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the extent the documents are, upon information and belief, in the possession, custody and control 
of the federal and state government. Jane Doe No. 3 further objects to this Request as overbroad, 
harassing and not calculated to lead to discoverable evidence relevant to the Florida Defamation 
Action. Jane Doc No. 3 objects to this Request in that it places an undue burden on this non-
party including, for example, requiring the non-party to search for "documents", which has been 
defined by Defendant to include a broad definition of electronically stored data, including 
requiring a search of "archives" and "back-up systems." 
24. All documents concerning, relating or referring to your assertions that you met 
former President Bill Clinton, former Vice President Al Gore and/or Mary Elizabeth "Tipper" 
Gore on Little Saint James island in the U.S. Virgin Islands. 
Response: In addition to the Preliminary Statement and General Objections. Non-Party 
Jane Doe No. 3 objects to this Request in that, on its face. it has absolutely nothing to do with the 
Florida Defamation Action. Former President Bill Clinton and the Gores are not, in any way. 
relevant to the Florida Defamation Action. Instead, this is a clear example of Defendant's 
attempt to abuse the subpoena power and rules of discovery by seeking information from a non-
party that is wholly unrelated to the case from which the subpoena has been issued. Defendant 
has gone on a very deep fishing expedition here and Jane Doe No. 3 objects to the overbroad and 
abusive nature of this Request. Jane Doe No. 3 objects to this Request to the extent that it seeks 
documents protected by the attorney-client privilege, the work product doctrine, the joint defense 
doctrine, the common interest privilege, or any other privilege or protection. Jane Doe No. 3 
objects to this Request to the extent it seeks confidential information from a non-party. Jane Doe 
No. 3 objects to this Request to the extent the documents are, upon information and belief, in the 
possession. custody and control of the federal and state government or the Defendant and his 
client, Mr. Epstein. Jane Doe No. 3 objects to this Request in that it places an undue burden on 
this non-party including, for example, requiring the non-party to search for "documents", which 
19 
EFTA01078845

has been defined by Defendant to include a broad definition of electronically stored data, 
including requiring a search of "archives" and "back-up systems." 
25. All documents concerning your retention of the law firm Boles, Schiller & Flexner 
LLP, including but not limited to: signed letter of retainer, retention agreement, explanation of 
fees, and/or any documents describing the scope of retention. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request in that it seeks documents protected by the attorney-client 
privilege, the work product doctrine, the joint defense doctrine, the common interest privilege, or 
any other privilege or protection. Jane Doe No. 3 also objects in that this Request seeks 
confidential information from a non-party that violates her privacy rights. Jane Doe No. 3 
further objects to this Request as overbroad, harassing and not calculated to lead to discoverable 
evidence relevant to the Florida Defamation Action. 
Dated: April 9, 2015 
Respectfully submitted, 
BOLES, SCHILLER & FLEXNER LLP 
Sigrid S. McCawlev F.sq. 
Florida Bar No. 129305 
Attorney's for Jane Doe No. 3 
401 East Las Olas Boulevard, Suite 1200 
Fort Laude 
301 
Telephone-
By: /s/ Siuri&S_McCawlev 
Sigrid S. McCawley, Esq. 
20 
EFTA01078846

CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that a true and correct copy of the foregoing was served by 
Electronic Mail on April 9, 2015 to the individuals identified on the attached Service List. 
By: Is/ Sigrid S. McCawley 
Sigrid S. McCawley 
21 
EFTA01078847

SERVICE LIST 
Thomas E. Scott 
Steven R. Safra 
COLE, SCOTT & KISSANE, P.A. 
9150 S. Dadeland Blvd., Suite 1400 
Miami, Florida 33156 
Rcnce.nailaikskleutcotn 
ichard A. Simpson 
Mary E. Boria 
Ashley E. Filer 
WILEY REIN, LLP 
1776 IC Street NW 
Washington, D.C. 20006 
Counsellor Defendant Alan Dershowiiz 
Jack Scarola 
SEARCY DENNEY SCAROLA BARNHART & 
SHIPLEY. P.A. 
2139 Palm Beach Lakes Blvd. 
West Palm Beach, FL 33409.6601 
Attorney for Plaintiffs 
22 
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EXHIBIT 1 
EFTA01078849

