Defendant objects to broad document requests for travel records and communications with Jeffrey Epstein related to Jane Doe #3 allegations

The passage reveals a defendant’s refusal to produce travel and communication records with Jeffrey Epstein, citing overbreadth and privilege, while acknowledging specific allegations of sexual miscond Defendant claims travel with Epstein between 1999‑2002 may exist but demands specific identification Requests for emails/texts from Dec 29, 2014 onward are blocked on privilege grounds, hinting at po