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Case 9:08-cv-80381-KAM Document 69 Entered on FLSD Docket 04/02/2009 Page 1 of 14 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80381-MARRA 
JANE DOE NO. 5 
Plaintiff, 
v. 
JEFFREY EPSTEIN, 
Defendant. 
DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 
5, TO RESPOND TO DEFENDANT'S FIRST REQUEST TO PRODUCE & TO 
OVERRULE OBJECTIONS, & FOR AN AWARD OF DEFENDANT'S 
REASONABLE EXPENSES 
Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, 
moves this Court for an order compelling Plaintiff, JANE DOE No. 5 to respond to 
specified production requests and to overrule her objections asserted in Plaintiffs 
Responses To Defendant's First Request To Produce, dated January 26, 2009. 
Defendant further seeks an award of his reasonable expenses, including expenses, 
associated with the making of this motion. Rule 37, Fed.R.Civ.P. (2008); Local Gen. 
Rules 7.1 and 26.1 H (S.D. Fla. 2008). In support of his motion, Defendant states: 
Introduction 
Prior to the filing of this motion, counsel for Defendant and counsel for Plaintiff 
corresponded with each other and were able to resolve some of the discovery issues 
related to Defendant's First Request to Produce and Plaintiffs Response thereto. By 
letter, dated March 3, 2009, the Plaintiff agreed to withdraw her "General Objections" 
set forth in her response. As well, issues as to production request no. 14 are presently 
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resolved. This motion addresses those requests on which the parties were unable to 
come to an agreement. 
Also, Defendant has filed simultaneously with this motion a Motion To Compel 
directed to certain of Plaintiffs Answers to Defendant's First Set of Interrogatories, also 
dated January 26, 2009, and which addresses identical discovery issues. Both motions 
should be determined at the same time. 
Motion To Compel Responses to Nos. 1 
1. Individual and/or joint income tax returns and supporting documentation 
including W-2 and 1099 forms for 2002-2007 and, as well as all records or 
documentation relative to the Plaintiff's earnings for the current year. 
Response: 
Plaintiff objects to this request as overbroad, unduly burdensome, and not reasonably 
calculated to lead to discovery of admissible evidence. Without waiving this objection, 
Plaintiff has no responsive documents. 
Legal Argument Supporting Entitlement to Discovery Sought in No. 1 
Plaintiff claims that the request is "overbroad" and "unduly burdensome," but fails 
to make any showing whatsoever how the request is overbroad or unduly burdensome 
as required under Rule 26(c) and Local Gen. Rule 26.1 H (S.D. Fla. (2008). On its face, 
the six year time period of 2002-2007 for Plaintiff's tax return's and supporting 
documentation is reasonable. Plaintiffs Second Amended Complaint alleges that the 
alleged sexual abuse and exploitation of her by Defendant occurred in "in 2002-2003." 
2d Am. Complaint, ¶8. Plaintiff also claims that the request is "not reasonably 
calculated to lead to the discovery of admissible evidence," and without waiving her 
objection, claims she "has no responsive documents. 
Although Plaintiff claims to have no such documents in her possession, in her 
answers to Defendant's First Set of Interrogatories, no. 2, dated January 26, 2009, 
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Plaintiff identifies four places of employment for various time periods beginning in 
approximately 2001 to approximately 2005-2006. Attached hereto as Exhibit D is 
Plaintiffs Answer to interrogatory no. 2. Defendant's counsel by faxed letter, dated 
March 31, 2009, requested that Plaintiff sign and submit two IRS Forms 4506-T 
requesting tax returns for Each of the years 2002 - 2007. In the event, Plaintiff 
complies with the request, Defendant will withdraw his motion to compel directed to 
request no. 1. 
Also, such information is both relevant and reasonably calculated to lead to the 
discovery of admissible evidence. It is well settled that relevant information is 
discoverable, even if not admissible at trial, so long as the discovery is reasonably 
calculated to lead to the discovery of admissible evidence. Rule 26(b)(1), Fed.R.Civ.P.; 
Donahav v. Palm Beach Tours & trans., Inc., 242 F.R.D. 685 (S.D. Fla. 2007). 
