disc¶
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA¶
CASE NO.: 08-CV-80380-MARRA-[REDACTED]¶
JANE DOE NO. 4,¶
Plaintiff,¶
v.¶
JEFFREY EPSTEIN,¶
Defendant.¶
_____/¶
PLAINTIFF'S ANSWERS TO DEFENDANT'S FIRST INTERROGATORIES¶
Plaintiff, JANE DOE 4, 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¶
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- 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.
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- Plaintiff objects to Defendant's Interrogatories to the extent that same are vague, ambiguous, incomprehensible and/or overly broad.
"A"¶
cc: JE, J&, DI¶
Doe No. 4 v. Epstein Page 6¶
Answer:¶
See Plaintiff's Answer to Interrogatory No. 5.¶
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- 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.¶
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- 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.¶
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- 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 nature of the Injury, and as to any injuries you contend are permanent, the effects on you that you claim are permanent.
Answer:¶
Plaintiff has suffered severe psychological and emotional injuries, including without limitation, corruption of morals, anxiety, intrusive thoughts, disturbed sleep, impaired concentration, disruption and distortion of normal development, loss of innocence.¶
Plaintiff's psychological and emotional injuries will be analyzed by aforensic expert, whose opinions and related information will be disclosed in accordance with the expert discovery rules of the Federal Rules of Civil Procedure. Plaintiff further reserves the right to supplement this response in accordance with the Federal Rules of Civil Procedure.¶
Doe No. 4 v. Epstein¶
Page 14¶
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- Please describe any statements made to you by any federal or state law enforcement agent or prosecutor regarding the availability of civil remedies against Mr. Epstein and regarding whether there would be any benefit from your voluntary cooperation with law enforcement.
VERIFICATION¶
being duly sworn, deposes and says that the foregoing answers to interrogatones are true and correct to the best of her knowledge, information and belief.¶
STATE OF FLORIDA¶
COUNTY OF PALM BEACH¶
SW olowing iden ification RIBED before me this a3 day of a.)-mmie; 20Dik by who is personally known to me or has produced lie b which is current or has been issued within the past five years and bears a serial or other Identifying number.¶
) ss¶
Doe No. 4 v. Epstein
Page 13¶
January 24, 2009¶
Respectfully submitted:¶
HERMAN & MERMELSTEIN P.A.
18205 Biscayne Blvd., Suite 2218
Miami, Florida 33160
www.hermanlaw.com
Tel: 305-931-2200
Fax: 305-931-0877¶
By:¶
Jeffrey M. Herman
jherman@hermanlaw.com
Florida Bar No. 521647
Stuart S. Mermelstein
smermelstein@hermanlaw.com
Florida Bar No. 947245
Adam D. Horowitz
ahorowitz@hermanlaw.com
Florida Bar No. 376980¶