046.pdf

Sigrid S. McCawley
Telephone: (954) 377-4223
Email: smccawley@bsfllp.com
May 7, 2020
VIA ECF
The Honorable Debra Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312
Re: Jane Doe 1000 v. Darren K. Indyke & Richard D. Kahn, 19-10577-LJL-DCF

Dear Judge Freeman:
We write on behalf of Plaintiff Jane Doe 1000 in the above-captioned litigation. Pursuant
to Individual Rule II.A and Local Civil Rule 37.2, Plaintiff respectfully requests a pre-motion
conference on Plaintiff’s anticipated motion to compel Defendants Darren K. Indyke and Richard
D. Kahn (1) to produce responsive documents from the Relevant Period as defined in Plaintiff’s
discovery requests; (2) to produce documents responsive to Plaintiff’s requests, not simply
documents that directly mention Plaintiff’s name; and (3) to respond to Plaintiff’s interrogatories.
1

The Court has made clear that discovery in this case would not be stayed pending the approval of
the claims administration program or a motion to dismiss absent a contrary order from the Court.
See Tr. of Nov. 21, 2019 Conf. at 26:10–12. Yet by failing to comply with their clear and
unequivocal discovery obligations, including not producing a single document to date, Defendants
are attempting to grant themselves a de facto stay of discovery. Defendants have provided no basis
for their delay.
I. Background
Plaintiff alleges that Jeffrey Epstein and his co-conspirators operated a decades-long
sex-trafficking scheme by which they recruited young women for sexual abuse. Compl. ¶¶ 23–
26. Plaintiff was one of those women. Epstein and his associates trafficked her after seeing her
modeling work in 1999, housed her in Epstein’s apartment building, and sexually abused her for
several years. Id. ¶¶ 38–46. After years of suffering in silence due to fear, Plaintiff filed a
complaint against Defendants on November 14, 2019.
On January 28, 2020, Plaintiff sent Defendants a document preservation notice and
identified various email accounts used by Jeffrey Epstein. Exhibit A, Jan. 28, 2020 Document
Preservation Notice. Defendants responded on February 3, 2020, by stating that they were abiding
by all of their discovery obligations, including their preservation obligations. Exhibit B, Feb. 3,

1 Pursuant to Individual Rule I.C., Plaintiff states that she conferred in good faith
with Defendants about the issues raised in this letter by telephone on April 27, 2020.
Case 1:19-cv-10577-LJL-DCF Document 46 Filed 05/07/20 Page 1 of 5
BSF BOIES
SCHILLER
FLEXNER
BOIES SCHILLER FLEXNER LLP
401 East Las Olas Boulevard. Suite 1200. Fort Lauderdale. FL 33301 1 (t) 954 356 0011 I (f) 954 356 0022 I www.bsfllp.com
2020 Letter from B. Moskowitz to S. McCawley. Yet on the very same day, Defendants sent
Plaintiff completely vacuous Rule 26 Disclosures. Defendants provided the name of one witness—
Plaintiff—and stated that they were not aware of any documents, ESI, or tangible things in their
possession, custody, or control that they would use to support their defenses. Exhibit C, Feb. 3,
2020 Initial Disclosures of Defendants Darren K. Indyke and Richard D. Kahn.
On March 10, 2020, Plaintiff served 79 Requests for Production (“RFPs”) and 18
Interrogatories on Defendants (collectively, Plaintiff’s “discovery requests”). In Plaintiff’s
interrogatories, she again asked Defendants to identify potential witnesses, in addition to email
accounts used by Epstein, telephone numbers used by Epstein, and other information to aid
Plaintiff in identifying witnesses and the location of evidence necessary to prove her case. On
April 16, 2020, after Plaintiff provided Defendants a week-long extension, Defendants served
responses and objections in which they failed to respond to a single Interrogatory (aside from
identifying Plaintiff as a witness to her own abuse) and failed to produce a single document.
Exhibit D, Defendants’ Apr. 16, 2020 Objections and Responses to Plaintiff’s First Set of
Interrogatories; Exhibit E, Defendants’ Apr. 16, 2020 Objections and Responses to Plaintiff’s First
Request for Production of Documents.
On April 27, 2020, after sending Defendants a letter regarding the clear deficiencies in their
responses and objections, Plaintiff met and conferred with Defendants for an hour and a
half. See Ex. F, Apr. 20, 2020 Letter from S. McCawley to B. Moskowitz. Defendants stated that
they had not yet fully processed the ESI in their possession, had not run any searches on the ESI,
and were not in a position to provide information about the ESI, despite having received Plaintiff’s
document retention notice in January and Plaintiff’s discovery requests in March. During the meet
and confer, Plaintiff also explained her position on the relevance and necessity of each of her
discovery requests, and offered to answer any questions that Defendants had about the relevance
of any of her requests. Defendants refused to accept the Relevant Period that Plaintiff defined in
her discovery requests, and stated that they would only produce documents that reference Plaintiff.
They also stated, without providing any legal basis for their position, that they would not produce
anything relating to Epstein’s sex trafficking or abuse of other victims.
As of today, May 7, 2020, Plaintiff has yet to receive a single document or piece of
information responsive to any of her discovery requests, including the documents that specifically
reference Plaintiff that Defendants agreed to produce. The only information Defendants have
provided to Plaintiff in the course of discovery is their statement that Plaintiff is a witness in this
case. Plaintiff has produced more than 10,000 pages of documents responsive to Defendants’
discovery requests to date, and has responded to all of Defendants’ interrogatories to the best of
her ability.
II. Defendants’ Objection to the Relevant Period is Improper.
Defendants have improperly objected to the Relevant Period that Plaintiff defined in her
discovery requests as January 1, 1999 to the present. Without providing any legal basis for their
Case 1:19-cv-10577-LJL-DCF Document 46 Filed 05/07/20 Page 2 of 5
position, Defendants contend that the relevant time period should be limited to the dates of
Plaintiff’s abuse as alleged in the Complaint.2
Under Rule 26 of the Federal Rules of Civil Procedure, parties may obtain discovery
“regarding any nonprivileged matter that is relevant to any party’s claim or defense.” Fed. R. Civ.
P. 26(b)(1). “[R]elevance for the purposes of discovery is an extremely broad concept.” Melendez
v. Greiner, No. 01 CIV.07888 SAS DF, 2003 WL 22434101, at *1 (S.D.N.Y. Oct. 23, 2003)
(Freeman, J.).
This case turns on (1) whether Jeffrey Epstein sexually trafficked and sexually assaulted
Plaintiff and (2) whether Plaintiff’s claims are timely, an affirmative defense that Defendants have
already raised in a motion to dismiss. ECF No. 34. Discovery from the Relevant Period as defined
by Plaintiff is relevant to both Plaintiff’s claims and Defendants’ statute of limitations defense,
and is reasonably calculated to lead to the discovery of admissible evidence.
Epstein’s sexual trafficking and assault of Plaintiff began in 1999 and lasted for several
years. But Plaintiff has reason to believe, based on publicly available documents, that Epstein and
his co-conspirators began trafficking and sexually abusing young girls and women in the same
manner that he trafficked and abused Plaintiff in the mid-1990s, and continued to do so up until
the date of Epstein’s arrest on July 8, 2019. Documents relating to the sexual trafficking and/or
sexual assault of others at any point during that period would make the fact that Epstein trafficked
and sexually assaulted Plaintiff, the key fact that Plaintiff bears the burden of proving in this case,
more probable than it would be without such evidence. See Fed. R. Evid. 401. Plaintiff also bears
the burden of proving Epstein’s intent to sexually assault her. See Cerilli v. Kezis, 16 A.D.3d 363,
364 (2d Dep’t 2005) (“The elements of battery are bodily contact, made with intent, and offensive
in nature.”). Evidence that he sexually trafficked and assaulted others would be directly relevant
to proving such intent. Such evidence would also likely be admissible at trial. See Fed. R. Evid.
415.
Further, Defendants have raised a statute of limitations defense in this matter, ECF No. 34,
and Plaintiff contends that they should be equitably estopped from doing so based on Epstein’s
misconduct. Compl. ¶ 15. Although Plaintiff disagrees with Defendants’ interpretation of the case
law, Defendants contend that to invoke equitable estoppel, Plaintiff bears the burden of proving
that Epstein’s “conduct cause[d] her to delay bringing suit,” that Epstein “made a definite
misrepresentation of fact, and had reason to believe that the plaintiff would rely on it,” and that
“plaintiff reasonably relied on that misrepresentation.” ECF No. 34 at 9–10. Documents relating
to Epstein’s misconduct after his abuse of Plaintiff ended could very well be relevant to equitable
estoppel, including to whether Plaintiff reasonably relied on that misconduct in staying silent about
her abuse until after Epstein’s death.
The fact that Epstein and his co-conspirators carried out a global sex-trafficking operation,
which directly injured Plaintiff, for 20 years does not mean that Plaintiff is not entitled to discovery
about that operation. Yet Defendants have taken that position and have not indicated any
willingness to change it. The Court should direct Defendants to search documents within their

2 This is despite the fact that Defendants themselves served discovery requests on Plaintiff
in which they defined the relevant time period as “the date on which you first learned of Decedent
through the date of your responses to these requests.”
Case 1:19-cv-10577-LJL-DCF Document 46 Filed 05/07/20 Page 3 of 5
possession, custody, or control from the Relevant Period as described in Plaintiff’s discovery
requests—1999 to the present.
III. Defendants Must Produce More than Documents That Explicitly Reference Plaintiff.
In addition to their blanket objection to the production of documents from any year aside
from the years during which Plaintiff was herself sexually assaulted, Defendants contend that they
will only produce one category of documents: those that specifically mention Jane Doe 1000.
Defendants have refused, without providing any legal basis for doing so, to produce any document
that does not directly reference Plaintiff, regardless of the year.
Defendant cannot broadly object to producing any documents that do not directly reference
Plaintiff. Documents relevant to Plaintiff’s claims and Defendants’ defenses go well beyond
documents that reference Plaintiff. The following is a small sampling of examples of relevant
documents that would not necessarily mention Plaintiff:
• As explained above, documents evidencing Epstein’s trafficking and sexual
assaults of others, although not about Plaintiff herself, are directly relevant to
whether he trafficked and sexually assaulted Plaintiff.
• Epstein’s communications with his co-conspirators are likely to evidence the
scheme by which Epstein recruited and abused Plaintiff, even if they do not
specifically mention Plaintiff. For example, documents in which Epstein and his
co-conspirators discuss recruiting young models or arranging for their housing in
Epstein’s apartment complex would corroborate Plaintiff’s allegations.
• Documents relating to payments from Epstein to his employees are relevant to
whether Epstein paid his employees to keep them quiet, and would be relevant in
impeaching witnesses in this case.
• Documents relating to Epstein’s silencing, intimidation, and manipulation of
victims other than Plaintiff is relevant to establishing whether Plaintiff reasonably
feared Epstein, which is relevant to Defendants’ statute of limitations defense and
Plaintiff’s equitable estoppel theory.
Plaintiff explained these theories of relevance during a meet and confer call with
Defendants. Without any legal basis, and while purporting to understand Plaintiff’s position,
Defendants consistently maintained that they would not produce any document that does not
directly mention Jane Doe 1000. This position unwarranted, legally baseless, and unacceptable,
and Defendants have not indicated that they are willing to change it. The Court should direct
Defendants to search for documents within their possession, custody, or control and not allow
Defendants to unilaterally and arbitrarily limit their search to documents that reference Plaintiff’s
name.
