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e No. 21. Epstein Page 16 Request No. 16. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Nada Marcinkova, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting
communications between Jeffrey Epstein and Nada Marcinkova, including, but not limited to, letters, notes,
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
orking sites, and e-mails. Request No. 16. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Nada Marcinkova, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 17. Any and all docume
communications between Jeffrey Epstein and Nada Marcinkova, including, but not limited to, letters, notes, t
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
No. 2 v. Epstein Page 16 Request No. 16. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Nada Marcinkova, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting
communications between Jeffrey Epstein and Nada Marcinkova, including, but not limited to, letters, notes,
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
communications between Jeffrey Epstein and Nada Marcinkova, including, but not limited to, letters, notes,
No. 2 v. Epstein Page 16 Request No. 16. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Nada Marcinkova, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting
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 Nadia Marcinkova and the Palm Beach Residence

Jeffrey Epstein
PERSON
Sarah Kellen
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONJane Doe
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSONthe Southern District
LOCATION
Jean-Luc Brunel
PERSON
Palm Beach
LOCATIONFBI
ORGANIZATION
Jay Lefkowitz
PERSON
New York
LOCATION
Scarlett Johansson
PERSONHaley Robson
PERSON
Woody Allen
PERSON
the United States District Court
ORGANIZATION
Michael Jackson
PERSONSouthern District
LOCATION