EFTA00221909

Case 9:08-cv-80119-KAM 
Document 196 
Entered on FLSD Docket 07/10/2009 
Page 1 of 20 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
JANE DOE NO. 2, 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
JANE DOE NO. 3, 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
JANE DOE NO. 4, 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
CASE NO: 08-CV-80232-MARRA/JOHNSON 
CASE NO: 08-CV-80380-MARRA/JOHNSON 
EFTA00221909

Case 9:08-cv-80119-KAM 
Document 196 
Entered on FLSD Docket 07/10/2009 
Page 2 of 20 
JANE DOE NO. 5, 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
JANE DOE NO. 6. 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
JANE DOE NO. 7, 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
CASE NO: 08-CV-80381-MARRA/JOHNSON 
CASE NO: 08-CV-80994-MARRA/JOHNSON 
CASE NO: 08-CV-80993-MARRA/JOHNSON 
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EFTA00221910

Case 9:08-cv-80119-KAM 
Document 196 
Entered on FLSD Docket 07/10/2009 
Page 3 of 20 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
CASE NO: 08-CV-80811-MARRA/JOHNSON 
C.M.A., 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
JANE DOE, 
CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON 
Plaintiff, 
Vs. 
JEFFREY EPSTEIN, et al. 
Defendant. 
DOE II, 
CASE NO: 09-CV-80469-MARRA/JOHNSON 
Plaintiff 
vs. 
JEFFREY EPSTEIN, et al. 
Defendants. 
3 
EFTA00221911

Case 9:08-cv-80119-KAM 
Document 196 
Entered on FLSD Docket 07/10/2009 
Page 4 of 20 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
JANE DOE NO. 101, 
CASE NO: 09-CV-80591-MARRA/JOHNSON 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
JANE DOE NO. 102, 
CASE NO: 09-CV-80656-MARRA/JOHNSON 
Plaintiff 
vs. 
JEFFREY EPSTEIN, 
Defendant 
PLAINTIFF JANE DOE'S MOTION TO COMPEL ANSWERS TO PLAINTFF'S FIRST 
SET OF INTERROGATORIES 
Plaintiff Jane Doe, hereby moves this Court for an order compelling defendant, 
Jeffrey Epstein, to answer her first set of interrogatories or, in the alternative, to prove 
that his invocation of his Fifth Amendment privilege is proper. 
Jane Doe has propounded 23 interrogatories, including such straightforward 
requests as: 
Interrogatory No. 2: Describe financial assets that are under your control, 
directly or indirectly, including interests in corporations or other business entities. 
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CASE NO: 08-CV-80119-MARRA/JOHNSON 
Interrogatory No. 3: Describe which financial assets listed in your answer to 
interrogatory #2 are located outside the 50 states of the United States and where they 
are located. 
Interrogatory No. 4: 
Describe your net worth, including income and 
expenses for 2005, 2006, 2007 and 2008. 
Interrogatory No. 5: 
Describe any real property in which you have a total 
or partial interest, either directly or indirectly. 
Interrogatory No. 7: 
Describe any transfer of assets under your control, 
either directly or indirectly, to locations outside the 50 United States in 2005, 2006, 2007 
and 2008. 
Interrogatory No. 8: Describe, with specificity, your travel to locations outside 
the 50 states of the United states in 2005, 2006, 2007, and 2008, including your dates 
of travel, location to which you traveled and persons that accompanied you in each such 
travel. 
Interrogatory No. 11: Have you heard or do you know about any statement or 
remark (verbal or written) made by or on behalf of any party to this lawsuit, other than 
yourself, concerning any issue in this lawsuit? If so, state the name and address of each 
person who heard or read it, and the date, time, place and substance of each statement 
or remark. 
Interrogatory No. 12: Do you intend to elicit testimony of witnesses other than 
Plaintiff regarding any statements she has ever made? If so, what statements do you 
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Case 9:08-cv-80119-KAM 
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Page 6 of 20 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
intend to produce through testimony? Through which witness do you intend to elicit 
such statement? And for what purpose do you intend to admit such statement? 
Interrogatory No. 23: State the facts upon which you rely for each affirmative 
defense in your answer. 
In response to these interrogatories, Epstein has given the following response 
(with only slight variations on the overbreadth objection): 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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, Defendant objects as the interrogatory is so overbroad and, 
thus, seeks information that is neither relevant to the subject matter of the 
pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. 
