
to be seized, the communication to be intercepted, and the 
nature of evidence to be obtained. This right shall be 
construed in conformity with the 4th Amendment to the 
United States Constitution, as interpreted by the United 
States Supreme Court. 
8. 
The overriding purpose of the Fourth Amendment is to protect personal 
privacy and dignity against unwarranted intrusion by the state, values which are basic to 
a free society. See Winston v. Lee, 470 U.S. 753 (1985). 
9. 
The Fourth Amendment is designed to prevent, not simply to redress, 
unlawful government action. See Steaciald, 451 U.S. 204 (1981). 
10. 
If the government wished to inspect Epstein's residence, it would first have 
to obtain a warrant based on probable cause, and the warrant would have to particularly 
describe the thing to be seized and the place to be searched. See Dalia v. U.S., 441 
U.S. 238 (1979). 
11. 
Contrary to the foregoing restrictions imposed on the government, 
seeks a non-particularized and limitless search of Epstein's "entire property." See 
Exhibit A. (Emphasis in original). Not only does 
ask to search the home, she wants 
to photograph and videotape (i.e. seize) its contents. 
EFTA00723276

gi. v. Epstein 
Case No. 502008CA037319XXXXMB AB 
Epstein's Objections to BB's Request and Motion for Protective Order 
Page 5 of 22 
12. 
The government would likely not be able to conduct the search requested 
bye: "the entire property located at [358 El Brillo Way] including but not limited to 
the driveway, the interior of the house, each and every room in the house, the massage 
table, the backyard, the swimming area and all other areas located on said 
property." See Exhibit A. Such an overbroad and vague search would certainly not 
pass muster under the particularity requirement of the Fourth Amendment. 
13. 
Additionally, 
has no probable cause to reasonable believe that any 
relevant evidence will be obtained from the search. See Section IV., infra., arguing that 
el Request is not relevant and not reasonably calculated to lead to the discovery of 
admissible evidence. 
14. 
Epstein's Fourth Amendment concerns are not unwarranted. In a federal 
companion case, 
Jane Doe 
No. 2 
v. Epstein, 
Case 
No. 
08-CIV-80119 
MARRPJJOHNSON, in the United States District Court for the Southern District of 
Florida, United States Magistrate Judge Linnea R. Johnson found, "[i]n 2008, Epstein 
entered into a Non-Prosecution Agreement with the United States Attorney General's 
Office for the Federal Southern District of Florida and the State Attorney's Office for 
Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal 
prosecution against Epstein is deferred as long as he abides by the certain terms and 
conditions contained therein. If at any time the United State's Attorney's Office has 
reason to believe Epstein is in breach of the Agreement, it need only provide Epstein's 
counsel with notice of the breach and then move forward with Epstein's prosecution. 
EFTA00723277