IV. Defendants Must Respond to Plaintiff’s Interrogatories.
Plaintiff served 18 interrogatories on Defendants, and Defendants failed to answer a single
one, aside from listing Plaintiff as an “individual who may have knowledge concerning the issues
in this lawsuit.” Ex. D at 3. Plaintiff asked Defendants to identify email accounts used by Epstein
or his employees or agents on his behalf—Defendants provided no answer. Id. Plaintiff asked
Case 1:19-cv-10577-LJL-DCF Document 46 Filed 05/07/20 Page 4 of 5
Defendants to identify telephone numbers used by Epstein or his employees or agents on his
behalf—Defendants provided no answer. Id. at 4. Plaintiff asked Defendants to provide a list of
Epstein’s employees in an effort to identify potential witnesses to Epstein’s abuse of Plaintiff and
other victims—Defendants provided no answer. Id. This is despite the fact that Defendant Kahn
was Epstein’s longtime accountant and likely knows who was on Epstein’s payroll. This total
failure to answer even basic questions about the location of documents and potential witnesses is
egregious.
When asked about their failure to respond to any interrogatories, in addition to raising their
meritless objections to the Relevant Period and to producing information that does not relate
directly to Plaintiff, Defendants stated that they do not have responsive information because
Epstein is dead and Defendants do not know where to look for responsive information. Defendants
also drew a distinction between their capacities as Epstein’s lawyer and accountant, as opposed to
their capacities as executors of his Estate, but could not give Plaintiff a clear answer as to their
position on how that distinction affects their discovery obligations. For example, Defendants’
counsel could not tell Plaintiff whether Darren Indyke—Epstein’s longtime lawyer who has ties to
Epstein’s co-conspirators3—or Richard Kahn—Epstein’s longtime accountant who assisted him
for years with both personal and professional accounting work—had ever been directly asked
whether they know of any individuals who might have information about Plaintiff’s claims.
Plaintiff still has no understanding of how Defendants have attempted to fulfill their
discovery obligations, or of what documents or information are within their possession, custody,
or control. At this stage in the litigation, such opaqueness is unacceptable and a clear attempt by
Defendants to avoid their discovery obligations in the hopes that the claims administration process
comes to fruition. But Defendants cannot unilaterally decide to stay this case. The Court should
direct Defendants to respond to Plaintiff’s interrogatories.
Respectfully submitted,
/s/ Sigrid S. McCawley
Sigrid S. McCawley, Esq.
cc: Counsel of Record (via ECF)

3 According to public records, Indyke, for example, helped Ghislaine Maxwell buy her
townhouse, was listed on documents relating to one of Maxwell’s nonprofits, held a power of
attorney over one of Leslie Wexner’s properties, and employed Lesley Groff as an executive
assistant for his law practice. See Julia La Roche et al., Jeffrey Epstein’s Lawyers Deeply Involved
in His Business Dealings for Decades, Documents Show, Yahoo Finance (Aug. 13, 2019),
https://finance.yahoo.com/news/jeffrey-epstein-lawyers-darren-indyke-jeffrey-schantz 164305188.html.
Case 1:19-cv-10577-LJL-DCF Document 46 Filed 05/07/20 Page 5 of 5
Exhibit A
Case 1:19-cv-10577-LJL-DCF Document 46-1 Filed 05/07/20 Page 1 of 4
Telephone: (954) 356-0011
Email: smccawley@bsfllp.com
January 28, 2020
VIA ELECTRONIC MAIL
Bennet J. Moskowitz
875 Third Avenue
New York, New York 10022
Re: Document Preservation Notice
Maria Farmer v. Darren K. Indyke and Richard D. Kahn, 19-10474;
Annie Farmer v. Darren K. Indyke, Richard D. Kahn, and
Ghislaine Maxwell, 19-10475;
Teresa Helm v. Darren K. Indyke and Richard D. Kahn, 19-10476;
Juliette Bryant v. Darren K. Indyke and Richard D. Kahn, 19-10479;
Jane Doe 1000 v. Darren K. Indyke and Richard D. Kahn, 19-10577;

Dear Mr. Moskowitz:
This is a document preservation notice issued in connection with the above-captioned civil
actions. Please read this notice carefully and take all steps necessary to preserve all documents
that might be relevant to this dispute. You should take affirmative steps to suspend any automated
deletion. The documents covered by this notice are potentially subject to discovery and production
in the above-captioned litigation and will be needed as evidence and/or to enable us to prepare
fully to take your clients’ sworn testimony in a deposition and/or at a trial
Pursuant to Federal Rule of Civil Procedure 26, you were required to identify “all
documents, electronically stored information, and tangible things that the disclosing party has in
its possession, custody, or control and may use to support its claims or defenses.” In your Initial
Disclosures for Annie Farmer, Teresa Helm, and Juliette Bryant, however, you stated that “[a]t
present, the Co-Executors are not aware of any such documents, electronically stored information,
and tangible things.” I assume that you mean that you are not aware that any “documents,
electronically stored information, [or] tangible things” that would be supportive of your clients’
defenses. If instead you are taking the position that your clients do not have possession, custody,
or control over Mr. Epstein’s documents (including his electronically stored information), please
state so in your reply so that we may bring that to the Court’s attention immediately.
At the November 21, 2019, conference Judge Freeman stated: “Counsel should know what
their obligations are and those obligations are pretty clear under the law and counsel should take
them seriously. If you do not preserve evidence that should be preserved that you had a reason to
believe was relevant to claims or defense in the case and that you didn’t take steps to preserve,
there can be negative consequences down the road.” Nov. 21, 2019, Hearing Tr. at 33:4-10. The
Court instructed that your preservation efforts should be “broad enough” to documents located at
Mr. Epstein’s “multiple residences in multiple countries across the world.”
Case 1:19-cv-10577-LJL-DCF Document 46-1 Filed 05/07/20 Page 2 of 4
BSF BOIES
SCHILLER
FLEXNER
BOIES SCHILLER FLEXNER LLP
401 East Las Olas Boulevard. Suite 1200, Fort Lauderdale, FL 33301 1 (t) 9S4 356 0011 I (f) 954 356 0022 I www.bsfllp.com
Bennet J. Moskowitz
January 28, 2020
Page | 2
Effective immediately, you should ensure that your clients preserve all documents, whether
they exist electronically or in paper files. This includes documents that presently exist, or that are
created in the future, in your clients’ possession, custody or control, including in common files
maintained for your clients.
Subject Matter
Preserve all documents that refer to, relate to, mention, or discuss the allegations in Plaintiffs’
complaints, including but not limited to any concerning the following subjects and found in the
following repositories:
1. The allegations in the Complaints filed in the above referenced matters;
2. The Plaintiffs;
3. Mr. Epstein’s sex-trafficking conspiracy;
4. Visitors and/or passengers at any of Mr. Epstein’s multiple residences or aircraft where
the sex trafficking occurred;
5. Communications between Mr. Epstein and his co-conspirators;
6. Communications between Mr. Epstein and his employees;
7. Communications between Mr. Epstein and any government official regardless of
country;
8. Mr. Epstein’s flight logs and helicopter logs;
9. Video tapes and photographs taken at Mr. Epstein’s properties or on his planes;
10. Financial records;
11. Mr. Epstein’s message pads and any phone call logs or phone/contact directories;
12. Amazon.com account details, including order history;
13. Electronic files Mark Lumberg managed on behalf of Mr. Epstein;
14. Mr. Epstein’s email accounts, including but not limited to:
a. “jeffreye@mindspring.com”;
b. “jeeproject@yahoo.com”;
c. “jeevacation@gmail.com”;
d. “zorroranch@aol.com”; and
e. “epsteinj@wanadoo.fr”;
15. Email accounts under the following domains: @Mindspring.com; @earthlink.net;
including those used by:
a. Ghislaine Maxwell;
b. Dana Burns;
c. Cecilia Steen; and
d. Sarah Kellen;
Case 1:19-cv-10577-LJL-DCF Document 46-1 Filed 05/07/20 Page 3 of 4
BSF
Bennet J. Moskowitz
January 28, 2020
Page | 3
16. Email accounts for “Cecilia Steen” that Mr. Epstein controlled, including
“cecilia@ellmax.com” and “cecilia.steen@gmail.com”.
Please construe this notice as broadly as possible and carefully read the following
descriptions.
The definition of “document” is not limited to paper files. A document is literally any
kind of record, whether stored electronically or in paper form, whether useful to you or not. See
S.D.N.Y. Local Civil Rule 26.3 (“Uniform Definitions in Discovery Requests”). A document is
any object in your possession that relates to the subject matter identified in this notice, including:
• Email. All of your clients’ emails relating to the subject matter, both internal and external,
whether in electronic or paper form; this includes anything created or stored on a wireless
device or smart phone.
• Computer Files. All other electronic records relating to the subject matter, including but
not limited to documents created using Microsoft Office (Word, PowerPoint, Excel,
Access, and Visio, for example), and stored anywhere; this includes files stored on your
clients’ computers, in shared or network drives, home computers, hard disks, CDs, DVDs,
flash drives, or anywhere else.
• Video and Audio. Microfilm, audio and video or other visual records, including voice
mail, video tapes, DVDs, digital photographs, etc.
• Paper Documents. All paper records—presentations, notes, calendars, day planners, logs,
lists, agendas, correspondence, photographs, facsimiles, data or other computer printouts
and the like.
• Text Messages. All text or SMS messages, messages sent via WhatsApp or other
messaging services.
Please ensure that any of your clients’ agents, such as administrative assistants, who may
have access to or know of records covered by this notice, are also made aware of the obligation to
preserve such material. Please confirm in writing by February 3, 2020, that your clients have
preserved and will continue to preserve all documents and communications described above, and
all other materials relevant or potentially relevant to the subject matter of the cases.
Sincerely,


/s/ Sigrid S. McCawley
Sigrid S. McCawley, Esq.
Case 1:19-cv-10577-LJL-DCF Document 46-1 Filed 05/07/20 Page 4 of 4
BSF
Exhibit B
Case 1:19-cv-10577-LJL-DCF Document 46-2 Filed 05/07/20 Page 1 of 2
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutman.com
Bennet J. Moskowitz
bennet.moskowitz@troutman.com
February 3, 2020
E-MAIL
Sigrid S. McCawley, Esq.
Boies Schiller Flexner LLP
401 East Las Olas Boulevard
Suite 1200
Fort Lauderdale, FL 33301
Re: Teresa Helm, 19-cv-10476; Juliette Bryant, 19-cv-10479; Annie Farmer, 19-cv 10475; Maria Farmer, 19-cv-10474; Jane Doe 1000, 19-cv-10577
Dear Ms. McCawley:
As you know, we represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of
the Estate of Jeffrey E. Epstein (together, the “Co-Executors”), in the above-referenced actions
(the “Actions”). We are writing in response to your letter dated January 28, 2020.
You state: “If … you are taking the position that your clients do not have possession, custody, or
control over Mr. Epstein’s documents (including his electronically stored information), please
state so in your reply so that we may bring that to the Court’s attention immediately.” We have
never taken that position. Accordingly, there is nothing to raise with the Court.
Separately, we confirm that our clients are abiding by all of their discovery obligations including
preservation obligations. However, your list of subject matters is inappropriate because it is
argumentative, assumes many unproven facts not in evidence and is overly broad.
