EFTA00725714.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80381-MARRA-JOHNSON JANE DOE NO. 5, Plaintiff, v. JEFFREY EPSTEIN, Defendant. PLAINTIFF JANE DOE NO. 5's SECOND SUPPLEMENTAL ANSWERS TO DEFENDANT'S FIRST INTERROGATORIES Plaintiff, JANE DOE NO. 5, 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 Obioctions 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. EFTA00725714 Doe No. 5 v. Epstein Page 2 3. Plaintiff objects to Defendants' Interrogatories to the extent that the Interrogatories seek to impose obligations beyond those imposed by applicable law and the applicable Rules of Civil Procedure. 4. The foregoing general objections are incorporated into each of the specific objections and responses that follow. The stating of a specific objection or response shall not be construed as a waiver of Plaintiffs general objections. Plaintiff reserves the right to supplement these responses and to make further objections. Plaintiffs responses shall neither waive nor prejudice any objections that Plaintiff may later assert. 5. Plaintiff reserves the right to supplement or amend its Responses and Objections to Defendant's Discovery as and if additional information becomes available. Subject to and without waiving any of the foregoing objections, which Plaintiff hereby incorporates into each Interrogatory set forth below, Plaintiff responds to Defendant's Interrogatories as follows: PLAINTIFF'S SECOND SUPPLEMENTAL ANSWERS TO DEFENDANT'S FIRST INTERROGATORIES 11. List the names and business addresses of each physician (including psychiatrist, psychologist, etc.) or medical provider (including chiropractors) who has treated or examined you, and each medical facility where you have received any treatment or examination for the injuries for which you seek damages in this case; and state as to each the date of treatment or examination and the injury or condition for which you were examined or treated. Answer: Plaintiff objects to this interrogatory as vague, overly broad, unduly burdensome, premature, and calling for an expert opinion. Subject to said objections, Plaintiff states: EFTA00725715 Doe No. 5 v. Epstein Page 3 William G. Wood Finney Psychotherapy 420 N. Center Dr., #141 Norfolk, VA 23502 2008-2009 Medication Management Rebecca Thomas Psy.D. & Associates 838 Granby St. Ste. 200 Norfolk, VA 23510 2008 Counseling 12. List the names and business addresses of all other physicians, medical facilities, rehab facilities (drug, alcohol or psychiatric) or other health care providers including psychiatrist, psychologist, mental health counselor and chiropractors by whom or at which you have been examined or treated in the past 10 years; and state as to each the dates of examination or treatment and the condition or injury for which you were examined or treated. Answer: Douglas Leonard Cassidy, ■. 1170 N. Military Hwy Norfolk, VA 23502 2007-2008 Eye doctor Bayview Medical Center 7924 Chesapeake Blvd. Norfolk, VA 23518 2007 General family practice March , 2010 Respectfully submitted: MERMELSTEIN & HOROWITZ P.A. 18205 Biscayne Blvd., Suite 2218 EFTA00725716 Doe No. 5 v. Epstein Page 4 Tel: 305-931-2200 Fax:,-305-931-0877 Florida Bar No. 947245 Adam D. Horowitz Florida Bar No. 376980 Jessica D. Arbour EFTA00725717 Doe No. 5 v. Epstein Page 5 Certificate of Service WE HEREBY CERTIFY that a true copy of tye foregoing has been sent via U.S. Mail and facsimile to the following addressees this day of March, 2010. Robert D. Critton, Jr, Esq. Burman, Critton, Luttier & Coleman 303 Banyan Blvd., Suite 400 West Palm Beach, FL 33401 Phone Fax Co-Counsel for Defendant Jeffrey Epstein Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, M. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Jeffrey Epstein EFTA00725718