Court Records
Case 9:08-cv-80994-KAM Document 41-1 Entered on FLSD Docket 05/07/2009 Page 0 x f UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80994-MARRAMMI JANE DOE NO. 6, Plaintiff, v. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S ANSWERS TO DEFENDANT'S FIRST INTERROGATORIES Plaintiff, JANE DOE 6, by and through her 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. At' EFTA02742844 Case 9:08-cv-80994-KAM Document 41-1 Entered on FLSD Docket 05/07/2009 Page 2 of 6 Doe No. 6 v. Epstein Page 5 Discovery is ongoing and will 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 Plaintiff's Answer 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 was diagnosed with PTSD following a car accident in 2003. 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: Plaintiff has suffered severe psychological and emotional injuries, including without limitation, anxiety, anger, distorted and disrupted development, restlessness, distrust, self destructive behaviors, suicidal behavior, substance abuse, severe Xanax addiction beginning after her encounter with Epstein, corruption of morals, antisocial behaviors, premature teenage pregnancy, loss of normal adolescent ideals, loss of innocence. EFTA02742845 Case 9:08-cv-80994-KAM Document 41-1 Entered on FLSD Docket 05/07/2009 Page 3 of 6 Doe No. 6 v. Epstein Page 6 Plaintiffs psychological and emotional injuries will be analyzed by a forensic expert, whose opinions and related information will be disclosed in accordance with the expert discovery rules of the Federal Rules of Civil Procedure. Plaintiff reserves the right to supplement this response in accordance with the Federal Rules of Civil Procedure. 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, calling for speculation, and calling for an expert opinion. Subject to said objections, Plaintiff states: Discovery is ongoing and will be supplemented in accordance with 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: 11Calliffillnain as se . 12. List the names and business addresses of all other physicians, medical facilities, rehab facilities (drug, alcohol or psychiatric) or other hearth care providers including psychiatrist, psychologist, mental health counselor and chiropractors by whom or at which you have been examined or treated in the past 10 years; and state as to each the dates of examination or treatment and the condition or injury for which you were examined or treated. Answer: EFTA02742846 Case 9:08-cv-80994-KAM Document 41-1 Entered on FLSD Docket 05/07/2009 Page 4 of 6 Doe No. 6 v. Epstein Page 11 See Plaintiff's Answer to Interrogatory No. 22. 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: Plaintiff received correspondence fro in July and September, 2008, advising her of civil remedies, among other things. No one represented that her cooperation with law enforcement would benefit her in a civil claim. 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: effrey M. Herman jhermanehermanlaw.com Florida Bar No. 521647 Stuart S. Mermelstein smermelsteine,hermanlaw.com Florida Bar No. 947245 Adam D. Horowitz ahorowitzahermanlaw.com Florida Bar No. 376980 EFTA02742847 Case 9:08-cv-80994-KAM Document 41-1 Entered on FLSD Docket 05/07/2009 Page 5 of 6 Doe No. 6 v. Epstein Page 11 VERIFICATION being duly sworn, deposes and says that the foregoi in erroga on s are true and correct to the best of her knowledge, information and belief. 1111M11.11.7 STATE OF FLORIDA COUNTY OF PALM BEACH ) ) ss ) CRIBED before me this HAlay of `sty , 2009 by who is personally known to me or has produced the wing i entification which is current or has been issued within the past five years and bears a serial or other identifying number. -- .1e$Cc1/4-.1. tom, Fora' Print Name NOTARY PUBLIC - STATE OF FLORIDA Commission Number: My commission expires: Aktenhh.A 5) 020/0 (Notarial Seal) By: Adam Horowitz Jeffrey M. Herman Stuart Mermelstein Herman & Mermelstein, P.A. 18205 Biscayne Blvd. Suite 2218 Miami, FL 33160 ([Phone Redacted] Fax: ([Phone Redacted] EFTA02742848 Case 9:08-cv-80994-KAM Document 41-1 Entered on FLSD Docket 05/07/2009 Page 6 of 6 Doe No. 6 v. Epstein Page 13 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 24 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 rcritObciclaw.com Co-Counsel for Defendant Jeffrey Epstein Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 [Phone Redacted] Fax: [Phone Redacted] [Email Redacted] Co-Counsel for Defendant Jeffrey Epstein el R. Tein, Esq. Tein, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, FL 33133 [Phone Redacted] Fax: [Phone Redacted] Co-Counsel for Defendant Jeffrey Epstein tein lewistein.com EFTA02742849