Discovery Requests Targeting Defendant’s Family Presence on Jeffrey Epstein Properties and Private Jet

Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 19 of 34 2a Copies of any and all documents evidencing the presence of your wife and daughter on Little Saint James Island, as described in paragraph 3 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. 2 Copies of any and all documents reflecting or relating to any and all occasions on which you have been physically present at Jeffrey Epstein’s Ranch in New Mexico including but not limited to your visit to Jeffrey Epstein’s Ranch in New Mexico, as described in paragraph 4 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 relating to the sole occasion on which Defendant was physically present at Jeffrey Epstein’s Ranch in New Mexico. 4. Copies of any and all documents evidencing the presence of your wife and daughter at Jeffrey Epstein’s Ranch in New Mexico, as described in paragraph 4 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. 5. Copies of any and all documents evidencing the presence of your wife and daughter 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. HOUSE_OVERSIGHT_014102