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Case 9:08-cv-80119-KAMCase 9:08-cv-80119-KAM
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efta-efta00221686DOJ Data Set 9Other

Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 66-2 Entered on FLSD Docket 03/26/2009 Page 1 of 3 C UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80232-MARRA-JOHNSON JANE DOE NO. 3, Plaintiff, I. JEFFREY EPSTEIN, Defendant. PLAINTIFF JANE DOE 3'S ANSWERS TO DEFENDANT'S FIRST INTERROGATORIES Plaintiff, JANE DOE 3, 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 °Mentions 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

Date
Unknown
Source
DOJ Data Set 9
Reference
EFTA 00221686
Pages
3
Persons
1
Integrity

Summary

Case 9:08-cv-80119-KAM Document 66-2 Entered on FLSD Docket 03/26/2009 Page 1 of 3 C UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80232-MARRA-JOHNSON JANE DOE NO. 3, Plaintiff, I. JEFFREY EPSTEIN, Defendant. PLAINTIFF JANE DOE 3'S ANSWERS TO DEFENDANT'S FIRST INTERROGATORIES Plaintiff, JANE DOE 3, 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 °Mentions 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

Persons Referenced (1)

Jeffrey Epstein

“... FLORIDA CASE NO.: 08-CV-80232-MARRA-JOHNSON JANE DOE NO. 3, Plaintiff, I. JEFFREY EPSTEIN, Defendant. PLAINTIFF JANE DOE 3'S ANSWERS TO DEFENDANT'S FIRST INTERROGATORIES Plaintiff, JANE DOE ...”

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Case 9:08-cv-80119-KAM Document 66-2 Entered on FLSD Docket 03/26/2009 Page 1 of 3 C UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80232-MARRA-JOHNSON JANE DOE NO. 3, Plaintiff, I. JEFFREY EPSTEIN, Defendant. PLAINTIFF JANE DOE 3'S ANSWERS TO DEFENDANT'S FIRST INTERROGATORIES Plaintiff, JANE DOE 3, 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 °Mentions 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. EXHIBIT "A" EFTA00221686 Case 9:08-cv-80119-KAM Document 66-2 Entered on FLSD Docket 03/26/2009 Page 2 of 3 .Doe No. 3 I. Epstein Page 13 C your current age. Describe the lewd or lascivious exhibition, the date and whether you received money or other consideration from the person Answer: Plaintiff objects to this interrogatory as vague, overly broad, unduly burdensome, harassing, and not reasonably calculated to lead to discovery of admissible evidence. Moreover, this interrogatory is outrageous, offensive and apparently posed for the purpose of intimidating the victim. Fed.R.Evid. 412 makes any answer to this Interrogatory inadmissible, and nothing In the answer could plausibly lead to discovery of admissible evidence. 22. List in detail all discussions/interviews which you had with any representative from FBI, U.S. Attorneys' Office, State Attorneys' Office (Palm Beach County), Palm Beach Sheriffs Office and Palm Beach Police Department regarding your meetings with Mr. Epstein. Include dates, who was present, the details of what was discussed, whether a court reporter was present and whether a taped statement was taken or whether you provided a written statement. Answer: Plaintiff met with the Palm Beach Police Department in 2007. She believes that she provided them with a written statement, and that they also tape recorded her interview. Plaintiff also spoke with FBI agents in 2007 investigating the case on 2-3 occasions, Including one meeting in person. Plaintiff does not believe that the statement was recorded. 23. State the names, addresses, ages and phone numbers of all females whom you claim were brought by you to Mr. Epstein's home to give him a massage. As to each female, state the amount of money you claim you were paid to bring each female. Answer: (Sane bee 4) Plaintiff was not paid by the Defendant of bringing'''. eCAne Lee- 4 ) bce Plaintiff was paid $1 0 for bringing (rant Doe a:\ EFTA00221687 Case 9:08-cv-80119-KAM Document 66-2 Entered on FLSD Docket 03/26/2009 Page 3 of 3 1 VERIFICATION Vane boe 3 being duly sworn, deposes and says that the foregoing answers to interrogatories are true and correct to the best of her knowledge, information and belief. TAX) C. STATE OF FLORIDA ) ss COUNTY OF PALM BEACH ) SWORN TO AND SUBSCRIBED before me this 19 day o any 2009 by who is personally known to me or has produced the following Ide —~nUtoation kecera--&—` • which is current or has been issued within the past five years and bears a serial or other identifying number. idlor-th 3,-Argar not Name Pet fam Sign z e NOTARY PUBLIC - STATE OF FLORIDA Commission Number. My commission expires: (Notarial Seal) Notary Pubilalail of Fleas f Sabath Ganz. %es Ay My Conrniake 00440926 e Wes Ce14/2009 EFTA00221688

