EFTA00728201

'Case 9:08-cv-80119-KAM 
Document 57-3 
Entered on FLSD Docket 03/02/2009 
Page 14 of 24 
Jane Doe No. 2 v. Epstein 
Page 14 
Request No. 14. Any and all documents consisting of, referring or relating to 
communications between Jeffrey Epstein and 
, including, but not 
limited to, letters, notes, text messages, messages on social networking sites, 
and e-mails. 
Response: Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. 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. 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, the 
information sought is privileged and confidential, and inadmissible pursuant to 
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 
408, and §90.410, Fla. Stat. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
In addition, the request seeks 
information concerning persons, not parties to this litigation, whose privacy rights 
are implicated. Plaintiffs complaint alleges a time period of "in or about 2004 — 
2005." Plaintiffs request has no time limitation. 
EFTA00728241

'Case 9:08-cv-80119-KAM 
Document 57-3 
Entered on FLSD Docket 03/02/2009 
Page 15 of 24 
Jane Doe No. 2 v. Epstein 
Page 15 
Request No. 15. Any and all documents consisting of, referring or relating to 
communications between Jeffrey Epstein and 
MI, including, but not 
limited to, letters, notes, text messages, messages on social networking sites, 
and e-mails. 
Response: Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. 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. 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, the 
information sought is privileged and confidential, and inadmissible pursuant to 
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 
408, and §90.410, Fla. Stat. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
In addition, the request seeks 
information concerning persons, not parties to this litigation, whose privacy rights 
are implicated. Plaintiff's complaint alleges a time period of "in or about 2004 — 
2005." Plaintiffs request has no time limitation. 
EFTA00728242

Case 9:08-cv-80119-KAM 
Document 57-3 
Entered on FLSD Docket 03/02/2009 
Page 16 of 24 
Jane Doe No. 2 v. Epstein 
Page 16 
Request No. 16. Any and all documents consisting of, referring or relating to 
communications between Jeffrey Epstein and Nada a, 
including, but 
not limited to, letters, notes, text messages, messages on social networking 
sites, and e-mails. 
Response: Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. 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. 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, the 
information sought is privileged and confidential, and inadmissible pursuant to 
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 
408, and §90.410, Fla. Stat. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
In addition, the request seeks 
information concerning persons, not parties to this litigation, whose privacy rights 
are implicated. Plaintiffs complaint alleges a time period of "in or about 2004 — 
2005." Plaintiffs request has no time limitation. 
EFTA00728243

Case 9:08-cv-80119-KAM 
Document 57-3 
Entered on FLSD Docket 03/02/2009 
Page 17 of 24 
Jane Doe No. 2 v. Epstein 
Page 17 
Request No. 17. Any and all documents consisting of, referring or relating to 
communications between Jeffrey Epstein and Ghislaine Maxwell, including, but 
not limited to, letters, notes, text messages, messages on social networking 
sites, and e-mails. 
Response: Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. 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. 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, the 
information sought is privileged and confidential, and inadmissible pursuant to 
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 
408, and §90.410, Fla. Stat. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
In addition, the request seeks 
information concerning persons, not parties to this litigation, whose privacy rights 
are implicated. Plaintiffs complaint alleges a time period of "in or about 2004 — 
2005." Plaintiffs request has no time limitation. 
EFTA00728244

Case 9:08-cv-80119-KAM 
Document 57-3 
Entered on FLSD Docket 03/02/2009 
Page 18 of 24 
Jane Doe No. 2 v. Epstein 
Page 18 
Request No. 18. Any and all documents and photographs placed by Defendant 
at any time in the period of these requests on a social networking website, 
including without limitation, Facebook.com and MySpace.com. 
Response: Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. 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. 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, the 
information sought is privileged and confidential, and inadmissible pursuant to 
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 
408, and §90.410, Fla. Stat. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
In addition, the request seeks 
information concerning persons, not parties to this litigation, whose privacy rights 
are implicated. Plaintiffs complaint alleges a time period of "in or about 2004 — 
2005." Plaintiff's request seeks documents and photographs for a time period of 
January 1, 2003 until present. 
EFTA00728245

Case 9:08-cv-80119-KAM 
Document 57-3 
Entered on FLSD Docket 03/02/2009 
Page 19 of 24 
Jane Doe No. 2 v. Epstein 
Page 19 
Request No. 19. 
Any and all documents reflecting or consisting of 
communications between Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, 
relating or referring to females coming into the United States from other countries 
to pursue a career in modeling, including, but not limited to, letters, notes and e-
mails. 
Response: Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. 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. 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, the 
information sought is privileged and confidential, and inadmissible pursuant to 
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 
408, and §90.410, Fla. Stat. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
In addition, the request seeks 
information concerning persons, not parties to this litigation, whose privacy rights 
are implicated. Plaintiffs complaint alleges a time period of "in or about 2004 — 
EFTA00728246

Case 9:08-cv-80119-KAM 
Document 57-3 
Entered on FLSD Docket 03/02/2009 
Page 20 of 24 
Jane Doe No. 2 v. Epstein 
Page 20 
2005." In addition, the request seeks documents pertaining to females who are 
not non-parties, and who possess privacy rights. 
Request No. 20. Any and all documents referring or relating to gifts or loans to 
females under the age of 21, including, but not limited to, notes, receipts and car 
rental agreements. 
Response: Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. 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. 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, the 
information sought is privileged and confidential, and inadmissible pursuant to 
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 
408, and §90.410, Fla. Stat. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
In addition, the request seeks 
information concerning persons, not parties to this litigation, whose privacy rights 
are implicated. Plaintiffs complaint alleges a time period of "in or about 2004 — 
2005." Plaintiffs request has no time limitation. 
EFTA00728247

