EFTA01076611Set 9
2010-03-1737p26,716w
individual identified ass?
9 A. Though I'd Ilice to answer each and every one 9 A. I believe from depositions that I've read her
10 of your questions ... have me invoke my Fifth
16 A. Again, Mr. Scarola, though Pd like to answer 16 Amendment, Sixth Amendment and 14th Amendment Right in
17 each and every ... Counsel, though I'd 21 identified by the initials Ini?
22 lute to answer these questions, if I do so, I risk 22 A. Mr. Scarola, at least today
https://www.justice.gov/epstein/files/DataSet%209/EFTA01076611.pdf
EFTA00801993Set 9
94p19,003w
required by the context to bring within
the scope of this production request any answer that might be deemed
outside its scope by another construction.
(x) "Related to" or "relating ... individually.
Defendants.
0 /
co JEFFREY EPSTEIN'S NOTICE OF SERVING UNVERIFIED AMENDED
ANSWERS TO DEFENDANT BRADLEY EDWARDS'S INTERROGATORIES
Plaintiff Jeffrey Epstein, by and through his undersigned ounsel and pursuant ... Florida Rules of Civil Procedure, hereby certifies that the original amended
answers to Defendant's Interrogatories was served upon Defendant via electronic service
this July 10, 2013.
/s/ Tonia Haddad
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801993.pdf
EFTA00798060Set 9
2017-09-0528p10,660w
ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
L.M., individually,
Defendant(s).
NOTICE OF SERVING ANSWERS TO INTERROGATORIES
Bradley J. Edwards, by and through his undersigned counsel, hereby files this Notice ... Serving Answers to Interrogatories with the Court propounded by Jeffrey Epstein on September
5, 2017, and said Answers to Interrogatories have been furnished to the attorneys for Jeffrey
Epstein ... Bradley J. Edwards
EFTA00798060
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Notice of Serving Answers to Interrogatories
COUNSEL LIST
William Chester Brewer, Esquire
wcblaw@aol.com; wcblawasst@gmail.com
250 S Australian Avenue, Suite
https://www.justice.gov/epstein/files/DataSet%209/EFTA00798060.pdf
EFTA01130196Set 9
2013-07-02220p48,765w
been an evolving process, so that's a
23 question that I can't answer for you, except to tell you
24 that it is my personal assessment that ... would prefer that it be more focussed before I attempt
13 to answer it.
14 In what regard?
15 Q. Well, are there limits on the -- the amount ... Pagc 18
1 referencing the statute. Certainly, if you want the
2 most accurate answer I am able to give you, I've got a
3 copy of the statute
https://www.justice.gov/epstein/files/DataSet%209/EFTA01130196.pdf
EFTA02444174Set 11
2009-05-0311p3,418w
SIGNATURE)
DO NOT LEAVE BLANK SPACES - IF A QUESTION IS "NOT APPLICABLE"
OR THE ANSWER IS "NONE" OR "NO," SO STATE.
(Attach additional pages if necessary)
[For purposes ... year and the name of the advisor or Investor Representative.) [Unless
otherwise indicated, the answer to this question is "No."
No: Yes:
12. The undersigned will have an attorney ... investment with respect to the undersigned's
personal situation. [Unless otherwise indicated, the answer to this question is "No.1
No: Yes:
13. The undersigned will have an advisor review
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02444174.pdf
EFTA00182476Set 9removed from DOJ
2009-10-20180p31,379w
sorry. Go ahead.
3 MR. REINHART: Do you need to expand on your
4 answer?
5 BY MR. MERMELSTEIN:
6 Q Were you finished?
7 A I worked regular hours ... that correct?
10 MR. CRITTON: Form.
11 BY MR. MERMELSTEIN:
12 Q You can answer.
13 A I cannot remember if they -- let me see.
14 remember . Because when ... What if I
21 used the term "body fluids," does that change your
22 answer at all?
23 A No.
24 Q It's the same, you never cleaned body
https://www.justice.gov/epstein/files/DataSet%209/EFTA00182476.pdf
EFTA01100608Set 9
2011-04-0830p8,889w
minors. Indeed, in recent
discovery Epstein has asserted his Fifth Amendment privilege rather than answer questions about the
extent of the sexual abuse of his many victims. Even more remarkably ... Filed 04/08/11 Page 8 of 30
Edwards has supplemented his deposition answers with an Affidavit that declares in no
uncertain terms his lack of involvement in any fraud perpetrated ... deposition whether he had any evidence of Edwards's involvement, Epstein
declined to answer, purportedly on attorney-client privilege grounds:
Q. I want to know whether you have any knowledge
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100608.pdf
EFTA00724170Set 9
2010-04-1310p2,005w
Plaintiff,
v.
