EFTA01078765

STATE OF 
MUNTY ON 
7j 1C__ 
) 
) ss.: 
1 
I3F.EORE ME• the uridersigneAJatithorits., duly licensed to administer oaths anti take 
acknowledgments. personally appeared , pane Doe No. 3) 
the 
of 
ri i 
 
1. I 
who productd : . •_i 
. 
ft : :as identiication• who 
being by mc first duly sown. deposes and says that he/she has read the foregoing answers to 
interrogatories, and that they an: true and correct. 
RUTH A 90LKEMA 
Notary Public 
Stale et Cciorado 
dm of 
; 
.2015. 
'.1ty l ek!l'i 
1.`r: 
\.:‘ forma isti...1:1 
(NO IARY 
EFTA01078825

EXHIBIT 9 
EFTA01078826

IN THE CIRCUIT COURT OF THE 
17TH JUDICIAL CIRCUIT IN AND FOR 
BROWARD COUNTY, FLORIDA 
CASE NO: CACE 15-000072 
BRADLEY J. EDWARDS and 
PAUL G. CASSELL, 
Plaintiffs/Counterclaim Defendants 
v. 
ALAN DERSHOWITZ, 
Defendant/Counterclaim Plaintiff 
NON-PARTY JANE DOE NO. 3's OBJECTIONS TO DEFENDANT 
ALAN DERSHOWITZ'S SUBPOENA DUCES TECUM 
Jane Doe No. 3, a non-party to this action, pursuant to Fla. R. Civ. P. 1.410(eX1), by and 
through undersigned counsel, hereby objects to the Subpoena Duces Tecum noticed by 
Defendant Alan Dershowitz in its entirety and submits these responses and objections 
("Responses") to the document requests ("Requests") contained therein. 
PRELIMINARY STATEMENT AND GENERAL OBJECTIONS 
Defendant has noticed Non-Party Jane Doe No. 3 with a subpoena duces tecum seeking 
an array of documents that are both irrelevant to this matter and entirely meant to harass and 
place an undue burden on this non-party. Defendant has made very public his disdain for Jane 
Doe No. 3, and has served this subpoena on her in an effort to intimidate and harass this non-
party. Notably, the face of the subpoena demonstrates that Dershowitz is not even seeking 
documents relevant to the matter before this Court and is, instead, attempting to obtain backdoor 
discovery for other actions he wants to bring in an effort to promote his stated goal of finding a 
1 
EFTA01078827

way to send this non-party to "jail." Defendant has stated, for example, "My goal is to bring 
charges against the client and require her to speak in court." See Exhibit I, Australian 
Broadcasting System (ABC), January 6, 2015; "She was hiding in Colorado...but we found her 
and she will have to be deposed. The end result is that she'll go to jail because she will repeat 
her lies and we'll be able to prove it and she will end up in prison for perjury." See also Exhibit 
2, New York Daily News, April 7, 2015. Defendant's subpoena is unreasonable and abusive and 
should be quashed in its entirety for the reasons set forth in Jane Doe No. 3's Motion to Quash. 
Jane Doc No. 3's Responses are subject to the following qualifications, explanations and 
objections which apply to each Request and are incorporated in full by this reference into each 
and every Response below as if fully set forth therein: 
1. 
Non-Party Jane Doe No. 3 responds to the Requests as Jane Doe No. 3 reasonably 
interprets and understands the Requests. Should Defendant subsequently assert an interpretation 
of any individual Request that differs from Jane Doe No. 3's understanding, Jane Doe No. 3 
reserves the right to supplement the Responses. 
2. 
To the extent a Request seeks documents protected from discovery by the 
attorney-client privilege, the work product doctrine, the joint defense doctrine, the common 
interest privilege, or any other privilege or protection, no such documents shall be produced even 
if no specific objection is asserted in response to each individual request. Inadvertent 
identification or production of privileged documents or information is not a waiver of any 
applicable privilege. 
3. 
Non-Party Jane Doe No. 3 objects to the Definitions and Instructions and to each 
Request to the extent they seek to alter or expand upon the obligations imposed by the Florida 
Rules of Civil Procedure or the Local Rules. For example, Jane Doe No. 3 objects to Instruction 
2 
EFTA01078828

