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

Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 26 of 34 22. Copies of any and all records for the period 1998-2007 reflecting or relating to travel by you and/or any member of your family on any aircraft, boat, helicopter, or other means of transport owned, controlled, or under the direction of Jeffrey Epstein and/or any business entity with which Jeffrey Epstein was affiliated at the time of travel. RESPONSE: Defendant objects to this Document Request as overly broad because Jane Doe #3 alleges in the Joinder Motion that she was “kept as [Jeffrey Epstein’s] sex slave from about 1999 through 2002.” Jane Doe #3 further alleges that she “escape[d]” from Mr. Epstein and moved to Australia in 2002. Therefore Defendant objects to this Document Request to the extent that it purports to seek documents relating to any time before 1999 or after 2002. Defendant further objects to this Document Request as overly broad and premature because Jane Doe #3 has not specified the dates on which she alleges Defendant engaged in misconduct on Mr. Epstein’s plane, which are the sole relevant allegations by Jane Doe #3 or her counsel concerning travel on Mr. Epstein’s plane that Defendant refutes and asserts are false. Subject to and without waiving the General Objections, Defendant responds that he will produce all responsive, non-privileged documents currently in his possession, custody or control relating to any occasions that may be specifically identified by Jane Doe #3 on which she contends that Defendant travelled on Jeffrey Epstein’s plane between 1999 and 2002. 23. Copies of any and all records, including emails and text messages, between you and Jeffrey Epstein between December 29, 2014 and today, regarding allegations made by Jane Doe #3 of sexual misconduct by either of you. RESPONSE: Defendant objects to this Document Request to the extent that it seeks documents regarding allegations made by Jane Doe #3 of sexual misconduct by Jeffrey Epstein because such documents are not relevant to the subject matter of this action and would be attorney-client privileged communications in any event. Subject to and without waiving the foregoing specific 1] HOUSE_OVERSIGHT_014109