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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
mation is privileged pursuant to Rule 501, Fed. Evid., and §90.503, Fla.Evid. Code. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). Interrogatory No. 9. List all items in Jeffrey Epstein's possession in Palm Beach, Florida, at any time during the period of these i
not identified in response to interrogatory no. 1 who at any time came to Defendant's Palm Beach Residence. No. 3. Identify all persons who came to the Palm Beach Residence and who gave a massage or were asked to give a massage to Defendant. No. 4. Identify all persons who came to the New York Residence and who gave a
mation is privileged pursuant to Rule 501, Fed. Evid., and §90.503, FIa.Evid. Code. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). Federal Rule of Evidence 401 provides that - "'Relevant evidence'" means evidence having any tendency to make the existence of any fa
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
mation is privileged pursuant to Rule 501, Fed. Evid., and §90.503, FIa.Evid. Code. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HI PAA). Interrogatory No. 9. List all items in Jeffrey Epstein's possession in Palm Beach, Florida, at any time during the period of these
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
mation is privileged pursuant to Rule 501, Fed. Evid., and §90.503, FIa.Evid. Code. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HI PAA). Interrogatory No. 9. List all items in Jeffrey Epstein's possession in Palm Beach, Florida, at any time during the period of these
Entities connected to both the Palm Beach Residence and the Health Insurance Portability and Accountability

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSONthe Southern District
LOCATIONHIPAA
ORGANIZATIONJane Doe
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
Adam D. Horowitz
PERSONJack Goldberger
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
Jean-Luc Brunel
PERSONthe New Mexico Residence
ORGANIZATIONthe St. Thomas Residence
ORGANIZATIONStuart S. Mermelstein
PERSON
Sarah Kellen
PERSONMichael J. Pike
PERSON
Jeffrey Marc Herman
PERSONthe Health Insurance Portability
ORGANIZATIONNadia Marcinkova
PERSON