©Mt Wt41--tvi-41)1Alir-Widg Der &l# gy,W fed 69 KW DOOM 141/04/2049 POy0 1- Of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CIV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 DEFENDANT, JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF'S, JANE DOE, MOTION TO COMPEL RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION IDE 971, WITH INCORPORATED MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN, hereby files his Response in Opposition to Plaintiffs, JANE DOE, Motion to Compel Response to Plaintiff's Request for Production IDE 97J (Consolidated Case No. 08-C1V-80119 IDE 194)). I. Procedural Background Plaintiff's Motion to Compel is filed at DE (97). The Motion to Compel was voluminous and orders had been entered by this court (DE 242 and 293) addressing other 5th Amendment issues; therefore, the undersigned counsel endeavored to eliminate certain requests outlined in Plaintiffs Motion to Compel. As a result, a Joint Notice of Agreement was entered advising the court that several of the requests had been addressed by counsel alleviating the court from having to rule on same. (DE 316). Defendant filed his Rule 4 Appeal (DE 282) and his Supplementary Brief (DE 283), which address several of the .5111 Amendment arguments applicable to the requests outlined EFTA02821300