JEFFREY EPSTEIN
and
Defendants.
I
DEFENDANT EPSTEIN'S MOTION TO AMEND ANSWER & AFFIRMATIVE DEFENSES, &
MOTION TO STRIKE DIRECTED TO PLAINTIFF'S SECOND AMENDED COMPLAINT
Defendant, JEFFREY EPSTEIN, (hereinafter ... attorneys, hereby moves this Court for an order allowing amendment to his
previously filed Answer & Affirmative Defenses, & Motion To Strike Directed To
Plaintiff's Second Amended Complaint, dated April ... motion, EPSTEIN states:
1. On April 13. 2010, EPSTEIN previously served and filed his Answer &
Affirmative Defenses, & Motion To Strike Directed To Plaintiff's Second Amended
Complaint, (hereinafter "original answer
https://www.justice.gov/epstein/files/DataSet%209/EFTA00724170.pdf
EFTA01112318Set 9
2015-12-1126p5,576w
they tell
you -- did you ask who contacted Leslie Wexner?
A. The first answer was
lawyer.
I then subsequently learned that among
those who contacted Leslie Wexnees lawyers was
David ... issue then came up a third time, with Dershowitz offering to answer a
question posed by Plaintiffs' counsel, but demurring until this Court could address the
"settlement communication" objection ... extortion plot, but you have
filed no criminal complaints against anyone,
correct?
A. To answer that question requires me to
disclose conversations I had with David Boies. I
would love
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112318.pdf
EFTA01248167Set 9removed from DOJ
2009-08-0774p36,354w
many stairs there were, to
5 A. I don't know, Ma'am. 5 answer your question there were three.
6 Q. I want to ask you to take this ... sorry. 15 Q. One of your duties was to answer the
16 MR. CRITTON: Why don't we go off the 16 door. Is that correct?
17 record ... Thereupon, a discussion was held off the 18 Q. Which door would you answer?
19 record.) 19 A. Mainly the kitchen.
20 THE VIDEOGRAPHER: We're back
https://www.justice.gov/epstein/files/DataSet%209/EFTA01248167.pdf
EFTA00738559Set 9
2009-07-3132p5,942w
defendant proposes to present."
8 We can turn to the sworn Interrogatory
9 answers, No. 8, wherein =. and, similarly,
10 , in slightly different words, states: "I
11 was touched, battered ... move on, that's
10 -
11 MR. EDWARDS: Yes, Your Honor.
12 THE COURT: -- Answer to Interro atories?
13 Why don't you read into the record Answer ... EDWARDS: I apologize, Your Honor.
16 THE COURT: Take your time.
17 MR. EDWARDS: Answer to Interrogatory No.
18 8 for indicates: "My injuries are
19 emotional and psychological
https://www.justice.gov/epstein/files/DataSet%209/EFTA00738559.pdf
EFTA00846231Set 9
2018-03-305p3,618w
just be listening. Despite my
disclaimer, during the call Deborah repeatedly pressured me to answer her questions and comments. I simply reminded
her that she could not expect ... live on your
income, I don't think I can give a more satisfying answer. It seems we just can't agree on how arithmetic works.
Regardless of whether ... Continue dialog by e-mail
You have sounded very frustrated by our unwillingness to answer direct questions you pose in your e-mail messages, or to
provide a line
https://www.justice.gov/epstein/files/DataSet%209/EFTA00846231.pdf
EFTA00058871Set 9removed from DOJ
2021-10-27453p77,697w
circumstances
11 surrounding it, and you are being asked to
12 voluntarily provide answers to our questions.
13 Will you agree to a voluntary interview with
14 the DOJ/OIG ... happened. "This is a voluntary interview.
17 Accordingly, you do not have to answer
18 questions. No disciplinary action will be
19 taken against you if you chose ... answer
20 questions. Any statements you furnish may be
21 used as evidence in any future criminal
22 proceedings, or agency disciplinary
23 proceedings, or both." And there
https://www.justice.gov/epstein/files/DataSet%209/EFTA00058871.pdf