1 Your
interpretation of Local Rule 26.3 is likewise inappropriate; we defer to the rule itself.
Very truly yours,
Bennet J. Moskowitz
Bennet J. Moskowitz
1It bears mentioning that counsel in another action against the Co-Executors previously attempted to
extract positions from us concerning a similar list and, failing that, to obtain relief from Magistrate
Freeman. Such counsel obtained no such relief. Nor was any relief necessary given our identical
representation in that action that our clients are abiding by their preservation obligations.
Case 1:19-cv-10577-LJL-DCF Document 46-2 Filed 05/07/20 Page 2 of 2
troutmariP
sanders
Exhibit C
Case 1:19-cv-10577-LJL-DCF Document 46-3 Filed 05/07/20 Page 1 of 5
41202549v2 1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-------------------------------------- X
JANE DOE 1000,
Plaintiff,
v.
DARREN K. INDYKE and RICHARD D.
KAHN in their capacities as the executors of
the ESTATE OF JEFFREY EDWARD
EPSTEIN,
Defendants.
:
:
:
:
:
:
:
:
:
:
:
:
:
Index No. 1:19-cv-10577-LGS-DCF
-------------------------------------- X
INITIAL DISCLOSURES OF DEFENDANTS DARREN K. INDYKE AND RICHARD D.
KAHN, CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN
Pursuant to Fed. R. Civ. P. 26(a)(1), Defendants Darren K. Indyke and Richard D. Kahn,
Co-Executors of the Estate of Jeffrey E. Epstein (together, the “Co-Executors”), make the
following initial disclosures to Plaintiff Jane Doe 1000. These disclosures are based on the
information reasonably available to the Co-Executors at present. The Co-Executors reserve the
right to supplement or modify these disclosures if additional, responsive information is obtained.
The Co-Executors provide this information without any concession, agreement,
admission or waiver of any ultimate determination of relevance or admissibility of particular
information or testimony for any purpose. The Co-Executors reserve the right to, at trial, call
any witness and present any exhibit or other evidence not listed here but identified through
discovery or investigation during this action. The Co-Executors do not waive their rights to
object to the production of any document or tangible thing based on the attorney-client privilege,
the work-product doctrine, relevance, undue burden or any other valid objection.
Case 1:19-cv-10577-LJL-DCF Document 46-3 Filed 05/07/20 Page 2 of 5
41202549v2 2
INITIAL DISCLOSURES
Rule 26(a)(1)(A)
i. the name, and if known, the address and telephone number of each individual
likely to have discoverable information – along with the subjects of that information –
that the disclosing party may use to support its claims or defenses, unless the use would
be solely for impeachment;
Response: Plaintiff. Plaintiff is likely to have discoverable information
concerning Jeffrey E. Epstein’s alleged conduct and Plaintiff’s claimed damages,
which the Co-Executors may use to support their defenses.
ii. a copy – or a description by category and location – of all documents,
electronically stored information, and tangible things that the disclosing party has in its
possession, custody, or control and may use to support its claims or defenses, unless the
use would be solely for impeachment;
Response: At present, the Co-Executors are not aware of any such documents,
electronically stored information, and tangible things.
iii. a computation of each category of damages claimed by the disclosing party – who
must also make available for inspection and copying as under Rule 34 the documents or
other evidentiary material, unless privileged or protected from disclosure, on which each
computation is based, including materials bearing on the nature and extent of injuries
suffered; and
Response: The Co-Executors do not claim damages.
iv. for inspection and copying as under Rule 34, any insurance agreement under
which an insurance business may be liable to satisfy all or part of a possible judgment in
the action or to indemnify or reimburse for payments made to satisfy the judgment.
Response: At present, the Co-Executors are unaware of any such insurance
agreement.
Case 1:19-cv-10577-LJL-DCF Document 46-3 Filed 05/07/20 Page 3 of 5
41202549v2 3
Dated: New York, New York
February 3, 2020
Respectfully submitted,
TROUTMAN SANDERS LLP
875 Third Avenue
New York, New York 10022
By: /s/ Bennet J. Moskowitz
Bennet J. Moskowitz
Attorneys for Defendants Darren K. Indyke and
Richard D. Kahn, Co-Executors of the Estate of
Jeffrey E. Epstein
Case 1:19-cv-10577-LJL-DCF Document 46-3 Filed 05/07/20 Page 4 of 5
41202549v2 4
CERTIFICATE OF SERVICE
The undersigned certifies that on February 3, 2020, I served a copy of the foregoing
Initial Disclosures of Defendants Darren K. Indyke and Richard D. Kahn, Co-Executor of the
Estate of Jeffrey E. Epstein, made pursuant to Fed. R. Civ. P. 26(a)(1), by sending them by email
to:
Sigrid McCawley
Boies, Schiller & Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Fort Lauderdale, FL 33301
(954)-377-4223
Fax: (954)-377-4223
Email: smccawley@bsfllp.com
s/Bennet J. Moskowitz
Case 1:19-cv-10577-LJL-DCF Document 46-3 Filed 05/07/20 Page 5 of 5
Exhibit D
Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 1 of 16
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JANE DOE 1000,
Plaintiff,
v.
DARREN K. INDYKE and RICHARD D. KAHN
in their capacities as the executors of the ESTATE
OF JEFFREY EDWARD EPSTEIN,
Defendants.
Case No. 1:19-cv-10577-LJL-DCF
DEFENDANTS’ OBJECTIONS AND RESPONSES TO PLAINTIFF JANE DOE 1000’S
FIRST SET OF INTERROGATORIES TO DEFENDANTS
Defendants Darren K. Indyke and Richard D. Kahn, as co-executors of the estate of Jeffrey
E. Epstein (the “Co-Executors”), by their attorneys, pursuant to Federal Rules of Civil Procedure
26 and 33, provide the following responses to Plaintiff Jane Doe 1000’s (“Plaintiff”) First Set of
Interrogatories to Defendants (the “Interrogatories”).
RESERVATION OF RIGHTS
These responses are made solely for the purpose of and in relation to discovery in the
above-captioned action. The Co-Executors submit these responses subject to, and without
intending to waive, and expressly preserving: (i) any objections as to relevancy, materiality,
competency, privilege and admissibility of any documents and information produced in discovery,
including without limitation herein; and (ii) the right to object to any other discovery requests. The
Co-Executors reserve their right to amend these responses if and when appropriate. Further, these
responses are neither an admission nor acceptance of any alleged facts, including without
limitation those stated in the Interrogatories.
Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 2 of 16
SPECIFIC OBJECTIONS TO DEFINITIONS
The Co-Executors object to Plaintiff’s definition of the term “Jeffrey Epstein” or “Epstein”
on the grounds that, insofar as it includes “any entities owned or controlled by Jeffrey Epstein, any
employee, agent, attorney, consultant, or representative of Jeffrey Epstein,” it is overbroad, unduly
burdensome, vague and ambiguous. The Co-Executors will interpret “Jeffrey Epstein” or
“Epstein” as Jeffrey E. Epstein.
The Co-Executors also object to Plaintiff’s definition of the term “Ghislaine Maxwell” or
“Maxwell” on the grounds that, insofar as it includes “any entities owned or controlled by
Ghislaine Maxwell, any employee, agent, attorney, consultant, or representative of Ghislaine
Maxwell,” it is overbroad, unduly burdensome, vague and ambiguous. The Co-Executors will
interpret “Ghislaine Maxwell” or “Maxwell” as Ghislaine Maxwell.
The Co-Executors also object to Plaintiff’s definition of the term “Massage” on the grounds
that it is more expansive than the common use of the term and is inconsistent with the term’s usage
in the Complaint.
SPECIFIC OBJECTIONS AND RESPONSES TO INTERROGATORIES
INTERROGATORY NO. 1
List the names and addresses of all persons who are believed or known by You, Your
agents, or Your attorneys to have any knowledge concerning any of the issues in this lawsuit, and
specify the subject matter about which the witness has knowledge.
RESPONSE:
The Co-Executors object to Interrogatory No. 1 on the grounds and to the extent that it
calls for the production of information protected by the attorney-client privilege, the attorney work
product doctrine, and any other applicable privilege or protection from disclosure. The Co Executors also object to Interrogatory No. 1 on the grounds that it seeks information that is neither
relevant to Plaintiff’s claims nor proportional to the needs of this case; it is also overly broad and
Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 3 of 16
unduly burdensome. Subject to and without waiving the foregoing objection, the Co-Executors
identify the following individual who may have knowledge concerning the issues in this lawsuit:
Plaintiff. The Co-Executors will supplement this response if any additional responsive information
is ascertained.
INTERROGATORY NO. 2
Identify all email accounts used by Epstein or any of his employees or agents on his behalf.
RESPONSE:
The Co-Executors object to Interrogatory No. 2 on the grounds that it seeks information
that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case; it is also
overly broad and unduly burdensome. The Co-Executors further object to this Interrogatory on
the grounds it seeks “discovery about discovery,” which would result in unnecessary expense.
Such matters are more appropriately and cost-effectively addressed in the context of the parties’
discussions regarding document discovery. The Co-Executors also object to this Interrogatory on
the grounds and to the extent that it calls for the production of information protected by the
attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or
protection from disclosure. The Co-Executors further object to this Interrogatory on the grounds
and to the extent that it calls for the production of information outside their possession, custody,
and control, and is unconstrained by time.
INTERROGATORY NO. 3
Identify all telephone numbers used by Epstein or any of his employees or agents acting
on his behalf, including beepers, Blackberry or PDA devices, cellular phones and land lines in any
of his residences, by stating the users name, complete telephone number(s), type of device and
name of the service provider.
Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 4 of 16
RESPONSE:
The Co-Executors object to Interrogatory No. 3 on the grounds that it seeks information
that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case; it is also
vague, overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory
on the grounds and to the extent that it calls for the production of information outside their
possession, custody, and control, and is unconstrained by time. The Co-Executors further object
to this Interrogatory on the grounds it seeks “discovery about discovery,” which would result in
unnecessary expense. Such matters are more appropriately and cost-effectively addressed in the
context of the parties’ discussions regarding document discovery. The Co-Executors also object
to this Interrogatory on the grounds and to the extent that it calls for the production of information
protected by the attorney-client privilege, the attorney work product doctrine, and any other
applicable privilege or protection from disclosure.
INTERROGATORY NO. 4
Identify all employees, including each employee’s position and dates and locations of
employment, who performed work or services in or on any property owned, leased, occupied, or
used by Epstein, including but not limited Epstein’s homes in Palm Beach, Florida, New York
City, the U.S. Virgin Islands, New Mexico, London and Paris, and provide the name and contact
information of the individual who hired, trained and supervised each employee.
RESPONSE:
The Co-Executors object to Interrogatory No. 4 on the grounds that it seeks information
that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case; it is also
overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
grounds that it assumes facts not in evidence and that the phrase “performed work or services in
or on any property” is vague and ambiguous. The Co-Executors also object to this Interrogatory
on the grounds and to the extent that it calls for the production of information protected by the
Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 5 of 16
attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or
protection from disclosure. The Co-Executors further object to this Interrogatory on the grounds
and to the extent that it calls for the production of information outside their possession, custody,
and control, and is unconstrained by time.
INTERROGATORY NO. 5
Identify all employees, including each employee’s position and dates and location of
employment, who performed work as an assistant, scheduler, secretary, masseuse or traveling
masseuse for Epstein and provide the name and contact information of the individual who hired,
trained and supervised each employee.
