Case 9:08-cv-80993-KAM Document 52-2 Entered on FLSD Docket 05/07/2009 Pad > UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80993-MARRA-JOHNSON JANE DOE NO. 7, Plaintiff, Vv. JEFFREY EPSTEIN, Defendant. / Enel PLAINTIFF JANE, DOE 7’S ANSWERS TO DEFENDANT'S FIRST INTERROGATORIES Plaintiff, JANE DOE 7, 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 Objections 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. EFTA00221222

--=PAGE_BREAK=--

Case 9:08-cv- - 08-cv-80993-KAM Document52-2 Entered on FLSD Docket 05/07/2009 Page 2 of 5 Doe No.7 v. Epstein Page 6 Jane Doe 1 (who is not represented by the undersigned attorneys) a — who brought Plaintiff to Defendant's estate on 2 occasions —_ — who accompanied Plaintiff to Defendant's estate on at lest one occasion accompanied Plaintiff to Defendant's estate on at least one occasion, but Plaintiff is unable to recall which sister it was. Discovery is ongoing and may be supplemented in accordance with the Federal Rules of Civil Procedure. 6. Please state the specific nature and substance of the knowledge that you believe the person(s) identified in your response to interrogatory no. 5 may have. Answer: See Plaintiff's Answer to Interrogatory No. 5. 7. Were you suffering from physical infirmity, disability, disease, sickness, OF psychiatric/psychological condition at the time of the incident(s) described in the complaint? If so, what was the nature of the infirmity, disability, or sickness? Answer: No. 8. Did you consume any alcoholic beverages or take any drugs or medications within 12 hours before the time of each incident(s) described in the complaint? If so, state the type and amount of alcoholic beverages, drugs, or medication which were consumed, and when and where you consumed them. Answer: No. 9. Describe each injury (physical, emotional, mental) for which you are claiming damages in this case, specifying the part of your body that was injured, the , EFTA00221223

--=PAGE_BREAK=--

Case 9:08-cv-80993-KAM Document 52-2 Entered on FLSD Docket 05/07/2009 Page 3of5 Doe No. 7 v. Epstein Page 13 Plaintiff received a letter dated Sept. 15, 2008, in care of her undersigned attorneys, titled “Amended Notification of Indentified Victim’. No statements regarding benefits from cooperation with law enforcement were made to Plaintiff at any time. January 24 , 2009 Respectfully submitted: HERMAN & MERMELSTEIN P.A. 2 : 18205 Biscayne Bivd., Suite 2218 Miami, Florida 33160 .hermanlaw.com Tel: 305-931-2200 Fax: -0877 By; Jeffrey M. Herman jherman@hermanlaw.com Florida Bar No. 521647 Stuart S. Mermelstein smerme|stein@hermanlaw.com Florida Bar No. 947245 Adam D. Horowitz ahorowitz@hermaniaw.com Florida Bar No. 376980 EFTA00221224

--=PAGE_BREAK=--

Case 9:08-cv-80993-KAM Document 52-2 01/23/2089 28:28 Entered on FLSD Docket 05/07/2009 Rage 4aafS Jene Doe No. 7 v, Epstein Page 15 against Mr. Epstein and regarding whether there would be: any benefit from your voluntary cooperation with law enforcement. VERIFICATION aia... duly sworn, depose and says that the foregoi rs fo interrogatories are true and bast of her knowledge, information and belief. STATE OF FLORIDA ) } ss COUNTY OF PALM BEACH ) CRIBED before me this 23° tay of Janwery 2008 by who is personally known to me or has prdduced the OO which is current or has been issued within the past five years and bears a sé al of other identifying number. NOTARY PUBLIC - STATE OF FLORIDA Commission Number: Dixe71 > cou My commission expires: Glue] aort i | Fi Comenf# DD07 15802 H Expires 9/18/2011 i Florida Notary Assn., hve ontetd oe EHROE RORDRARR ST TORDenaE /RRSEEROREDS EFTA00221225

--=PAGE_BREAK=--

Case 9:08-cv-80993-KAM Document52-2 Entered on FLSD Docket 05/07/2009 Page 5 of 5 Doe No.7 v. Epstein Page 15 Certificate of Service WE HEREBY CERTIFY that a true copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this ZG day of January, 2009. Robert D. Critton, Jr, Esq. Burman, Critton, Luttier & Coleman 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561/842-2820 Phone 561/515-3148 Fax rcrit@bciclaw.com Co-Counsel for Defendant Jeffrey Epstein Jack Alan Goldberger, Esq. Atterbury-Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 jagesq@bellsouth.net Co-Counsel for Defendant Jeffrey Epstein Michael R. Tein, Esq. Lewis Tein, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, FL 33133 305-442-1101 Fax: 305 442 6744 . Co-Counsel for Defendant Jeffrey Epstein tein@lewistein.com —— EFTA00221226