Case 9:08-cv-80119-KAM Document 545-1 Entered on FLSD Docket 05/12/2010 Pa UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV- 80893 — MARRA... JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT'S RESPONSE & OBJECTIONS TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION (dated 03/23/09) Defendant, JEFFREY EPSTEIN, ('EPSTEIN"), by and through his undersigned attorneys, pursuant to Fed.R.Civ.P., 34, and S.D. Fla. 26.1.G., serves his response to Plaintiff JANE DOE's First Request For Production, dated March 23, 2009. Copies of all telephone records in your or your attorneys' Request No. 1: possession from 2002 through 2005 that in any way relate to you (including all phone lines owned by you or that were used to contact girls for the purposes of scheduling massages for you.) Response; Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Drawing an adverse inference under these circumstances would Constitution. unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. All massage appointment books, diaries, computer calendars or Request No. 2: scheduling entities, scheduling books or any other writing or correspondence that contains the names of any of the girls that were called, contacted, scheduled or who EFTA02749441