RESPONSE:
The Co-Executors object to Interrogatory No. 5 on the grounds that it seeks information
that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case; it is also
overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
grounds that the terms “scheduler” and “traveling masseuse” are vague and ambiguous. The Co Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors also object to this Interrogatory on the grounds and to the
extent that it calls for the production of information protected by the attorney-client privilege, the
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to this Interrogatory on the grounds and to the extent that it calls
for the production of information outside their possession, custody, and control, and is
unconstrained by time.
INTERROGATORY NO. 6
Identify all companies and/or persons who provided transportation services to Epstein,
whether as an employee or independent contractor, including without limitation drivers,
chauffeurs, boat captains, pilots, and aircraft crew, and provide the contact information for each
listed person or company.
Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 6 of 16
RESPONSE:
The Co-Executors object to Interrogatory No. 6 on the grounds that it seeks information
that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case; it is also
overly broad and unduly burdensome. The Co-Executors additionally object to this Interrogatory
on the grounds and to the extent that it calls for the production of information protected by the
attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or
protection from disclosure. The Co-Executors also object to this Interrogatory on the grounds that
the phrase “transportation services” is vague and ambiguous. The Co-Executors further object to
this Interrogatory on the grounds and to the extent that it calls for the production of information
outside their possession, custody, and control, and is unconstrained by time.
INTERROGATORY NO. 7
Identify all females by name and age for whom Epstein or his employees or agents provided
accommodations at 301 East 66th Street, New York, New York for any period of time.
RESPONSE:
The Co-Executors object to Interrogatory No. 7 on the grounds that it seeks information
that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case; it is also
overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
grounds and to the extent that it assumes facts not in evidence and on the grounds that the phrase
“provided accommodations” is vague and ambiguous. The Co-Executors additionally object to
this Interrogatory on the grounds and to the extent that it calls for the production of information
protected by the attorney-client privilege, the attorney work product doctrine, and any other
applicable privilege or protection from disclosure. The Co-Executors also object to this
Interrogatory on the grounds and to the extent that it assumes facts not in evidence. The Co Executors further object to this Interrogatory on the grounds and to the extent that it calls for the
Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 7 of 16
production of information outside their possession, custody, and control, and is unconstrained by
time.
INTERROGATORY NO. 8
Identify by name and age all persons who gave a massage or were asked to give a massage
to Epstein, Maxwell or a guest, or to whom Epstein or Maxwell gave a massage, at any of Epstein’s
residences and provide the location of each massage.
RESPONSE:
The Co-Executors object to Interrogatory No. 8 on the grounds that it seeks information
that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case; it is also
overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally
object to this Interrogatory on the grounds and to the extent that it calls for the production of
information protected by the attorney-client privilege, the attorney work product doctrine, and any
other applicable privilege or protection from disclosure. The Co-Executors further object to this
Interrogatory on the grounds and to the extent that it calls for the production of information outside
their possession, custody, and control, and is unconstrained by time.
INTERROGATORY NO. 9
Identify all dates when Andrew Albert Christian Edward, Duke of York (a/k/a Prince
Andrew) was present in any of Epstein’s residences from 1995 to the present, and provide the
location and purpose of each visit.
RESPONSE:
The Co-Executors object to Interrogatory No. 9 on the grounds that it seeks information
that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case; it is also
overly broad and unduly burdensome. The Co-Executors additionally object to this Interrogatory
on the grounds and to the extent that it calls for the production of information protected by the
Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 8 of 16
attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or
protection from disclosure. The Co-Executors also object to this Interrogatory on the grounds and
to the extent that it assumes facts not in evidence. The Co-Executors additionally object to the
time period stated in the Request, which is inconsistent with the time frame alleged in the
Complaint. The Co-Executors further object to this Interrogatory on the grounds and to the extent
that it calls for the production of information outside their possession, custody, and control.
INTERROGATORY NO. 10
Identify all dates when Alan Dershowitz was present in any of Epstein’s residences from
1995 to the present, and provide the location and purpose of each visit.
RESPONSE:
The Co-Executors object to Interrogatory No. 10 on the grounds that it seeks information
that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case; it is also
overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
grounds and to the extent that it assumes facts not in evidence. The Co-Executors also object to
this Interrogatory on the grounds and to the extent that it calls for the production of information
protected by the attorney-client privilege, the attorney work product doctrine, and any other
applicable privilege or protection from disclosure. The Co-Executors additionally object to the
time period stated in the Request, which is inconsistent with the time frame alleged in the
Complaint. The Co-Executors further object to this Interrogatory on the grounds and to the extent
that it calls for the production of information outside their possession, custody, and control.
INTERROGATORY NO. 11
Identify all dates when William “Bill” J. Clinton was present in any of Epstein’s residences,
on any of Epstein’s helicopters or planes, at any of Epstein’s offices, or at any event hosted or
affiliated with Epstein from 1995 to the present, and provide the location and purpose of each
encounter.
Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 9 of 16
RESPONSE:
The Co-Executors object to Interrogatory No. 11 on the grounds that it seeks information
that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case; it is also
overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
grounds that the phrase “any event hosted or affiliated with Epstein” is vague and ambiguous. The
Co-Executors additionally object to this Interrogatory on the grounds and to the extent that it calls
for the production of information protected by the attorney-client privilege, the attorney work
product doctrine, and any other applicable privilege or protection from disclosure. The Co Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to the time period stated in the Request,
which is inconsistent with the time frame alleged in the Complaint. The Co-Executors further
object to this Interrogatory on the grounds and to the extent that it calls for the production of
information outside their possession, custody, and control.
INTERROGATORY NO. 12
Identify any telecommunications, information technology, or audio-visual technology
company that Epstein hired for work in any of his residences or offices and provide the name and
contact information for each individual or company listed, in addition to the residence or office
serviced.
RESPONSE:
The Co-Executors object to Interrogatory No. 12 on the grounds that it seeks information
that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case; it is also
overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
grounds that the phrase “hired for work” is vague and ambiguous. The Co-Executors additionally
object to this Interrogatory on the grounds and to the extent that it calls for the production of
information protected by the attorney-client privilege, the attorney work product doctrine, and any
Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 10 of 16
other applicable privilege or protection from disclosure. The Co-Executors also object to this
Interrogatory on the grounds and to the extent that it assumes facts not in evidence. The Co Executors further object to this Interrogatory on the grounds and to the extent that it calls for the
production of information outside their possession, custody, and control, and is unconstrained by
time.
INTERROGATORY NO. 13
Identify the method or means in which Maxwell was paid by Epstein or any affiliated
entities from 1995 to the present.
RESPONSE:
The Co-Executors object to Interrogatory No. 13 on the grounds that it seeks information
that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case; it is also
overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
grounds that the phrases “method or means in which Maxwell was paid” and “affiliated entities”
are vague and ambiguous. The Co-Executors also object to this Interrogatory on the grounds and
to the extent that it assumes facts not in evidence. The Co-Executors also object to this
Interrogatory on the grounds and to the extent that it calls for the production of information
protected by the attorney-client privilege, the attorney work product doctrine, and any other
applicable privilege or protection from disclosure. The Co-Executors additionally object to the
time period stated in the Request, which is inconsistent with the time frame alleged in the
Complaint. The Co-Executors further object to this Interrogatory on the grounds and to the extent
that it calls for the production of information outside their possession, custody, and control.
INTERROGATORY NO. 14
Provide detailed quantification for all compensation Maxwell received for any services she
performed for the benefit of Epstein or any of his affiliated entities, broken down by year from
1995 to the present.
Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 11 of 16
RESPONSE:
The Co-Executors object to Interrogatory No. 14 on the grounds that it seeks information
that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case; it is also
overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
grounds that the phrase “services she performed for the benefit of Epstein or any of his affiliated
entities” is vague and ambiguous. The Co-Executors also object to this Interrogatory on the
grounds and to the extent that it assumes facts not in evidence. The Co-Executors also object to
this Interrogatory on the grounds and to the extent that it calls for the production of information
protected by the attorney-client privilege, the attorney work product doctrine, and any other
applicable privilege or protection from disclosure. The Co-Executors additionally object to the
time period stated in the Request, which is inconsistent with the time frame alleged in the
Complaint. The Co-Executors further object to this Interrogatory on the grounds and to the extent
that it calls for the production of information outside their possession, custody, and control.
INTERROGATORY NO. 15
Identify any loans or lines of credit issued to Maxwell from Epstein or any affiliated
entities, including the amount of the loans, the term of the loans, the interest rate of the loans, and
any payments made by Maxwell or on Maxwell’s behalf to repay such loans.
RESPONSE:
The Co-Executors object to Interrogatory No. 15 on the grounds that it seeks information
that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case; it is also
overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
grounds that the terms “lines of credit” and “any affiliated entities” are vague and ambiguous. The
Co-Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors also object to this Interrogatory on the grounds and to the
Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 12 of 16
extent that it calls for the production of information protected by the attorney-client privilege, the
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
INTERROGATORY NO. 16
Identify the dates, recipients, and purpose of the “two . . . payments, one in the amount of
$250,000 and another in the amount of $100,000 to . . . two employees or associates of Mr.
Epstein’s” referenced by Assistant United States Attorney Alexander Rossmiller at Epstein’s bail
hearing on July 15, 2019. See Transcript of July 15, 2019 Bail Hearing at 9:15-20, United States
v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.).
RESPONSE:
The Co-Executors object to Interrogatory No. 16 on the grounds that it seeks information
that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case. The Co Executors also object to this Interrogatory on the grounds and to the extent that it calls for the
production of information protected by the attorney-client privilege, the attorney work product
doctrine, and any other applicable privilege or protection from disclosure.
INTERROGATORY NO. 17
Identify all attorneys Epstein used from 1999 to 2002, including the attorney’s name and a
description of the work performed for Epstein, or any work performed for a third party paid for by
Epstein.
RESPONSE:
The Co-Executors object to Interrogatory No. 17 on the grounds that it is vague and seeks
information that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case.
The Co-Executors also object to this Interrogatory on the grounds and to the extent that it calls for
the production of information protected by the attorney-client privilege, the attorney work product
doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors
further object to this Interrogatory on the grounds and to the extent that it calls for the production
of information outside their possession, custody, and control.
Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 13 of 16
INTERROGATORY NO. 18
Identify all persons who have made a claim, complaint, demand or threat against Epstein
relating to alleged sexual abuse or misconduct on a female, and for each provide the following
information:
a. The person’s full name, last known address and telephone number;
b. The person’s attorney, if represented
c. The date of the alleged incident(s); and
d. If a civil case has been filed by or on behalf of the person, the case number and
identifying information.
RESPONSE:
The Co-Executors object to Interrogatory No. 18 on the grounds that it seeks information
that is neither relevant to Plaintiff’s claims nor proportional to the needs of this case; it is also
overly broad and unduly burdensome. The Co-Executors further object to this Interrogatory on the
grounds and to the extent that it calls for the production of information protected by the attorney client privilege, the attorney work product doctrine, and any other applicable privilege or
protection from disclosure. The Co-Executors object to this Interrogatory on the grounds that it
seeks publicly available information and information already known to Plaintiff or her counsel.
The Co-Executors also object to this Interrogatory on the grounds that the terms “claim, complaint,
demand or threat” and “misconduct” are overly broad, vague and ambiguous. The Co-Executors
further object to this Interrogatory on the grounds and to the extent that it calls for the production
of information outside their possession, custody, and control.
Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 14 of 16
Dated: New York, New York
April 16, 2020 TROUTMAN SANDERS LLP
By: /s/Bennet Moskowitz
Bennet Moskowitz
875 Third Avenue
New York, New York 10022
Tel: (212) 704- 6087
bennet.moskowitz@troutman.com
Attorney for Darren K. Indyke and
Richard D. Kahn, as co-executors of the
estate of Jeffrey E. Epstein
Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 15 of 16
CERTIFICATE OF SERVICE
The undersigned certifies that on April 16, 2020, I served a copy of the foregoing
Defendants’ Objections and Responses to Plaintiff Jane Doe 1000’s First Set of Interrogatories to
Defendants, by sending them by email to:
Sigrid McCawley
Boies, Schiller & Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Fort Lauderdale, FL, 33301
Email: smccawley@bsfllp.com
TROUTMAN SANDERS LLP
By: /s/Mary Grace W. Metcalfe
Mary Grace W. Metcalfe
875 Third Avenue
New York, New York 10022
Tel: (212) 704-6029
marygrace.metcalfe@troutman.com
Attorney for Darren K. Indyke and
Richard D. Kahn, as co-executors of the
estate of Jeffrey E. Epstein
Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 16 of 16
Exhibit E
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 1 of 51
41990916v3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JANE DOE 1000,
Plaintiff,
v.
DARREN K. INDYKE and RICHARD D. KAHN
in their capacities as the executors of the ESTATE
OF JEFFREY EDWARD EPSTEIN,
Defendants.
Case No. 1:19-cv-10577-LJL-DCF
DEFENDANTS’ OBJECTIONS AND RESPONSES TO PLAINTIFF JANE DOE 1000’S
FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS
Defendants Darren K. Indyke and Richard D. Kahn, as co-executors of the estate of Jeffrey
E. Epstein (the “Co-Executors”), by their attorneys, pursuant to Federal Rules of Civil Procedure
26 and 34, provide the following responses to Plaintiff Jane Doe 1000’s (“Plaintiff”) First Request
for Production of Documents (the “Requests”).
RESERVATION OF RIGHTS
These responses are made solely for the purpose of and in relation to discovery in the
above-captioned action. The Co-Executors submit these responses subject to, and without
intending to waive, and expressly preserving: (i) any objections as to relevancy, materiality,
competency, privilege and admissibility of any documents and information produced in discovery,
including without limitation herein; and (ii) the right to object to any other discovery requests. The
Co-Executors reserve their right to amend these responses if and when appropriate. Further, these
responses are neither an admission nor acceptance of any alleged facts, including without
limitation those stated in the Requests.
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 2 of 51
2
SPECIFIC OBJECTIONS TO DEFINITIONS
The Co-Executors object to Plaintiff’s definition of the term “Jeffrey Epstein” or “Epstein”
on the grounds that, insofar as it includes “any entities owned or controlled by Jeffrey Epstein, any
employee, agent, attorney, consultant, or representative of Jeffrey Epstein,” it is overbroad, unduly
burdensome, vague and ambiguous. The Co-Executors will interpret “Jeffrey Epstein” or
“Epstein” as Jeffrey E. Epstein.
The Co-Executors also object to Plaintiff’s definition of the term “Ghislaine Maxwell” or
“Maxwell” on the grounds that, insofar as it includes “any entities owned or controlled by
Ghislaine Maxwell, any employee, agent, attorney, consultant, or representative of Ghislaine
Maxwell,” it is overbroad, unduly burdensome, vague and ambiguous. The Co-Executors will
interpret “Ghislaine Maxwell” or “Maxwell” as Ghislaine Maxwell.
The Co-Executors also object to Plaintiff’s definition of the term “Sarah Kellen” or
“Kellen” on the grounds that, insofar as it includes “any entities owned or controlled by Sarah
Kellen, any employee, agent, attorney, consultant, or representative of Sarah Kellen,” it is
overbroad, unduly burdensome, vague and ambiguous. The Co-Executors will interpret “Sarah
Kellen” or “Kellen” as Sarah Kellen.
SPECIFIC OBJECTIONS AND RESPONSES TO REQUESTS
REQUEST NO. 1
All Documents relating to Plaintiff, Jane Doe 1000, whether or not they reference her by
name. This Request includes, but is not limited to, all communications, diaries, journals, calendars,
blog posts (whether published or not), notes (handwritten or otherwise), memoranda,
documentation of car services, airline tickets and/or travel itineraries, wire transfer receipts, or any
other Documents that concern Jane Doe 1000 in any way, whether or not they reference her by
name.
RESPONSE:
The Co-Executors object to Request No. 1 on the grounds and to the extent that it calls for
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 3 of 51
3
the production of documents and information protected by the attorney-client privilege, attorney
work product doctrine, and any other applicable privilege or protection from disclosure. The Co Executors further object to Request No. 1 on the grounds that, to the extent it seeks documents that
are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s claims nor
proportional to the needs of this case; it is also overly broad and unduly burdensome.
Subject to and without waiving these objections and the parties’ entry into a mutually
acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
located pursuant to mutually agreeable search parameters. The Co-Executors are working to
collect and process documents for these purposes and will meet and confer with counsel for
Plaintiff about the search as soon as practicable.
REQUEST NO. 2
All telephone records and other Documents reflecting telephone calls made by Epstein or
to Epstein, including without limitation cell phone records, telephone logs, and message pads, to
or from Epstein’s employees.
RESPONSE:
The Co-Executors object to Request No. 2 on the grounds and to the extent that it calls for
the production of documents and information protected by the attorney-client privilege, attorney
work product doctrine, and any other applicable privilege or protection from disclosure. The Co Executors further object to Request No. 2 on the grounds that, to the extent it seeks documents that
are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s claims nor
proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co Executors further object to this Request on the grounds and to the extent that it calls for the
production of documents and information outside their possession, custody, and control.
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 4 of 51
4
REQUEST NO. 3
All telephone records and other documents reflecting telephone calls made by Epstein or
to Epstein, including without limitation cell phone records, telephone logs and message pads, to
or from Maxwell or Kellen.
RESPONSE:
The Co-Executors object to Request No. 3 on the grounds and to the extent that it calls for
the production of documents and information protected by the attorney-client privilege, attorney
work product doctrine, and any other applicable privilege or protection from disclosure. The Co Executors further object to Request No. 3 on the grounds that, to the extent it seeks documents that
are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s claims nor
proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co Executors further object to this Request on the grounds and to the extent that it calls for the
production of documents and information outside their possession, custody, and control.
REQUEST NO. 4
All telephone records associated with Epstein, Maxwell, or Kellen, including cell phone
records, telephone logs, and message pads, that show any communications with Jane Doe 1000 or
members of Jane Doe 1000’s family.
RESPONSE:
The Co-Executors object to Request No. 4 on the grounds and to the extent that it calls for
the production of documents and information protected by the attorney-client privilege, attorney
work product doctrine, and any other applicable privilege or protection from disclosure. The Co Executors further object to Request No. 4 on the grounds that, to the extent it seeks documents that
are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s claims nor
proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co Executors additionally object to this Request on the grounds and to the extent that it specifically
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 5 of 51
5
calls for the production of documents and information outside their possession, custody, and
control.
REQUEST NO. 5
All Documents relating to calendars, schedules, or appointments for Epstein.
RESPONSE:
The Co-Executors object to Request No. 5 on the grounds and to the extent that it calls for
the production of documents and information protected by the attorney-client privilege, attorney
work product doctrine, and any other applicable privilege or protection from disclosure. The Co Executors further object to Request No. 5 on the grounds that, to the extent it seeks documents that
are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s claims nor
proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co Executors also object to this Request on the grounds and to the extent that it assumes facts not in
evidence.
REQUEST NO. 6
All Documents relating to contact lists, phone lists, or address books for Epstein.
RESPONSE:
The Co-Executors object to Request No. 6 on the grounds and to the extent that it calls for
the production of documents and information protected by the attorney-client privilege, attorney
work product doctrine, and any other applicable privilege or protection from disclosure. The Co Executors further object to Request No. 6 on the grounds that, to the extent it seeks documents that
are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s claims nor
proportional to the needs of this case; it is also overly broad and unduly burdensome.
REQUEST NO. 7
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All Documents relating to any Amazon.com account associated with Epstein or
Maxwell, including without limitation the purchase order history for each account.
RESPONSE:
The Co-Executors object to Request No. 7 on the grounds and to the extent that it calls for
the production of documents and information protected by the attorney-client privilege, attorney
work product doctrine, and any other applicable privilege or protection from disclosure. The Co Executors further object to Request No. 7 on the grounds that, to the extent it seeks documents that
are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s claims nor
proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co Executors additionally object to this Request on the grounds and to the extent that it specifically
calls for the production of documents and information outside their possession, custody, and
control. The Co-Executors also object to this Request on the grounds and to the extent that it
assumes facts not in evidence.
REQUEST NO. 8
All video tapes, audio tapes, photographs, portraits, including film negatives or film slides,
CDs, or any other print or electronic media depicting Epstein, Maxwell or Kellen in the presence
of Jane Doe 1000.
RESPONSE:
The Co-Executors object to Request No. 8 on the grounds and to the extent that it calls for
the production of documents and information protected by the attorney-client privilege, attorney
work product doctrine, and any other applicable privilege or protection from disclosure. The Co Executors additionally object to this Request as duplicative of Request No. 9. The Co-Executors
additionally object to this Request on the grounds and to the extent that it specifically calls for the
production of documents and information outside their possession, custody, and control. The Co Executors also object to this Request on the grounds and to the extent that it assumes facts not in
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 7 of 51
7
evidence.
Subject to and without waiving these objections and the parties’ entry into a mutually
acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
located pursuant to mutually agreeable search parameters. The Co-Executors are working to
collect and process documents for these purposes and will meet and confer with counsel for
Plaintiff about the search as soon as practicable.
REQUEST NO. 9
All video tapes, audio tapes, photographs, portraits, including film negatives or film slides,
CDs, or any other print or electronic media depicting or relating to Jane Doe 1000.
RESPONSE:
The Co-Executors object to Request No. 9 on the grounds and to the extent that it calls for
the production of documents and information protected by the attorney-client privilege, attorney
work product doctrine, and any other applicable privilege or protection from disclosure. The Co Executors additionally object to this Request as duplicative of Request No. 8. The Co-Executors
additionally object to this Request on the grounds and to the extent that it specifically calls for the
production of documents and information outside their possession, custody, and control. The Co Executors also object to this Request on the grounds and to the extent that it assumes facts not in
evidence.
Subject to and without waiving these objections and the parties’ entry into a mutually
acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
located pursuant to mutually agreeable search parameters. The Co-Executors are working to
collect and process documents for these purposes and will meet and confer with counsel for
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Plaintiff about the search as soon as practicable.
REQUEST NO. 10
All Documents relating to any communications between Epstein, Maxwell, or Kellen and
Jane Doe 1000 or family members of Jane Doe 1000.
RESPONSE:
The Co-Executors object to Request No. 10 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 10 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control. The Co-Executors also object to this Request on the grounds and to the
extent that it assumes facts not in evidence. The Co-Executors further object to this Request on
the grounds that it seeks information already known to Plaintiff or her counsel.
