* 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 wh