no. 3 in that it seeks to impose an obligation for the production of a privilege log on a non-party 
in response to a subpoena duces tecum when no such log is required under Florida law. See West 
Co., Inc. v. Scott Lewis' Gardening & Trimming, Inc., 26 So. 3d. 620, 623 (Ha. 4th DCA 2009) 
(a privilege log is not required from a non-party). 
4. 
Non-Party Jane Doe No. 3 objects to the Definitions and Instructions and to each 
Request to the extent that each calls for the production of documents that are not in the custody, 
possession, or control of Jane Doe No. 3. 
5. 
A statement in response to a specific Request that Jane Doe No. 3 will produce 
documents is not a statement that any such documents exist but, rather, means only that such 
documents that do exist and are responsive to a specific Request will be produced. 
6. 
To the extent that Jane Doe No. 3 produces documents in response to specific 
Requests to which Jane Doe No. 3 has objected, Jane Doe No. 3 reserves the right to maintain 
such objections with respect to any additional information and such objections are not waived by 
the production of responsive documents. 
7. 
Non-Party Jane Doe No. 3 objects to the Requests to the extent they seek private 
and confidential financial information, or confidential information of any kind. 
8. 
Non-Party Jane Doe No. 3 objects to the Requests to the extent they seek personal 
and confidential financial information related to third-parties. 
9. 
Non-Party Jane Doe No. 3 objects to the Requests to the extent that they seek 
documents already in Defendant's possession or to the extent they arc publicly available. 
10. 
Non-Party Jane Doe No. 3 objects to the Requests as overbroad as no time limit 
has been specified for any of the Requests. To the extent the Court directs discovery from this 
3 
EFTA01078829

non-party, it should be limited to the date of the filing of this action, January 6, 2015 to the 
present. 
11. 
Non-Party Jane Doe No. 3 objects to the Requests as they seek to place an undue 
burden on a non-party to the pending litigation. 
RESPONSES AND OBJECTIONS 
I. All documents that reference by name, Alan M. Dershowitzl, which support and/or 
confirm the allegations set forth in Paragraphs 24-31 of your Declaration dated January 19, 2015 
and/or Paragraph 49 of your Declaration dated February 5, 2015, which were filed with the 
United States District Court for the Southern District of Florida, in Jane Doe 41 and Jane Doe #2 
v. United States of America, Case No. 05-50736-0V-MARRA/JOHNSON, [ECF No. 291-1] 
(the "Federal Action"). 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request in that Defendant is wrongfully attempting to use the 
subpoena power in the Florida Defamation Action to obtain backdoor discovery relating to a 
different matter as he admits in his subpoena Request set forth above referencing — Case No. OS-
50736-CIV-MARRA/JOHNSON. Non-Party Jane Doe No. 3 objects to this Request in that it 
seeks information protected by the attorney-client privilege, work product doctrine, joint defense 
doctrine, common interest privilege and other related protections. Non-Party Jane Doe No. 3 
objects to this Request to the extent it seeks confidential information from a non-party. Non-
Party Jane Doe No. 3 objects to this Request as harassing, oppressive and not intended to lead to 
discoverable evidence relevant to the Florida Defamation Action. Non-Party Jane Doe No. 3 
objects to this Request in that it seeks to place an undue burden on this non-party to have to 
search and collect documents that are unrelated to the underlying Florida Defamation Action. 
Non-Party Jane Doe No. 3 objects to this Request to the extent it seeks information that is 
' "For purposes of this Schedule "A", reference to "Alan M. Dershowitz" herein shall mean and 
refer to any reference to the Defendant in this action, including but not limited to, as "Alan", 
"Alan M. Dershowitz", "Professor Dershowitz", or "Dershowitz", and the like." 
4 
EFTA01078830

