EFTA01085298.pdf

JEFFREY EPSTEIN, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: CROW Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. PLAINTIFF/COUNTER-DEFENDANT EPSTEIN'S AMENDED RESPONSES TO NET WORTH INTERROGATORIES TO4EFFREY-EPST-EIN Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure hereby files his amended responses to Defendant/Counter-Plaintiff Bradley Edward's Net Worth Interrogatories to Jeffrey Epstein: I. What is your full name? Jeffrey Edward Epstein 2. How are you currently employed? Answer: Self-employed and Philanthropist. EFTA01085298  3. State the amount of your current annual income from all sources for each of the past 3 years and describe all additional benefits received by you or payable to you for each of the past 3 years including bonuses, allowances, pension and profit sharing participations, stock options, deferred compensation, insurance benefits and other prerequisites of your employment including dollar amount or dollar value of each. Answer: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). ""[T]he act of production itself' may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. documents are relevant to net worth determination for a punitive damages claim. bane-v, Capital Acquisitions, 212 F.R.D. 667 (S.D. Fla. 2005). Plaintiffs' request for non current finaneial-infecmatien-is-iffelevant-te-a-peniUve-demages-deteminatienr and-a-request-as far back as five years is doomed over broad. See Lane r. Capital Acquisitions, 212 F.R.D. 667 (S.D. Fla. 2005) ("[t]hc Court, however, does find that Plaintiffs' discovery requcoto are overbroad on their face in that come oeck financial recordo for a five year period."). Te—the—ement—that—this—Intercegateey—Fequests—inceenatieci—that—is—oevered—by—the Aseauntanf/Glient—and—or—the—AtternefiGlienf—rui4leger 1—asseft—said—pFivileges—as previEled-fer--in-g4907-502-and-907-50-5-5-4-the-Florga-Statutes, Finally, is-infermetien-is-a4rede-seeret-and-peateeted-free-diselesure-undeFThe-Flecida Idnifemi--Trade-Seerets-Autr §.688,04-ei-segref-the-glerida-Staffiteste-witas-a-sueeessful ftuaneierr l-have-Eleveleped infenuatienr ineluding-a-feenular pattemr cempilatien7 pregramr devieer inefhedr teehniquer er--preeess-that (a)-defives-independent-eeenemie valuer aetual-er-petentiair frem-net-being-genemily-known-terand aseefteinable-byrepeFmeens-hyr ether--pefsens-whe-ean-ebtein-eeenemie-value-frern-its disclosure or use; and (b) is the subject of efforts that are reasonable under the eir-sunistanees-te-maintain-its-sesces " 5688 102(4)-Pa(2014), 4. If you own or have any beneficial interest in any stocks, bonds, mutual funds, or other securities of any class in any government, governmental organization, company, firm or corporation, whether foreign or domestic, please state: 2 EFTA01085299  a. The name and address of the entity in which you own or have any beneficial property or security interest of any sort; b. The date and cost of acquisition; c. The current fair market value of each such interest; d. The manner in which such value was calculated. Answer: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "IT]he act of production itself may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. This—infeenatien—is—a—tcade—seer-et—and—pr-eteeted—fr-em—disekasuFe—under---Tae—Her-ida Uniform Trade Secrets Act, 6SS.01 ci scg. of the Florida Statutc.i; to wit: as a financiet 1—have—develeped infeenatienr ineleding—a—fermular pettemr cempilatienr pregram7 devieermethedrteehniqueref—preeess—thet (a)—derives—independent—eeenemie—value; aetual—er—petentialr frefn—net—being—genecally—lenown—ter and—net—beillg—readily aseeftainahle-by-prepec-nwans-byr ether-pecsens-whe-ean-ebtain-ecenemie-vakie-freon-its diselesure—er—useand—fb-)—is—the—sebjeet—ef--effefts—that—afe—reasenale—tulder—the eir-c-unistanees-te-maintain-its-seereey 688402(-4-)-Fa(4014 Furthermore, to the extent that this Interrogatory requires "the date and cost of asquisitienand the-eueent-fair--mafket-vakie-ef--eaeh-stiek-interest