SHOW: AUSTRALIAN BROADCASTING SYSTEM (ABC) 7.30 8:05 PM AEST ABC 
January 6, 2015 Tuesday 
LENGTH: 942 words 
HEADLINE: Prince Andrew under pressure as Palace disputes teen sex scandal 
claims 
REPORTERS: Philip Williams 
BODY: 
LEIGH SALES, PRESENTER: It's been a few years since Britain's Royal Family has 
been embroiled in a serious scandal, but once again, Prince Andrew has stepped 
forward. 
He's accused of having sex with an underage girl in sensational details aired in an 
American court case. 
The young woman says she was forced to entertain the Duke at the behest of his 
friend, billionaire and convicted paedophile Jeffrey Epstein. 
Prince Andrew's ex-wife, Sarah Ferguson, has leapt to his defence and Buckingham 
Palace is also strenuously denying the allegations. 
But, as Europe correspondent Philip Williams reports, the claims have blown apart 
the always uneasy calm between the Palace and the British press. 
PHILIP WILLIAMS, REPORTER: As fifth in line to the throne, whatever Prince Andrew 
does or says will never go unnoticed. 
So when media reports about a lawsuit in the US emerged linking his name with 
underage sex, the long period of relative Royal calm was abruptly shattered. 
This woman, 
, is believed to be the person named in court papers as 
"Jane Doe 3". In a newspaper interview she claims she was used for underage sex by 
American billionaire Jeffrey Epstein and says she was lent out to his rich and 
powerful friends, including Prince Andrew. It's claimed she had sex with him three 
times when she was 17 at Jeffrey Epstein's luxury Caribbean Island home and in New 
York and London, all denied by Prince Andrew. 
VICTORIA MURPHY, UK MIRROR ROYAL CORRESPONDENT: If this doesn't go away 
quickly, if these allegations continue to be made, if more allegations are added, this 
could be incredibly damaging, not just for Andrew, but for the monarchy as a whole. 
PHILIP WILLIAMS: It all seems a world away from the golden glow of recent Royal 
events - a wedding that cemented the popularity of Prince William and his bride. 
Followed of course by the arrival of baby Prince George. And for the Queen, a 
diamond jubilee, a celebration of 60 years on the throne, reason for her to smile as 
the nation and beyond said thanks for her never-ending job. 
EFTA01078850

Over the weekend, that run of feel-good luck expired. 
Normally with a story like this, Buckingham Palace would be more inclined to stay 
quiet, not to give any oxygen whatsoever to the sort of claims that have been made. 
But this time, it's very, very different. Not one, but two statements saying Prince 
Andrew is completely innocent of all the accusations. 
VICTORIA MURPHY: They issued one statement initially in response to the allegations 
that Prince Andrew had had sex with an underage minor and that was what they 
were responding to and they were categorically denying that that had been the case. 
However, in doing that they had left the door open that perhaps he was only denying 
the fact that she was a minor and questions were being asked about that. So when 
more of her allegations surfaced, they decided that they needed to release an even 
stronger denial, categorically denying any sexual contact whatsoever. 
PHILIP WILLIAMS: What isn't in dispute is that Prince Andrew and Jeffrey Epstein 
were good friends over a number of years. 
In 2008, Mr Epstein was sentenced to 18 months' jail for soliciting an underage girl 
for the purposes of prostitution. That, after a controversial plea bargain. He remains 
a registered sex offender. 
Yet in 2011, after his release, Prince Andrew was seen with his old friend in New 
York Central Park. That cost Prince Andrew an unpaid job he was said to have loved 
as the UK's Trade and Industry special representative, opening doors for British 
business overseas. 
CHRIS BRYANT, LABOUR MP (March, 2011): But I'm afraid he's now just become a 
national embarrassment. And my worry is that sometimes when he goes on these 
trips, I'm not sure whether he's helping us out or he's just helping himself. 
PHILIP WILLIAMS: For him, that door closed as a direct result of his association with 
Jeffrey Epstein. 
VICTORIA MURPHY: People who know Prince Andrew have said that he is very loyal 
to his friends and that that is one of his strong points. However, I think that those 
closest to him now accept that that particular friendship and the loyalty to Jeffrey 
Epstein that continued until after he was convicted of paedophilia, I think people are 
now saying, you know, he accepts that that was a mistake. However, what is being 
said is that Andrew is only guilty of choosing his friends badly. He's not guilty of 
anything else. 
PHILIP WILLIAMS: Prince Andrew isn't the only one named in the court documents, 
and while he isn't publicly defending himself, another of those accused certainly is. 
Harvard Law Professor Alan Dershowitz has been doing the media rounds of the US 
and beyond. He denies even knowing his accuser, let alone having sex with her. 
ALAN DERSHOWITZ, HARVARD LAW SCHOOL: My goal is to bring charges against 
the client and require her to speak in court. She - if she believes she has been hurt 
by me and by Prince Andrew, she should be suing us for damages. I welcome that 
lawsuit. I welcome any opportunity which would put her under oath and require her 
to state under oath these false allegations. 
EFTA01078851

PHILIP WILLIAMS: Under the plea bargain struck with prosecutors by Jeffrey Epstein, 
it appears that other potential allegations may not end up tested in court and that 
could apply to possible co-conspirators, an arrangement alleged victims were not 
involved with. 
Through Palace statements, the Duke of York has unequivocally denied any 
wrongdoing. He's not charged with anything, nor has he been questioned by police. 
But the Queen's second son is In a spotlight he cannot wish away. His annus 
horribilis may have just begun. 
LEIGH SALES: Philip Williams reporting from London. 
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EXHIBIT 2 
EFTA01078853

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