EFTA00723218

in 
ase No. 502008CA031i1XXXXMB AB 
Epstein's Objections to 
Request and Motion for Protective Order 
Page 6 of 22 
Accordingly, the undersigned would agree with Epstein ... 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.'" 
See August 4, 2009 Order on Plaintiffs Motion to Compel Answers to Interrogatories 
and Production of Documents at 4 (attached as Exhibit B) and September 9, 2009 
Omnibus Order at 2 (attached as Exhibit C). 
15. 
Permitting 
attorneys, photographers, videographers and various 
others to scour Epstein's residence and photograph and videotape its contents runs 
afoul of the limits set forth in the Fourth Amendment. Indeed, nothing would prevent 
counsel, or anyone on its photography or videography production teams, or any of 
the various "others," from sharing/providing their photographs and/or videotapes with 
the United States Attorney's Office ("USAO"). 
16. 
Moreover, it is certainly possible that someone in the 'cast of thousands" 
requests to be present at the inspection could be a Government informant. 
17. 
Even if the Court entered a protective order limiting the persons entitled to 
view the photographs/video, it would likely be ineffective against a subpoena from the 
USAO or a Federal Grand Jury. 
18. 
Thus, the USAO would potentially be provided with a rare glimpse into 
Epstein home, which it could not otherwise obtain absent a warrant based on probable 
cause particularly describing the place to be searched. Under these circumstances, the 
EFTA00723278

V. EoStein 
Case No. 502008CA03;11,2pXXMB AB 
Epstein's Objections to =Request and Motion for Protective Order 
Page 7 of 22 
USAO could circumvent the warrant and probable cause requirements by relying on 
counsel and photography/videography team to perform the search for them. 
19. 
Assuming arguendo that a court order permitting a civil party rather than a 
law enforcement officer is not strictly subject to the Fourth Amendment, as certain cases 
have held, the policies, principles, and overriding purpose of the Amendment — to 
provide and protect the citizen's expectation of privacy, particularly in a "man's castle" 
(i.e. his residence) — should provide the context for the Court's determination of the 
reasonableness of the request for what at its essence is a court ordered search and 
seizure. 
20. 
For this reason and the reasons set forth herein, the Court should deny 
Request and preclude any inspection of Epstein's property. 
Ill. 
The Inspection Could Violate Epstein's Fifth Amendment Rights Against 
Self — Incrimination 
21. 
The Fifth Amendment 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 proceedings." 
See 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 
and extends not only to answers that would support a criminal conviction, but extends 
also to those answers which would furnish a link in the chain of evidence needed to 
prosecute the claimant for a crime. See Hoffman v. United States, 341 U.S. 479, 486 
(1951). Information is protected by the privilege not only if it would support a criminal 
EFTA00723279

R
iidaggin 
e No. 502008CA0371IXXXM8 AB 
Epstein's Objections to 
Request and Motion for Protective Order 
Page 8 of 22 
conviction, but also in those instances where "the responses would merely 'provide a 
lead or clue' to evidence having a tendency to incriminate.' See United States v. Neff, 
315 F.2d 1235, 1239 (9th Cir.), cent denied 447 U.S. 925 (1980). 
22. 
Moreover, the act of production itself may implicitly communicate 
statement and, for this reason, the Fifth Amendment privilege also encompasses the 
circumstances where the act of producing documents in response to a subpoena or 
production request has a compelled testimonial aspect. See United States v. Hubbell, 
530 U.S. 27, 35-36 (2000). Thus, where the existence 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. See In re Grand Jury Subpoena, 
1 F.3d 87, 93 (2nd Cir. 1993). 
23. 
In the instant case, ■ 
requests, for example, to inspect the massage 
table. See Exhibit A. Any compelled 'production" by Epstein of "the massage table" for 
the inspection would violate his Fifth Amendment rights in that he is implicitly being 
asked to authenticate it. To the extent 
counsel requests Epstein to identify the 
room where the alleged acts occurred, such also violates the Fifth Amendment for the 
same reason. 
24. 
Photographing and videotaping the massage table and the room where 
the acts allegedly occurred could potentially provide a 'lead or clue' to evidence having 
a tendency to incriminate but more important, any expectation that Epstein would, as a 
EFTA00723280

