EFTA01116153

se 9:08-cv-80119-KAM 
Document 242 
Entered on FLSD Docket 08/04/2009 
Page 15 of 22 
©rl o 
his mansion for the purpose of sexual exploitation. Substantively, the interrogatories 
are narrowly tailored to discover only information that is directly relevant to Plaintiffs 
claims and/or Epstein's defenses. Epstein's HIPAA objections are unfounded as the 
request seeks only the identification of Epstein's health care providers.' 
allegation that Epstein has a psychosexual condition, which, if true, could very well 
Finally, the requested ten-year time frame is not Overly broad considering the 
have existed most, if not all, of his adult life. The Court agrees with Epstein, 
however, that Plaintiffs allegation of child abuse, does not alone provide Plaintiff with 
carte blanche access to a list of ALL of Defendant's medical providers. Instead, the 
undersigned limits the interrogatory to a request for "identification, by name, title and 
address and/or telephone number, of all of Epstein's psychologists, psychiatrists, 
therapists, or mental health counselors for the last ten years." Accordingly, except 
as mentioned above with respect to health care professionals, the Court finds Epstein's 
objections to Interrogatories 7, 8 
nfounded and orders Epstein to provide 
responses to same in accordance with the a ore-stated terms, within ten (10) days from 
the date hereof. 
4-
PRODUCTIO 
As noted previously, the Fifth Amendment privilege may not apply to specific 
' In addressing Interrogatory 8, both parties refer to the need for the Court to 
hold an in camera inspection of the documents to determine, as to each document, 
whether Fla. Stat. §39.204 is applicable. The request at issue, however, is an 
INTERROGATORY request, not a document request, and therefore these concerns are 
inapplicable. 
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EFTA01116153

305-9312230 
Herman SiMermelstein, P 
06:26:19 p.m. 
09-12-2008 
9/86 
JANE DOE NO. 2, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-130119-MARRA/JOHNSON 
\t‘1O2--
AMENDED FIRST SET OF INTERROGATORIES 
TO DEFENDANT JEFFREY EPSTEIN 
Plaintiff, JANE DOE No. 2, by and through undersigned counsel, propounds this 
Amended First Set of Interrogatories upon Defendant, JEFFREY EPSTEIN, pursuant to the 
Federal Rules of Civil Procedure, to be answered in writing, under oath, within thirty (30) days 
of the date hereof. 
Definitions and Instructions 
a. 
The word "document" shall mean any written or graphic matter or other means of 
preserving thought or expression, and all tangible things from which information can be pro-
cessed or transcribed, including, but not limited to correspondence, memoranda, notes, messages, 
letters, telegrams, teletype messages, bulletins, diaries, chronological data, minutes, books, 
reports, charts, ledgers, invoices, worksheets, receipts, computer printouts, schedules, affidavits, 
contracts, transcripts, surveys, graphic representations of any kind, photographs, graphs, micro-
film, videotapes, tape recordings, motion pictures or other films. "Document" shall be deemed to 
include the original and any draft thereof, and any copy of an original or a draft which differs in 
any respect from such original or draft. 
b. 
The word "person" shall be deemed to mean any natural person or any legal entity 
including but not limited to the corporation, partnership, and or unincorporated association, and 
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Herman 8/11.44rmelsteln, P 
06:26:34 p.m. 
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• 
any officer, director, employee, agent personal representative or other person acting or 
purporting to act on its behalf. 
c. 
The words "identity" or "identify", when used with reference to a natural person, 
call for the following information: 
i) 
His or her full name, profession, address, telephone number and email 
address, or, if such present information is unknown, provide the last known identifying same; 
ii) 
The full name and address of each of his or her employers; and 
iii) 
His or her present position and his or her position at the time of the act to 
which the Interrogatory answer relates. 
d. 
