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This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →

FBI VOL00009

EFTA00222038

11 pages
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Case 9:08-cv-80119-KAM 
Document 57-2 
Entered on FLSD Docket 03/02/2009 
Page 1 of 11 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA-JOHNSON 
JANE DOE NO. 2, 
JEFFREY EPSTEIN, 
Plaintiff, 
Defendant. 
DOCKET 
912.6109 
DEFENDANT EPSTEIN'S RESPONSE & OBJECTIONS 
TO PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES 
Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, 
serves his responses and objections to Plaintiffs December 9, 2008 Amended First Set 
Of Interrogatories To Defendant Jeffrey Epstein, attached hereto. 
Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing has been sent by fax and 
U.S. Mail to the following addressees this  26th 
 day of January, 2009: 
Adam D. Horowitz, Esq. 
Jeffrey Marc Herman, Esq. 
Stuart S. Mermelstein, Esq. 
18205 Biscayne Boulevard 
Suite 2218 
Miami, FL 33160 
305-931-2200 
Fax: 305-931-0877 
ahorowitzahermanlaw.com 
jhermanahermanlaw.com 
lrivera
hermanlaw.com 
Counsel for Plaintiff Jane Doe #2 
Jack Alan Goldberger 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach, FL 33401-5012 
561-659-8300 
Fax: 561-835-8691 
jaqesqabellsouth.net 
Co-Counsel for Defendant Jeffrey Epstein 
EXHIBIT "A" 
EFTA00222038
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• Case 9:08-cv-80119-KAM 
Document 57-2 
Entered on FLSD Docket 03/02/2009 
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Jane Doe No. 21. Epstein 
Page 2 
Respectfully su2 
tted, 
By: 
ROBERT 
RITTON, JR., ESQ. 
Florida Ba No. 224162 
rcrit • bcl. aw.com 
MICHAEL J. PIKE, ESQ. 
Florida Bar #617296 
mpikeabcIclaw.com 
BURMAN, CRITTON, LUTTIER & COLEMAN 
515 N. Flagler Drive, Suite 400 
West Palm Beach, FL 33401 
561/842-2820 Phone 
561/515-3148 Fax 
(Co-Counsel for Defendant Jeffrey Epstein) 
EFTA00222039
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Case 9:08-cv-80119-KAM 
Document 57-2 
Entered on FLSD Docket 03/02/2009 
Page 3 of 11 
Jane Doe No. 2 1. Epstein 
Page 3 
DEFENDANT JEFFREY EPSTEIN'S ANSWERS AND OBJECTIONS TO 
PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES 
Interrogatory No. 1. 
Identify all employees who performed work of services inside 
the Palm Beach Residence. 
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." Plaintiffs interrogatory seeks information for a time period from 
January 1, 2003 until present. Also, see "Employee" as defined in paragraph g of 
Plaintiffs interrogatories. 
Interrogatory No. 2. 
Identify all Employees not identified in response to 
interrogatory no. 1 who at any time came to Defendant's Palm Beach Residence. 
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 2004-2005." Plaintiffs interrogatory seeks information for "all Employees" "who at 
any time" came to the residence. Also, see "Employee" as defined in paragraph g of 
Plaintiffs interrogatories. 
EFTA00222040
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Document 57-2 
Entered on FLSD Docket 03/02/2009 
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Jane Doe No. 21. Epstein 
Page 4 
Interrogatory No. 3. 
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 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. 4. 
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 2004-2005." 
Interrogatory No. 5. 
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 
EFTA00222041
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• Case 9:08-cv-80119-KAM 
Document 57-2 
Entered on FLSD Docket 03/02/2009 
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Jane Doe No. 21 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. Plaintiffs 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 
EFTA00222042
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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. 2I. Epstein 
Page 6 
discovery of admissible evidence. Plaintiffs 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 
(HIPAA). 
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 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 2004 — 2005," while Plaintiffs interrogatory seeks information from 
EFTA00222043
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Case 9:08-cv-80119-KAM 
Document 57-2 
Entered on FLSD Docket 03/02/2009 
Page 7 of 11 
Jane Doe No. 2'. 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. Plaintiff's 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. 
EFTA00222044
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' Case 9:08-cv-80119-KAM 
Document 57-2 
Entered on FLSD Docket 03/02/2009 
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Jane Doe No. 2'. Epstein 
Page 8 
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 2004-2005" and involve Defendant's Palm Beach residence. 
Interrogatory No. 13. 
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 
Defendant's 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 26 disclosures made by Defendant's 
counsel in this case. 
Interrogatory No. 14. 
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. 
EFTA00222045
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Case 9:08-cv-80119-KAM 
Document 57-2 
Entered on FLSD Docket 03/02/2009 
Page 9 of 11 
Jane Doe No. 2'. Epstein 
Page 9 
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 
Defendant's attorneys. 
Interrogatory No. 15. 
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 person's full name, last known address and telephone number; 
b. The person's attorney, if represented; 
c. The date of the alleged incident(s); 
d. 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 (d), Defendant's counsel states that such information is 
public record and equally attainable by Plaintiff. 
Interrogatory No. 16. 
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 
EFTA00222046
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Case 9:08-cv-80119-KAM 
Document 57-2 
Entered on FLSD Docket 03/02/2009 
Page 10 of 11 
Jane Doe No. 21. Epstein 
Page 10 
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. 17. 
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 witness's 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 
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 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." 
STATE OF nor'% <Ia. 
COUNTY OF9c,\cy, e)es:13-. ) 
I hereby certify that on this day, before me, an officer duly authorized to administer oaths 
and take acknowledgments, personally appeared  Je-cre..t 
•Rs 
 , known to 
me to be the person described in and who executed the fore 
ing Interrogatories who 
EFTA00222047
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. ..Case 9:08-cv-80119-KAM 
Document 57-2 
Entered on FLSD Docket 03/02/2009 
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Jane Doe No. 2'. Epstein 
Page 11 
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 
26) 
day of  
o.,e,,No.r,A 
 2009. 
(SEAL) 
NOTARY PUBLIC-STATE OF FLORIDA 
Nayanira Alanis 
E`Comoussion SDDS41844 
Expires: DEC. 01,2012 
BONDED TRI2U ATIAITC BONDING Ca, Dit. 
PRINT NAME: lV amyan: 
1 \ Arl% s 
Notary Public/State of Florida 
Commission #: 
My Commission Expires: 
EFTA00222048