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Case 9:08-cv-80380-KAM Document 73-1 Entered on FLSD Docket 03/27/2009 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80380-MARRAa 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 Obiectlons 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" EFTA02740803 Case 9:08-cv-80380-KAM Document 73-1 Entered on FLSD Docket 03/27/2009 Page 2 of 4 ' Doe No. 4 v. Epstein Page 9 I 14. Please state if you (or parents or guardian on your behalf) have ever been a party, either plaintiff or defendant, in a lawsuit other than the present matter, and, if so, state whether you were plaintiff or defendant, the nature of the action, and the date and court in which such suit was filed. Answer: None. 15. List all dates you allege you were at Mr. Epstein's home in Florida, include date, time arrived and left, the name(s) of anyone who went with you to the home when you were there, the time spent with Mr. Epstein and the name(s) and address of any individuals who were present in the house with Mr. Epstein and you. Answer: Re dac-fe d 16. State in detail how you came to be at Mr. Epstein's home on each occasion, i.e. did someone bring you or ask you if you would or wanted to go; if so, state the name and address of that individual and what he/she told you and the purpose of your visit. Answer: Plaintiff remembers other friends talking about giving massages to the Defendant at his estate, and that they were paid for it. Her friends, including NEM SOS and, invited her to go, which she eventually cli rl) erne e 3 EFTA02740804 Case 9:08-cv-80380 -KAM Document 73-1 Entered on FLSD Docket 03/27/2009 Page 3 of 4 C Doe No. 4 v. Epstein Page 14 25. 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 ,.,Kuve_ Doc 1-1 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. %lc Doc ___ STATE OF FLORIDA ) ss COUNTY OF PALM BEACH ) 1 SWORN TO AND SUBSCRIBED before me this a3 day of —./Wifte; 200$ by - . _Toole 42e_, 4 • , who is personally known to me or has produced e following identification -Pi_ b (--- which is current or has been issued within the past five years and bears a serial or other identifying number. EFTA02740805 Case 9:08-cv-80380 -KAM Document 73-1 Entered on FLSD Docket 03/27/2009 Page 4 of 4 doe No. 4 v. Epstein Page 15 portiovig fl .se_70,44s_s-Print Name .dim,, 6 be- /0-ny, Signature 1 NOTARY PUBLIC - STATE OF FLORIQA_ Commission Nuinber t' 70 6 V -5 3 MY:4110/111§eigb e fres: //-1/----,/ • N(NotariaLiSealOrlda 7xis2i00/ 227060S3 by •:" nfrt. exprgs Nov. It 2011 By: ROBERT D. ITTON, JR., ESQ. Florida Bar N . 224162 rcrit a bcicla com MICHAEL J. •IKE, ESQ. Florida Bar #617296 mpikeabcIclaw.com BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561/842-2820 Phone 561/515-3148 Fax (Counsel for Defendant Jeffrey Epstein) Certificate of Service I HEREBY CERTIFY that a true copy of the and U.S. Mail to the following addressees on thi Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstein, Esq. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 [Phone Redacted] Fax: [Phone Redacted] [Email Redacted] jherman hermanlaw.com Irivera(&hermanlaw.com regoing has been served by fax ay of December 2008: Jack Alan Goldberger Atterbury Goldberger & Weiss, PA. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 [Phone Redacted] Fax: [Phone Redacted] jaciesqbellsouth.net Co-Counsel for Defendant Jeffrey Epstein EFTA02740806