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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA/JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
PLAINTIFF'S MOTION TO COMPEL ANSWERS TO 
INTERROGATORIES AND PRODUCTION OF DOCUMENTS, 
AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT 
Plaintiff, by and through undersigned counsel, files this Motion to Compel Answers to 
Interrogatories and Production of Documents, and Memorandum of Law in Support, pursuant to 
Fed.R.Civ.P. 26 and 37 and S.D.Fla.L.R. 26.1(H)(2), as follows: 
I. 
INTRODUCTION 
Plaintiff in this case propounded 17 interrogatories and 24 documents requests. In response, 
Defendant has produced no information and no documents. Defendant's principal objection 
concerns his Fifth Amendment privilege against self-incrimination. Defendant, however, fails to set 
forth a sufficient predicate in his responses to interrogatories or documents requests for his refusal to 
provide any responsive documents or information. Defendant, rather, repeats in each response an 
all-encompassing, blanket assertion of Fifth Amendment privilege. 
Defendant's responses also include a laundry list of objections to Plaintiff's interrogatories 
and documents requests, none of which serve as a basis for a denial of all discovery. For the reasons 
discussed below, Plaintiff requests an order compelling Defendant to answer interrogatories and 
produce responsive documents.' 
' This Motion addresses almost entirely general or blanket objections to discovery, which are 
repeated in multiple or all of the Defendant's responses to Plaintiff's discovery requests. 
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II. 
EPSTEIN'S BLANKET ASSERTION OF PRIVILEGE 
AGAINST SELF-INCRIMINATION IN RESPONSES 
TO INTERROGATORIES IS INSUFFICIENT 
Defendant's response to each and every one of Plaintiff's Interrogatories2 contains the 
following privilege objection: 
I intend to respond to all relevant questions regarding this lawsuit, 
however, my attorney has counseled me that I must accept this advice 
or risk losing my Sixth Amendment right to effective representation. 
Accordingly, I assert my federal constitutional rights under the Fifth, 
Sixth, and Fourteenth Amendments as guaranteed by the United 
States Constitution. 
Defendant's canned objection represents a "blanket" refusal to answer questions in this civil 
case. See Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987) (rejecting a "blanket" refusal to 
testify as unacceptable). While Plaintiff does not dispute that Defendant Epstein's Fifth Amendment 
privilege may be asserted in a civil case,; the Fifth Amendment's "protection must be confined to 
instances where the witness has reasonable cause to apprehend danger from a direct answer." 
Hoffman v. United States, 341 U.S. 479, 486 (1951) (emphasis supplied). 
"[A] witness has some minimal burden to justify invocation of the privilege." In re I.M.V.. 
Inc. 90 F.R. 737, 739 (Bankr. E.D. Pa. 1988). The privilege must be asserted in response to a 
particular question, and in each instance "[i]t is for the court to decide whether a witness' silence is 
justified and to require him to answer if it clearly appears to the Court that the witness asserting the 
privilege is mistaken as to its validity." In re Morganroth, 718 F.2d 161, 166-167 (6th Cir. 1983) 
Accordingly, Plaintiff deviates where necessary from the format set forth in S.D.Fla.L.R. 26.1(H)(2) 
in the interests of clarity and efficiency. 
'Attached as Exhibit "A" is Defendant's Response and Objections to Plaintiff's Interrogatories. 
3 This discussion addresses the Defendant's Fifth Amendment claim of privilege. Defendant also 
asserts a privilege under the Sixth and Fourteenth Amendments. The Sixth Amendment does not 
provide a basis to refuse to answer questions in a civil case as a means to preserve the Defendant's 
"right to effective representation", as Defendant asserts in his responses. 
The Fourteenth 
Amendment likewise is inapposite, as state action is not at issue in this federal case. 
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(holding that it was not sufficient for witness to answer every question with conclusory assertion of 
Fifth Amendment privilege). Accord Anglada, 822 F.2d at 1037 (noting that Court should not have 
to speculate as to which questions would tend to incriminate)• See also Hoffman, 341 U.S. at 486 
(witness' "say-so does not of itself establish the hazard of self-incrimination"); In re Wincek 202 
B.R. 161, 168 (Bankr. M.D. Fla. 1996) (rejecting assertion of Fifth Amendment privilege in "broad, 
unsupported fashion"). 