his-Fequest-laeks relevance and is not calculated to lead to the discover' of admissible evidenec, as-the acquisition coot of an ascet and its corresponding current fair market value of each such intecest-are-iFrelevant-te-the-ement-that-suth-sests-aFe-eppeFlunity-sests-ef--helding-the sesufityr repfesent-at-best-papec-gains-er—lessesr afid-are-net-an-aetuai-refiestien-ef-an inerease-er-deerease-in-a-paFtyls-peFsonal-weakhrSee-Lene-Capkel-AvatiffiSitieftsr 24-2 F.R.D. 667 (S.D. Ha. 2005). . Additionallyr to-the-ement-that-this-Interregater-y-requests the-Faanner--in-whish-the-value was-ealeulated ebjeet-as-this-is-prepfietafy-infeimatioil-and-therefer-e-subjest-te-the Flerida-Unifeen-Trade-Seerets-Ast-as-dessEibed-abeweT This-ealeulatien-is-deemed-Work-produet -Te-the-e-x-tent-that-this-Inteeegatepy-requests infeFmatien-that-is-eever-ed-by-the-wer4-pr-eduet-pr-iviIeger Assountant/Client-and-er-the 3 EFTA01085300 Attecney/Glient—privileger l—asseft—said—pfivilegesr ioeluiling—these—pcovided—foc—in §4907-502-and-907-5055-athe-glerida-Statides, of third partics under Art 1, a 12 of Ow Florida Constitution. 5. As to each income tax return filed by you or on your behalf with any taxing authority for the years 2009 through 2012, identify as specifically as identified in your tax return the source of all reported income and the separate amounts derived from each source. Answer: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "'[T]he act of production itself may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. This-Intecregateefis-inaRaftly-drafted-aod-wiguethis-Inteifrogatepy-appeafs-te-be-asking fer-a-summartef--the-i.nformation-eontaittetlawithin-deeumems-that-are-the-subjeet-ef--a Request to Produce. In accordance with Rule 1.340(c) of the Florida Rules of Civil Procedure, Edwards is directed to examine the tax returns for said response. Additienallyr arky-i.nfeErnatien-r-equested-that-is-the-subjeet-of--aeeeuntant-werk-sheets-is pcoteeted—by—the—wederpr-eduet—privileger Asseuntant/Glient—pFivilege—andler Attecney/C—lientrivilege-and-as-sueh-l-asseEt-said-pcivileges-as-pcoviEled-fec-in-H90,542 and 90.5055 of the Florida Statutes. To the extent that the sources of all reported income and the separate amounts derived frem-eaell-seuroe-is-proppietafy-inferroafton-that-f-alis-wifhin-the-definition-of-tr-ade-seer-et as-defined-by-i6887002(4)-of-the-Fierida-StaMesr II-ebjest-te-the-pfeduetien-of--sueh informationr as-this-iefoFmati so-preteeted-hrthe-Flor-i4aaifoiTo-Trode4eerets Aet. FuFthemoce-respending-to-this-Intecregatoff-kvould-riesessarily-infenge-on-the-pfivaey rights of third parties, which are guaranteed and protected under Art 1, § 12 of the Plerida-C-enstitution7 6. For each parcel of real property in which you hold any interest: state: a. The address; 4 EFTA01085301  b. The legal description of the property; c. The assessed value of the property for tax purposes; d. The date and price of acquisition; e. Whether, when, by whom, why and at what amount the property has been appraised since the time of purchase; f. Whether, when and at what price the property has been offered for sale since the time of purchase; g. The name and address of each real estate agent with whom the property has been listed for sale since the time of purchase; h. The cost of any improvements made to the property since purchase; i. The nature of your interest in the property; j. The current fair market value of the property and a description of the manner in which that value was calculated. Answer: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "'[T]he act of production itself' may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. This-Interregatepris-repetitive-el-a-Request-te-Preduee-and-is-eriee-again-e-reszpiest-fer-a summapfref-the-requested-pfeduetiongeder-Rule-1,340(e)-4-the-Flor-ida-R PFeeedureEdwards-is-diFemed-te-examine-the-seicespending-Request-fer-Predustion-fer the-respense-te-this-leteffegeteiy, This-hiteiTegatery-leeks-relevaftee-ead-is-net-ettlettlefed-fe-lead-te-the-diseevery-ef adniissihle-evideneespeeifieaily-subpaFts-fd)r (Or (0-and-04-request-infeenation-that reflests-eppeanity-eesis-aniVer-paper-lesses-er--gains-whish-is-irrelevant-to-the-value-ef the-assei-m-seme-time-in-the-future:-See-Latte-yrcapikti-74egirisifient-242-F,R,D,-66.7 (S.D. Ha. 2005). 