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FBI VOL00009

EFTA00221686

3 sivua
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Case 9:08-cv-80119-KAM 
Document 66-2 
Entered on FLSD Docket 03/26/2009 
Page 1 of 3 
C 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80232-MARRA-JOHNSON 
JANE DOE NO. 3, 
Plaintiff, 
I. 
JEFFREY EPSTEIN, 
Defendant. 
PLAINTIFF JANE DOE 3'S ANSWERS TO DEFENDANT'S FIRST 
INTERROGATORIES 
Plaintiff, JANE DOE 3, 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 °Mentions 
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" 
EFTA00221686
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Case 9:08-cv-80119-KAM 
Document 66-2 
Entered on FLSD Docket 03/26/2009 
Page 2 of 3 
.Doe No. 3 I. Epstein 
Page 13 
C 
your current age. 
Describe the lewd or lascivious exhibition, the date and 
whether you received money or other consideration from the person 
Answer: 
Plaintiff objects to this interrogatory as vague, overly broad, unduly burdensome, 
harassing, and not reasonably calculated to lead to discovery of admissible 
evidence. Moreover, this interrogatory is outrageous, offensive and apparently 
posed for the purpose of intimidating the victim. Fed.R.Evid. 412 makes any 
answer to this Interrogatory inadmissible, and nothing In the answer could 
plausibly lead to discovery of admissible evidence. 
22. 
List in detail all discussions/interviews which you had with any representative 
from FBI, U.S. Attorneys' Office, State Attorneys' Office (Palm Beach County), 
Palm Beach Sheriffs Office and Palm Beach Police Department regarding your 
meetings with Mr. Epstein. Include dates, who was present, the details of what 
was discussed, whether a court reporter was present and whether a taped 
statement was taken or whether you provided a written statement. 
Answer: 
Plaintiff met with the Palm Beach Police Department in 2007. She believes that 
she provided them with a written statement, and that they also tape recorded her 
interview. 
Plaintiff also spoke with FBI agents in 2007 investigating the case on 2-3 
occasions, Including one meeting in person. 
Plaintiff does not believe that the 
statement was recorded. 
23. 
State the names, addresses, ages and phone numbers of all females whom you 
claim were brought by you to Mr. Epstein's home to give him a massage. As to 
each female, state the amount of money you claim you were paid to bring each 
female. 
Answer: 
(Sane bee 4) 
Plaintiff was not paid by the Defendant of bringing'''. eCAne Lee- 4 ) 
bce 
Plaintiff was paid $1 0 for bringing 
(rant Doe a:\ 
EFTA00221687
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Case 9:08-cv-80119-KAM 
Document 66-2 
Entered on FLSD Docket 03/26/2009 
Page 3 of 3 
1 
VERIFICATION 
Vane boe 3 
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. 
TAX) C. 
STATE OF FLORIDA 
) ss 
COUNTY OF PALM BEACH 
) 
SWORN TO AND SUBSCRIBED before me this  19 day o 
any 
2009 by 
who is personally known to me or has produced the 
following Ide
—~nUtoation
 
kecera--&—` • which is current or has been issued 
within the past five years and bears a serial or other identifying number. 
idlor-th 3,-Argar 
not Name 
Pet fam
Sign z e 
NOTARY PUBLIC - STATE OF FLORIDA 
Commission Number. 
My commission expires: 
(Notarial Seal) 
Notary Pubilalail of Fleas
f 
Sabath Ganz. 
%es Ay My Conrniake 00440926 
e 
Wes Ce14/2009 
EFTA00221688