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admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. Answer: Defendant is asserting specific legal objections to the interrogatori
ents that are attorney-client and work product privileged in that it seeks "all documents obtained in discovery or investigation relating either to the Florida Criminal Case or the Federal Criminal Case ... ." In addition, such documents are privileged and confidential as they are the subject of a pending investigation.
admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. Answer: Defendant is asserting specific legal objections to the interrogatori
ents that are attorney-client and work product privileged in that it seeks "all documents obtained in discovery or investigation relating either to the Florida Criminal Case or the Federal Criminal Case ... ." In addition, such documents are privileged and confidential as they are the subject of a pending investigation.
admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. Answer: Defendant is asserting specific legal objections to the interrogatori
ents that are attorney-client and work product privileged in that it seeks "all documents obtained in discovery or investigation relating either to the Florida Criminal Case or the Federal Criminal Case ... ." In addition, such documents are privileged and confidential as they are the subject of a pending investigation.
Entities connected to both the New Mexico Residence and the Florida Criminal Case

Jeffrey Epstein
PERSON
Alan Dershowitz
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Adam D. Horowitz
PERSONAtterbury Goldberger & Weiss
ORGANIZATIONJane Doe
PERSONHIPAA
ORGANIZATIONthe Palm Beach Residence
ORGANIZATION
Ghislaine Maxwell
PERSON
Jeffrey Marc Herman
PERSON
United States
LOCATION
Jean-Luc Brunel
PERSONthe State Court
ORGANIZATIONMichael J. Pike
PERSONU.S. Mail
ORGANIZATIONthe Health Insurance Portability
ORGANIZATIONStuart S. Mermelstein
PERSONthe St. Thomas Residence
ORGANIZATIONJANE DOE NO
PERSON