The "reasonable cause" for invocation of the Fifth Amendment privilege is not self-evident 
from the interrogatories propounded by Plaintiff. For example, Interrogatory no. 1 asks the 
Defendant to identify employees who performed work or services at his Palm Beach residence. It is 
not apparent that identifying the chef, chauffeur, gardener, etc., would tend to incriminate the 
Defendant. The information sought in the bulk of the Plaintiff's interrogatories may be categorized 
generally as follows: 
Type of Information 
Interrogatory No. 
identification of persons 
Defendant's travel schedule and 
locations 
identification of health care providers 
telephone numbers used by Epstein 
and his employees 
general information based on Florida 
Standard Interrogatories, Fla.R.Civ.P. 
Form 2, nos. 7, 10, 12 
I, 2, 3, 4, 5, 6, 10, 17 
7 
8 
II, 12 
13, 14, 164
These Interrogatories, on their face, do not infringe upon or otherwise implicate the 
Defendant's rights under the Fifth Amendment. It is, therefore, incumbent upon the Defendant to set 
forth reasonable cause for his invocation of the Fifth Amendment in response to each of these 
Plaintiff does not challenge at this time Defendant's assertion of a Fifth Amendment privilege in 
response to interrogatory no. 9, which seeks information on Defendant's sexual aids. 
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Interrogatories. Absent some interrogatory-by-interrogatory showing of reasonable cause, Plaintiff 
asks that Defendant's claims of privilege under the Fifth Amendment be rejected and overruled. 
III. 
DEFENDANT'S BLANKET ASSERTION OF 
FIFTH AMENDMENT PRIVILEGE IN RESPONSE 
TO REQUESTS FOR PRODUCTION IS INSUFFICIENT 
In response to Plaintiff's Requests for Production,5 Defendant has asserted an identical, 
"blanket" objection to each and every request, as follows: 
I intend to produce all relevant documents regarding this lawsuit. 
However, my attorneys have counseled me that at the present time I 
cannot select, authenticate, and produce documents relevant to this 
lawsuit and I must accept this advice or risk losing my Sixth 
Amendment right to effective representation. Accordingly, I assert 
my federal constitutional rights under the Fifth, Sixth, and Fourteenth 
Amendments as guaranteed by the United States Constitution. 
Initially, it 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). Accordingly, a party cannot avoid discovery merely because 
demanded documents contain incriminating evidence, "whether written by others or voluntarily 
prepared by himself." Id. 
Nonetheless, the act of procuring documents may be considered testimonial and protected by 
the Fifth Amendment privilege in two instances: (1) if the existence and location of the documents 
are unknown; or (2) where production would "implicitly authenticate" the documents. 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). It is the Defendant's 
Defendant's Response to Request for Production, which sets forth each Request and the 
Defendant's Response, is attached hereto as Exhibit "B". 
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burden to demonstrate that the act of producing any particular responsive documents would entail 
testimonial self-incrimination. United States v. Wujkowski, 929 F.2d 981, 984 (4th Cir. 1991). It is 
not self-evident or apparent from the Plaintiff's requests that the act of producing responsive items 
would be protected under the Fifth Amendment. In particular, there is no reason to believe that 
production of documents in response to the following requests would compel testimonial self-
incrimination: 
Types of Documents Requested 
Request Nos. 
Agreements with the U.S. Attorney 
and State Attorney, and documents 
exchanged between Defendant and 
the U.S. Attorney or State Attorney 
1-4 
Telephone records 
5-6 
Videos, photographs of residence 
7 
Documents relating to Plaintiff Jane Doe 
8 
Air travel records 
10 
Documents relating to modeling agencies 
I 1 
Correspondence with other witnesses 
14, 15, 16, 17, 19 
Social networking documents 
18 
Gifts to minor females 
20 
Personal calendars, diaries 
21, 22 
Prescription medicines 
236
As to the above-listed items, it is not possession or control of these items that would prove 
incriminating; rather, if anything, it is their contents, which are not protected by the Fifth 
Amendment privilege so long as they were created voluntarily. Fisher 425 U.S. at 410; see also In 
`Plaintiff concedes that the act of producing items in response to request no. 9, concerning witness 
statements, and request nos. 12-13, concerning photographs or images of females, may implicate the 
Fifth Amendment. 
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re Ross 156 B.R. 272, 177-78 (Bankr. D. Idaho 1993). Nor would production of items in response 
to these requests "implicitly authenticate" items that are themselves incriminating. See In re Grand 
Jury Subpoena 1 F.3d at 93-94 (holding that defendant's calendar/diary not protected from 
discovery by "act of production" doctrine under the Fifth Amendment). 
