Case 9:08-cv-80232-KAM Document 51 Entered on FLSD Docket 03/02/2009 Page 1 of 16 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80232-MARRA JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND PRODUCTION OF DOCUMENTS, AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT Plaintiff, by and through undersigned counsel, files this Motion to Compel Answers to Interrogatories and Production of Documents, and Memorandum of Law in Support, pursuant to Fed.R.Civ.P. 26 and 37 and S.D.FIa.L.R. 26.1(H)(2), as follows: I. INTRODUCTION Plaintiff in this case propounded 17 interrogatories and 24 documents requests. In response, Defendant has produced no information and no documents. Defendant's principal objection concerns his Fifth Amendment privilege against self-incrimination. Defendant, however, fails to set forth a sufficient predicate in his responses to interrogatories or documents requests for his refusal to provide any responsive documents or information. Defendant, rather, repeats in each response an all-encompassing, blanket assertion of Fifth Amendment privilege. Defendant's responses also include a laundry list of objections to Plaintiff's interrogatories and documents requests, none of which serve as a basis for a denial of all discovery. For the reasons discussed below, Plaintiff requests an order compelling Defendant to answer interrogatories and -1- EFTA02739516