5 EFTA01085302 Under-Rule-1,840(e)-ef--the-glepida4tdes-ef-C-ivil-Preeedurer Edwards-is-direeted-te-the relevant-preduetien-with-respeet-te-a-cespense40-subpaFt-(44)-sinee-eapital-inipFe*ements te-real-eatetelife-relleeted-in-the-takable-basis-ef--therepefty, Frubparts-(4)-ancl-e)-are-preprietaiy-infermatienrelessified-as-trade-seerets-and-subjeet-te the-Fleficia-Unifenn-T-r-ade-Seeretantr as-explained-abeve, Subpact-(g)-is-irrelevant-and-net-reasenably-ealenlated-te-lead-te-the-diseevepy-ef achnissible-evideneer as-whether-a-prepegy-has-been-ksted-for-sale-and-the-name-of--the agertt-given-the-listiftgris-irrelevant-te-mreutfectt-Finaneial-Net-WerthrSee-Lane-v: Capital Acquisitions, 212 F.R.D. 667 (S.D. Fla. 2005). 7. List each item and state the estimated value of all personal tangible, and intangible property in which you have an interest which personal property was acquired at a cost in excess of $10,000 or which personal property has an estimated present value in excess of $10,000, and as to each state: a. The date of acquisition; b. The cost of acquisition; c. The current estimated fair market value; d. The manner in which the fair market value was estimated. Answer: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "IT]he act of production itself' may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. Thin Interrogatory lacks relevance and is not reasonably ealcul.t,d to lead to the pr-esent-valner as-niest-assets-depr-eniate-evef-time-sush4hat-the-encrent-valne-ecthe-asset has-ne-relevanee-te-theamlue-ef-the-er-eding-asset-at-seme-peint-in-the-future, Subpact-(4)-asks-fer-infeEmatien-suhleet-te-Y10A-preduet-pcivilegerAccountant/Client andier-Atterney/C-hent-pfi4leger .ert worsea-and-907-50-5-5-44-the-glerida-Sietutes, 6 EFTA01085303 Uniform Trade Secret Act as defined above. Furthermore, intangible assets arc the ef--the-Intervegateffis-repetitiveT 8. If any of the real or personal property owned by you, either individually, jointly or otherwise, is encumbered by a real estate mortgage, chattel mortgage, or any other type of lien, then for each property, state a description of the nature and amount of the encumbrance, the date the encumbrance arose, whether the encumbrance is evidenced by any written document and, if so, a description of that document. Answer: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "IT]he act of production itself' may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. This-Intervegateffis-ina rafted-as-te-what-is-meant-byer--ethew4s and-as-stieh eafinet-be-properirresponded-le-as-asked: Te-the-ement-that-this-InteFregately-Fequ incematien-regaFding-thir-d-paFtiesr this information io protected by the third party':; right to financial and economic privacy, as guaranteed-by-lid:I-1r§-12-ef--the-FleFida-Genstitutien, 9. If you have an ownership interest in any businesses, for each business state: a. The name and address of the business; b. The present book value and the present market value of your interest in the business, and its percentage of the total value of the business; c. A description of the manner in which the fair market value was calculated. Answer: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "IT]he act of production itself' may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future 7 EFTA01085304 criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. Thio Interrogatory io inartfully dmfted and vague ouch that I am unable to formulate a preper-Fespense-te-this-inteeegatepy, To-the-extent-that-this-Intefregatefy-r-equests-infeenatien-r-egar-ding-thiFd-paptiesr that infoimatim-is-preteeted-brthe-third-part ht-te-finaneial-itild-eeeitemie-privaeras guaranteed-by-AfFir §42-4-the-Fierida-C-enstitutien, Additionallyr