Discoverability of such information is governed by Rule 26, Fed.R.Civ.P., pursuant to 
which the scope of discovery is broad. Donahav, supra, at 686, and cases cited therein. 
"Parties may obtain discovery regarding any matter, not privileged, which is relevant to 
the claims or defense of any party involved in the pending action." Id. 
Plaintiff's tax returns, along with the requested supporting documentation, for the 
six year period are relevant to Plaintiffs damages claims detailed below herein. Such 
information would show Plaintiffs employment and earning history, as well as provide 
evidence as to how Plaintiff has been able to function in her daily life before, during and 
after the alleged incident. Was she self-sufficient? Was she able to get out of bed each 
morning and support herself? What type of job did she hold? One's ability to earn a 
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living and be self-supporting has not only a financial component, but also an 
emotional/psychological/mental component. 
In her Second Amended Complaint, Plaintiff attempts to allege claims in Count I 
for "Sexual Assault and Battery," Count II for "Intentional Infliction of Emotional 
Distress," and in Count III for "Coercion and Enticement to Sexual Activity in Violation of 
18 U.S.C.A. §2422," and seeks damages pursuant to 18 U.S.C. §2255(a). (Plaintiff 
alleges diversity of citizenship as a basis for this Court's jurisdiction. 2d Am. Complaint, 
¶5). Counts I and II are brought pursuant to state law. 
In her complaint, Plaintiff alleges that "she has suffered and will continue to suffer 
severe and permanent traumatic injuries, including mental, psychological and emotional 
damages," "severe emotional distress," and "severe mental anguish and pain." She 
also seeks actual (Count III) and compensatory damages for her alleged injuries. 2d 
Am. Complaint,¶¶21, 26-27, 33, and "Wherefore" clauses. In her answers to 
interrogatory no. 9, Plaintiff further states that: 
Plaintiff has sustained mental and emotional injuries, including, but not limited 
to, depressive episodes, anger, low self-esteem, flashbacks, mood swings, lack 
of trust generally, and lack of trust of men (particularly of older men around her 
daughter). (Interrog. No. 9). 
Plaintiff also alleges that "Epstein's scheme involved the use of young girls to 
recruit underage girls." "Epstein's plan and scheme reflected a particular pattern and 
method" in the alleged recruiting of girl's to come to EPSTEIN's Palm Beach mansion 
and give him "massages" in exchange for money. 2nd Am. Complaint, ¶8-11. According 
to the complaint allegations — "Upon information and belief Epstein has a sexual 
preference and obsession for underage minor girls." ¶8. The "girl would be led up a 
flight of stairs to a bedroom that contained a massage table ... The girl would be alone 
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with EPSTEIN; "Epstein would then perform one or more lewd, lascivious and sexual 
acts, including masturbation and touching the girl's vagina." 2nd Am. Complaint, ¶11. 
Plaintiff alleges that "in 2002-2003," she, "then approximately 15-16 years old, fell into 
Epstein's trap and became one of his victims." ¶8, 12. Plaintiff alleges that "she was 
recruited to give Epstein a massage for monetary compensation." ¶12. She was 
brought with another girl to Epstein's Palm Beach mansion, and were led up a flight of 
stairs by to a room with a massage table. ¶12. Plaintiff and the other girl 
were directed to remove their clothes and give Epstein a massage; "While on the 
massage table, Epstein masturbated and touched both girls on their vaginas ... ." ¶12. 
Plaintiff alleges that Epstein's actions constitute "sexual assault." ¶13, Count I — Sexual 
Assault and Battery. 