The words "identity" or "identify", when used with reference to any entity other 
than a natural person, call for the full name of the entity, the type of entity (department, agency, 
corporation, partnership, etc.), and the address and telephone number of its principal place of 
business or operations, its principal business or other activity and its relationship, if any, to the 
parties to this litigation. If such entity no longer maintains an address, is engaged in business or 
other activity or bears any relationship to a party to this litigation, state his last known address, 
activity and/or relationship, and the date(s) thereof. 
e. 
The words "identity" or "identify", when used with reference to a document or a 
communication, call for the following information: 
i. 
Its nature (i.e., letter, telegram, memorandum, chart, report, canceled 
check, etc.), date, the signatory, the recipient, and the name and address of each; 
ii 
The identity of each person who signed the document or of each person 
who participated in the making of the communication; 
ii 
The title or heading of the document or communication, if any. 
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06:26:48 p.m. 
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f. 
The words "Defendant", "you" or "your" refers to Defendant, Jeffrey Epstein, and 
any agent, representative, employee or person acting or purporting to act on his behalf. 
g. 
"Employee" shall mean any person employed to perform work or services for 
Defendant or by Defendant either directly or indirectly, including without limitation: 
i. 
a limited partnership, corporation, limited liability company, or other 
company or entity of which Defendant is a member, director, officer or person in control; 
and 
ii. 
persons employed by a partnership or a subsidiary of a partnership in 
which Defendant is a general partner or person in control. 
h. 
"Palm Beach Residence" shall mean that certain property located in Palm Beach, 
Florida, having an address of 358 EI Brillo Way, Palm Beach Fl 33480. 
i. 
"New York Residence" shall mean that certain property located in New York, 
New York having an address of 9 East 71st Street, New York, NY 10021. 
j. 
"New Mexico Residence" shall mean that certain property located in New Mexico 
having an address of 49 Zorro Ranch Road, Stanley, New Mexico, 87056-9743. 
k. 
"St. Thomas Residence" shall mean that certain property located in St. Thomas 
having an address of 6100 Red Hook Quarters, Suite B-3, St. Thomas, 
00807. 
1. 
The time period for the responses to these Interrogatories is January 1, 2003 to 
present, unless otherwise stated. 
3 
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• 
Case 9:08-cv-80119-KAM 
Document 57-2 
Entered on FLSD Docket 03/02/2009 
Page 5 of 11 
Jane Doe No. 2 v. Epstein 
Page 5 
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 2004-2005? 
Interrogatory No. 6. 
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. Plaintiff's Complaint alleges a time period of "in or 
about 2004-2005? 
Interrogatory No. 7. 
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 
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' Case 9:08-cv-80119-KAM 
Document 57-2 
Entered on FLSD Docket 03/02/2009 
Page 6 of 11 
Jane Doe No. 2 v. Epstein 
Page 6 
discovery of admissible evidence. Plaintiff's Complaint alleges a time period of "in or 
about 2004-2005.° Plaintiffs interrogatory seeks information for a time period from 
January 1, 2003 until present. 
Interrogatory No. 8. 
Identify all of Jeffrey Epstein health care providers in the 
past (10) 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 501, Fed. Evid., and §90.503, Fla.Evid. Code. In addition, such information is 
protected by the provisions of the Health Insurance Portability and Accountability Act 
(Ell PAA). 
Interrogatory No. 9. 
List all items in Jeffrey Epstein's 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 hls 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 2004 — 2005: while Plaintiffs interrogatory seeks information from 
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• Case 9:08-cv-80119-KAM 
Document 57-2 
Entered on FLSD Docket 03/0212009 
Page 7 of 11 
Jane Doe No. 2 v. Epstein 
Page 7 
January 1, 2003, until present. Further, the request is meant to embarrass and harass 
the Defendant. 
Interrogatory No. 10. 
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. 11. 
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 2004-2005' and involve Defendant's Palm Beach residence. 
Interrogatory No. 12. 
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. 
EFTA01116159