This Court should order Epstein to answer all of these interrogatories or, in the 
alternative, prove that his Fifth Amendment invocations are valid. It is for the court, not 
the claimant, to determine whether the hazard of incrimination is justified. United States 
Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). "A court must make a 
particularized inquiry, deciding, in connection with each specific area that the 
questioning party wishes to explore, whether or not the privilege is well-founded." Id. 
Typically this is done in an in camera proceeding wherein the person asserting the 
privilege is given the opportunity "to substantiate his claims of the privilege and the 
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Document 196 
Entered on FLSD Docket 07/10/2009 
Page 7 of 20 
CASE NO: 08-CV-80119-MARRAMONNSON 
district court is able to consider the questions asked and the documents requested by 
the summons." Id. 
Here Epstein has made boilerplate invocation of the Fifth Amendment to each 
and every question propounded by Jane Doe, including for example the question: 
Do you intend to elicit testimony of witnesses other than Plaintiff regarding any 
statements she has ever made? This obviously is not an interrogatory with Fifth 
Amendment implications. Nor is Epstein's claim that this interrogatory is somehow 
"overbroad" or "not calculated to lead to the discovery of admissible evidence" even 
facially plausible. 
Epstein's "cut and paste" response to the interrogatories also blatantly 
disregards the requirements for invoking privilege under the Court's local rules. Local 
rule 26.1.G very specifically requires the preparation of a privilege log with respect to all 
documents and oral communications (among other things) that are withheld on the 
basis of privilege. Epstein has failed to prepare such a log, making it impossible for 
Jane Doe to effectively challenge his generic assertions. The Local Rules do not permit 
this tactic, and Epstein should be (at a minimum) promptly required to produce a 
privilege log. 
For all these reasons, the Court should compel Epstein to answer the 
interrogatories or provide a particularized justification for his Fifth Amendment 
invocation with regard to each request. 
It should be noted that the only two grounds on which Epstein can refuse to 
answer the interrogatories are either proof of a valid Fifth Amendment privilege or proof 
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Document 196 
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Page 8 of 20 
CASE NO: 08-CV-80119-MARRAMONNSON 
of a valid overbreadth objection. These are the only two objections Epstein has 
asserted. As a result, any other objections to production are deemed waived. See 
Local Rule 26.1G.3.(a) ("Any ground [for an objection] not stated in an objection within 
the time provided by the Federal Rules of Civil Procedure, or any extensions thereof, 
shall be waived."). 
SPECIFIC INTERROGATORIES 
For the convenience of the court — and in compliance with Local Rule 26.1 H 
(party filing motion to compel shall list specific requests in succession) — Jane Doe's 
interrogatories are as follows: 
1. 
What is the full name and Florida address of the person answering these 
interrogatories, and, if applicable, the person's official position or relationship with 
the party to whom the interrogatories are directed? 
[Note: This is the only interrogatory Epstein answered in any way] 
2. 
Describe financial assets that are under your control, directly or indirectly, 
including interests in corporations or other business entities. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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, Defendant objects as the interrogatory is so overbroad and, 
thus, seeks information that is neither relevant to the subject matter of the 
pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. 
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Case 9:08-cv-80119-KAM 
Document 196 
Entered on FLSD Docket 07/10/2009 
Page 9 of 20 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
3. 
Describe which financial assets listed in your answer to interrogatory #2 that are 
located outside the 50 states of the United States and where they are located. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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, Defendant objects as the interrogatory is so overbroad and, 
thus, seeks information that is neither relevant to the subject matter of the 
pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. 
4. 
Describe your net worth, including income and expenses for 2005, 2006, 2007, 
and 2008. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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, Defendant objects as the interrogatory is so overbroad and, 
thus, seeks information that is neither relevant to the subject matter of the 
pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. 
5. 
Describe any real property in which you have a total or partial ownership interest, 
either directly or indirectly. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
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EFTA00221917

Case 9:08-cv-80119-KAM 
Document 196 
Entered on FLSD Docket 07/10/2009 
Page 10 of 20 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
me that I cannot provide answers to any questions 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 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, Defendant objects as the interrogatory is so overbroad and, 
thus, seeks information that is neither relevant to the subject matter of the 
pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. 
6. 
Describe which real properties listed in your answer to interrogatory #5 are 
located outside the 50 United States and where the properties are located. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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, Defendant objects as the interrogatory is so overbroad and, 
thus, seeks information that is neither relevant to the subject matter of the 
pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. 
