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additional facts are ascertained, analyses are made, research is completed and contentions are made.
INTERROGATORY NO. 4:
Identify each employee of, agent of, or other individual associated with Decedent with whom you communicated or interacted; and identify the date of, and describe the nature of, each such communication or interaction.
RESPONSE TO INTERROGATORY NO. 4:
Ghislaine Maxwell - Jane Doe interacted with Maxwell repeatedly between 1994 and 1998. During that time, Maxwell facilitated Decedent's sexual abuse of Doe and was frequently present when Decedent's sexual abuse of Doe occurred.
Juan Alessi - drove minor Jane Doe from her home in West Palm Beach, Florida to Decedent's home in Palm Beach, Florida multiple times between 1994 and 1996.
Darren Indyke - called Jane Doe in 1998/9 threatening that Jane Doe owed Decedent $10,000 for rent Decedent paid on the apartment Jane Doe lived in at prior to her moving to Los Angeles, CA.
Adam Perry Lang - Jane Doe travelled with Adam Perry Lang and Decedent on at least one occasion between 1994 and 1998.
Lesley Groff - Doe interacted with Groff multiple times in New York. Groff facilitated meetings between Doe and Decedent. Groff also bought gifts for Doe on behalf of Decedent, including a set of makeup brushes.
Mark Epstein - Mark Epstein, Decedent's younger brother, was present with Decedent and Doe on multiple occasions between 1994 and 1999.
Sarah Kellen - Doe interacted with Kellen multiple times in New York between 1994 and 1999. Kellen facilitated meetings between Doe and Decedent. Plaintiff also believes she communicated with Kelly Bovino Umekubo and
DOJ REDACTION concerning Decedent Epstein.
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