EFTA00221222.pdf

Case 9:08-cv-80993-KAM Document 52-2 Entered on FLSD Docket 05/07/2009 Pitt 5-7f UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80993-MARRA-JOHNSON JANE DOE NO. 7, Plaintiff, v. JEFFREY EPSTEIN, Defendant. PLAINTIFF JANE, DOE 7'S ANSWERS TO DEFENDANTS FIRST INTERROGATORIES ed counsel, and pursuant Plaintiff, JANE DOE 7, by and through their undersign nds to Defendant, JEFFREY to Federal Rules of Civil Procedure Rule 33, hereby respo follows: EPSTEIN'S First Set of Interrogatories to Plaintiff as General Objections the extent that the 1. Plaintiff objects to Defendant's Interrogatories to protected by the attorney-client Interrogatories call for the disclosure of information applicable privilege or immunity, privilege, attorney work-product doctrine, or other tiff claims such privileges and whether created by statute or common law. Plain ry, and excludes privileged and protections to the extent implicated by each Interrogato t's discovery. Any disclosure is protected information from any responses to Defendan privileges or protections, which are inadvertent and is not intended to waive those specifically reserved. exten t that same are 2. Plaintiff objects to Defendant's Interrogatories to the broad. vague, ambiguous, incomprehensible and/or overly A EFTA00221222 Case 9:08-cv-80993-KAM Document 52-2 Entered on FLSD Docket 05/07/2009 Page 2 of 5 Doe No. 7 v. Epstein Page 6 by the undersigned attorneys) Jane Doe 1 (who is not represented Defendant's estate on 2 occasions ain s c assmate who brought Plaintiff to Plaintif f to Defendant's estate on at lest "ti s classmate who accompanied Pfai one occasion 's estate accompanied Plaintiff to Defendant . f is unable to recall which sister it was on at least one occasion, but Plaintif Federal plemented in accordance with the Discovery is ongoing and may be sup Rules of Civil Procedure. believe ase stat e the spe cific nat ure and substance of the knowledge that you 6. Ple se to interrogatory no. 5 may have. the person(s) identified in your respon Answer: No. 5. See Plaintiffs Answer to Interrogatory s, or re you suff erin g from phy sica l infirmity, disability, disease, sicknes 7. We ed in the at the time of the incident(s) describ psychiatric/psychological condition nes s? plai nt? If so, wha t was the nat ure of the infirmity, disability, or sick com Answer: No. medications beverages or take any drugs or 8. Did you consume any alcoholic dent(s) described in the complaint? If hou rs bef ore the time of eac h inci within 12 which holic beverages, drugs, or medication so, state the type and amount of alco re you consumed them. were consumed, and when and whe Answer: No. ming otional, mental) for which you are clai Describe each injury (physical, em 9. part of your body that was injured, the damages in this case, specifying the EFTA00221223 Case 9:08-cv-80993-KAM Document 52-2 Entered on FLSD Docket 05/07/2009 Page 3 of 5 Doe No. 7 v. Epstein Page 13 care of her undersigned Plaintiff received a letter dated Sept. 15, 2008, in tified Victim". No statements attorneys, titled "Amended Notification of Inden cement were made to Plaintiff regarding benefits from cooperation with law enfor at any time. January 2(, 2009 Respectfully submitted: HERMAN & MERMELSTEIN PA 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 www.hermanlaw.com Tel: 305-931-2200 Fax: i -08 7 By Jeffrey M. Herman jhermanahermanlaw.com Florida Bar No. 521647 Stuart S. Merrnelstein smermelsteinAhermanlaw.com Florida Bar No. 947245 Adam D. Horowitz ahorowitzahermanlaw.com Florida Bar No. 376980 EFTA00221224 Case 9:08-cv-80993-KAM Document 52-2 Entered on FLSD Doc, 05/07/2009 poisig 4ifif 5 01/23/2009 28:20 FENX KINKOS Jane Doe No. 7 v. Epstein Page15 b@ any bene fit from your against Mr. Epstein end regarding whether there would voluntary cooperation with law enforcement. VERIFICATION being duly sworn, deposes and says that the of her knowledge, forego' wers o interrogate are true and correct t trsst information and belief. STATE OF FLORIDA ) ss COUNTY OF PALM BEACH ca.n. 2008 by WOR Tn anrn cr iBSCRIBED before me this at a day of the who is personally known to me or has p uced d which is curro nt or has been issue er identifying nJmber. within the past five years an ears a sen o -3—va. Ft vv..e. past Signatu NOTARY PUBLIC - STATE OF FLORIDA Commission Number. Diu)" o cOmmissi My comm on expires: Clikei a-0 It ission JUAN FERNAN012 °r''.,, Commit 0D07115002 s Expires 9/18/2011 Florid, Nolan' Aspn.,Int nnimpont EFTA00221225 Case 9:08-cv-80993-KAM Document 52-2 Entered on FLSD Docket 05/07/2009 Page 5 of 5 Doe No. 7 v. Epstein Page 15 Certificate of Service WE HEREBY CERTIFY that a true copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this 7G day of January, 2009. Robert D. Critton, Jr, Esq. Burman, Critton, Luttier & Coleman 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561/842-2820 Phone 561/515-3148 Fax rcrit beiclaw•will Co-Counsel for Defendant Jeffrey Epstein Jack Alan Goldberger, Esq. AtterburyGoldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 jaqesoAbellsouth.net Co-Counsel for Defendant Jeffrey Epstein Michael R. Tein, Esq. Lewis Tein, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, FL 33133 305-442-1101 Fax 305 442 6744 ' Co-Counsel for Defendant Jeffrey Epstein teinAlewistein.com EFTA00221226