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PANISH SHEA & BOYLE LLP
1111 Santa Monica Boulevard, Suite 700 Los Angeles California 90025 310.477.1700 phone – 310.477.1699 fax
INTERROGATORY NO. 3:
Identify the existence, custodian and location of, and generally describe, all documents and communications concerning the subject matter of this litigation.
RESPONSE TO INTERROGATORY NO. 3:
Doe identifies the following, which includes, but is not limited to: Flight records from Decedent Jeffrey Epstein's private planes showing Jane Doe as a passenger; Phone records from Darren Indyke showing calls made by him to Jane Doe; and records of the following: cash payments to Doe, rent payments made for Doe's apartment car trips for Doe by Decedent's drivers (including Juan Alessi), plane tickets, plane trips (via Decedent's private jet), tickets to Broadway shows, tuition payments to the Professional Children's School, clothing (including underwear and bras), books, voice lessons with acting classes at Herbert Berkoff Studios and at The Acting Studio, payments for summer camp on behalf of Plaintiff at Interlochen Arts Camp and Boston University Tanglewood Institute and Plaintiff's brother at Interlochen Arts Camp, set of Bobbi Brown makeup brushes, and several sessions with photographers.
Upon information and belief, Plaintiff also identifies photographs of her as a minor taken of her without her knowledge by Decedent Jeffrey Epstein that are currently in the custody and control of the federal government.
Discovery and investigation continues and Plaintiff reserves the right to supplement all discovery responses up to, and including the time of trial, as
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
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DOJ-OGR-00015260