* Case 9:08-cv-80119-KAM

* Case 9:08-cv-80119-KAM Document 57-4 Entered on FLSD Docket 03/02/2009 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, I. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S RESPONSE & OBJECTIONS TO SECOND REQUEST FOR PRODUCTION, dated December 19, 2008 Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, serves his responses and objections to the Request to Produce, dated December 19, 2008 and states: Request No. 1. All policies of insurance, including the declarations page and all binders, amendments, and endorsements, covering Defendant's residence at 358 El Brillo Way, Palm Beach, FL 33480. Response: Objection, overly broad, not relevant and material and not calculated to lead to the discovery of admissible evidence. Plaintiff alleged claims occurred during a specific time period in 2004 - 2005, yet to be specifically identified. Yet, no time period whatsoever is set forth in the Request for Production. Additionally, Defendant objects in that the policies contain value and/or asset information which is not relevant, material nor calculated to lead to the discovery of admissible evidence at this point in time; said information is both private and confidential. EXHIBIT "C" EFTA00222073 Case 9:08-cv-80119-1M Document 57-4 Entered on FLSD Docket 03/02/2009 Page 2 of 2 Jane Doe No. 2 . Epstein Page 2 Certificate of Service WE HEREBY CERTIFY that a true copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this 26th day of January, 2009. Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstein, Esq. Miami FL 33160 Fax: ounse or laintiff Jane Doe #2 Jack Alan Goldberger , P.A. West Palm Beach, FL 33401-5012 Fax: uo-uounsei tor tietendant Jeffrey Epstein Respectfully sub By: ROBERT D CRITTON, JR., ESQ. Florida Ba' No. 224162 , ESQ. Florida Bar #617296 BURMAN, CRI I TON, LUTTIER & COLEMAN es ch, 33401 Fax: (Co-counsel for e endant Jeffrey Epstein) EFTA00222074