Without more, therefore, Defendant's blanket claim of a Fifth Amendment privilege in 
response to all of Plaintiff's document requests should be rejected, and responsive documents 
ordered to be produced. 
IV. 
DEFENDANT'S OBJECTION AND STATEMENT CONCERNING 
ADVERSE INFERENCE IS INAPPROPRIATE AND INCORRECT 
Defendant makes the following self-serving and unnecessary assertion in response to each 
and every interrogatory and document request propounded by Plaintiff: 
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. 
Although a defendant's assertion of his Fifth Amendment privilege cannot be used against a 
criminal defendant, it is well established that "an adverse inference based on a refusal to testify in a 
civil case is an appropriate remedy as it provides some relief to the civil litigant whose case is 
unfairly prejudicial by a witness' assertion of the Fifth Amendment privilege ..." United States v. 
Custer Battles, L.L.C., 415 F. Supp. 2d 628, 632 (E.D. Va. 2006); accord Basler v. Palmigiano, 425 
U.S. 408, 318 (1976) ("the Fifth Amendment does not forbid adverse inferences against parties to 
civil actions when they refuse to testify in response to probative evidence offered against them"); 
Securities and Exhange Comm'n v. Graystone Nash, Inc., 25 F.3d 187, 190 (3d Cir. 1994) ("[t]he 
[defendant's] dilemma of choosing between complete silence and presenting a defense [in a civil 
case] does not fatally infect the right against compelled self-incrimination").7
'Moreover, a defendant in a civil case may not manipulate his use of the Fifth Amendment privilege 
by shielding himself from inquiries during discovery, and then submitting surprise testimony in a 
summary judgment affidavit or at trial. Id. at 191. 
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In any event, the issue of adverse inference, at this juncture, is premature. It is first 
necessary to determine whether the Fifth Amendment privilege is validly asserted in response to 
particular questions. This issue is typically resolved on a motion to compel. Custer Battles 415 F. 
Supp. 2d at 633. If it is determined that the privilege is properly asserted, then adverse inferences 
are admissible consistent with the Rules of Evidence, i.e., where they are relevant, reliable and not 
unfairly prejudicial, confusing or cumulative. Id. at 634. Such evidentiary issues concerning 
adverse inference are appropriately addressed at the time of summary judgment or trial. It is 
inappropriate and unnecessary to challenge the use of adverse inferences through self-serving 
statements in blanket objections to interrogatories. 
V. 
PLAINTIFF IS ENTITLED TO DEFENDANT'S 
HEALTH CARE INFORMATION IN DISCOVERY 
A. 
Interrogatory at Issue 
"Interrogatory No. 8. Identify all of Jeffrey Epstein's health care providers in the past (10) 
ten years, including without limitation, psychologists, psychiatrists, mental health counselors, 
physician, hospital and treatment facilities." 
B. 
Pertinent Portion of Defendant's Objection 
. . [s]uch information is privileged pursuant to Rule 501, Fed.Evid., and §90.503, Fla.Evd. 
Code. In addition, such information is protected by the provision of the Health Insurance Portability 
and Accountability Act (HIPAA)." 
C. 
Grounds for Objection and Reasons for Motion 
The substantive basis for Defendant's objection is a claim of privilege under state law, 
Florida Statute §90.503 (psychotherapist-patient privilege) and federal law, HIPAA, 42 U.S.C. 
§1320d et seq. Neither of these privilege claims are a basis to withhold relevant health care 
information in this case. Initially, Florida Statute §90.503 does not protect as privileged the identity 
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of health care providers, which is all that is sought in Plaintiffs interrogatory. Rather, it protects 
"confidential communications" with a psychotherapist. Florida Statute §90.503(2). Further, 
Plaintiff is ultimately entitled to discovery from the Defendant's psychotherapists because §90.503 
does not apply to relevant documents in a case of child abuse under Florida Statute §39.204. This 
Statute abrogates the psychotherapist-patient privilege in cases involving child abuse: 
Abrogation of privileged communications in cases involving child 
abuse, abandonment, or neglect.- the privileged quality of 
communication . . . between any professional person and his or her 
patient or client, and any other privileged communication except that 
between attorney and client or the privilege provided ins. 90.505, as 
such communication relates both to the competency of the witness 
and to the exclusion of confidential communications, shall not apply 
to any communication involving the perpetrator or alleged 
perpetrator in any situation involving known or suspected child 
abuse.... 
