EFTA00310340.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 17 Civ 616 (JGK) DEFENDANT INITIAL RULE 26(a)(1)(A) DISCLOSURE STATEMENT Defendant by and through her attorneys, Steptoe & Johnson LLP, hereby submits her Initial Disclosures pursuant to Rule 26(aXI)(A) of the Federal Rules of Civil Procedure based upon information currently known or available. PRELIMINARY STATEMENT =joys the protections of the self-incrimination clause of the Fifth Amendment to the United States Constitution (the "Fifth Amendment"). It is press intent in this Disclosure Statement to claim the fullest possible protection of the United States Constitution. f oes not intend by any of her disclosures to waive such protection and requests that, in cases of any doubt or ambiguity, her disclosures be construed as an assertion rather than a waiver of such privilege. . also reserves her right to amend her disclosures without compromising her rights under the Fifth Amendment. In addition, the production of any documents referred to in this Disclosure Statement shall not be construed to waive: (i) the attorney-client privilege and/or the work-product doctrine, either generally or as they may attach to particular documents; or (ii) the admissibility of the Doc ft DC-12118509 v.1 EFTA00310340 documents in this case. This Disclosure Statement shall not in any way constitute a waiver of defenses. Meserves her right to supplement and amend these Initial Disclosures as discovery proceeds and additional information becomes known or discoverable without compromising any of the aforementioned rights, privileges, protections, or the admissibility of any documents. Disclosures I. Rule 26(a)(1)(A)(i) Disclosures II. ss erts her right under the Fifth Amendment to decline to make this disclosure. Rule 26(a)(1)(A)(ii) Disclosures = asserts her right under the Fifth Amendment to decline to make this disclosure. III. Rule 26(a)(1)(A)(iii) Disclosures oes not currently claim any damages in connection with this action. IV. Rule 26(a)(1)(A)(iv) Disclosures Subject to and without compromising any of the above-referenced rights, privileges, protections, and/or the admissibility of any documents has is no insurance agreements under which an insurance business may be liable to satisfy all of part of a possible judgment or to indemnify or to reimburse for payments made to satisfy the judgment. -2- Doc ft DC-12118509 v.1 EFTA00310341 Dated: August 2018 New York, New York STEPTOE & JOHNSON LLP By: Is/ Michael C. Miller Michael C. Miller Justin Y.K. Chu Attorn s or De endants Je re E stein, -3- Doc ft DC-12118509 v.1 EFTA00310342  CERTIFICATE OF SERVICE I hereby certify that, on , 2018, I served the foregoing document via e-mail on the counsel of record for all parties appearing in this matter. /s/ Justin Y.K. Chu -4- Doc ft DC-12118509 v.1 EFTA00310343