Epstein Secrets

ment 57-2 Entered on FLSD Docket 03/02/2009 Page 1 of 11 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 INT

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

ating; 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 r

06:10:2009 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 5, Plaintiff, Vs. JE

s a self-incriminating testimonial communication or "a compelled testimonial aspect." United States v. Hubbell, 530 U.S. 27, 120 S.Ct. 2037 (2000); Fisher v. United States, 425 U.S. 391 (1976)• McCormick on Evidence, Title 6, Chap. 13. The Privilege Against Self-Incrimination, §138 (6th Ed.). See also

that the papers existed, were in his possession or control, and were authentic. United States v. Doe. 465 U.S., at 613, and n. 11, 104 S.Ct. 1237; Fisher, 425 U.S., at 409-410, 96 S.Ct. 1569; id, at 428. 432, 96 S.Ct. 1569 (concurring opinions). See Braswell v. United States, 1487 U.S.,I at EFTA00221

Defendant. CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CV-80380-MARRA/JOHNSON JANE DOE NO. 5, CASE NO.: 08-CV-80381-MARRA/JOHNSON Plaintif

f 22 documents is considered testimonial and is protected by the Fifth Amendment. 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

Case 9:08-cv-80119-KAM Document 242 Entered on FLSD Docket 08/04/2009 Page 2 of 22 JEFFREY EPSTEIN, Defendant. JANE DOE NO. 6, CASE NO.: 08-80994-CIV-MARRNJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 7, Plaintiff, vs. JEFFREY EPSTEIN, Defendant

f 22 documents is considered testimonial and is protected by the Fifth Amendment. 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

ourt for the purpose of initlating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) DEFENDANTS JEFFREY EPSTEIN (a) PLAINTIFFS JANE DOE NO. 3, ) (b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF PALM BEACH COUNTY (EXCEPT IN U.S, PLAINTIFF CASES) COUNTY OF RESIDENCE OF FIRST LISTED DEFE

nt Attorney General Department of Justice Criminal Division 950 Pennsylvania Avenue NW Room 2107 Washington, DC 20530 Re: Jeffrey Epstein Dear Ms. Fisher: « T represent Jeffrey Epstein, who, as you may be aware, was the target of a dual investigation by both state and federal authorities in Florida fo