Case Document Entered on FLSD Docket Page of sl i UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CV-80119-MARRA-JOHNSON JANE DOE NO EXHIBIT A Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page2 By ROBERT RITTON JR ESQ Florida Ba No rcrit bcl aw.com MICHAEL PIKE ESQ Florida Bar mpike bclclaw.com BURMAN CRITTON LUTTIER COLEMAN Flagler Drive Suite West Palm Beach FL Phone Fax Co-Counsel for Defendant Jeffrey Epstein Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page3 DEFENDANT JEFFREY EPSTEINS ANSWERS AND OBJECTIONS TO PLAINTIFFS AMENDED FIRST Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page4 Interrogatory No Identify all persons who came to the Palm Beach Residence and who gave a massage or were asked to give a massage to Defendant Answer Defendant is asserting specific legal objections to the interrogatories as well as his U.S constitutional privileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitution rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges Defendant objects as the interrogatory is overbroad and seeks information that is neither relevant to the subject matter of the pending action nor does it appear reasonably calculated to lead to the discovery of admissible evidence Plaintiffs Complaint alleges a time period of in or about Interrogatory No Identify all persons who came to the New York Residence and who gave a massage or were asked to give a massage to Defendant Answer Defendant is asserting specific legal objections to the interrogatories as well as his U.S constitutional privileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges Defendant objects as the interrogatory is overbroad and seeks information that is neither relevant to the subject matter of the pending action nor does it appear reasonably calculated to lead to the discovery of admissible evidence Plaintiffs Complaint alleges a time period of in or about Interrogatory No Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant Answer Defendant is asserting specific legal objections to the interrogatories as well as his U.S constitutional privileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges Defendant objects as the interrogatory is overbroad and seeks information that is neither relevant to the subject matter of the pending action nor does it appear reasonably calculated to lead to the discovery of admissible evidence Plaintiffs Complaint alleges a time period of in or about Interrogatory No Identify all persons who came to the St Thomas Residence and who gave a massage or were asked to give a massage to Defendant Answer Defendant is asserting specific legal objections to the interrogatories as well as his U.S constitutional privileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges Defendant objects as the interrogatory is overbroad and seeks information that is neither relevant to the subject matter of the pending action nor does it appear reasonably calculated to lead to the discovery of admissible evidence Plaintiffs Complaint alleges a time period of in or about Interrogatory No List all the time periods during which Jeffrey Epstein was present in the State of Florida including for each the date he arrive and the date he departed Answer Defendant is asserting specific legal objections to the interrogatories as well as his U.S constitutional privileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges Defendant also objects as the interrogatory is overbroad and seeks information that is neither relevant to the subject matter of the pending action nor does it appear reasonably calculated to lead to the Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page discovery of admissible evidence Plaintiffs Complaint alleges a time period of in or about Plaintiffs interrogatory seeks information for a time period from January until present Interrogatory No Identify all of Jeffrey Epstein health care providers in the past ten years including without limitation psychologists psychiatrists mental health counselors physicians hospitals and treatment facilities Answer Defendant is asserting specific legal objections to the interrogatories as well as his U.S constitutional privileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges Defendant also objects as the interrogatory is overbroad and seeks information that is neither relevant to the subject matter of the pending action nor does it appear reasonably calculated to lead to the discovery of admissible evidence In addition such information is privileged pursuant to Rule Fed Evid and Fla.Evid Code In addition such information is protected by the provisions of the Health Insurance Portability and Accountability Act HIPAA Interrogatory No List all items in Jeffrey Epsteins possession in Palm Beach Florida at any time during the period of these interrogatories which were used or intended to be used as sexual aids sex toys massage aids and/or vibrators and for each list the manufacturer model number if applicable and its present location Answer Defendant is asserting specific legal objections to the interrogatories as well as his U.S constitutional privileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges Defendant also objects as the interrogatory is overbroad and seeks information that is neither relevant to the subject matter of the pending action nor does it appear reasonably calculated to lead to the discovery of admissible evidence Plaintiffs Amended Complaint alleges a time period of in or about while Plaintiffs interrogatory seeks information from Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page January until present Further the request is meant to embarrass and harass the Defendant Interrogatory No Identify all persons who provide transportation services to Jeffrey Epstein whether as employees or independent contractors including without limitation chauffeurs and aircraft crew Answer Defendant is asserting specific legal objections to the interrogatories as well as his U.S constitutional privileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges Defendant also objects as the interrogatory is overbroad and seeks information that is neither relevant to the subject matter of the pending action nor does it appear reasonably calculated to lead to the discovery of admissible evidence Plaintiff places no time limitation Interrogatory No Identify all telephone numbers