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Case #9:08-CV-80119-KAM

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DOJ Data Set 9OtherUnknown

Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 99 Entered on FLSD Docket 05:14:2009 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CV-80119-MARRA/JOHNSON CASE NO.: 08-CV-80232-MARRA/JOHNSON CASE NO.: 08-CV-80380-MARRA/JOHNSON JANE DOE NO. 5, CASE NO.: 08-CV-80381-MARRA/JOHNSON Plaintiff, VS. JEFFREY EPSTEIN, EFTA00222605 Case 9:08-cv-80119-KAM Document 99 Entered on FLSD Docket 05/14/2009 Page 2 of 4 Defendant. JANE DOE NO. 6, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80994-CIV-MARRA/JOHNSON JANE DOE NO. 7, CASE NO.: 08-80993-CIV-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. C.M.A., CASE NO.: 08-80811-CIV-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE, CASE NO.: 08- 80893-CIV-MARRA/JOHNSON Plain

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DOJ Data Set 10OtherUnknown

EFTA01308033

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DOJ Data Set 9OtherUnknown

Ca_4ate.24h24/43134.01FrietibtOrtlefifitin0a0le28013,8111$2eafiabef146f 22

Ca_4ate.24h24/43134.01FrietibtOrtlefifitin0a0le28013,8111$2eafiabef146f 22 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealinu Sealed Materials Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue EFTA00074964 Ca_QatIgt24743tictoWneDbtOrfiefiVIMOXIle?BOWERKVaffizte12401 22 Introduction This Court asked the parties to brief three issues: "(a) the weight of presumption of public access that should be afforded to an item, (b) the identification and weight of any countervailing interests supporting continued sealing/redaction of the item, and (c) whether the countervailing interests rebut the presumption of public access to the item." DE 1044 at 1. Plaintiff and the Miami Herald's responses improperly afford the highest level of presumption to discovery dispute documents, deny that any co

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DOJ Data Set 9OtherUnknown

Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 206 Entered on FLSD Docket 0716/2009 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CV-80119-MARRA/JOHNSON CASE NO.: 08-CV-80232-MARRA/JOHNSON CASE NO.: 08-CV-80380-MARRA/JOHNSON JANE DOE NO. 5, CASE NO.: 08-CV-80381-MARRA/JOHNSON Plaintiff, VS. JEFFREY EPSTEIN, EFTA00214072 Case 9:08-cv-80119-KAM Document 206 Entered on FLSD Docket 07/16/2009 Page 2 of 4 Defendant. JANE DOE NO. 6, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 7, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80994-CIV-MARRA/JOHNSON CASE NO.: 08-80993-CIV-MARRA/JOHNSON C.M.A., CASE NO.: 08-80811-CIV-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE, CASE NO.: 08- 80893-CIV-MARRA/JOHNSON Plai

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DOJ Data Set 9OtherUnknown

(USAFLS)

(USAFLS) From: Roy Black < Sent: Wednesda , Februa 11, 2015 8:50 AM To: (USAFLS) Subject: RE: Your phone call Great. Speak to you then. Original Message From: (USAFLS) Imailt Sent: Wednesday, February 11, 2015 8:49 AM To: Roy Black Subject: Re: Your phone call Hi Roy. Thanks for your message. Dexter wants to participate in the call so it is helpful to have a roadmap of the discussion points. We will call your office at 2:00. If there is a better number to call, just shoot me an email. Talk to you soon. Assistant U.S. Attorney Southern District of Florida 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 On Feb 10, 2015, at 7:35 PM, "Roy Black" < mailto: wrote: Marie I was not calling you about the correspondence so don't worry about that. I called you to discuss the plaintiff's replies filed as dockets 310 and 311. We think there are serious misstatements by them in these pleadings. So I just wanted to let you know what our suggested responses are.

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