Subject to and without waiving these objections and the parties’ entry into a mutually
acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
located pursuant to mutually agreeable search parameters. The Co-Executors are working to
collect and process documents for these purposes and will meet and confer with counsel for
Plaintiff about the search as soon as practicable.
REQUEST NO. 11
All Documents relating to any gifts or monetary payments provided to, or for the benefit
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of, Jane Doe 1000 by Epstein, Maxwell, or Kellen, or any related entity.
RESPONSE:
The Co-Executors object to Request No. 11 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control. The Co-Executors also object to this Request on the grounds and to the
extent that it assumes facts not in evidence. The Co-Executors further object to this Request on
the grounds that it seeks information already known to Plaintiff or her counsel.
Subject to and without waiving these objections and the parties’ entry into a mutually
acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
located pursuant to mutually agreeable search parameters. The Co-Executors are working to
collect and process documents for these purposes and will meet and confer with counsel for
Plaintiff about the search as soon as practicable.
REQUEST NO. 12
All Documents relating to communications between Epstein and Maxwell or Kellen about
Jane Doe 1000.
RESPONSE:
The Co-Executors object to Request No. 12 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
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10
specifically calls for the production of documents and information outside their possession,
custody, and control. The Co-Executors also object to this Request on the grounds and to the
extent that it assumes facts not in evidence.
Subject to and without waiving these objections and the parties’ entry into a mutually
acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
located pursuant to mutually agreeable search parameters. The Co-Executors are working to
collect and process documents for these purposes and will meet and confer with counsel for
Plaintiff about the search as soon as practicable.
REQUEST NO. 13
All Documents relating to Jane Doe 1000’s travel to Florida.
RESPONSE:
The Co-Executors object to Request No. 13 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control. The Co-Executors also object to this Request on the grounds and to the extent
that it assumes facts not in evidence. The Co-Executors further object to this Request on the
grounds that it seeks documents in Plaintiff’s possession.
Subject to and without waiving these objections and the parties’ entry into a mutually
acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
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11
located pursuant to mutually agreeable search parameters. The Co-Executors are working to
collect and process documents for these purposes and will meet and confer with counsel for
Plaintiff about the search as soon as practicable.
REQUEST NO. 14
All Documents relating to Epstein or his employees obtaining or preparing travel
documents for Jane Doe 1000’s travel.
RESPONSE:
The Co-Executors object to Request No. 14 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors also object to this Request on the grounds that the term “travel
documents” is vague and ambiguous. The Co-Executors additionally object to this Request on the
grounds and to the extent that it specifically calls for the production of documents and information
outside their possession, custody, and control.
Subject to and without waiving these objections and the parties’ entry into a mutually
acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
located pursuant to mutually agreeable search parameters. The Co-Executors are working to
collect and process documents for these purposes and will meet and confer with counsel for
Plaintiff about the search as soon as practicable.
REQUEST NO. 15
All Documents relating to any modeling referral, job, audition, casting, or other
opportunity that Epstein or his employees assisted Jane Doe 1000 in obtaining.
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12
RESPONSE:
The Co-Executors object to Request No. 15 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control. The Co-Executors further object to this Request on the grounds that it seeks
information in Plaintiff’s possession.
Subject to and without waiving these objections and the parties’ entry into a mutually
acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
located pursuant to mutually agreeable search parameters. The Co-Executors are working to
collect and process documents for these purposes and will meet and confer with counsel for
Plaintiff about the search as soon as practicable.
REQUEST NO. 16
All Documents relating to any accommodations made by Epstein or his employees for Jane
Doe 1000 at an apartment building located at 301 E. 66th Street, New York, NY.
RESPONSE:
The Co-Executors object to Request No. 16 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
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13
possession, custody, and control.
Subject to and without waiving these objections and the parties’ entry into a mutually
acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
located pursuant to mutually agreeable search parameters. The Co-Executors are working to
collect and process documents for these purposes and will meet and confer with counsel for
Plaintiff about the search as soon as practicable.
REQUEST NO. 17
All Documents relating to McDonald/Richards Model Management.
RESPONSE:
The Co-Executors object to Request No. 17 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 17 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control.
REQUEST NO. 18
All Documents relating to any service that Epstein, Maxwell, or Kellen provided or funded
for Jane Doe 1000, including but not limited to hair appointments and dentist appointments.
RESPONSE:
The Co-Executors object to Request No. 18 on the grounds and to the extent that it calls
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14
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control. The Co-Executors also object to this Request on the grounds and to the
extent that it assumes facts not in evidence. The Co-Executors further object to this Request on
the grounds that it seeks documents in Plaintiff’s possession.
Subject to and without waiving these objections and the parties’ entry into a mutually
acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
located pursuant to mutually agreeable search parameters. The Co-Executors are working to
collect and process documents for these purposes and will meet and confer with counsel for
Plaintiff about the search as soon as practicable.
REQUEST NO. 19
All Documents relating to any employee lists or records associated with Epstein or any
related entity.
RESPONSE:
The Co-Executors object to Request No. 19 on the grounds and to the extent that it
calls for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 19 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
REQUEST NO. 20
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15
All Documents relating to payments made from Epstein, or any related entity, to Maxwell,
Kellen, Nadia Marcinkova (a/k/a Nadia Marcinko), Lesley Groff, and Adriana Ross (a/k/a Adriana
Mucinska), including payments or bonuses for work performed, gifts, real estate purchases, living
expenses, business ventures, and payments to Maxwell’s charitable endeavors, including the
TerraMar project.
RESPONSE:
The Co-Executors object to Request No. 20 on the grounds and to the extent that it
calls for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 20 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control.
REQUEST NO. 21
All Documents relating to any credit card, business, or store account used by Maxwell,
Kellen, Groff, Nadia Marcinkova, or Adriana Ross that was paid for by Epstein or any related
entity.
RESPONSE:
The Co-Executors object to Request No. 21 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 21 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
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16
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 22
All Documents relating to confidentiality or separation agreements between Epstein or any
associated entity and any employee or associate of Epstein.
RESPONSE:
The Co-Executors object to Request No. 22 on the grounds and to the extent that it
calls for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 22 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence.
REQUEST NO. 23
All Documents relating to any house staff, employees, or individuals who were
compensated by Epstein or any individual or entity affiliated with Epstein, during and/or after
employment ceased, including but not limited to the following individuals: Jean-Luc Brunel,
Emmy Tayler, Sarah Kellen, Nadia Marcinkova, Lesley Groff, Cecilia Steen, Adriana Ross,
Luciano “Jojo” Fontanilla, Rosalyn “Lynn” Fontanilla, Juan Alessi, Maria Alessi, Louella Rabuyo,
Michael Liffman, Cathy and Miles Alexander, Deidre Stratton, Floyd Stratton, Brice Gordon,
Karen Gordon, Michael O’Dell, Kate O’Dell, David Barger, Larry Visoski, David Rodgers, Andy
Stewart, Adam Perry Lang, Ryon Dionne and Igor Zinoviev.
RESPONSE:
The Co-Executors object to Request No. 23 on the grounds and to the extent that it
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17
calls for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 23 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control.
REQUEST NO. 24
All Documents relating to Rinaldo Rizzo from 2002 to the present.
RESPONSE:
The Co-Executors object to Request No. 24 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 24 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control.
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REQUEST NO. 25
All Documents identifying any employees that performed work or services in or on any
property owned, occupied, or used by Epstein.
RESPONSE:
The Co-Executors object to Request No. 25 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 25 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control.
REQUEST NO. 26
All Documents reflecting Your or Epstein’s direct or indirect interest or control over
business or personal assets of any employee or associate of Epstein, including but not limited to
articles of incorporation, power of attorneys, contracts, and meeting minutes.
RESPONSE:
The Co-Executors object to Request No. 26 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 26 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to Request No. 26 on the grounds of and to the extent it
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19
seeks documents necessarily held in a capacity other than as Co-Executors of the Estate. The Co Executors also object to this Request on the grounds and to the extent that it assumes facts not in
evidence.
REQUEST NO. 27
All video tapes, audio tapes, photographs, portraits, including film negatives or film slides,
CDs, flash drives, memory cards, or any other print or electronic media depicting Epstein in the
presence of Maxwell or Kellen.
RESPONSE:
The Co-Executors object to Request No. 27 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 27 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control.
REQUEST NO. 28
All Documents relating to Maxwell, including but not limited to all Documents relating to
communications between Epstein and Maxwell or Kellen.
RESPONSE:
The Co-Executors object to Request No. 28 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 28 on the grounds that, to the extent it seeks
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20
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control.
REQUEST NO. 29
All Documents relating to any agreements (including but not limited to confidentiality
agreements, insurance policies or indemnification agreements, employment agreements,
separation agreements, or agreements to pay legal fees) between Epstein and Maxwell or Kellen,
whether such agreements are written, verbal, or merely understood among the parties and not
otherwise expressed, whether or not such agreements were ever executed or carried out.
RESPONSE:
The Co-Executors object to Request No. 29 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 29 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control. The Co-Executors also object to this Request on the grounds
that the phrase “merely understood among the parties and not otherwise expressed” is vague and
ambiguous.
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21
REQUEST NO. 30
All Documents relating to any Joint Defense Agreement entered into between Epstein and
Maxwell or Kellen.
RESPONSE:
The Co-Executors object to Request No. 30 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 30 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence.
REQUEST NO. 31
All Documents relating to or describing any work Maxwell or Kellen performed for or
with Epstein or any affiliated entity.
RESPONSE:
The Co-Executors object to Request No. 31 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 31 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
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22
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 32
All Documents related to any communications between Epstein or Epstein’s attorneys and
Kellen or Kellen’s attorneys related to the issue of sexual abuse of females.
RESPONSE:
The Co-Executors object to Request No. 32 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 32 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 33
All Documents related to any communications between Epstein or Epstein’s attorneys and
Maxwell or Maxwell’s attorneys related to the issue of sexual abuse of females.
RESPONSE:
The Co-Executors object to Request No. 33 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 33 on the grounds that, to the extent it seeks
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23
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 34
All Documents related to any communications between Epstein or Epstein’s attorneys and
Kellen or Kellen’s attorneys related to the recruitment of any female for any purpose, including
socializing or performing any type of work or service.
RESPONSE:
The Co-Executors object to Request No. 34 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 34 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 35
All Documents related to any communications between Epstein or Epstein’s attorneys
and Maxwell or Maxwell’s attorneys related to the recruitment of any female for any purpose,
including socializing or performing any type of work or service.RESPONSE:
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The Co-Executors object to Request No. 35 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 35 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 36
All Documents relating to any bank account, household account, or financial account
identifying Maxwell in any way, including without limitation as an authorized user on the account.
RESPONSE:
The Co-Executors object to Request No. 36 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 36 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control. The Co-Executors also object to this Request on the grounds
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 25 of 51
25
that the terms “household account” and “financial account” are vague and ambiguous.
REQUEST NO. 37
All Documents or other media (including photographs) describing or depicting nude or
partially nude females, including but not limited to all Documents or other media describing or
depicting how such photographs were displayed in any of Epstein’s various residences.
RESPONSE:
The Co-Executors object to Request No. 37 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 37 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control. The Co-Executors further object to this Request on the grounds
that it seeks publicly available information and information already known to Plaintiff or her
counsel.
REQUEST NO. 38
All Documents relating to any payments Epstein made to educational institutions or
programs, visual or performing arts schools, or scholarship programs and, to the extent the
payment was made for the benefit of another person, any Documents reflecting the identity of that
person.