fhis-information-is-beth-the-stibjee4-4-and-stibjeet-te-eenfidentiality agfeements-andier--ehligatiens-sush-that-diselesur-e-of--this-infoffaatien-is-pr-ehibitedrThe requested-informatim-is-preprieftwrinformatien-that-faHs-within-the-clefinitien-ef--trade seeret-as-defined-by4688,002(-4-)-ef-the-Florida-Staimiesr-This-infocmatien-is-alse pretead-by-the-FleFida-Unifeim4rade-Seer-ets-Ast, 10. Identify all banks, credit union and savings and loan accounts, in which you have an interest or right of withdrawal and for each account state: a. Where the account is located; b. The highest and lowest balance in the account during the 365 day period immediately preceding your receipt of these interrogatories. Answer: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "[T]he act of production itself may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. Additienallyr this-lateriegatopy-is-evethr-eadr vague-and-inaftf- Faftedr as-it-r-equests desuments-regar-dingali-bankrasseunts in-whish-Epsfein-has a-Fight-te-withdraw funds vitheat-respeet-fer--third-pagies=Fighf-terivaey-as-gueranteed-under--Aft- §-1-2 ef-the-Flopida-C-enstitution, FLuFthermer-er right that-the-funcls-in-eaeli-aseount-fer--whish-l-may-withdr-aw-funds-ar-e-ewned-hy-merOr that 8 EFTA01085305 Finallyr this-Interagatepfris-a-request-fec-a-summapy-ef-Request-fer—Predustien-ner94 Under Rule 1.340(c) of the Florida Rulcs of Civil Proccdurc, Edwarda is directed to examille-the-Fespenses-te-the-Request-fer-ProduetienrEpstein-FeasseFts-eaeh-aad-evey ebjeetien-te4heaequest-fer-Predustien-ner9-herete, II. Identify all other assets of a value in access of $10,000 which assets were not previously identified and as to each state: a. The date of acquisition; b. The cost of acquisition; c. The current estimated fair market value; d. The means utilized to estimate the current fair market value. Answer: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "IT]he act of production itself may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. This-l.nteFregatefy-luts-already-been-answeced,See-l.ntefregalepy-Number-7-abeve-and respense—ther-efe te—wit this—Inteifregatepy—laeks—relevanee—and—is—net—reasenably ealeulated-te4ead-te-the-disseveptof-admissible-evidefleer as-the-aequisitien-sesf-ef-an asset-is-icrelevant-te-its-present-valuer sush-that-the-euFrent-value-ef-the-asset-has-ma relevanee-te-the>,Aakie-of--the-e-rnding-asset-at-seme-poi4+1-44-die-futuFe, Subpart (d) asks for information that is subject to work product privilege, said-pcivilege-as-previded-fer-in4P0402-and-907-50-5-5-ef-the-Plefkla-Statuteth Additienallyr intengible-assets-are-trade-seerets-and-as-sueli-ar-e-subjeet-te-the-Refida Uniform Trade Secrct Act as defined above. Furthermore, intangible assets are the 444he-Inteffegately-is-repetitive, 9 EFTA01085306  12. Identify all other liabilities of an amount in excess of $10,000 not previously identified and as to each state: a. The date the liability arise; b. The amount of the liability at inception; c. The terms of repayment or satisfaction; d. The current outstanding balance. Answer: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "IT]he act of production itself may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. There-is-iieilher-e-dafe-ner-time-fratne-pfevided-in-this-requestrand-te-the-etteitt-that-this IntepegateFy-asIEs-fer-nen-euwent-infeffnationr ettled-la that-enly-eueent-finaneial-infeenatien-is-relevant-te-a-c-laini-fer-punitive detnitgesrLane-Gesplieti-Atiptaiiietta6-7-6STIDrFlar2405): 13. As to any calculation or estimate of your net worth at any time in the five years immediately preceding your receipt of these interrogatories, state: a. The date of the calculation or estimate; b. The name and address of the person or entity responsible for performing the work; c. The reason for performing the calculation or estimate; d. The amount of net worth calculated or estimated. Answer: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "IT]he act of production itself may implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for 10 EFTA01085307 concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. This4iitefregateeris—over-ly—bur-densetner finaneial—infematien—is—relevant—te—a—elaim—fer—punitive—damagesrLane—vrgeipital Atittisitionsir242—F41-71)=667-6S7Da=2.905)rPlaintiff-s-request-fer-ften-eurrent financial information is irrelevant to a punitive damages determination, and-a-request-as far back as five yearn is deemed overly burdensome. Sec Lane i Capita! Acguisirion.7, 24-2—F7R,D=667-6S,D=Fler200-5)—eNhe—Courir hewevecr dees—find—that—Plaimilfs2 d:.. sts ethr ..d the C than ek f n al rd.. C five-year-petio&L)7 To the extent that this Interrogatory requests information that is covered by the Accotinfant/Glient—and—or—the—Aftemeylelien4—ptivileger 1—assect—said—privileges—as provided for in §90.502 and § 90.5055 of the Florida Statutcs. This subject of this Intefrogatoty-isitise-pfefeeted-brwerk-preduet-privilege 14. -What is your present net worth? Answer: I have already indicated my willingness to stipulate to a net worth in excess of one hundred million dollars. 15. As to all transfers of anything of a value in excess of $10,000 made by you or on your behalf within the past 5 years, state: a. A description of the transferred property; b. The reason for the transfer; c. The value of the item(s) transferred at the time of transfer; d. The date and cost of your acquisition of the item(s); e. Whether you received anything of value in exchange for the transferred item(s) and, if so, a description of what you received and the dollar value of what you received; f. The name and address of the recipient of each transferred item. Answer: Objection. This Request for Production requires the identification of the existence of detailed financial information which communicates statements of fact. Fisher v. United States, 425 U.S. 391, 410 (1976). "'[T]he act of production itself may 11 EFTA01085308 implicitly communicate "statements of fact" that are testimonial in nature. United States v. Hubbell, 530 U.S. 27, 35-36 (2000). I have a substantial and reasonable basis for concern that these statements of fact that are testimonial in nature could reasonably furnish a "link in the chain of evidence" that could be used to prosecute me in future criminal proceedings. See Hoffman v. United States, 341 U.S. 479, 486 (1951). I cannot provide answers/responses to questions relating to my financial history and condition without waiving my Fifth, Sixth and Fourteenth Amendment rights as guaranteed by the United States Constitution. This—litteFregatety—is—everly—burdensemer its—ft—is—well-settled—law—that—enly—eurTent financial information i relevant to a claim for punitive damages. Lane v Capital Acquisitions, 212 F.R.D. 667 (S.D. Fla. 2005). Plaintiffs' request for non current ffflaneial-infeatien-is-iFrelevent-te-a-punifive-demages-deleinationr and-a-request-as far--baek-as-five-yeaFs-is-deemed-ever-ly-13ur-densemerSee-befte-i'=C-apital--Aegwaitieff,7 242-F469=667-(PrerFla=200-5-)-(ffilhe-Geurtr beweverr dees-find-that-Plaintiffs diocovery reguestt are overbroad on their face in that come ocek financial rccordc for a five year period."). Te-the-e-x-tent-that-this-InteEregateetr-equests-infermafien-regar-ding-thiFd-pat4iesr that infermatien-is-pfaested-by-the-third-par~t-le-financial-and-esenemis-privaey, T-e—the—eMent—that—this—Interzr-egately—r-equests—infermafien—that—irreevered—by—the Aecesantem/C-liefit-pfivileger l-fiSSeft-said-pfivilege-as-previded-fer-in—§-90,505-5-ef--the Florida Statutes. This subject of this Interrogatory aba may be protected by work product [THIS PORTION INTENTIONALLY LEFT BLANK] 12 EFTA01085309 State of County of Before me, the undersigned authority, this day personally appeared Jeffrey Epstein, who is personally known to me, and who first being duly sworn, says that all of the matters contained herein are true and correct. NOTARY PUBLIC Sworn and Subscribed before me this Febritafy-22Julv , 2013. 13 EFTA01085310