As discussed above, the tax returns, and supporting documentation, will provide 
direct evidence as to Plaintiff's claimed damages. Such information does not only go to 
compensatory or actual damages as alleged in the complaint, but also her 
emotional/psychological/mental health type damages. (Plaintiff did not answer 
interrogatory no. 10 regarding each item of damage claimed but, in addition to 
objections, stated that "discovery is ongoing and will be supplemented ... ). The time 
period will allow Defendant to compare how Plaintiff was doing in her life prior to, during, 
and after the alleged incident. Accordingly, Plaintiffs objection is required to be 
overruled, and Defendant is entitled to the documents requested. 
Production Requests Nos. 10, 11, 17, & 18 
10. All photographs, movies, dvds, and videotapes in which you performed 
sexual acts or simulated sexual acts. 
Response: 
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Plaintiff objects to this request as harassing and not reasonably calculated to lead to 
discovery of admissible evidence. Moreover, this interrogatory [sic] is outrageous, 
offensive and is apparently posed for the purpose of intimidating the Plaintiff. Any 
evidence that could conceivably be obtained through this request would not be 
admissible under Fed.R.Evid. 412. Without waiving this objection, none to Plaintiff's 
knowledge. 
11. All photographs, movies, dvds, and videotapes in which you performed 
sexual acts or simulated sexual acts in exchange for money or other consideration. 
Response: 
Plaintiff objects to this request as harassing and not reasonably calculated to lead to 
discovery of admissible evidence. Moreover, this interrogatory [sic] is outrageous, 
offensive and is apparently posed for the purpose of intimidating the Plaintiff. Any 
evidence that could conceivably be obtained through this request would not be 
admissible under Fed.R.Evid. 412. Without waiving this objection, none to Plaintiff's 
knowledge. 
17. All documents reflecting the names and addresses of other individuals 
with whom you have had sexual activity from January 1, 2000 — December 31, 2005 
Response: 
Plaintiff objects to this request as harassing and not reasonably calculated to lead to 
discovery of admissible evidence. Moreover, this interrogatory [sic] is outrageous, 
offensive and is apparently posed for the purpose of intimidating the Plaintiff. Any 
evidence that could conceivably be obtained through this request would not be 
admissible under Fed.R.Evid. 412. 
18. All documents reflecting the names and addresses of other individuals 
with whom you have had sexual activity from January 1, 2006 through November 30, 
2008 
Response: 
Objection. See Plaintiffs response to Request No. 17. 
Legal Argument Supporting Entitlement to Discovery Sought in 10, 11, 17, & 18 
Plaintiff does not make a relevancy objection, but instead claims that the 
requests are "not reasonably calculated to lead to the discovery of admissible 
evidence," claiming that such "evidence ... would not be admissible under Fed.R.Evid. 
412." Plaintiff further claims, without making any showing in her answer and without 
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moving for a protective order in accordance with Rule 26(c) and Local Gen. Rule 26.1 H 
(S.D. Fla. 2008), that the interrogatory is "harassing,' "outrageous, offensive and is 
apparently posed for the purpose of intimidating Plaintiff." See Defendant's Motion to 
Compel directed to Plaintiff's Answers to Defendant's First Set of Interrogatories, 
addressing identical discovery issues. Both Defendant's interrogatories and production 
requests seek information regarding Plaintiffs sexual conduct and history; Plaintiff 
raised the same objections. 
In her responses to nos. 10 and 11, Plaintiff also states that — "Without waiving 
this objection, none to Plaintiffs knowledge." Plaintiffs response is evasive — either the 
requested items exist or do not existed. Defendant is entitled to a better response 
specifically indicating whether the items requested in each of the production requests 
nos. 10 and 11 - (1) exist or do not exist; (2) are in the possession or control of Plaintiff 
or some other person that Plaintiff is able to identify; and (3) why Plaintiff qualifies her 
answer of "none" with the phrase "to Plaintiffs knowledge." (Did such items exist and 
Plaintiff destroyed or deleted them?) 
As to the relevance of the information sought, it is well settled that relevant 
information is discoverable, even if not admissible at trial, so long as the discovery is 
reasonably calculated to lead to the discovery of admissible evidence. Rule 26(b)(1), 
Fed.R.Civ.P.; Donahay v. Palm Beach Tours & trans., Inc., 242 F.R.D. 685 (S.D. Fla. 
