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t seeks information concerning persons, not parties to this litigation, whose privacy rights are implicated. Whatever public documents exist are in the State Court file and equally accessible to Plaintiff. Request No.4. All documents obtained in discovery or investigation relating to either the Florida Crimi
OBJECTIONS TO PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES Interrogatory No. 1. Identify all employees who performed work of services inside the Palm Beach Residence. Answer: Defendant is asserting specific legal objections to the interrogatories as well as his U.S. constitutional privileges. I intend to respon
t seeks information concerning persons, not parties to this litigation, whose privacy rights are implicated. Whatever public documents exist are in the State Court file and equally accessible to Plaintiff. Request No.4. All documents obtained in discovery or investigation relating to either the Florida Crimi
ts are implicated. Request No. 7. All surveillance videos, slides, film, videotape, digital recording or other audio or video depiction or image of the Palm Beach Residence. Response: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to pr
t seeks information concerning persons, not parties to this litigation, whose privacy rights are implicated. Whatever public documents exist are in the State Court file and equally accessible to Plaintiff. Request No.4. All documents obtained in discovery or investigation relating to either the Florida Crimi
OBJECTIONS TO PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES Interrogatory No. 1. Identify all employees who performed work of services inside the Palm Beach Residence. Answer: Defendant is asserting specific legal objections to the interrogatories as well as his U.S. constitutional privileges. I intend to respon
t seeks information concerning persons, not parties to this litigation, whose privacy rights are implicated. Whatever public documents exist are in the State Court file and equally accessible to Plaintiff. Request No.4. All documents obtained in discovery or investigation relating to either the Florida Crimi
OBJECTIONS TO PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES Interrogatory No. 1. Identify all employees who performed work of services inside the Palm Beach Residence. Answer: Defendant is asserting specific legal objections to the interrogatories as well as his U.S. constitutional privileges. I intend to respon
Entities connected to both the State Court and the Palm Beach Residence

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSONthe Southern District
LOCATION
Kenneth Marra
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Alan Dershowitz
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
the United States District Court
ORGANIZATION
Adam D. Horowitz
PERSONJANE DOE NO
PERSON
Sarah Kellen
PERSON
Jean-Luc Brunel
PERSON
Scarlett Johansson
PERSONHIPAA
ORGANIZATION
Jay Lefkowitz
PERSONStuart S. Mermelstein
PERSONU.S. Mail
ORGANIZATION
Jeffrey Marc Herman
PERSON