7. 
Describe any transfer of assets under [y]our control, either directly or indirectly, to 
locations outside the 50 United States in 2005, 2006, 2007, and 2008. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 United States Constitution. Drawing an adverse inference under these 
circumstances would unconstitutionally burden my exercise of my 
10 
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Case 9:08-cv-80119-KAM 
Document 196 
Entered on FLSD Docket 07/10/2009 
Page 11 of 20 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
constitutional rights, would be unreasonable, and would therefore violate 
the Constitution. In addition to and without waiving his constitutional 
privileges, Defendant objects as the interrogatory is so overbroad and, 
thus, seeks information that is neither relevant to the subject matter of the 
pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. 
8. 
Describe, with specificity, your travel to locations outside the 50 states of the 
United States in 2005, 2006, 2007, and 2008, including your dates of travel, 
location to which you traveled and persons that accompanied you in each such 
travel. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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, Defendant objects as the interrogatory is so overbroad and, 
thus, seeks information that is neither relevant to the subject matter of the 
pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. 
9. 
List each telephone number used by you or your assistants to call minor females 
directly, or indirectly, for the purpose of scheduling a massage to take place at 
your house located at 358 El Brillo Way, West Palm Beach (includes landlines, 
cell phones, and private jet or airplane lines). For each cell phone, list the 
provider. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 United States Constitution. Drawing an adverse inference under these 
circumstances would unconstitutionally burden my exercise of my 
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CASE NO: 08-CV-80119-MARRAMONNSON 
constitutional rights, would be unreasonable, and would therefore violate 
the Constitution. 
10. 
List the last known name, address and telephone numbers of all persons that 
may have any knowledge about any of the allegations in the Complaint, 
including, but not limited to, friends, acquaintances, employees, or others to 
whom you have spoken about the subject matter which forms the basis of this 
Complaint or who have observed such activity. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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, Defendant objects as the interrogatory is so overbroad and, 
thus, seeks information that is neither relevant to the subject matter of the 
pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. The scope of the information is so 
overbroad that it also includes information that is attorney-client and work-
product privileged. 
11. 
Have you heard or do you know about any statement or remark (verbal or 
written) made by or on behalf of any party to this lawsuit, other than yourself, 
concerning any issue in this lawsuit? If so, state the name and address of each 
person wo made the statement or remark, the name and address of each person 
who heard or read it, and the date, time, place and substance of each statement 
or remark. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit„ however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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 
12 
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CASE NO: 08-CV-80119-MARRA/JOHNSON 
the Constitution. In addition to and without waiving his constitutional 
privileges, Defendant objects as the interrogatory is so overbroad and, 
thus, seeks information that is neither relevant to the subject matter of the 
pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. The scope of the information is so 
overbroad that it also includes information that is attorney-client and work-
product privileged. 
12. 
Do you intend to elicit testimony of witnesses other than Plaintiff regarding any 
statements she has ever made? If so, what statements do you intend to produce 
through testimony? 
Through which witness do you intend to elicit such 
statement? And for what purpose do you intend to admit such statement? 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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, Defendant objects as the interrogatory is so overbroad and, 
thus, seeks information that is neither relevant to the subject matter of the 
pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. 
Additionally, work-product and 
attorney-client. 
13. 
Are you transferring, or do you plan to, or might you transfer money or assets out 
of the country during the course of this litigation? 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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, Defendant objects as the interrogatory is so overbroad and, 
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CASE NO: 08-CV-80119-MARRA/JOHNSON 
thus, seeks information that is neither relevant to the subject matter of the 
pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. 
14. 
Describe each property owned by you, including location, approximate value, and 
whether there is a mortgage on the property and the amount of any such 
mortgage. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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, Defendant objects as the interrogatory is so overbroad and, 
thus, seeks information that is neither relevant to the subject matter of the 
pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. 
15. 
Describe with specificity the amount of money available to you in cash or that can 
be readily liquidated as such. Include the bank financial institution, holding 
company, or other location of this money and the name of the account. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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, Defendant objects as the interrogatory is so overbroad and, 
thus, seeks information that is neither relevant to the subject matter of the 
pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. 
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16. 
State with as much specificity as possible when you met the Plaintiff, and 
including in your answer the following: (a) the circumstances and location of how 
and where you met (b) describe the nature of your relationship, (c) describe how 
many occasions she was with you at your residence located at 358 El Brillo Way 
in Palm Beach, Florida. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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. 