2007). Contrary to Plaintiff's assertion, Rule 412 does not automatically result in a 
determination that such sexual history and sexual activity/behavior information is never 
admissible. In fact, written into the Rule are the procedures to follow in determining 
when such information is admissible at trial. The Advisory Committee Notes to Rule 
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412, Fed.R.Evid, makes clear that the procedures to determine admissibility of an 
alleged victim's/plaintiffs sexual conduct or activity in civil cases does not apply to 
discovery of such information. Rather, discoverability of such information is governed 
by Rule 26, Fed.R.Civ.P., pursuant to which the scope of discovery is broad. Donahay,
supra, at 686, and cases cited therein. "Parties may obtain discovery regarding any 
matter, not privileged, which is relevant to the claims or defense of any party involved in 
the pending action." Id. 
Rule 412, entitled "Sex Offense Cases; Relevance of Alleged Victim's Past 
Sexual Behavior or Alleged Sexual Predisposition," provides in relevant part -
(a) Evidence generally inadmissible.--The following evidence is not admissible 
in any civil ... proceeding involving alleged sexual misconduct except as 
provided in subdivisions (b) and (c): 
(1) Evidence offered to prove that any alleged victim engaged in other sexual 
behavior. 
(2) Evidence offered to prove any alleged victim's sexual predisposition. 
(b) Exceptions.—
(2) In a civil case, evidence offered to prove the sexual behavior or sexual 
predisposition of any alleged victim is admissible if it is otherwise admissible 
under these rules and its probative value substantially outweighs the danger of 
harm to any victim and of unfair prejudice to any party. Evidence of an alleged 
victim's reputation is admissible only if it has been placed in controversy by the 
alleged victim. 
(c) Procedure to determine admissibility. —
(1) A party intending to offer evidence under subdivision (b) must—
(A) file a written motion at least 14 days before trial specifically describing 
the evidence and stating the purpose for which it is offered unless the court, for 
good cause requires a different time for filing or permits filing during trial; and 
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(B) serve the motion on all parties and notify the alleged victim or, when 
appropriate, the alleged victim's guardian or representative. 
(2) Before admitting evidence under this rule the court must conduct a 
hearing in camera and afford the victim and parties a right to attend and be 
heard. The motion, related papers, and the record of the hearing must be 
sealed and remain under seal unless the court orders otherwise. 
In confirming that Rule 412 does not control the discoverability of such 
information, the Advisory Committee Notes (1994 Amendments) state - 
The procedures set forth in subdivision (c) do not apply to discovery of a 
victim's past sexual conduct or predisposition in civil cases, which will be 
continued to be governed by Fed. R. Civ. P. 26. In order not to undermine the 
rationale of Rule 412, however, courts should enter appropriate orders pursuant 
to Fed. R. Civ. P. 26 (c) to protect the victim against unwarranted inquiries and 
to ensure confidentiality. Courts should presumptively issue protective orders 
barring discovery unless the party seeking discovery makes a showing that 
the evidence sought to be discovered would be relevant under the facts 
and theories of the particular case, and cannot be obtained except 
through discovery. In an action for sexual harassment, for instance, while 
some evidence of the alleged victim's sexual behavior and/or predisposition in 
the workplaceauLperhaps be relevant, non-work place conduct will usually be 
irrelevant. Cf. v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962-
63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant 
to issue of unwelcomeness of sexual advances at work). Confidentiality 
orders should be presumptively granted as well. 
(Emphasis added). 
In accordance with Rule 412 and Rule 26, the discovery sought regarding any 
photos, movies, dvds, and videotapes as decscribed in requests nos. 10 and 11, and 
Plaintiffs sexual activity with males, as described in nos. 17 and 18, including whether 
she received any compensation or consideration therefore, are all relevant to Plaintiffs 
damages claims and the type of injury she claims she has suffered. Defendant has no 
other means of obtaining such information and obtaining such information through 
Plaintiff will better protect the confidentiality until the Court can make a determination in 
accordance with the procedures under Rule 412(c) whether such information will be 
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admissible at trial. See Rule 412(c) quoted above. Defendant will agree to an order 
keeping the confidentiality of the information obtained through discovery. 