publicly available. Non-Party Jane Doe No. 3 objects to this Request in that it seeks information 
in the possession, custody and control of the Defendant or it seeks information that has been 
previously produced. 
2. All photographs and video in the original, native format in which they were taken (not 
a paper copy) of you with Alan M. Dershowitz. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request in that it is solely intended to harass and embarrass Jane 
Doe No. 3 by seeking photographs and videos of Jane Doe No. 3 when she was a minor child 
and is not intended to lead to discoverable evidence relevant to the Florida Defamation Action. 
Non-Party Jane Doe No. 3 objects to this Request in that it seeks documents, upon information 
and belief, in the custody and control of the state or federal government. Non-Party Jane Doe 
No. 3 objects to this Request in that it seeks information in the possession, custody and control of 
the Defendant, or in the possession of the Defendant's client, Jeffrey Epstein. Non-Party Jane 
Doe No. 3 objects to this Request to the extent the requested photos and/or videos are publicly 
available. Non-Party Jane Doe No. 3 objects to this Request to the extent it seeks information 
protected by a privilege including attorney-client privilege, work product doctrine, joint defense 
doctrine, common interest privilege and other related protections. Non-Party Jane Doe No. 3 
objects to this Request to the extent it seeks confidential material from a non-party. 
3. All photographs and video in the original, native format in which they were taken (not 
a paper copy) not produced in response to Request No. 2, above, of Alan M. Dershowitz at (i) 
Jeffrey Epstein's Manhattan home in New York City, New York; (ii) Mr. Epstein's home in Palm 
Beach, Florida; (iii) Mr. Epstein's Zorro Ranch in Santa Fe, New Mexico; (iv) Little Saint James 
island in the U.S. Virgin Islands; and (v) Mr. Epstein's airplane, on the same date and time that 
you were also present at such location. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request in that it is solely intended to harass Jane Doe No. 3 by 
5 
EFTA01078831

seeking photographs and videos of Jane Doe No. 3 when she was a minor child and is not 
intended to lead to discoverable evidence relevant to the Florida Defamation Action. Non-Party 
Jane Doe No. 3 objects to this Request in that it seeks documents, upon information and belief, in 
the custody and control of the state or federal government. Non-Party Jane Doe No. 3 objects to 
this Request in that it seeks information in the possession, custody and control of the Defendant, 
or in the possession of the Defendant's client, Jeffrey Epstein. Non-Party Jane Doe No. 3 objects 
to this Request to the extent the requested photos and/or videos are publicly available. Non-
Party Jane Doe No. 3 objects to this Request to the extent it seeks information protected by a 
privilege including attorney-client privilege, work product doctrine, joint defense doctrine, 
common interest privilege and other related protections. Non-Party Jane Doe No. 3 objects to 
this Request to the extent it seeks confidential material from a non-party. Finally, Non-Party 
Jane Doe No. 3 objects to this Request in that defendant is wrongfully attempting to use the 
subpoena power in the Florida Defamation Action to obtain backdoor discovery relating to 
different matters including, the Federal Action, Case No. OS-S0736-CIV-MARRA/JOHNSON, 
which is irrelevant to the matter involved with this subpoena. 
4. All photographs and video in the original, native format in which they were taken (not 
a paper copy) of you not produced in response to Request No.3, above, that evidence and/or 
show you were present at the same location as Alan M. Dershowitz on that same date and time. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request in that it is solely intended to harass and embarrass Jane 
Doe No. 3 by seeking photographs and videos of Jane Doe No. 3 when she was a minor child 
and is not intended to lead to discoverable evidence relevant to the Florida Defamation Action. 
Non-Party Jane Doe No. 3 objects to this Request in that it seeks documents, upon information 
and belief, in the custody and control of the state or federal government. Non-Party Jane Doe 
6 
EFTA01078832

