Requests for flight records and documents linking Epstein’s legal team and relatives to his private plane

Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 20 of 34 6. Copies of any and all documents evidencing the presence of your nephew on Jeffrey Epstein’s private plane, as described in paragraph 5 of the sworn Declaration of Alan M. Dershowitz. RESPONSE: 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. 7. Copies of any and all documents evidencing the presence of “members of Mr. Epstein’s legal team”, as described in paragraph 5 of the sworn Declaration of Alan M. Dershowitz. RESPONSE: Defendant objects to this Document Request as overly broad because Jane Doe #3 alleges in the filing titled “Jane Doe #3 and Jane Doe #4’s Motion Pursuant to Rule 21 For Joinder In Action” (Doc. No. 279) (the “Joinder Motion’) in the civil action captioned Jane Doe #1, et al. v. United States, Case No. 08-80736 (S.D. Fla.) (the “Federal Action”) that she was “kept as [Jeffrey Epstein’s] sex slave from about 1999 through 2002.” Jane Doe #3 further alleges in the Joinder Motion that she “escape[d]” from Mr. Epstein and moved to Australia in 2002. Paragraph 5 of the sworn Declaration of Alan M. Dershowitz refers to plane travel by members of Mr. Epstein’s legal team after 2002 and therefore Defendant further objects because this Document Request does not seek documents relevant to this action or documents reasonably calculated to lead to the discovery of admissible evidence. 8. Copies of any and all flight manifests reflecting your presence or the presence of any member of your family on any aircraft on which Jeffrey Epstein was also a passenger during the same flight. RESPONSE: Defendant responds that he has no responsive, non-privileged documents. 9. Copies of any and all “absolute proof” as described in paragraph 8 of the sworn Declaration of Alan M. Dershowitz. HOUSE_OVERSIGHT_014103