Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 81 Entered on FLSD Docket 04)20:2009 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80I I 9-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. REPLY MEMORANDUM IN SUPPORT OF MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND PRODUCTION OF DOCUMENTS Plaintiff, by and through undersigned counsel, files this Reply Memorandum in Support of Motion to Compel Answers to Interrogatories and Production of Documents, as follows: I. Introduction Defendant relies upon generalization s regarding the nature of the case and the allegations in the pleadings in justifying his assertion of the Fifth Amendment privilege in response to each and every interrogatory and document request propounded by Plaintiffs. This blanket assertion of the privilege is insufficient to deny Plaintiffs all discovery in these cases. Defendant otherwise fails to set forth any basis for denying Plaintiffs any and al