v. Epstein 
Case No. 502008CA037=XXXXMB AB 
Epstein's Objections to'. Request and Motion for Protective Order 
Page 9 of 22 
result of the motion or any court order, be required to facilitate the inspection by 
identifying the residence, any part of the residence, any object, or to be ordered to do 
anything other than to passively acquiesce to a court order would threaten to invade his 
privilege against being required to produce and/or testify. 
25. 
In 
Jane 
Doe 
No. 
2 
v. 
Epstein, 
Case 
No. 
0B-CIV-80119 
MARRA/JOHNSON, the Court sustained Epstein's Fifth Amendment objections to 
interrogatories: asking Epstein to identify all employees who performed work inside his 
Palm Beach residence and all other employees who came to the residence 
(Interrogatory Nos. 1 — 2), asking Epstein to identify any who gave or were asked to 
give him. massages (Interrogatories Nos. 3 - 6), requesting information regarding the 
identity of persons who provided transportation services (Interrogatory No. 9), seeking a 
list of Epstein's employees' telephone numbers (Interrogatory No. 12), asking Epstein to 
indentify any persons or witnesses who have knowledge or are in possession of 
physical evidence pertaining to the events in question (Interrogatories Nos. 13, 14 and 
17), seeking information related to alleged sexual abuse or misconduct on a minor 
(Interrogatory No. 15), and seeking the facts on upon which Epstein relies to support 
pleading denials and affirmative defenses (Interrogatory No. 16). See August 4, 2009 
Order on Plaintiffs Motion to Compel Answers to Interrogatories and Production of 
Documents. 
26. 
If the Fifth Amendment protects Epstein from disclosing the identity of any 
person who has knowledge or are in possession of physical evidence (i.e. photographs, 
EFTA00723281

B,B. v, Eosteiq 
Case No. 502008CA03 
XMB AB 
Epstein's Objections to 
Request and Motion for Protective Order 
Page 10 of 22 
videos, written statements, etc.) pertaining the events in question (Interrogatory Nos. 
13, 14 and 17 supra), it follows that Epstein's production of the massage table and 
massage room to be photographed and videotaped would also violate his Fifth 
Amendment rights. 
Stated differently, if Epstein can properly invoke his Fifth 
Amendment right to not identify a person who may have a photograph of, for example, 
the massage table, how can Epstein be required to produce the massage table for ■ 
to inspect, photograph and videotape? 
27. 
To the extent 
requests Epstein produce the massage table or 
authenticate anything in his residence (i.e. the massage room, the kitchen where 
alleged conversations occurred, etc.), Epstein invokes his rights under the Fifth 
Amendment. 
IV. 
The Court Should Prohibit an Inspection of Epstein's Residence as 
Epstein's Home is Irrelevant and Not Reasonable Calculated to Lead to the 
Discovery of Admissible Evidence 
28. 
Rule 1.350(a)(3), Florida Rules of Civil Procedure, provides: 
Any party may request any other party to permit entry upon 
designated land or other property in the possession or 
control of the party upon whom the request is served for the 
purpose 
of 
inspection 
and 
measuring, 
surveying, 
photographing, testing, or sampling the property or any 
designated object or operation on it within the scope of 
rule 1.280(b). 
(Emphasis added). 
29. 
Rule 1.280(b), Florida Rules of Civil Procedure, provides in pertinent part, 
"[p]arties may obtain discovery regarding any matter, not privileged, that is relevant to 
EFTA00723282