used by Epstein including cellular phones and land lines in any of his residences by stating the complete telephone number and the name of the service provider Answer Defendant is asserting specific legal objections to the interrogatories as well as his U.S constitutional privileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges Defendant also objects as the interrogatory is overbroad and seeks information that is neither relevant to the subject matter of the pending action nor does it appear reasonably calculated to lead to the discovery of admissible evidence Plaintiffs allegations claim a time period of in or about and involve Defendants Palm Beach residence Interrogatory No Identify all telephone numbers of employees of Epstein used in the course or scope of their employment including cellular phones and land lines in any of his residences by stating the complete telephone number and the name of the service provider Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page Answer Defendant is asserting specific legal objections to the interrogatories as well as his U.S constitutional privileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges Defendant objects as the interrogatory is overbroad and seeks information that is neither relevant to the subject matter of the pending action nor does it appear reasonably calculated to lead to the discovery of admissible evidence Plaintiffs allegations claim a time period of in or about and involve Defendants Palm Beach residence Interrogatory No List the names and addresses of all persons who are believed or known by your your agents or your attorneys to have any knowledge concerning any of the issues in this lawsuit and specify the subject matter about which the witness has knowledge Answer Defendant is asserting specific legal objections to the interrogatories as well as his U.S constitutional privileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the interrogatory seeks information that is attorney-client and work product privileged as it seeks information known by Defendants attorneys The interrogatory is so overbroad that Defendant cannot reasonably form a response including the raising of additional privileges which may apply Without waiving any objection see Rule disclosures made by Defendants counsel in this case Interrogatory No State the name and address of every person known to you your agents or your attorneys who has knowledge about possession or custody or control of any model plat map drawing motion picture videotape or photograph pertaining to any fact or issue involved in this controversy and describe as to each what item such person has the name and address of the person who took or prepared it and the date it was taken or prepared Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page Answer Defendant is asserting specific legal objections to the interrogatories as well as his U.S constitutional privileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges the interrogatory seeks information that is attorney-client and work product privileged as it seeks information known by Defendants attorneys Interrogatory No Identify all persons who have made a claim complaint demand or threat against you relating to alleged sexual abuse or misconduct on a minor and for each provide the following information a The persons full name last known address and telephone number The persons attorney if represented The date of the alleged incident If a civil case has been filed by or on behalf of the person the case number and identifying information Answer Defendant is asserting specific legal objections to the interrogatories as well as his U.S constitutional privileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges and without waiving such objection with regard to subparagraph Defendants counsel states that such information is public record and equally attainable by Plaintiff Interrogatory No State the facts upon which you intend to rely for each denial of a pleading allegation and for each affirmative defense you intend to make in these cases Answer Defendant is asserting specific legal objections to the interrogatories as well as his U.S constitutional privileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept this advice or risk Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges no answer to the Amended Complaint has been filed by defense counsel in this case however Defendant does not intend to waive his constitutional privilege against self-incrimination Defendant further objects in that Plaintiffs interrogatory attempts to obtain discovery in other cases filed by her undersigned counsel Interrogatory No Identify all witnesses from whom you have obtained or requested a written transcribed or recorded statement relating to any issue in these cases and for each in addition to the witnes identifying information state the date of the statement and identify the person taking the statement Answer Defendant is asserting specific legal objections to the interrogatories as well as his U.S constitutional privileges I intend to respond to all relevant questions regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit and I must accept this advice or risk losirig my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In addition to and without waiving his constitutional privileges Defendant objects to this interrogatory in that it seeks information that is attorney-client and work product privileged In addition the request is overbroad in that it seeks information relating to any issue I hereby certify that on this day before me an officer duly authorized to administer oaths and take acknowledgments personally appeared known to me to be the person described in and who executed the foregoing Interrogatories who Case Document Entered on FLSD Docket Page of Jane Doe No Epstein Page acknowledged before me that he/she executed the same that I relied upon the following form of identification of the above-named person personally known/identification and that an oath was/was not taken WITNESS my hand and official seal in the County and State last aforesaid this day of a.Y uo-r NOTARY PUBLIC-STATE OF FLORIDA PR CA A Nayanira Alanis Notary Public/StateoFlorida SEAL I commission Commission Expires DEC nom EDTHRu ATLANTICBoNDINGco.,INc omm1ss1on xp1res
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