Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 57 Entered on FLSD Docket 03;022009 Page 1 of 16 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND PRODUCTION OF DOCUMENTS, AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT Plaintiff, by and through undersigned counsel, files this Motion to Compel Answers to Interrogatories and Production of Documents, and Memorandum of Law in Support, pursuant to Fed.R.Civ.P. 26 and 37 and S.D.Fla.L.R. 26.1(H)(2), as follows: I. INTRODUCTION Plaintiff in this case propounded 17 interrogatories and 24 documents requests. In response, Defendant has produced no information and no documents. Defendant's principal objection concerns his Fifth Amendment privilege against self-incrimination. Defendant, however, fails to set forth a sufficient predicate in his responses to interrogatories or docume