Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES, and RESPONSES TO 1st and 2nd PRODUCTION OF DOCUMENTS, AND INCORPORATED MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, serves his response and supporting memorandum of law to Plaintiffs Motion to Compel Answers to Interrogatories and Production of Documents, and Incorporated Memorandum of Law In Support, dated March 2, 2009. In support of Defendant's assertion of constitutional privileges and objections to discovery and in response to Plaintiff's motion to compel, Defendant states: Introduction As discussed more fully herein, Defendant has asserted constitutional based protections to the discovery requests p