No. 3 objects to this Request in that it seeks information in the possession, custody and control of 
the Defendant, or in the possession of the Defendant's client, Jeffrey Epstein. Non-Party Jane 
Doe No. 3 objects to this Request to the extent the requested photos and/or videos are publicly 
available. Non-Party Jane Doe No. 3 objects to this Request to the extent it seeks information 
protected by a privilege including attorney-client privilege, work product doctrine, joint defense 
doctrine, common interest privilege and other related protections. Non-Party Jane Doe No. 3 
objects to this Request to the extent it seeks confidential material from a non-party. Finally, 
Non-Party Jane Doe No. 3 objects to this Request in that Defendant is wrongfully attempting to 
use the subpoena power in the Florida Defamation Action to obtain backdoor discovery relating 
to different matters including, the Federal Action, Case No. OS-S0736-CIV-
MARRAJJOHNSON, which is irrelevant to the matter involved with this subpoena. 
5. Any documents and information that support and/or confirm your presence at the 
various locations named in Paragraphs 24-31 of your Declaration on the particular dates and 
times when Alan M. Dershowitz was also present. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request in that Defendant is wrongfully attempting to use the 
subpoena power in the Florida Defamation Action to obtain backdoor discovery relating to 
different matters including, the Federal Action, Case No. OS-S0736-CIV-MARRA/JOHNSON. 
This Request specifically references a declaration filed in the Federal Action, not in the Florida 
Defamation Action, which is the case governing this subpoena. Non-Party Jane Doe No. 3 
objects to this Request in that it seeks information protected by the attorney-client privilege, 
work product doctrine, joint defense doctrine, common interest privilege and other related 
protections. Non-Party Jane Doe No. 3 objects to this Request to the extent it seeks confidential 
information from this non-party. Non-Party Jane Doe No. 3 objects to this Request as harassing 
7 
EFTA01078833

and not intended to lead to discoverable evidence relevant to the Florida Defamation Action. 
Non-Party Jane Doe No. 3 objects to this Request in that it seeks to place an undue burden on 
this non-party to have to search and collect documents that are unrelated to the underlying 
Florida Defamation Action. Non-Party Jane Doe No. 3 objects to this Request to the extent it 
seeks information that is publicly available. Non-Party Jane Doe No. 3 objects to this Request in 
that it seeks information in the possession, custody and control of the Defendant, the Defendant's 
client, Jeffrey Epstein, or it seeks information that has been previously produced. 
6. Any documents and information that show Alan M. Dershowitz was present at the 
various locations named in Paragraphs 24-31 of your Declaration on the particular dates and 
times when you allege to have been present in your response to Request No.5, above. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request in that Defendant is wrongfully attempting to use the 
subpoena power in the Florida Defamation Action to obtain backdoor discovery relating to 
different matters including, the Federal Action, Case No. OS-S0736-CIV-MARRAJJOIINSON. 
This Request specifically references a declaration filed in the Federal Action, not in the Florida 
Defamation Action, which is the case governing this subpoena. Non-Party Jane Doe No. 3 
objects to this Request in that it seeks information protected by the attorney-client privilege, 
work product doctrine, joint defense doctrine, common interest privilege and other related 
protections. Non-Party Jane Doe No. 3 objects to this Request to the extent that it seeks 
confidential information from a non-party. Non-Party Jane Doe No. 3 objects to this Request as 
harassing and not intended to lead to discoverable evidence relevant to the Florida Defamation 
Action. Non-Party Jane Doe No. 3 objects to this Request in that it seeks to place an undue 
burden on this non-party to have to search and collect documents that are unrelated to the 
underlying Florida Defamation Action. Non-Party Jane Doe No. 3 objects to this Request to the 
8 
EFTA01078834

extent it seeks information that is publicly available. Non-Party Jane Doe No. 3 objects to this 
Request in that it seeks information in the possession, custody and control of the Defendant, the 
Defendant's client, Jeffrey Epstein, or it seeks information that has been previously produced. 
7. All statements, written or recorded, which you have provided to anyone that reference 
by name, Alan M. Dershowitz. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request in that it seeks information protected by the attorney-
client privilege, work product doctrine, joint defense doctrine, common interest privilege and 
other related protections. Non-Party Jane Doe No. 3 objects to this Request to the extent it seeks 
confidential information from a non-party. Non-Party Jane Doe No. 3 objects to this Request as 
harassing and not intended to lead to discoverable evidence relevant to the Florida Defamation 
Action. Non-Party Jane Doe No. 3 objects to this Request in that it seeks to place an undue 
burden on this non-party to have to search and collect documents that are unrelated to the 
underlying Florida Defamation Action. Non-Party Jane Doe No. 3 objects to this Request to the 
extent it seeks information that is publicly available. Non-Party Jane Doe No. 3 objects to this 
Request in that it seeks information in the possession, custody and control of the Defendant or it 
seeks information that has been previously produced. Non-Party Jane Doe No. 3 objects to this 
Request in that it is overly broad seeking "all statements" to "anyone" and unduly burdensome. 
8. All notes of, or notes prepared for, any statements or interviews in which you 
referenced by name or other description, Alan M. Dershowitz. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request in that it is overly broad and unduly burdensome and 
requests this non-party to produce "all statements" "provided to anyone". Jane Doe No. 3 
objects to this Request to the extent that it seeks documents protected by the attorney-client 
9 
EFTA01078835