s  v. Epstein 
Case No. 502008CA03 
XXXXMB AB 
Epstein's Objections to 
Request and Motion for ProtectWe Order 
Page 11 of 22 
the subject matter of the pending action, whether it relates to the claim or defense of 
the party seeking discovery or the claim or defense of any other party...." (Emphasis 
added). 
30. 
"Relevant evidence is evidence tending to prove or disprove a material 
fact." See Fla. Stat. §90.401. 
31. 
In the instant case, there are no allegations in 
complaint that would 
be proven or disproven by evidence obtained from the inspection, and the inspection 
will not lead to the discovery of admissible evidence. 
32. 
■ 
asserts causes of action for negligence, coercion into prostitution, 
battery and intentional infliction of emotional distress. See Second Am. Compl. The 
only allegations in 
11-page, 4-count complaint regarding Epstein's residence are: 
a. Epstein had a residence located at 358 El Brillo Way. Id. ¶4; 
b. Epstein plans to reside permanently at 358 El Brillo Way. Id. ¶5; 
c. II was brought to Epstein's residence and was left alone in a room 
at Epstein's "mansion." Id. ¶9; 
d. Epstein has a "lavish home." Id. ¶11; 
e. The alleged acts took place at Epstein's residence. Id. ¶14; and 
f. Epstein used his house for the purpose of lewdness or prostitution. 
Id. ¶20D.; 
EFTA00723283

IL
v. Epstein 
No. 502008CA037319XXXXMB AB 
Epstein's Objections to IIERequest end Motion for Protective Order 
Page 12 of 22 
33. 
What relevant evidence (i.e. tending to prove or disprove a material fact) 
will be obtained from inspecting Epstein's back yard, the attic, the garage, the cabinets, 
drawers, storage closets or any other area of the house? The answer is simple: none.
34. 
Moreover, the room where the alleged acts occurred and massage table 
were not instrumentalities of the claims alleged in the complaint. The massage table 
has absolutely no relevance to 
claims, save for the fact that the massage table 
itself existed. 
Nothing about the massage table's dimensions, construction or 
appearance proves or disproves any material facts. The same rationale applies to the 
massage room. There are no allegations that put the massage room at issue such that 
a video or photograph will provide relevant evidence or lead to the discovery of 
admissible evidence. 
35. 
This is not a case where ■ 
fell off the massage table and broke her leg. 
Nor is this a case where ■ 
slipped and fell in the massage room because of a defect in 
the floor. Both of those scenarios might provide some justification for an inspection of 
the massage table and massage room, respectively, because the inspection could lead 
to the discovery of admissible evidence. See Welzel v. Bernstein, 233 F.R.D. 185, 186 
(D.C. 2005) (noting that in cases in which a site inspection has been allowed, the 
rationale has been because the specific location relates to the cause of action). 
36. 
Nevertheless, the house has been remodeled and thus its appearance is 
substantially different than when the alleged acts occurred. 
EFTA00723284

faLfain 
Case No. 502008CA037=XXXMB AB 
Epstein's Objections to =Request and Motion for Protective Order 
Page 13 of 22 
37. 
The following cases addressing entry onto land for inspection illustrate the 
circumstances under which an inspection may or may not be appropriate: 
a. Strasser v. Yalamanchi, 669 So. 2d 1142 (Fla. 4th DCA 1996) 
involved a dispute between former plastic surgeon partners related 
to compensation. 
Plaintiff requested to inspect defendant's 
computer for billing and collection information. The court permitted 
limited access to defendant's computer systems only to search for 
financial information that had allegedly been deleted. Id. at 1145; 
b. Hauser v. Volusia County Dept. of Corrections, 872 So. 2d 987 
(Fla. 1st DCA 2004) (permitting defendant to inspect plaintiffs' 
residences to collect air samples and observe ventilation systems 
where plaintiffs claimed they were injured due to exposure to toxic 
mold at their place of employment); 
c. Menke v. Broward County School Bd., 916 So. 2d 8 (Fla. 4th DCA 
2005) (denying unfettered access to defendant's computers in case 
involving disciplinary proceedings brought against teacher for 
exchanging sexually explicit emails with students); 
d. Goodyear Tire & Rubber Co. v. Cooey 359 So. 2d 1200 (Fla. 1st 
DCA 1978) (quashing order permitting inspection of tire plant 
because plaintiff did not demonstrate that tires made at the plant 
were substantially similar to the tire involved in the subject accident, 
EFTA00723285