(Emphasis supplied).8 "With the exceptions of the attorney-client privilege and the clergy 
communications privilege, section 39.204 abrogates the various evidentiary privileges in cases 
involving child abuse, abandonment or neglect." Nussbaumer v. State 882 So.2d 1067 (Fla. 2d 
DCA 2004). It represents a determination by the legislature that discovery of facts relating to claims 
of child abuse is more important than the protection of otherwise confidential psychotherapist-
patient communications: 
Obviously, the psychotherapist privilege provided by section 
90.503(2) is intended to encourage people who need treatment for 
mental disorders (including child abusers) to obtain it by insuring the 
confidentiality of communication during treatment. We must assume, 
however, that the legislature, in passing [§39.204] weighed the 
desirability of encouraging treatment for child abusers against the 
desirability of discovering them and decided that the latter was more 
important than the former. The intent of [§39.204] is to discourage 
child abuse. That discouragement, in view of the statutory language, 
can occur by way of a civil lawsuit for damages as well as by way of 
'The term "child abuse" is defined broadly in the Statute to encompass the acts and conduct alleged 
against Epstein in this case. A "child" is a person under the age of 18, and "abuse" means "any 
willful or threatened act that results in any physical, mental, or sexual injury or harm that causes or 
is likely to cause the child's physical, mental or emotional health to be significantly impaired." 
Florida Statutes §39.201. 
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a criminal prosecution. 
Carson v. Jackson, 466 So.2d 1188, 1190 (Fla. 4th DCA 1985) (analyzing predecessor statute, 
§415.512, Fla. Stat.). 
Defendant also asserts HIPAA, the Health Insurance Portability and Accountability Act, 42 
U.S.C. §1320d et seq., as a ground for objection to Plaintiff's interrogatory. "HIPAA does not 
create substantive rights that act as a bar on discovery. . . . HIPAA regulations is (sic) purely 
procedural in nature and does not create a federal physician-patient or hospital-patient privilege." 
Allen v. Woodford 2007 WL 309485 *I I (E.D. Cal. 2007). Under HIPAA, health care information 
may be disclosed in discovery under a qualified protective order, which prohibits using or disclosing 
protected health care information for any purpose other than the litigation and requires return or 
destruction of the protected health care information. 45 C.F.R. §164.512(i)(e). Accordingly, there is 
no basis to withhold from discovery Epstein's health care information, particularly as it relates to 
Plaintiff's allegations of child abuse. 
VI. 
DEFENDANT HAS NO VALID GROUNDS FOR OBJECTION 
TO PRODUCTION OF INSURANCE DOCUMENTS 
A. 
Item to be Compelled 
Plaintiff's Second Request for Production contains a single request for insurance documents, 
as follows: 
All policies of insurance, including the declarations page and all 
binders, amendments, and endorsements, covering Defendant's 
residence at 358 El Brillo Way, Palm Beach, FL 33480. 
B. 
Specific Objections and Grounds 
Defendant provided no responsive documents and objected9 on grounds that (i) no time 
period is specified, other than the 2004-05 time period for the events alleged in the Complaint; (ii) 
A copy of Defendant's Response and Objections to Second Request for Production is attached 
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the policies "contain value and/or asset information which is not relevant, material nor calculated to 
lead to discovery of admissible evidence."; and (iii) "said information is both private and 
confidential". 
C. 
Reasons for Motion 
Plaintiff's request for insurance documents is reasonable under the circumstances of this 
case, and well within the scope of Fed.R.Civ.P. 26. Requests for such insurance documents are 
common and typical in cases alleging personal injuries. Plaintiff agrees to limit such request to 
policies covering the years 2003, 2004 and 2005, which is reasonable. Defendant's objections 
should therefore be overruled. 
VII. 
OTHER OBJECTIONS TO PLAINTIFF'S 
DISCOVERY REOUESTS ARE MERITLESS 
A. 
Overbroad; Relevance 
In response to each and every interrogatory propounded by Plaintiff, Defendant asserts in 
blanket and conclusory fashion that it is "overbroad and seeks information that is neither relevant to 
the subject matter of the pending action nor dies it appear reasonably calculated to lead to the 
discovery of admissible evidence." Defendant also objects to each and every document request as 
overbroad. These objections are groundless. Plaintiff's discovery requests fall within the scope of 
broad discovery and relevance under Fed.R.Civ.P. 26. All of Plaintiff's interrogatories and 
document requests are sufficiently narrow and tailored for Defendant to reasonably provide 
substantive responses. Defendant fails to indicate unfair prejudice or undue burden from any 
interrogatory or document request. Defendant provides no responsive information whatsoever, nor 
has he made any suggestion to reasonably narrow or limit any of the Plaintiff's discovery requests. 