privilege, the work product doctrine, the joint defense doctrine, the common interest privilege, or 
any other privilege or protection. Non-Party Jane Doe No. 3 objects to this Request to the extent 
it seeks confidential information from a non-party. Non-Party Jane Doe No. 3 further objects to 
this Request to the extent it seeks documents already in Defendant's possession, custody or 
control or which have been previously produced. Jane Doe No. 3 further objects to this Request 
as overbroad, harassing and not calculated to lead to discoverable evidence relevant to the 
Florida Defamation Action. 
9. All documents concerning any communications by you or on your behalf with any 
media outlet concerning Alan M. Dershowitz or the Federal Action, whether or not such 
communications were "on the record" or "off the record." 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request because it is seeking backdoor discovery for the "Federal 
Action" which is not the underlying action from which the subpoena was generated. Non-Party 
Jane Doe No. 3 objects to this Request in that it seeks information protected by the attorney-
client privilege, work product doctrine, joint defense doctrine, common interest privilege and 
other related protections. Non-Party Jane Doe No. 3 objects to this Request to the extent it seeks 
confidential information from a non-party. Non-Party Jane Doe No. 3 objects to this Request as 
harassing and not intended to lead to discoverable evidence relevant to the Florida Defamation 
Action. Non-Party Jane Doe No. 3 objects to this Request in that it seeks to place an undue 
burden on this non-party with the overly broad request of "all" documents. Non-Party Jane Doe 
No. 3 objects to this Request to the extent it seeks information that is publicly available. Non-
Party Jane Doe No. 3 objects to this Request in that it seeks information in the possession, 
custody and control of the Defendant or it seeks information that has been previously produced. 
10. All notes, writings, photographs, and/or audio or video recordings made or recorded 
by or of you on the dates on which you allege you were present with Alan M. Dershowitz, 
10 
EFTA01078836

including but not limited to your calendar, diary or journal entries on those dates, regardless 
whether the notes, writings, photographs, and/or audio or video recordings refer to Mr. 
Dershowitz. To the extent that any responsive materials are photographs or video recordings, 
please provide them in the original, native format in which they were taken (not a paper copy). 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request in that it seeks highly sensitive, confidential, and personal 
information from a non-party including personal "diaries" or "journals." Jane Doe No. 3 objects 
to this Request to the extent that it seeks documents protected by the attorney-client privilege, the 
work product doctrine, the joint defense doctrine, the common interest privilege, or any other 
privilege or protection. Jane Doe No. 3 further objects to this Request to the extent it seeks 
documents already in Defendant's possession, custody or control, or upon information and 
belief, in the possession, custody and control of the federal or state government. Jane Doe No. 3 
further objects to this Request as overbroad, harassing and not calculated to lead to discoverable 
evidence relevant to the Florida Defamation Action. 
122. All documents relating to your travel to or from locations for those occasions when 
you allege you were present with Alan M. Dershowitz. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request to the extent that it seeks documents protected by the 
attorney-client privilege, the work product doctrine, the joint defense doctrine, the common 
interest privilege, or any other privilege or protection. Jane Doe No. 3 objects to this Request to 
the extent it seeks confidential information from a non-party. Jane Doe No. 3 further objects to 
this Request to the extent it seeks documents already in Defendant's possession, custody or 
control, or upon information and belief, in the possession, custody and control of the federal or 
state government. Jane Doe No. 3 objects to this Request to the extent the information is already 
'The requests are mis-numbered and there is no Request No. 11 in the original Subpoena Duces 
Tecum. 
11 
EFTA01078837