17. 
Provide the names, addresses, and phone numbers of all your current 
accountants, financial planners or money managers handling, or assisting in the 
handling, of your money or assets. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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, Defendant objects as the interrogatory is so overbroad and, 
thus, seeks information that is neither relevant to the subject matter of the 
pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. 
18. 
Did you ever ask the Plaintiff to introduce you to minor females and/or to bring 
minor females to your house in Palm Beach, Florida and if so, when did this 
occur, and what was she asked by you to do, and what did you tell her about the 
reason for her to bring these other minor girls? 
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Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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. 
19. 
Did you ever engage in sexual activity of any kind whatsoever with the Plaintiff, 
and including in your answer what type of sexual activity took place, where it took 
place, and the dates or general timeframe when this activity occurred. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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. 
20. 
Were there parameters or instructions by you to the Plaintiff as to the types of 
girls to bring to your Palm Beach, Florida house, including age, range, what they 
would be asked to do, body type or socio-economic background? 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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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CASE NO: 08-CV-80119-MARRAAJOHNSON 
21. 
Describe any words or actions that you made to assure the Plaintiff that sexual 
activity with you was propera or appropriate? 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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. 
22. 
Describe what age you thought the Plaintiff was when you first had sexual activity 
with her, including your reasons for that belief. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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. 
23. 
State the facts upon which you rely for each affirmative defense in your answer. 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant 
questions regarding this lawsuit, however, my attorneys have counseled 
me that I cannot provide answers to any questions 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 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, Defendant objects as the interrogatory is so overbroad and, 
17 
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Document 196 
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Page 18 of 20 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
thus, seeks information that is neither relevant to the subject matter of the 
pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. No answer has yet been filed, so not 
applicable. 
CONCLUSION 
For all these reasons, the Court should compel Epstein to answer the 
interrogatories or provide a particularized justification for his Fifth Amendment 
invocation with regard to each request. Epstein should also be required to produce a 
privilege log. Counsel for Jane Doe have conferred with opposing counsel on the 
issues raised in this motion, and no resolution was possible. 
DATED July 10, 2009 
Respectfully Submitted, 
s/ Bradley J. Edwards 
Bradley J. Edwards 
ROTHSTEIN ROSENFELDT ADLER 
Las Olas City Centre 
401 East Las Olas Blvd., Suite 1650 
Fort Lauderdale, Florida 33301 
Telephone (954) 522-3456 
Facsimile (954) 527-8663 
Florida Bar No.: 542075 
E-mail: bedwardsOrra-law.com 
and 
Paul G. Cassell 
Pro Hac Vice 
332 S. 1400 E. 
Salt Lake City, UT 84112 
Telephone: 801-585-5202 
Facsimile: 
801-585-6833 
E-Mail: 
cassellpPlaw.utah.edu 
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Entered on FLSD Docket 07/10/2009 
Page 19 of 20 
CASE NO: 08-CV-80119-MARRA/JOHNSON 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on July 10, 2009, I electronically filed the foregoing 
document with the Clerk of the Court using CM/ECF. I also certify that the foregoing 
document is being served this day on all parties on the attached Service List in the 
manner specified, either via transmission of Notices of Electronic Filing generated by 
CM/ECF or in some other authorized manner for those parties who are not authorized to 
receive electronically filed Notices of Electronic Filing. 
s/ Bradley J. Edwards 
Bradley J. Edwards 
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Case 9:08-cv-80119-KAM 
Document 196 
Entered on FLSD Docket 07/10/2009 
Page 20 of 20 
CASE NO: 08-CV-80119-MARRAAJOHNSON 
SERVICE LIST 
Jane Doe I. Jeffrey Epstein 
United States District Court, Southern District of Florida 
Jack Alan Goldberger, Esq. 
[email protected] 
Robert D. Critton, Esq. 
[email protected] 
Isidro Manual Garcia 
[email protected] 
Jack Patrick Hill 
[email protected] 
Katherine Warthen Ezell 
[email protected] 
Michael James Pike 
[email protected] 
Paul G. Cassell 
[email protected] 
Richard Horace Willits 
[email protected] 
Robert C. Josefsberg 
[email protected] 
Adam D. Horowitz 
[email protected] 
Stuart S. Mermelstein 
[email protected] 
William J. Berger 
[email protected] 
20 
EFTA00221928