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DEFENDANT'S EXHIBIT J-15-R S2 20 Cr. 330 (AJN) UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defendants. Case No. 1:20-cv-00484-JKG PLAINTIFF'S RESPONSE TO FIRST SET OF INTERROGATORIES PROPOUNDED BY DEFENDANTS DARREN K. INDYKE AND RICHARD D. KAHN, CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN PROPOUNDING PARTY: Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein RESPONDING PARTY: Plaintiff Jane Doe SET NO.: One Pursuant to Rule 33 of the Federal Rules of Civil Procedure, Plaintiff Jane Doe ("Responding Party") hereby submits these objections and responses to the First Set of Interrogatories propounded by Defendants CO-EXECUTORS ("Propounding Parties"). PRELIMINARY STATEMENT Nothing in this response should be construed as an admission by Responding Party with respect to the admissibility or relevance of any fact, or of the truth or accuracy of any characterization or statement of any kind contained in Propounding Party's Interrogatories. Responding Party has not completed his investigation of the facts relating to this case, his discovery or his preparation for trial. All responses and objections contained herein are based only upon information that is presently available to and specifically known by Responding Party. It is anticipated that PLAINTIFF'S RESPONSE TO FIRST SET OF INTERROGATORIES PROPOUNDED BY DEFENDANTS DARREN K. INDYKE AND RICHARD D. KAHN, CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN 1 DOJ-OGR-00015259