V. Epstein 
ase No. 50200BCA037319XXXXIMB AS 
Epstein's Objections to MRequest and Motion for Protective Order 
Page 14 of 22 
noting that plaintiff presented no evidence to support the need for 
an inspection); 
e. Murphy v. Cooper Tire & Rubber Co.  , 2008 WL 3926715 (N.D. Fla. 
2008) (denying request to inspect defendants tire plant since the 
tire at issue was no longer manufactured at the plant and since the 
plant had been changed and did not reflect the manufacturing 
conditions that existed when the subject tire was made; the court 
noted that the current condition of the plant was "only marginally 
relevant-at best."); and 
f. Marcort v. Goodwill Industries- Manasota, Inc., 220 F.R.D. 377 
(M.D. Fla. 2003) (involving alleged violations of the Americans with 
Disabilities Act, plaintiff requested a wholesale inspection of 
defendant's property for ADA compliance. 
The court limited 
inspection of defendant's premises to "the specific barriers to 
access Plaintiffs alleged in their complaint."). 
38. 
The instant case is unlike Yalamachi, where plaintiff sought to inspect 
defendant's computers for financial information directly relevant to his breach of contract 
claim; and it is unlike Hauser where the plaintiffs put the quality of the air in their homes 
at issue by suing their employer for exposure to toxic mold. 
EFTA00723286

It.
 v. Epstein 
Case No. 502008CAOILUMOCXMB AB 
Epstein's Objections tW 
Request and Motion for Protective Order 
Page 15 of 22 
39. 
This case is more analogous to Murphy and Gooey, where the court 
prohibited inspection because the plaintiffs could not demonstrate the how the 
inspection would be relevant to their respective cases. 
40. 
Moreover, federal courts have recognized that "entry upon a party's 
premises may entail greater burdens and risks than mere production of documents" and 
"the degree to which the proposed inspection will aid in the search for truth must be 
balanced against the burdens and dangers created by inspection." See Belcher v. 
Bassett Furniture Industries, Inc., 588 F.2d 904, 908 (4th Cir. 1978) (also known as 
"The Belcher Test"). 
41. 
An inquiry into when to compel an inspection goes beyond mere relevance 
and must balance the need presented by the moving party against the burdens and 
dangers created by the inspection. See Johnson v. Mundy Industrial Contractors. Inc., 
2002 WL 31464984 *3 (E.D .N.C. 2002) (quotations omitted). 
42. 
As noted by professors Wright & Miller: 
[lit is clear that the right to discovery is a qualified right that 
does 
not 
extend 
to 
making 
unnecessary 
and 
unwarranted excursions onto the property of another 
under the guise of supportable litigative need. Public 
policy supports reasonable and necessary demands for 
information in the hands of the adversary, in order that the 
case may be well and truly tried. But any such invasion of a 
person's property rights must, in the language of our 
Supreme Court, 'be judged with care .... Properly to balance 
these competing interests is a delicate and difficult task.' 
See Wright & Miller, Federal Practice & Procedure, §2040 at 286-87 (1970 ed.) 
(Emphasis added). 
EFTA00723287

v. Epstein 
Case No. 502008CA037319XXXXIM AB 
Epstein's Objections to BB's Request end Motion for Protective Order 
Page 16 of 22 
43. 
Moreover, an inspection of Epstein's residence would violate his 
constitutional right to privacy. See Fla. Const., Art I. §23. The constitutional right of 
privacy in the Florida Constitution is broader than the protection provided in the United 
States Constitution. See Berkeley v. Eisen, 699 So. 2d 789, 790 (Fla. 4th DCA 1997), 
citing Rasmussen v. South Fla. Blood. Serv., Inc. 500 So. 2d 533, 536 (Fla. 1987). 
Orders compelling discovery constitute state action that may impinge on the 
constitutional right of privacy. See Berkeley, 699 So. 2d at 790. The court must 
balance the competing interests, privacy versus the need for discovery, that would be 
served by granting or denying discovery. Id. at 791. 
44. 
The fact ■ 
wants to photograph and videotape the residence amplifies 
the invasion of privacy. 
45. 
Again, the Fourth Amendment is implicated. The physical entry of the 
home is the chief evil against which the Fourth Amendment is directed and a principal 
protection against unnecessary intrusions into private dwellings is the warrant 
requirement imposed by the Fourth Amendment. See Welsh v. Wisconsin, 466 U.S. 
740 (1984). 
46. 
As set forth herein, Epstein's residence is, at best, only marginally 
relevant to the instant case. On the other hand, the right of privacy in one's home is 
sacred. 
47. 
For the foregoing reasons, the Court should deny 
Request and enter 
a protective order, pursuant to Fla. R. Civ. P. 1.280(c), prohibiting such discovery as it is 
EFTA00723288