In her Second Amended Complaint, Plaintiff attempts to allege claims in Count I 
for "Sexual Assault and Battery," Count II for "Intentional Infliction of Emotional 
Distress," and in Count III for "Coercion and Enticement to Sexual Activity in Violation of 
18 U.S.C.A. §2422," and seeks damages pursuant to 18 U.S.C. §2255(a). (Plaintiff 
alleges diversity of citizenship as a basis for this Court's jurisdiction. 2d Am. Complaint, 
¶5). Counts I and II are brought pursuant to state law. 
In her complaint, Plaintiff alleges that "she has suffered and will continue to suffer 
severe and permanent traumatic injuries, including mental, psychological and emotional 
damages," "severe emotional distress," and "severe mental anguish and pain." She 
also seeks actual (Count III) and compensatory damages for her alleged injuries. 2d 
Am. Complaint,¶¶21, 26-27, 33, and "Wherefore" clauses. In her answers to 
interrogatory no. 9, Plaintiff further states that: 
Plaintiff has sustained mental and emotional injuries, including, but not limited 
to, depressive episodes, anger, low self-esteem, flashbacks, mood swings, lack 
of trust generally, and lack of trust of men (particularly of older men around her 
daughter). (Interrog. No. 9). 
Plaintiff also alleges that "Epstein's scheme involved the use of young girls to 
recruit underage girls." "Epstein's plan and scheme reflected a particular pattern and 
method" in the alleged recruiting of girl's to come to EPSTEIN's Palm Beach mansion 
and give him "massages" in exchange for money. 2 nd Am. Complaint, ¶8-11. According 
to the complaint allegations — "Upon information and belief Epstein has a sexual 
preference and obsession for underage minor girls." ¶8. The "girl would be led up a 
flight of stairs to a bedroom that contained a massage table ... The girl would be alone 
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with EPSTEIN; "Epstein would then perform one or more lewd, lascivious and sexual 
acts, including masturbation and touching the girl's vagina? 2nd Am. Complaint, ¶11. 
Plaintiff alleges that "in 2002-2003," she, "then approximately 15-16 years old, fell into 
Epstein's trap and became one of his victims." ¶8, 12. Plaintiff alleges that "she was 
recruited to give Epstein a massage for monetary compensation." ¶12. She was 
brought with another girl to Epstein's Palm Beach mansion, and were led up a flight of 
stairs by to a room with a massage table. ¶12. Plaintiff and the other girl 
were directed to remove their clothes and give Epstein a massage; "While on the 
massage table, Epstein masturbated and touched both girls on their vaginas ... ." ¶12. 
Plaintiff alleges that Epstein's actions constitute "sexual assault." ¶13, Count I — Sexual 
Assault and Battery. 
The evidence sought is relevant based on the facts and theories of this action. The 
items sought are clearly relevant to the injuries and damages claimed by Plaintiff. The 
nature of her claimed injuries and damages are such that Defendant is entitled to 
evidence which would show the nature of her relationship with males, whether she has 
suffered other acts of sexual misconduct, including exploitation and abuse, as alleged in 
her complaint, whether she suffered injury and damages as a result of the other claimed 
sexual misconduct with males, and whether she has willingly or not willingly engaged in 
sexual activity that has been photographed, or filmed by means of movie, dvd or 
videotapes. See United States v. Bear Stops, 997 F.2d 451 (8'h Cir. 1993)(Defendant 
charged with sexual abuse of six year old boy was entitled to admission of evidence 
relating to victim's sexual assault by 3 older boys to establish alternative explanation for 
why victim exhibited behavioral manifestations of sexually abused child.). 