Defendant complains that the time period covered in the interrogatories is too broad. The 
stated time period, applicable to Plaintiff's interrogatories and documents requests generally, as 
as Exhibit "C". 
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noted in Defendant's responses, is January 1, 2003 to present. This time frame is sufficiently 
narrow, especially since the plan and scheme alleged in the Complaint to lure girls to the 
Defendant's Palm Beach mansion for "massages" has been in place since at least that date. 
Defendant's overbroad/relevance objections should, accordingly, be overruled. 
B. 
Work Product; Attorney-Client Privilege 
In response to various interrogatories and all of the documents requests, Defendant asserts in 
conclusory fashion objections based on the attorney work product and attorney-client 
communication privilege. I° In making these privilege claims, Defendant failed to provide a 
privilege log as required by S.D.Fla.L.R. 26.1(G)(3). These interrogatories and requests generally 
do not on their face implicate the work product or attorney client privileges." These privilege 
claims should therefore be rejected and overruled. 
C. 
Plaintiff's Definitions of "Employee is Reasonable 
Defendant contests the definition of "Employee" in Plaintiff's document requests and 
interrogatories, which states as follows: 
g. 
"Employee" shall mean any person employed to perform 
work for services for Defendant or by Defendant, either directly or 
indirectly, including without limitation: 
i. 
a limited partnership, corporation, limited liability 
company, or other company or entity in which Defendant is a 
member, director, officer or person in control; and 
ii. 
persons employed by a partnership or a subsidiary of a 
partnership in which Defendant is a general partner or person in 
control. 
'These privileges are asserted in response to Interrogatory nos. 13, 14, and 17, and each and every 
document request. 
11 The only possible exception would be Plaintiff's Document Request no. 9, which seeks witness 
statements; nonetheless, Defendant is required to comply with the Local Rule and provide a 
privilege log in response to this request as well as the others. 
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The term "Employee" appears in Interrogatory nos. 1, 2, and Document Request no. 6. The 
breadth of this definition is reasonable under the circumstances of this case. Upon information and 
belief, Defendant Epstein conducted his business and personal affairs through a labyrinth of 
corporate entities and other business forms. This definition of "Employee" is reasonable to 
encompass responsive information and documents. 
D. 
Fed.R.Civ.P. 408 and 410 Do Not 
Create a Privilege in Discovery 
Defendant objects to Document Request nos. 1-5, which seek the Defendant's agreements 
with the U.S. Attorney and State Attorney, and documents exchanged with their offices, on the 
grounds of Fed.R.Evid. 408 and 410. These Rules cover the admissibility in evidence of 
compromises and plea agreements; they do not set forth a privilege applicable to such agreements in 
discovery. To the extent a protective order with regard to such documents is deemed appropriate, 
Plaintiff's counsel agrees to limit their use to this litigation, and not to disclose documents 
responsive to these requests to third parties. 
E. 
Third Party Pri‘ile% Rights 
Defendant broadly and vaguely asserts third party privacy rights in response to various 
document requests. To the extent that any such privacy rights are properly raised in this case, 
Plaintiff consents to the entry of an appropriate protective order under which such documents will 
not be disseminated to third parties and will be used only for purposes of this litigation. 
VIII. Conclusion 
Based on the foregoing, Plaintiff respectfully requests that Defendant's assertions of 
privilege and objections be denied and overruled, and that an Order be entered directing Defendant 
to answer the Plaintiff's Interrogatories and produce documents responsive to Plaintiff's Requests 
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for Production, subject to such protective order as may be necessary and appropriate. Plaintiff 
further requests such other relief as this Court deems just and proper. 
Dated: March 2, 2009 
Respectfully submitted, 
By: 
s/ Adam D. Horowitz 
Stuart S. Mermelstein (FL Bar No. 947245) 
Adam D. Horowitz (It Bar No. 376980) 
MERMELSTEIN & HOROWITZ, P.A. 
