Case 9:08-cv-80993-KAM

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 Plaintiff, JANE DOE 7, by and through their undersigned counsel, and pursuant to Federal Rules of Civil Procedure Rule 33, hereby responds to Defendant, JEFFREY EPSTEIN'S First Set of Interrogatories to Plaintiff as follows: General Objections 1. Plaintiff objects to Defendant's Interrogatories to the extent that the Interrogatories call for the disclosure of information protected by the attorney-client privilege, attorney work-product doctrine, or other applicable privilege or immunity, whether created by statute or common law. Plaintiff claims such privileges and protections to the extent implicated by each Interrogatory, and excludes privileged and protected information from any responses to Defendant's discovery. Any disclosure is inadvertent and is not intended to waive those privileges or protections, which are specifically reserved. 2. Plaintiff objects to Defendant's Interrogatories to the extent that same are vague, ambiguous, incomprehensible and/or overly broad. 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 Jane Doe 1 (who is not represented by the undersigned attorneys) ain s c assmate who brought Plaintiff to Defendant's estate on 2 occasions ai Pf" ti s classmate who accompanied Plaintiff to Defendant's estate on at lest one occasion accompanied Plaintiff to Defendant's estate on at least one occasion, but Plaintiff is unable to recall which sister it was. Discovery is ongoing and may be supplemented in accordance with the Federal Rules of Civil Procedure. 6. Please state the specific nature and substance of the knowledge that you believe the person(s) identified in your response to interrogatory no. 5 may have. Answer: See Plaintiffs Answer to Interrogatory No. 5. 7. Were you suffering from physical infirmity, disability, disease, sickness, or psychiatric/psychological condition at the time of the incident(s) described in the complaint? If so, what was the nature of the infirmity, disability, or sickness? Answer: No. 8. Did you consume any alcoholic beverages or take any drugs or medications within 12 hours before the time of each incident(s) described in the complaint? If so, state the type and amount of alcoholic beverages, drugs, or medication which were consumed, and when and where you consumed them. Answer: No. 9. Describe each injury (physical, emotional, mental) for which you are claiming damages in this case, specifying the part of your body that was injured, 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 Plaintiff received a letter dated Sept. 15, 2008, in care of her undersigned attorneys, titled "Amended Notification of Indentified Victim". No statements regarding benefits from cooperation with law enforcement were made to Plaintiff 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 poiisig 4ifif 5 01/23/2009 28:20 FENX KINKOS Jane Doe No. 7 v. Epstein Page15 against Mr. Epstein end regarding whether there would b@ any benefit from your voluntary cooperation with law enforcement. VERIFICATION being duly sworn, deposes and says that the forego' wers o interrogate are true and correct t trsst of her knowledge, information and belief. STATE OF FLORIDA COUNTY OF PALM BEACH ) ss WOR Tn anrn cr iBSCRIBED before me this at aday of ca.n. 2008 by who is personally known to me or has p uced the which is curront or has been issued within the past five years an ears a sen o er identifying nJmber. -3—va. Ft vv..e. past Signatu NOTARY PUBLIC - STATE OF FLORIDA Commission Number. Diu)" o My commission cOmmission expires: Clikei a-0 It JUAN FERNAN012 s Expires 9/18/2011 °r''.,, Commit 0D07115002 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