EFTA00603608Set 9
2015-01-06129p34,335w
that might refute or allow
defense of this information).
In sum, Plaintiffs' objections to Interrogatory Nos. 13 and 21 and to Document Request
Nos ... claims to have been a "sex slave" for Epstein. See
Exhibit A, Responses to Interrogatory Nos. 13, 21; Exhibit C, Responses to Document Request
Nos ... lead to the discovery of admissible evidence
Accordingly, Plaintiffs' relevancy and/or admissibility objections to Interrogatory Nos.
13 & 21 and Document Request Nos
https://www.justice.gov/epstein/files/DataSet%209/EFTA00603608.pdf
EFTA01070451Set 9
2009-07-2050p15,294w
Responses to Production Requests Nos. 1, 2, 4, 5, and 19,
and Answers to Interrogatories Nos. 2, 18, and 23.
Production Request No. 1
1. Individual and/or joint income ... Commit Tedious Assault only
10, which seek Information about
In her answers to interrogatory nos. 9 and
C.M.A.'s damages claims, Plaintiff answered that:
Amended Complaint Is pending.
Defendant ... Commit Tortlous Assault only against
which seek information about
In her answers to Interrogatory nos. 9 and 10,
C.M.A.'s damages claims, Plaintiff answered that:
I lost my self-esteem
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070451.pdf
EFTA01070407Set 9
2009-02-1344p15,146w
Compel Responses to Production Requests Nos.1, 2, 4. 5, and 19,
and Answers to Interrogatories Nos. 2, 18. and 23.
Production Request No. 1
1. Individual and/or Joint income ... Conspiracy to Commit Tortbus Assault only against
seek Information about
in her answers to interrogatory nos. 9 and 10, which
C.M.A.'s damages claims, Plaintiff answered that:
Complaint Is pending ... Conspiracy to Commit Tortious Assault only against
seek information about
In her answers to interrogatory nos. 9 and 10, which
C.M.A.'s damages claims, Plaintiff answered that
self-esteem
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070407.pdf
EFTA00723218Set 9
2009-12-0977p19,203w
work inside his Palm
Beach residence, all other employees who came to the residence (Interrogatory Nos. 1
— 2), those who gave or were asked to give him massages (Interrogatories Nos ... knowledge or are in possession of physical
evidence pertaining to the events in question (Interrogatories Nos. 13, 14 and 17), and
EFTA00723223
inv. Epstein
Case No. 502008CA037319X)MMB AB
Page ... physical evidence (i.e. photographs,
videos, written statements, etc.) pertaining the events in question (Interrogatory Nos.
13, 14 and 17 supra), it follows that Epstein's production of his genitalia
https://www.justice.gov/epstein/files/DataSet%209/EFTA00723218.pdf
EFTA01070533Set 9
2009-07-2041p13,997w
Motion To Compel Responses to Production Requests Nos. 23.
and Answers to Interrogatories Nos. 2.18, and
Production Request No. 1
documentation
1. Individual and/or Joint income tax returns and supporting ... Commit Tortlous Assault only against Defen
seek Information about
In her answers to Interrogatory nos. 9 and 10, which
C.MA.'s damages claims, Plaintiff answered that
ded Complaint is pending ... Commit Tortious Assault only agains
which seek information about
In her answers to Interrogatory nos. 9 and 10,
C.M.A.'s damages claims, Plaintiff answered that:
my self-esteem. le began
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070533.pdf
EFTA00728201Set 9
2009-03-0253p14,628w
general partner or person in
control.
'These privileges are asserted in response to Interrogatory nos. 13, 14, and 17, and each and every
document request.
11 The only possible exception ... Entered on FLSD Docket 03/02/2009 Page 12 of 16
The term "Employee" appears in Interrogatory nos. 1, 2, and Document Request no. 6. The
breadth of this definition is reasonable
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728201.pdf
EFTA00222502Set 9
2009-03-0216p3,973w
general partner or person in
control.
'These privileges are asserted in response to Interrogatory nos. 13, 14, and 17, and each and every
document request.
11 The only possible exception ... Entered on FLSD Docket 03/02/2009 Page 12 of 16
The term "Employee" appears in Interrogatory nos. 1, 2, and Document Request no. 6. The
breadth of this definition is reasonable
https://www.justice.gov/epstein/files/DataSet%209/EFTA00222502.pdf
EFTA00222162Set 9
2009-05-069p1,992w
Plaintiffs properly objected to these interrogatories in that discovery on
Plaintiffs also object to Interrogatory nos. 19, 20, and 21, served on each of them, which seek the
identities ... regarding all men other than Epstein with whom the Plaintiffs
have had sexual activity, interrogatory nos. 19-21 are at least limited to criminal conduct.
Nonetheless, these interrogatories are overbroad ... based on the discovery sought. Here, Defendant contends that the information it seeks in
interrogatory nos. 19-21 is relevant to Plaintiffs' damages claims, but fails to state in this
https://www.justice.gov/epstein/files/DataSet%209/EFTA00222162.pdf
EFTA00221691Set 9
2009-01-2612p3,567w
psychological and emotional
damages," and "severe mental anguish and pain." In her answers to interrogatories
nos. 9 and 10, Plaintiff further states that:
Plaintiff has suffered severe psychological and emotional ... psychological and emotional
damages," and "severe mental anguish and pain." In her answers to interrogatories
nos. 9 and 10, dated January 26, 2009, Plaintiff further states that
EFTA00221698
Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00221691.pdf