R
v. Epstein 
e No. 502008CA03.1XXXXMB AB 
Epstein's Objections to 
Request and Motion for Protective Order 
Page 17 of 22 
harassing, not relevant or reasonably calculated to lead to the discovery of admissible 
evidence and violates Epstein's constitutional right to privacy. 
V. 
Alternatively, if the Court Permits Inspection, it Should be Strictly Limited 
48. 
If the Court finds the home inspection will somehow yield relevant 
evidence and outweighs Epstein's right of privacy, the inspection should be limited to 
the following: 
a. One photographer, accompanied by one attorney; 
b. To take five (5) still photographs (no video) of the room in which 
the alleged acts occurred', 
c. To be supervised by Epstein's security guard and his attorney; 
d. To be completed in 30 minutes or less; and 
e. Ill be required to produce copies of all photographs to Epstein's 
counsel. 
49. 
Request to inspect the "entire property" for four hours with an 
entourage of attorneys, videographers, photographers, and their respective teams and 
"various others to assist in the process" is grossly overbroad. There are no allegations 
placing, for example, the back yard at issue. In only alleges that certain acts took 
place in a particular room. Thus, the inspection should be limited to said room. 
50. 
Just as the Government, constrained by the Fourth Amendment, would 
first have to obtain a warrant based on probable cause, and the warrant would have to 
1 For the reasons s
loyees 
in Section III., supra, neither Epstein nor his counsel nor any of his 
will identify or show 
counsel or photographers the room where the alleged acts occurred. 
should 
erg
have no problem providing her counsel with sufficient information to identify the room. 
EFTA00723289

B.B. v. Epstein 
Case No. 502008CA03 
XXXXMB AB 
Epstein's Objections to 
Request and Motion for Protective Order 
Page 18 of 22 
particularly describe the thing to be seized and the place to be searched (see Dalia v. 
U.S. 441 U.S. 238 (1979)), so should this Court require s 
to justify her Request (i.e. 
show probable cause). That is, SI should be required to demonstrate to the Court the 
relevant evidence she intends to discover and where said evidence is reasonably 
believed to be. If, and only if, ■ 
presents sufficient evidence to justify the inspection, 
the Court's order should particularly describe the place to be searched based on the 
evidence put forth by 
(i.e. the room in which the alleged acts occurred). 
51. 
In addition, having teams of photographers, videographers, attorneys and 
"others" present at a four-hour inspection is unduly burdensome for Epstein to endure in 
his own home. It is also harassing. 
52. 
Moreover, such a scenario is ripe for misconduct. With a large group of 
people trouncing around Epstein's house, it is not beyond the bounds of reasonable 
possibility that something would be stolen or broken. And given the amount of publicity 
surrounding this case and its contentious nature, it would not be difficult for a member of 
the "photography team," for example, to sneak off and photograph irrelevant portions of 
the home and either publish or sell the photos. 
53. 
In Wetzel v. Bernstein, plaintiff brought an action against her former 
employer alleging discrimination and retaliation. 233 F.R.D. 185. Plaintiff asserted the 
office configuration exacerbated her mistreatment by defendant. The court noted that 
plaintiff could argue she suffered heightened emotional distress because other 
employees were aware of how she was being treated by virtue of the glass walls in her 
EFTA00723290