publicly available or previously produced. Jane Doe No. 3 further objects to this Request as 
overbroad, harassing and not calculated to lead to discoverable evidence relevant to the Florida 
Defamation Action. Jane Doe No. 3 objects to this Request in that it places an undue burden on 
this non-party including, for example, requiring the non-party to search for "documents", which 
has been defined by Defendant to include a broad definition of electronically stored data, 
including a requirement to search "archives" and "back-up systems." 
13. To the extent not produced in response to the above list of requested documents, all 
notes. writings, photographs, and/or audio or video recordings made at any time that refer or 
relate in any way to Alan M. Dershowitz. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request in that is overly broad and unduly burdensome in that it 
seeks "all writings" "made at any time" that "refer or relate in any way to Dershowitz". Jane 
Doe No. 3 also objects to this Request to the extent that it seeks documents protected by the 
attorney-client privilege, the work product doctrine, the joint defense doctrine, the common 
interest privilege, or any other privilege or protection. Non-Party Jane Doe No. 3 objects to this 
Request to the extent it seeks confidential information from a non-party. Jane Doe No. 3 further 
objects to this Request to the extent it seeks documents already in Defendant's possession, 
custody or control, or upon information and belief, in the possession, custody and control of the 
federal or state government. Jane Doe No. 3 objects to this Request to the extent the information 
is already publicly available or previously produced. Jane Doe No. 3 further objects to this 
Request as overbroad, harassing and not calculated to lead to discoverable evidence relevant to 
the Florida Defamation Action. Jane Doe No. 3 objects to this Request in that it places an undue 
burden on this non-party. 
14. All drafts of declarations or affidavits by you that relate in any way to Alan M. 
Dershowitz and/or Jeffrey Epstein. 
12 
EFTA01078838

Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request to the extent that it seeks documents protected by the 
attorney-client privilege, the work product doctrine, the joint defense doctrine, the common 
interest privilege, or any other privilege or protection. Non-Party Jane Doe No. 3 objects to this 
Request to the extent it seeks confidential information from a non-party. Jane Doe No. 3 further 
objects to this Request in that the face of the Request demonstrates that the Defendant is abusing 
the subpoena power by serving a subpoena on a non-party that seeks discovery unrelated to the 
underlying matter but, instead, allegedly relevant to a "Federal Action" which involves "Epstein" 
who is not a party to the Florida Defamation Action. Jane Doe No. 3 further objects to this 
Request as overbroad, harassing and not calculated to lead to discoverable evidence relevant to 
the Florida Defamation Action. Jane Doe No. 3 objects to this Request in that it places an undue 
burden on this non-party. 
15. All documents relating to any telephone, including any cellular telephone, used by 
you between January 1, 1999 and December 31, 2002. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request to the extent that it seeks documents protected by the 
attorney-client privilege, the work product doctrine, the joint defense doctrine, the common 
interest privilege, or any other privilege or protection. Jane Doe No. 3 objects to this Request to 
the extent it seeks confidential information from a non-party. Jane Doe No. 3 objects to this 
Request as overbroad in that it seeks "all documents" for a three year period. Jane Doe No. 3 
objects to this Request to the extent it seeks documents in the possession, custody, and control of 
Defendant or Defendant's client, Mr. Epstein. 
16. Any diary, journal or calendar concerning your activities between January 1. 1999 
and December 31, 2002. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
13 
EFTA01078839

Jane Doe No. 3 objects to this Request to the extent that it seeks documents protected by the 
attorney-client privilege, the work product doctrine, the joint defense doctrine, the common 
interest privilege, or any other privilege or protection. Jane Doe No. 3 objects to this Request to 
the extent it seeks confidential and highly sensitive personal information in the form of a "diary" 
sought only to harass this non-party. Jane Doc No. 3 objects to this Request as overbroad, 
harassing and not calculated to lead to discoverable evidence relevant to the Florida Defamation 
Action. 
17. All documents concerning any actual or potential book, television or movie deals 
concerning your allegations about being a sex slave. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request to the extent that it seeks documents protected by the 
attorney-client privilege, the work product doctrine, the joint defense doctrine, the common 
interest privilege, or any other privilege or protection. Jane Doe No. 3 objects to this Request to 
the extent it seeks confidential information from a non-party. Jane Doe No. 3 further objects to 
this Request in that it is vague and ambiguous with respect to its reference to "deals". Jane Doe 
No. 3 further objects to this Request as overbroad, harassing and not calculated to lead to 
discoverable evidence relevant to the Florida Defamation Action. Jane Doe No. 3 objects to this 
Request in that it places an undue burden on this non-party including, for example, requiring the 
non-party to search for "documents", which has been defined by Defendant to include a broad 
definition of electronically stored data, including a requiring a search of "archives" and "back-up 
systems." 
18. All documents concerning any monetary payments or other consideration received 
by you from any media outlet in exchange for your statements (whether "on the record" or "off 
the record") regarding Jeffrey Epstein, Alan M. Dershowitz, Prince Andrew, Duke of York, 
and/or being a sex slave. 
14 
EFTA01078840

Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request to the extent that it seeks documents protected by the 
attorney-client privilege, the work product doctrine, the joint defense doctrine, the common 
interest privilege, or any other privilege or protection. Jane Doe No. 3 objects to this Request in 
that it seeks confidential financial information from a non-party. Jane Doe No. 3 further objects 
to this Request to the extent it seeks documents already in Defendant's possession, custody or 
control or which have been previously produced. Jane Doe No. 3 further objects to this Request 
as overbroad, harassing and not calculated to lead to discoverable evidence relevant to the 
Florida Defamation Action. Jane Doe No. 3 objects to this Request in that it places an undue 
burden on this non-party including, for example, requiring the non-party to search for 
"documents", which has been defined by Defendant to include a broad definition of 
electronically stored data, including requiring a search of "archives" and "back-up systems." 
19. All documents showing, concerning, relating or referring to when you were at or on 
(i) Jeffrey Epstein's Manhattan home in New York City, New York; (ii) Mr. Epstein's home in 
Palm Beach, Florida; (iii) Mr. Epstein's Zorro Ranch in Santa Fe, New Mexico; (iv) Little Saint 
James island in the U.S. Virgin Islands; and (v) Mr. Epstein's airplane from January I, 1999 
through December 31, 2002. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request to the extent that it seeks documents protected by the 
attorney-client privilege, the work product doctrine, the joint defense doctrine, the common 
interest privilege, or any other privilege or protection. Jane Doe No. 3 objects to this Request to 
the extent it seeks confidential information from a non-party. Jane Doe No. 3 further objects to 
this Request in that the face of the Request demonstrates that the Defendant is abusing the 
subpoena power by serving a subpoena on a non-party that seeks discovery unrelated to the 
underlying matter but, instead, allegedly relevant to a "Federal Action." The "Federal Action" 
involves "Epstein" who is not a party to the Florida Defamation Action. Jane Doe No. 3 objects 
15 
EFTA01078841

to this Request to the extent the documents are in the possession, custody and control of the 
Defendant and the Defendant's client, Mr. Epstein. Jane Doe No. 3 objects to this Request to the 
extent the documents are, upon information and belief, in the possession. custody and control of 
the federal and state government. Jane Doe No. 3 further objects to this Request as overbroad, 
harassing and not calculated to lead to discoverable evidence relevant to the Florida Defamation 
Action. Jane Doe No. 3 objects to this Request in that it places an undue burden on this non-party 
including, for example, requiring the non-party to search for "documents", which has been 
defined by Defendant to include a broad definition of electronically stored data, including 
requiring a search of "archives" and "back-up systems." 
20. All documents showing any payments or remuneration of any kind made by Jeffrey 
Epstein or any of his agents or associates to you from January 1, 1999 through December 31, 
2002. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request to the extent that it seeks documents protected by the 
attorney-client privilege, the work product doctrine, the joint defense doctrine, the common 
interest privilege, or any other privilege or protection. Jane Doe No. 3 objects to this Request in 
that it seeks confidential financial information from a non-party. Jane Doe No. 3 further objects 
to this Request to the extent it seeks documents already in Defendant's possession, custody or 
control or which have been previously produced. Jane Doe No. 3 further objects to this Request 
as overbroad, harassing and not calculated to lead to discoverable evidence relevant to the 
Florida Defamation Action. Jane Doe No. 3 objects to this Request in that it places an undue 
burden on this non-party including, for example, requiring the non-party to search for 
"documents", which has been defined by Defendant to include a broad definition of 
electronically stored data, including searching "archives" and "back-up systems." 
21. All travel records of any kind, including but not limited to tickets, hotel room 
16 
EFTA01078842

