* 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,
I.
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"
EFTA00222073
Case 9:08-cv-80119-1M Document 57-4 Entered on FLSD Docket 03/02/2009 Page 2 of 2
Jane Doe No. 2 . Epstein
Page 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. Jack Alan Goldberger
Jeffrey Marc Herman, Esq. , P.A.
Stuart S. Mermelstein, Esq.
West Palm Beach, FL 33401-5012
Miami FL 33160
Fax:
Fax:
uo-uounsei tor tietendant Jeffrey
Epstein
ounse or laintiff Jane Doe #2
Respectfully sub
By:
ROBERT D CRITTON, JR., ESQ.
Florida Ba' No. 224162
, ESQ.
Florida Bar #617296
BURMAN, CRI I TON, LUTTIER &
COLEMAN
es ch, 33401
Fax:
(Co-counsel for e endant Jeffrey Epstein)
EFTA00222074