RESPONSE:
The Co-Executors object to Request No. 38 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
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26
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 38 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 39
All Documents relating to any request, proposal, or inquiry made by Epstein, Maxwell or
Kellen to any modeling agency for casting, recruitment, potential employment, and/or other
advancement opportunities and Documents reflecting the identity of any person responding to
the request, proposal, or inquiry.
RESPONSE:
The Co-Executors object to Request No. 39 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 39 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control.
REQUEST NO. 40
All Documents relating to calendars, schedules, or appointments for Epstein that relate to
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27
visits with or communications with females, excluding immediate family members.
RESPONSE:
The Co-Executors object to Request No. 40 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 40 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 41
All Documents identifying any individuals who ever provided Epstein with a massage.
RESPONSE:
The Co-Executors object to Request No. 41 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 41 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
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28
custody, and control.
REQUEST NO. 42
All Documents identifying any individuals who Epstein paid for sexual acts, either with
Epstein or with other individuals.
RESPONSE:
The Co-Executors object to Request No. 42 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 42 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 43
All Documents identifying any females recruited or referred by Maxwell or Kellen for
work, sexual acts, or companionship for Epstein.
RESPONSE:
The Co-Executors object to Request No. 43 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 43 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
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29
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 44
All Documents relating to any females Maxwell or Kellen introduced to Epstein for work,
sexual acts, or companionship for Epstein.
RESPONSE:
The Co-Executors object to Request No. 44 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 44 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 45
All Documents relating to any females Epstein paid to perform any kind of service,
including but not limited to work as an assistant, massage therapist, model, private exercise
instructor, dance instructor or companion.
RESPONSE:
The Co-Executors object to Request No. 45 on the grounds and to the extent that it calls
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30
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 45 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 46
All Documents relating to massages, including but not limited to Documents reflecting
recruiting or hiring masseuses, advertising for masseuses, flyers created for distribution at high
schools or colleges, and Documents reflecting e-mails or calls to individuals relating to massages.
RESPONSE:
The Co-Executors object to Request No. 46 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 46 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
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31
REQUEST NO. 47
All Documents relating to passports applied for, obtained, or paid for by Epstein on behalf
of any female recruited to work for Epstein to perform any kind of service, including but not
limited to work as an assistant, massage therapist, model, private exercise instructor, dance
instructor, or companion.
RESPONSE:
The Co-Executors object to Request No. 47 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 47 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 48
All Documents relating to Epstein’s travel, when that travel was either with Maxwell,
Kellen, or other females or to meet Maxwell, Kellen, or other females, including but not limited
to documentation of commercial flights, private flights, helicopters, boat charters, and car services,
passport records, records indicating passengers traveling with Epstein, hotel records, and credit
card receipts.
RESPONSE:
The Co-Executors object to Request No. 48 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 48 on the grounds that, to the extent it seeks
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 32 of 51
32
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 49
All Documents relating to Epstein’s travel to and from Florida between 1999 and 2003.
RESPONSE:
The Co-Executors object to Request No. 49 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 49 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
REQUEST NO. 50
All Documents, including flight logs, identifying passengers, manifests, or flight plans for
any helicopter or plane ever owned, leased, chartered, or controlled by Epstein or any associated
entity, from 1995 to the present.
RESPONSE:
The Co-Executors object to Request No. 50 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 50 on the grounds that, to the extent it seeks
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 33 of 51
33
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to the time period stated in the Request, which is inconsistent
with the time frame alleged in the Complaint.
REQUEST NO. 51
All Documents relating to travel with Epstein of any female, including but not limited to
documentation of commercial flights, private flights, helicopters, boat charters, car services,
passport records, records indicating passengers traveling with Epstein, hotel records, and credit
card receipts.
RESPONSE:
The Co-Executors object to Request No. 51 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 51 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 52
All video tapes, audio tapes, photographs or any other print or electronic media depicting
any of Epstein’s residences or aircrafts or inside of any of Epstein’s residences or aircrafts.
RESPONSE:
The Co-Executors object to Request No. 52 on the grounds and to the extent that it calls
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34
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 52 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
REQUEST NO. 53
All Documents relating to Epstein’s ownership, lease, occupancy, use, or management of
property located at 301 East 66th Street, New York, NY.
RESPONSE:
The Co-Executors object to Request No. 53 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 53 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
REQUEST NO. 54
All Documents relating to Alan Dershowitz.
RESPONSE:
The Co-Executors object to Request No. 54 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 54 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
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35
The Co-Executors additionally object to this Request as duplicative of Request No. 55. The Co Executors additionally object to this Request on the grounds and to the extent that it specifically
calls for the production of documents and information outside their possession, custody, and
control.
REQUEST NO. 55
All Documents relating to any communications between Epstein or Epstein’s attorneys and
Alan Dershowitz or Alan Dershowitz’s attorneys.
RESPONSE:
The Co-Executors object to Request No. 55 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 55 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control. REQUEST NO. 56
All Documents relating to any communications between Epstein or Maxwell and Alan
Dershowitz relating to Jane Doe 1000.
RESPONSE:
The Co-Executors object to Request No. 56 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 36 of 51
36
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control. The Co-Executors also object to this Request on the grounds and to the
extent that it assumes facts not in evidence.
Subject to and without waiving these objections and the parties’ entry into a mutually
acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
located pursuant to mutually agreeable search parameters. The Co-Executors are working to
collect and process documents for these purposes and will meet and confer with counsel for
Plaintiff about the search as soon as practicable.
REQUEST NO. 57
All Documents relating to any communications between Epstein’s attorneys and Alan
Dershowitz or Alan Dershowitz’s attorneys relating to Jane Doe 1000.
RESPONSE:
The Co-Executors object to Request No. 57 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 57 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
REQUEST NO. 58
All Documents relating to any Joint Defense Agreement entered into between Epstein and
Alan Dershowitz.
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37
RESPONSE:
The Co-Executors object to Request No. 58 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 58 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
REQUEST NO. 59
All Documents relating to Alan Dershowitz traveling with Epstein or to any of Epstein’s
homes.
RESPONSE:
The Co-Executors object to Request No. 59 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 59 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control.
REQUEST NO. 60
All Documents relating to Eva Dubin or Glen Dubin.
RESPONSE:
The Co-Executors object to Request No. 60 on the grounds and to the extent that it calls
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38
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 60 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
REQUEST NO. 61
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 emails
RESPONSE:
The Co-Executors object to Request No. 61 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 61 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 62
All Documents relating to communications with William “Bill” J. Clinton or persons acting
on his behalf.
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39
RESPONSE:
The Co-Executors object to Request No. 62 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 62 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
REQUEST NO. 63
All Documents relating to communications between You or Epstein and John Doe, the
intervenor in Giuffre v. Maxwell, No. 15-cv-07433-LAP (S.D.N.Y.), or John Doe’s attorneys.
RESPONSE:
The Co-Executors object to Request No. 63 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 63 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to Request No. 63 on the grounds of and to the extent it
seeks documents necessarily held in a capacity other than as Co-Executors of the Estate. The Co Executors additionally object to this Request on the grounds and to the extent that it specifically
calls for the production of documents and information outside their possession, custody, and
control. The Co-Executors further object to this Request on the grounds that it seeks information
already known to Plaintiff or her counsel.
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40
REQUEST NO. 64
All Documents relating to Leslie Wexner or Abigail Wexner.
RESPONSE:
The Co-Executors object to Request No. 64 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 64 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to this Request on the grounds of and to the extent it seeks
documents necessarily held in a capacity other than as Co-Executors of the Estate. The Co Executors additionally object to this Request on the grounds and to the extent that it specifically
calls for the production of documents and information outside their possession, custody, and
control.
REQUEST NO. 65
All Documents reflecting Your or Epstein’s direct or indirect interest or control over
business or personal assets of Leslie Wexner or Abigail Wexner, including but not limited to
articles of incorporation, power of attorneys, contracts, and meeting minutes.
RESPONSE:
The Co-Executors object to Request No. 65 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 65 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 41 of 51
41
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to Request No. 65 on the grounds of and to the extent it
seeks documents necessarily held in a capacity other than as Co-Executors of the Estate. The Co Executors also object to this Request on the grounds and to the extent that it assumes facts not in
evidence.
REQUEST NO. 66
All Documents relating to any business transactions, including real estate and other
financial transactions, between Epstein and Leslie Wexner from 1990 to the present.
RESPONSE:
The Co-Executors object to Request No. 66 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 66 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to the time period stated in the Request, which is inconsistent
with the time frame alleged in the Complaint. The Co-Executors also object to this Request on the
grounds and to the extent that it assumes facts not in evidence.
REQUEST NO. 67
All Documents relating to Victoria’s Secret models or actresses who were ever in the
presence of Epstein between 1999 and the present.
RESPONSE:
The Co-Executors object to Request No. 67 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 42 of 51
42
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 67 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 68
All Documents relating to any work that Epstein performed for Victoria’s Secret or
authority that Epstein possessed over Victoria’s Secret.
RESPONSE:
The Co-Executors object to Request No. 68 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 68 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 69
All Documents relating to modeling jobs, auditions, casting calls, or other opportunities
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 43 of 51
43
with Victoria’s Secret or any modeling agency, that Epstein assisted any person in securing.
RESPONSE:
The Co-Executors object to Request No. 69 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 69 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 70
All Documents relating to communications between Epstein and Andrew Albert Christian
Edward, Duke of York (a/k/a Prince Andrew) or persons acting on his behalf.
RESPONSE:
The Co-Executors object to Request No. 70 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 70 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 44 of 51
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not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 71
From January 2012 to the present, all Documents concerning any source of funding for the
TerraMar Project or any other not-for-profit entities for which Epstein provided funding, including
but not limited to funding for the Clinton Global Initiative, the Clinton Foundation (a/k/a William
J. Clinton Foundation, a/k/a/ the Bill, Hillary & Chelsea Clinton Foundation), and the Clinton
Foundation Climate Change Initiative.
RESPONSE:
The Co-Executors object to Request No. 71 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 71 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
extent that it specifically calls for the production of documents and information outside their
possession, custody, and control.
REQUEST NO. 72
All Documents relating to Epstein’s estate planning, will, or any financial transactions that
occurred between the date of his arrest on July 6, 2019, and his death on August 10, 2019.
RESPONSE:
The Co-Executors object to Request No. 72 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
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attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 72 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
REQUEST NO. 73
All Documents relating to communications between Epstein or Epstein’s attorneys or
agents and any law enforcement entity, including the FBI, NYPD, Palm Beach Police Department,
and West Palm Beach Police Department, relating to any criminal investigation, cooperation in
any criminal investigation, potential criminal charges, immunity, deferred prosecution, or
suspected or known criminal activity.
RESPONSE:
The Co-Executors object to Request No. 73 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 73 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors further object to this Request on the grounds that it seeks publicly available
information and information already known to Plaintiff or her counsel.
REQUEST NO. 74
All Documents relating to communications between Epstein and Epstein’s attorneys or
agents and Alexander Acosta, Maria Villafana, or other attorneys associated with the United States
Attorney’s Office for the Southern District of Florida.
RESPONSE:
The Co-Executors object to Request No. 74 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 46 of 51
46
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 74 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors further object to this Request on the grounds that it seeks publicly available
information and information already known to Plaintiff or her counsel.