receipts or other documents concerning, relating or referring to any travel undertaken by you 
between January 1, 1999 and December 31, 2002. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request to the extent that it seeks documents protected by the 
attorney-client privilege, the work product doctrine, the joint defense doctrine, the common 
interest privilege, or any other privilege or protection. Jane Doe No. 3 objects to this Request to 
the extent it seeks confidential information from a non-party. Jane Doe No. 3 objects to this 
Request to the extent the documents are in the possession, custody and control of the Defendant 
or the Defendant's client, Mr. Epstein or have already been produced. Jane Doe No. 3 objects to 
this Request to the extent the documents are, upon information and belief, in the possession, 
custody and control of the federal and state government. Jane Doe No. 3 further objects to this 
Request as overbroad, harassing and not calculated to lead to discoverable evidence relevant to 
the Florida Defamation Action. 
22. All records of any interviews given by you to any party concerning, relating or 
referring to Jeffrey Epstein or any of his agents or associates. 
Response: In addition to the Preliminary Statement and General Objections. Non-Party 
Jane Doe No. 3 objects to this Request to the extent that it seeks documents protected by the 
attorney-client privilege, the work product doctrine, the joint defense doctrine, the common 
interest privilege, or any other privilege or protection. Jane Doe No. 3 objects to this Request to 
the extent it seeks confidential information from a non-party. Jane Doe No. 3 further objects to 
this Request in that the face of the Request demonstrates that the Defendant is abusing the 
subpoena power by serving a subpoena on a non-party that seeks discovery unrelated to the 
underlying matter but, instead, allegedly relevant to a "Federal Action." The "Federal Action" 
involves "Epstein" who is not a party to the Florida Defamation Action. Jane Doe No. 3 objects 
to this Request in that it is overly broad and vague in its failure to identify the "agents or 
17 
EFTA01078843

associates" rendering it impossible for Jane Doe No. 3 to interpret the Request. Jane Doe No. 3 
objects to this Request to the extent the documents are in the possession, custody and control of 
the Defendant and the Defendant's client, Mr. Epstein. Jane Doe No. 3 objects to this Request to 
the extent the documents are, upon information and belief, in the possession. custody and control 
of the federal and state government. Jane Doe No. 3 further objects to this Request as overbroad, 
harassing and not calculated to lead to discoverable evidence relevant to the Florida Defamation 
Action. Jane Doe No. 3 objects to this Request in that it places an undue burden on this non-
party including, for example, requiring the non-party to search for "documents", which has been 
defined by Defendant to include a broad definition of electronically stored data, including 
requiring a search of "archives" and "back-up systems." 
23. All manuscripts and/or other writings, whether published or unpublished, created in 
whole or in part by you, concerning, relating or referring to Jeffrey Epstein and any of his agents 
or associates. 
Response: In addition to the Preliminary Statement and General Objections, Non-Party 
Jane Doe No. 3 objects to this Request to the extent that it seeks documents protected by the 
attorney-client privilege, the work product doctrine, the joint defense doctrine, the common 
interest privilege, or any other privilege or protection. Jane Doe No. 3 objects to this Request to 
the extent it seeks confidential information from a non-party. Jane Doe No. 3 further objects to 
this Request in that the face of the Request demonstrates that the Defendant is abusing the 
subpoena power by serving a subpoena on a non-party that seeks discovery unrelated to the 
underlying matter but, instead, allegedly relevant to a "Federal Action." The "Federal Action" 
involves "Epstein" who is not a party to the Florida Defamation Action. Indeed, this Request 
does not even reference the Defendant in this matter. Jane Doc No. 3 objects to this Request in 
that it is overly broad and vague in its failure to identify the "agents or associates" rendering it 
impossible for Jane Doe No. 3 to interpret the Request. Jane Doe No. 3 objects to this Request to 
18 
EFTA01078844