Case 9:08-cv-80119-KAM 
Document 57-3 
Entered on FLSD Docket 03/02/2009 
Page 21 of 24 
Jane Doe No. 2 v. Epstein 
Page 21 
Request No. 21. Any and all personal calendars or schedules of or for Jeffrey 
Epstein from January 1, 2003 to the present. 
Response: Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. 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. 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, the 
information sought is privileged and confidential, and inadmissible pursuant to 
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 
408, and §90.410, Fla. Stat. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
In addition, the request seeks 
information concerning persons, not parties to this litigation, whose privacy rights 
are implicated. Plaintiffs complaint alleges a time period of "in or about 2004 — 
2005." In addition, the request encompasses attorney-client privileged material. 
Request No. 22. All documents written by Jeffrey Epstein consisting of personal 
thoughts, feelings or descriptions of events, incidents or occurrences in 
Defendant's life, including without limitation, any diaries of Jeffrey Epstein. 
EFTA00728248

Case 9:08-cv-80119-KAM 
Document 57-3 
Entered on FLSD Docket 03/02/2009 
Page 22 of 24 
Jane Doe No. 2 v. Epstein 
Page 22 
Response: Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. 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. 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, the 
information sought is privileged and confidential, and inadmissible pursuant to 
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 
408, and §90.410, Fla. Stat. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
In addition, the request seeks 
information concerning persons, not parties to this litigation, whose privacy rights 
are implicated. Plaintiffs complaint alleges a time period of "in or about 2004 - 
2005." On its fact, the request goes beyond the scope of allowable discovery 
and is meant to harass, embarrass and overburden the Defendant. Further, the 
request is so overly broad that it includes attorney-client and work product 
privileged materials. 
Request No. 23. All documents referring to or relating to Jeffrey Epstein's 
purchase or consumption of prescription medicine. 
EFTA00728249

Case 9:08-cv-80119-KAM 
Document 57-3 
Entered on FLSD Docket 03/02/2009 
Page 23 of 24 
Jane Doe No. 2 v. Epstein 
Page 23 
Response: Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. 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. 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, the 
information sought is privileged and confidential, and inadmissible pursuant to 
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 
408, and §90.410, Fla. Stat. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
In addition, the request seeks 
information concerning persons, not parties to this litigation, whose privacy rights 
are implicated. Plaintiffs complaint alleges a time period of "in or about 2004 — 
2005." Defendant's medical condition is not at issue in this action. Such a 
request is meant to harass and embarrass Defendant. Further, such information 
is privileged pursuant to Fed. Rule 501 and §90.503, Fla. Stat. In addition, such 
information is protected by the provisions of the Health Insurance Portability and 
Accountability Act (HIPAA). 
EFTA00728250

Case 9:08-cv-80119-KAM 
Document 57-3 
Jane Doe No. 2 v. Epstein 
Page 24 
Entered on FLSD Docket 03/02/2009 
Page 24 of 24 
Certificate of Service 
WE HEREBY CERTIFY that a true copy of the foregoing has been sent 
via U.S. Mail and facsimile 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 
Fax: 561-835-8691 
Co-Counsel for Defendant Jeffrey 
Epstein 
Respectfully su 
By: 
ROBERT I. CRITTON, JR., ESQ. 
Florida B. No. 224162 
MICHAEL J. PIKE, ESQ. 
Florida Bar #617296 
LUTTIER & 
COLEMAN.
515 N. Flagler Drive, Suite 400 
West Palm Beach, FL 33401 
561-842-2820 
Fax: 561-515-3148 
(Co-counsel for Defendant Jeffrey Epstein) 
EFTA00728251

* Case 9:08-cv-80119-KAM 
Document 57-4 
Entered on FLSD Docket 03/02/2009 
Page 1 of 2 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA-JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
v. 
JEFFREY EPSTEIN, 
Defendant. 
DEFENDANT JEFFREY EPSTEIN'S RESPONSE & OBJECTIONS TO 
SECOND REQUEST FOR PRODUCTION, dated December 19, 2008 
Defendant, JEFFREY EPSTEIN, by and through his undersigned 
attorneys, serves his responses and objections to the Request to Produce, dated 
December 19, 2008 and states: 
Request No. 1. 
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. 
Response: Objection, overly broad, not relevant and material and not 
calculated to lead to the discovery of admissible evidence. Plaintiff alleged 
claims occurred during a specific time period in 2004 - 2005, yet to be 
specifically identified. Yet, no time period whatsoever is set forth in the Request 
for Production. Additionally, Defendant objects in that the policies contain value 
and/or asset information which is not relevant, material nor calculated to lead to 
the discovery of admissible evidence at this point in time; said information is both 
private and confidential. 
EXHIBIT "C" 
EFTA00728252

Case 9:08-cv-80119-KAM 
Dqcument 57-4 
Jane Doe No. 2 v. Epstein(
Page 2 
Entered on FLSD Docket 03/02/2009 
Page 2 of 2 
Certificate of Service 
WE HEREBY CERTIFY that a true copy of the foregoing has been sent 
via U.S. Mail and facsimile 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 
Fax: 561-835-8691 
Go-uounseTtbr uetendant Jeffrey 
Epstein 
Respectfully sub 
By: 
ROBER I URI F IONTJR., ESQ. 
Florida Ba' No. 224162 
SQ. 
Florida Rar #617246 
—BURMAN, CRITTON, LUTTIER & 
COLEMAN 
515 N. Flagler Drive, Suite 400 
West Palm Beach, FL 33401 
561-842-2820 
Fax: 561-515-3148 
(Co-counsel for Defendant Jeffrey Epstein) 
EFTA00728253