REQUEST NO. 75
All Documents concerning any action or lawsuit brought against Epstein or Maxwell or
Kellen, including but not limited to actions or lawsuits brought in foreign jurisdictions.
RESPONSE:
The Co-Executors object to Request No. 75 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 75 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors further object to Request No. 75 on the grounds that it seeks publicly available
information and information already known to Plaintiff or her counsel.
REQUEST NO. 76
All Documents produced by Epstein or Maxwell in discovery in Giuffre v. Maxwell, No.
15-cv-07433-LAP (S.D.N.Y.).
RESPONSE:
The Co-Executors object to Request No. 76 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 47 of 51
47
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 76 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control. The Co-Executors further object to this Request on the grounds that it seeks
publicly available information and information already known to Plaintiff or her counsel.
REQUEST NO. 77
All Documents seized by any government agency from Epstein’s home located at 9 East
71st Street, New York, New York or at 358 El Brillo Way, Palm Beach, Florida.
RESPONSE:
The Co-Executors object to Request No. 77 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 77 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
The Co-Executors additionally object to this Request on the grounds and to the extent that it
specifically calls for the production of documents and information outside their possession,
custody, and control.
REQUEST NO. 78
All Documents relating to the “two . . . payments, one in the amount of $250,000 and
another in the amount of $100,000 to . . . two employees or associates of Mr. Epstein’s” referenced
by Assistant United States Attorney Alexander Rossmiller at Epstein’s bail hearing on July 15,
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48
2019, including Documents sufficient to identify the recipients of those payments. See Transcript
of July 15, 2019 Bail Hearing at 9:15-20, United States v. Epstein, No. 19-cr-490 (RMB)
(S.D.N.Y.).
RESPONSE:
The Co-Executors object to Request No. 78 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 78 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
REQUEST NO. 79
All Documents relating to Shoppers Travel, including records of payment to Shoppers
Travel, communications with Shoppers Travel, or records of any airline tickets, hotel reservations,
or other travel accommodations booked through Shoppers Travel by Epstein or his agents or
employees for himself or any other person.
RESPONSE:

The Co-Executors object to Request No. 79 on the grounds and to the extent that it calls
for the production of documents and information protected by the attorney-client privilege,
attorney work product doctrine, and any other applicable privilege or protection from disclosure.
The Co-Executors further object to Request No. 79 on the grounds that, to the extent it seeks
documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff’s
claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.

Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 49 of 51
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Dated: New York, New York
April 16, 2020 TROUTMAN SANDERS LLP
By: /s/Bennet Moskowitz
Bennet Moskowitz
875 Third Avenue
New York, New York 10022
Tel: (212) 704- 6087
bennet.moskowitz@troutman.com
Attorney for Darren K. Indyke and
Richard D. Kahn, as co-executors of
the estate of Jeffrey E. Epstein

Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 50 of 51
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CERTIFICATE OF SERVICE
The undersigned certifies that on April 16, 2020, I served a copy of the foregoing
Defendants’ Objections and Responses to Plaintiff Jane Doe 1000’s First Request for Production
of Documents to Defendants, by sending them by email to:
Sigrid McCawley
Boies, Schiller & Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Fort Lauderdale, FL, 33301
Email: smccawley@bsfllp.com
TROUTMAN SANDERS LLP
By: /s/Mary Grace W. Metcalfe
Mary Grace W. Metcalfe
875 Third Avenue
New York, New York 10022
Tel: (212) 704-6029
marygrace.metcalfe@troutman.com
Attorney for Darren K. Indyke and
Richard D. Kahn, as co-executors of the
estate of Jeffrey E. Epstein
Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 51 of 51
Exhibit F
Case 1:19-cv-10577-LJL-DCF Document 46-6 Filed 05/07/20 Page 1 of 4
Sigrid S. McCawley
Telephone: (954) 377-4223
Email: smccawley@bsfllp.com
April 20, 2020
VIA EMAIL
Bennet J. Moskowitz
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
Tel: (212) 704-6087
bennet.moskowitz@troutman.com
Re: Jane Doe 1000 v. Indyke et al., Case No. 19-cv-10577

Dear Bennet:
I write on behalf of Plaintiff Jane Doe 1000 in response to Defendants Darren K. Indyke
and Richard D. Kahn, as co-executors of the Estate of Jeffrey E. Epstein (the “Estate”), responses
and objections to the Plaintiff’s discovery requests provided on April 16, 2020. As you likely have
anticipated, I specifically write in response to your total failure to respond to your discovery
obligations. I ask that we meet and confer about your lack of responses as soon as practicable.
First, as you are aware, Plaintiff served eighteen interrogatories on Defendants. You
answered none of them; rather, each interrogatory is met with an assortment of boilerplate
objections, ranging from objections to relevancy or “discovery about discovery” or assuming
“facts not in evidence” (which is especially puzzling, given that the very purpose of discovery is
to find such facts). At best, these objections are deficient; at worst, they are meritless and
borderline frivolous.
Similarly, you have failed to adequately respond to most of Plaintiff’s document requests.
Again, your objections are premised on conclusory objections, ranging from objections to
relevancy and claims that certain documents are outside Defendants’ possession, custody, and
control. As part of your discovery obligations, “generalized objections that discovery requests are
vague, overly broad, or unduly burdensome are not acceptable.” Shanchun Yu v. Diguojiaoyu,
Inc., 18-CV-7303, 2019 WL 6174204, *4-5 (S.D.N.Y. Nov. 20, 2019) (granting plaintiffs’ motion
to compel discovery after defendants “raised repeated and rote objections to Plaintiffs’ document
requests, [] refused to provide Plaintiffs any documents whatsoever, and []answered the
interrogatories in [a] substantially similar fashion”); see also Harris v. Bronx Parent Housing
Network, Inc., 18-CV-11681, 2020 WL 763740, at *2 (S.D.N.Y. Feb. 14, 2020) (“Boilerplate
objections that include unsubstantiated claims of undue burden, overbreadth and lack of relevancy,
accompanied by a lack of document production or interrogatory response, are a paradigm of
discovery abuse.”) (internal quotation marks and citation omitted). “A party resisting discovery
Case 1:19-cv-10577-LJL-DCF Document 46-6 Filed 05/07/20 Page 2 of 4
BSF BOIES
SCHILLER
FLEXNER
BOIES SCHILLER FLEXN ER LLP
401 East Las Oles Boulevard. Suite 1200, Fort Lauderdale. FL 333011 (t) 9S4 3S6 00ll I (f) 9S4 3S6 0022 I www.bsfllp.com
April 20, 2020
Page 2
has the burden of showing specifically how, despite the broad and liberal construction afforded
the federal discovery rules, each interrogatory is not relevant or how each question is overly broad,
burdensome or oppressive . . . by submitting affidavits or offering evidence revealing the nature
of the burden.” Harris, 2020 WL 763740, at *2 (internal quotation marks and citations omitted).

Second, your relevance objections are meritless. All of Plaintiff’s requests are relevant.
For example, please explain how documents relating to Jane Doe 1000 are not relevant to her
claims or are not reasonably calculated to lead to the discovery of admissible evidence. See
Request 1. Epstein abused Plaintiff several times a week for years and housed her in one of his
apartment buildings. She is entitled to any documents that relate to her. Plaintiff’s other requests
are also directly relevant to her claims or the Estate’s affirmative defenses. She is entitled to
discovery, for example, about Epstein’s relationship with Les Wexner, Victoria’s Secret, or any
other modeling connections about which Epstein lied (e.g., RFPs 15, 17, 39, 61, 64-69); any
Epstein-affiliated attorney she was forced to meet with at Epstein’s direction (e.g., RFPs 54-55,
57-59; Interrogatories 10, 17); Epstein’s communications with associates who were present in his
homes when Plaintiff was abused (e.g., RFP 70); documents relating to the co-conspirators who
helped Epstein recruit and abuse Plaintiff (e.g., RFPs 3, 4, 12, 25, 28, 29); and Plaintiff’s and
Epstein’s travel to the places in which Epstein abused Plaintiff. (e.g., RFPs 13, 14, 48-51;
Interrogatory 6).
Moreover, Plaintiff is entitled to know the breadth and nature the sex-trafficking operation
that she was victimized by. See Fed. R. Evid. 415 (“In a civil case involving a claim for relief
based on a party’s alleged sexual assault or child molestation, the court may admit evidence that
the party committed any other sexual assault or child molestation.”). Plaintiff alleges that Epstein
utilized his sex-trafficking operation to recruit and abuse countless young girls and women in a
methodical and similar fashion. Epstein’s recruitment, trafficking, and assault of other girls in the
same way that he recruited, trafficked, and assaulted Plaintiff would make Plaintiff’s allegations
more probable. See Fed. R. Evid. 401. Plaintiff’s discovery requests are therefore directly relevant
to the allegations in her Complaint, or, at a minimum, are reasonably calculated to lead to the
discovery of admissible evidence.
Third, your objections to certain of the time periods stated in the Requests are meritless for
several reasons. As explained above, Epstein’s other sexual assaults would be both relevant and
admissible in this case, regardless of time period. Further, you have raised a statute of limitations
defense in Plaintiff’s case, and Plaintiff has made an equitable estoppel argument in response.
Plaintiff is entitled to discovery relevant to her equitable estoppel theory, including but not limited
to any threats or misrepresentations that Epstein made to Plaintiff to prevent her from filing this
lawsuit, outside of the time period during which Plaintiff was physically abused by Epstein.
Fourth, your objection to Plaintiff’s definition of Jeffrey Epstein as including “any entities
owned or controlled by Jeffrey Epstein, any employee, agent, attorney, consultant, or
representative of Jeffrey Epstein” is an improper attempt to narrow your discovery obligations in
this matter. Your objection directly contradicts the Local Rules of this Court, which define the
Case 1:19-cv-10577-LJL-DCF Document 46-6 Filed 05/07/20 Page 3 of 4
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April 20, 2020
Page 3
word “parties” as including a defendant’s “employees, partners, . . . or affiliates.” Local Rule
26.3(c)(5). Plaintiff’s definition is proper.
Fifth, your responses and objections state many times that certain documents and
information are outside of the Estate’s possession, custody, and control. If that is the case, please
explain what is and is not within the Estate’s possession and control. For example, please explain
in detail what computers, hard drives, email accounts, telephone records, or hard copy documents
you have reviewed and provide a list of search terms that were used and specifically list what items
you claim to not have access to. We know that Epstein at a minimum used the following email
accounts:
jeffreye@mindspring.com;
jeeproject@yahoo.com;
jeevacation@gmail.com;
jepstein@revonet.com;
zorroranch@aol.com;
cecilia@ellmax.com;
cecilia.steen@gmail.com;
jeffrey.epstein@centurytel.net; and
epsteinj@wanadoo.fr
Confirm that you have accessed and searched each of these accounts and provide the
protocol used for the search. In the alternative, if the Estate contends that information that is
responsive to Plaintiff’s discovery requests was destroyed, provide all details relating to the
destruction.
Please let us know your availability for a meet and confer on the following dates and times:
Wednesday, April 22, 2020 between 2:00 and 3:00 EST;
Thursday, April 23, 2020 between 3:00 EST and 6:00 EST; and
Friday, April 24, 2020 between 3:00 EST and 5:00 EST.
Sincerely,
/s/ Sigrid S. McCawley
Sigrid S. McCawley
cc: Counsel of Record
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