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In further support of Defendant's motion, a copy of Balas v. Ruzzo, 703 So.2d 
1076 (Fla. 5'h DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), is attached hereto as 
Exhibit A as it is on point to the discovery issues in this action, and the relevancy and 
discoverability of Plaintiffs history of sexual activity and any payment, therefore. See 
interrogatories 8, 22 and 30 propounded in the Balas case and footnote 1 herein. 1
Additionally and significantly, in other pending state court civil actions against Defendant 
EPSTEIN attempting to assert similar claims and damages, the Circuit Court Judges 
have already ruled that such information is discoverable as it is relevant to the damages 
claims of Plaintiff. See Composite Exhibits B and C hereto. Composite Exhibit B 
are the Orders, dated February 23, 2009, entered in the case of A.C. v. Epstein, and 
Case No. 502008CA025129 MB Al, 151h Judicial Circuit, In and For Palm Beach 
County, State of Florida, which granted Defendant's motion to compel therein directed 
to discovery identical to interrogatory no. 18 above, and to requests for production nos. 
17 and 18 addressed below herein. (In the A.C. case, the Plaintiff answered without 
objection interrogatories identical to nos. 19, 20, and 21 herein.) Composite Exhibit C 
is a portion the transcript from a March 3, 2009 hearing on Defendant's motion to 
compel discovery in the case of Jane Doe II v. Epstein, and Case No. 
502008CA020614 MB AF, 15Ih Judicial Circuit Court, In and For Palm Beach County, 
State of Florida. Again, the Circuit Court Judge determined that the information sought 
is relevant to the issue of damages and, thus, discoverable. 
1 In Balas v. Ruzzo supra, the Plaintiffs alleged a multicount complaint including claims for 
"coercion of prostitution" pursuant to §796.09, Fla. Stat.; for battery for the unwanted and 
offensive touching of petitioners' bodies; false imprisonment for physically confining the 
petitioners against their will; invasion of privacy; and intentional infliction of emotional distress. 
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WHEREFORE, Defendant requests that this Court enter an order granting 
Defendant's motion to compel, overruling Plaintiffs objections, and compelling Plaintiff 
be to produce the items sought and/or to better respond to the requests as specified 
above. Defendant further requests that this Court award his attorney's fees and costs, 
associated with this motion, in accordance with Rule 37, Fed.R.Civ.P., and applicable 
Local Rules. 
Rule 7.1 Certification 
I hereby certify that counsel for the respective parties communicated by letters in 
a good faith effort to resolve the discovery issues prior to th iling of this motion to 
compel. Some of the issues were resolved. 
Robert D. ritton, Jr. 
Attorney f r Defendant Epstein 
Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with 
the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being 
served this day on all counsel of re r identified on the following Service List in the 
manner specified by CM/ECF on this day of  April, 2009: 
Stuart S. Mermelstein, Esq. 
Adam D. Horowitz, Esq. 
Mermelstein & Horowitz, P.A. 
18205 Biscayne Boulevard 
Suite 2218 
Miami, FL 33160 
[Phone Redacted] 
Fax: [Phone Redacted] 
[Email Redacted] 
[Email Redacted] 
Counsel for Plaintiff Jane Doe #2 
Jack Alan Goldberger 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach, FL 33401-5012 
[Phone Redacted] 
Fax: [Phone Redacted] 
[Email Redacted] 
Co-Counsel for Defendant Jeffrey Epstein 
Respectfully sub ed, 
By: 
ROBERT D. •RITTON, JR., ESQ. 
Florida Bar N.. 224162 
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[Email Redacted] 
MICHAEL J. PIKE, ESQ. 
Florida Bar #617296 
mpikeebciclaw.com 
BURMAN, CRITTON, LUTTIER & COLEMAN 
515 N. Flagler Drive, Suite 400 
West Palm Beach, FL 33401 
561/842-2820 Phone 
561/515-3148 Fax 
(Co-Counsel for Defendant Jeffrey Epstein) 
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