Court Records
305-6312200Case 9:08-cv-80381-KAM Document 86-1 Entered on FLSD Docket 05/06/2026- 91-29 ogage 1 01952 Herman aMermelsteln, 10.18:19 p.m. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80381-MARRA JANE DOE NO. 5, Plaintiff, v. JEFFREY EPSTEIN, Defendant. PLAINTIFF JANE DOE NO. 5's ANSWERS TO DEFENDANT'S FIRST INTERROGATORIES Plaintiff, JANE DOE NO. 5, 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. EFTA02742113 Case 9:08-cv-80381-KAM Document 86-1 Entered on FLSD Docket 05/06/2009 Page 2 Ca 2 [Phone Redacted] Herman &Mermelsteln, P 10.29:13 p.m. 26-01-2009 Doe No. 5 v. Epstein Page 6 Psychologist who mated Plaintiff in approximately June 2007. 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 response 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: Plaintiff objects to this interrogatory as vague and overly broad. Subject to said objections, Plaintiff states: 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 nature of the injury, and as to any injuries you contend are permanent, the effects on you that you claim are permanent. Answer: EFTA02742114 [Phone Redacted] P Case 9:08-cv-80381-KAM Document 86-1 Entered on FLSD Doket 05/06/200901-20 Page 3 o14952 Herman 6Merrnateln, 1 9:24 p.m. 26- Doe No. 5 v. Epstein Page 7 Plaintiff objects to this interrogatory as vague, overly broad, unduly burdensome, ' premature, and calling for an expert opinion. Subject to said objections, Plaintiff states: Plaintiff has sustained mental and emotional injuries, including, but not limited to, depressive episodes, anger, low self-esteem, flashbacks, mood swings, lack of trust generally, and lack of trust of men (particularly of older men around Plaintiffs daughter). Discovery is ongoing and will be supplemented in accordance with the Federal Rules of Civil Procedure. In particular, Plaintiffs psychological and emotional injuries will be the subject of expert review, analysis and testimony. 10. Please state each item of damage that you claim, and include in your answer the count to which the item of damages relates; the factual basis for each item of damages; and an explanation of how you computed each item of damages, including any mathematical formula used. Answer: Plaintiff objects to this interrogatory as vague, overly broad, unduly burdensome, premature, and calling for an expert opinion. Subject to said objections, Plaintiff states: Discovery is ongoing and will be supplemented in accordance with the Federal Rules of Civil Procedure. 11. List the names and business addresses of each physician (including psychiatrist, psychologist, etc.) or medical provider (including chiropractors) who has treated or examined you, and each medical facility where you have received any treatment or examination for the injuries for which you seek damages in this case; and state as to each the date of treatment or examination and the injury or condition for which you were examined or treated. Answer: Plaintiff objects to this interrogatory as vague, overly broad, unduly burdensome, premature, and calling for an expert opinion. Subject to said objections, Plaintiff states: EFTA02742115 Case 9:08-cv-80381-ICAM Document 86-1 Entered on FLSD Doct p.m. - 2 05/06g099 ogage 4 gtg2- [Phone Redacted] Herman MAermelsteln, P 10:40: Doe No. 5 v. Epstein Page 13 Answer: Plaintiffs only contact with the FBI was by phone, so she is unaware if anyone was recording the interview or taking notes. 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. Answer: No such statements were made. January % , 2009 Respectfully submitted: HERMAN & MERMELSTEIN P.A. 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 www.hermanlaw.com Tel: [Phone Redacted] Fax: [Phone Redacted] By: Jeffrey M. Fi rman jhermanehermanlaw.com Florida Bar No. 521647 Stuart S. Merrnelstein smermelstein(alhermanlaw.com Florida Bar No. 947245 Adam D. Horowitz ahorowitzehermanlaw.com Florida Bar No. 376980 EFTA02742116 Case 9:08-cv-80381-KAM Document 86-1 Entered on FLSD Dii:a4s;95/06/a0c1/2920gage 5 011652 [Phone Redacted] Herman 6Mermeisteln,P VERIFICATION g duly sworn, deposes and says that the foregoing to atories are true and cogrect to the best of her knowledge, information and belief. STATE OfSaiA SS COUNTY O SCRIBED before me this /9 day e2--;-,WOR TO 009 by to me or has pr duced the o e ing entificatio current or has en issued within the past five years and bears a serial or other identifying number. lasv -C/74 Print Name who is •erson NOTARY PUBLIC - STATE OF FLORIDA Commission Number. My commission expires: (Notarial Seal) 1 A a— a 421...r ^ la .... 4as T" PURNIMA K. PATEL Notary Public Commonwealth of Virginia 331022 My Commission Expires Dec 31, 2(311 EFTA02742117 Case 9:08-cv-80381-KAM Document 86-1 Entered on FLSD Docket 05/06/2009 Page 6 of 6 15-9312200 Herman Warms/151,ln, P 10:411:06 p.m. 26-01-2009 52 /52 Doe No. 5 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 26. day of January, 2009. Robert D. Critton, Jr, Esq. Burman, Critton, Luther & Coleman 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561/842-2820 Phone 561/515-3148 Fax rcritabcIclaw.com Co-Counsel for Defendant Jeffrey Epstein Jackalan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 [Phone Redacted] Fax: [Phone Redacted] jaqescabellsouth.net Co-Counsel for Defendant Jeffrey Epstein a3i ael R. Tein, Esq. Tein, P.L. 9 Grand Avenue, Suite 340 Coconut Grove, FL 33133 [Phone Redacted] Fax: [Phone Redacted] Co-Counsel for Defendant Jeffrey Epstein teinalewistein.com • •CIPte• EFTA02742118