Attorneys for Plaintiff 
18205 Biscayne Blvd., Suite 2218 
Miami, Florida 33160 
Tel: 305-931-2200 
Fax: 305-931-0877 
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CERTIFICATE PURSUANT TO S.D.FLA.L.R. 7.1(A)(3) 
Counsel for Plaintiff has made reasonable efforts to confer with counsel for Defendant, by 
letter dated February 25, 2009, seeking in good faith to resolve or narrow the issues raised in the 
Motion, but Defendant's counsel failed to respond to Plaintiff's letter, and Plaintiff's counsel has 
been unable to resolve this dispute. 
s/Adam D. Horowitz 
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CERTIFICATE OF SERVICE 
I hereby certify that on March 2, 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 
to 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 Notices of Electronic Filing. 
s/ Adam D. Horowitz 
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SERVICE LIST 
DOE vs. JEFFREY EPSTEIN 
United States District Court, Southern District of Florida 
Jack Alan Goldberger Es . 
Robert D. Critton, Esq. 
s/ Adam D. Horowitz 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRAa 
JANE DOE NO. 2, 
Plaintiff, 
v. 
JEFFREY EPSTEIN, 
Defendant. 
DOCKET 
912.61O 
DEFENDANT EPSTEIN'S RESPONSE & OBJECTIONS 
TO PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES 
Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, 
serves his responses and objections to Plaintiffs December 9, 2008 Amended First Set 
Of Interrogatories To Defendant Jeffrey Epstein, attached hereto. 
Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing has been sent by fax and 
U.S. Mail to the following addressees this  26th 
 day of January 2009: 
Adam D. Horowitz, Esq. 
Jeffrey Marc Herman, Esq. 
Stuart S. Mermelstein, Esq. 
18205 Biscayne Boulevard 
Suite 2218 
Miami, FL 33160 
305-931-2200 
Fax: 305-931-0877 
counsel for Plaintiff Jane Doe #2 
Jack Alan Goldberger 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach, FL 33401-5012 
561-659-8300 
Far 561-R:i-R6c11 
Co-Counsel for Defendant Jeffrey Epstein 
EXHIBIT "A" 
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Jane Doe No. 2 v. Epstein 
Page 2 
Respectfully su2 
tted, 
By: 
ROBERT 
RITTON, JR., ESQ. 
Florida Ba No. 224162 
MICHAEL J. PIKE, ESQ. 
Florida Bar #617296 
BURMAN, CRITTON, LUTTIER & COLEMAN 
515 N. Flagler Drive, Suite 400 
West Palm Beach, FL 33401 
561/842-2820 Phone 
561/515-3148 Fax 
(Co-Counsel for Defendant Jeffrey Epstein) 
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Jane Doe No. 2 v. Epstein 
Page 3 
DEFENDANT JEFFREY EPSTEIN'S ANSWERS AND OBJECTIONS TO 
PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES 
Interrogatory No. 1. 
Identify all employees who performed work of services inside 
the Palm Beach Residence. 
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 the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant objects as the 
interrogatory is overbroad and 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. Plaintiff's Complaint alleges a time period of "in or 
about 2004-2005." Plaintiffs interrogatory seeks information for a time period from 
January 1, 2003 until present. Also, see "Employee" as defined in paragraph g of 
Plaintiffs interrogatories. 
Interrogatory No. 2. 
Identify all Employees not identified in response to 
interrogatory no. 1 who at any time came to Defendant's Palm Beach Residence. 
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 the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant objects as the 
interrogatory is overbroad and 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. Plaintiffs Complaint alleges a time period of "in or 
about 2004-2005." Plaintiffs interrogatory seeks information for "all Employees" "who at 
any time" came to the residence. Also, see "Employee" as defined in paragraph g of 
Plaintiffs interrogatories. 
EFTA00728219

' Case 9:08-cv-80119-KAM 
Document 57-2 
Entered on FLSD Docket 03/02/2009 
Page 4 of 11 
Jane Doe No. 2 v. Epstein 
Page 4 
Interrogatory No. 3. 
Identify all persons who came to the Palm Beach Residence 
and who gave a massage or were asked to give a massage to Defendant. 
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 the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant objects as the 
interrogatory is overbroad and 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. Plaintiffs Complaint alleges a time period of "in or 
about 2004-2005." 
Interrogatory No. 4. 
Identify all persons who came to the New York Residence 
and who gave a massage or were asked to give a massage to Defendant. 
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 the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant objects as the 
interrogatory is overbroad and 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. Plaintiffs Complaint alleges a time period of "in or 
about 2004-2005." 
Interrogatory No. 5. 
Identify all persons who came to the New Mexico Residence 
and who gave a massage or were asked to give a massage to Defendant. 
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 
EFTA00728220