v, Epstein 
Case No. 502008CA03 
XXXXMB AB 
Epstein's Objections to
 Request and Motion for Protective Order 
Page 19 of 22 
office. Id. at 187. In permitting the inspection, the court limited it to one-hour and to the 
suite of offices at issue. 
54. 
While 
has not and cannot demonstrate a need for inspection like the 
plaintiff in Welzel (i.e. that the configuration of the office itself exacerbated her emotional 
distress), if the Court permits an inspection of Epstein's residence, it should enter a 
protective order limiting the scope to the room in which the alleged acts occurred and 
limiting the time to one half hour. See Fla. R. Civ. P. 1.280(c) (permitting the court to 
limit the scope of discovery). 
55. 
Additionally, any photographs should be subject to a confidentiality order. 
The photographs should be strictly limited for use in this litigation, not shown to anyone 
except counsel and experts, and returned to Epstein after the conclusion of this 
litigation. Any expert permitted to view the photographs should be required to sign an 
assurance providing that he or she agrees to abide by the terms of a confidentiality 
order. Due to the substantial due process and privacy concerns articulated herein, the 
Court should further order that a violation of the confidentiality order be punishable by 
contempt of court. 
attorneys have not been shy about contacting the press. 
VI. 
Any Inspection Should Occur After 
Deposition and Just Prior to Trial 
56. 
If the Court permits an inspection, it should take place shortly before trial, 
but after■ has been deposed to avoid any attempt by her to tailor her testimony to the 
information obtained from the inspection. 
The integrity of 
memory will be 
compromised if she is permitted to view images from inside the residence. An analogy 
EFTA00723291

v. Epstein 
Case No. 502008CA0 
XXXXMB AB 
Epstein's Objections to
 Request and Motion for Protective Order 
Page 20 of 22 
can be made to cases involving impermissibly suggestive showups.2 See e.g. Neil v. 
Biggers, 409 U.S. 188 (1972). In Neil, the United States Supreme Court, addressing 
suggestive showups, noted that "the primary evil to be avoided is a very substantial 
likelihood of irreparable misidentification." Id. at 198. (Internal quotations omitted). It 
went on to state that suggestive confrontations are disapproved because they increase 
the likelihood of misidentification, which would violate a defendant's due process rights. 
Id. 
57. 
Just like a victim's propensity to misidentify a criminal suspect in a 
suggestive showup, there is a strong likelihood that El will tailor her recollection and 
testimony to the photographs/video taken at the inspection. There would be no way to 
test whether her testimony was a result of independent recollection of the alleged 
events or from viewing the photographs. This would, of course, violate Epstein's due 
process rights. 
58. 
On the other hand, 
will not be prejudiced by postponing the inspection 
until after her deposition. 
59. 
Ergo, if the Court permits 
to inspect Epstein's residence, Epstein 
requests the inspection be conducted after 
deposition and just prior to trial. 
WHEREFORE, Defendant, JEFFREY EPSTEIN, respectfully requests the Court 
sustain his objections to E.W.'s Request for Entry Upon Land, enter a protective order 
precluding entry on Epstein's property or, in the alternative, enter a protective order 
Z A „showup" is a pretrial identification procedure in which a suspect is confronted with a witness to or the 
victim of a crime. Unlike a lineup, a showup is a one-on-one confrontation. See Black's Law Dictionary 
(8th ed. 2004). 
EFTA00723292

1.3 .,EaLeti 
Case No. 502008CA0UIWYJO(XMB AB 
Epstein's Objections t
 Request and Motion (or Protective Order 
Page 21 of 22 
limiting the inspection as follows: (a) one photographer, accompanied by one attorney; 
(b) to take five (5) still photographs (no video) of the room in which the alleged acts 
occurred; (c) to be supervised by Epstein's security guard and Epstein's attorney; (d) to 
be completed in 30 minutes or less; (e) to occur after le deposition; and (f) any 
photographs be subject to a confidentiality order proscribing dissemination to anyone 
except 
counsel and experts, a violation of which would be punishable by contempt 
of court, and to grant any additional relief the Court deems just and proper. 
Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. 
Mail to the following addressees on this 14th day of September, 2009: 
Theodore J. Leopold, Esq. 
Spencer T. Kuvin, Esq. 
Leo 
Jack Goldberger, Esq. 
ss, P.A. 
Fax: 
Co-counsel for Defendant Jeffrey Epstein 
BURMAN, CRITTON, LUTTIER 
& COLEMAN, LLP 
303 Banyan Blvd., Suite 400 
FL 33401 
By: 
F 
Robert . Critton, Jr. 
Florid 
ar #224162 
Michael J. Pike 
Florida Bar #617296 
EFTA00723293

v, Epstein 
Case No. 502008CA0 
XXXXMB AB 
Epstein's Objections to.. Request and Motion for Protective Order 
Page 22 of 22 
(Counsel for Defendant Jeffrey Epstein) 
EFTA00723294