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PANISH SHEA & BOYLE LLP 11111 Santa Monica Boulevard, Suite 700 Les Angeles, California 90025 * 310.477.1699 fax 310.477.1700 phone Co Oo moO TD DO NH eR WH HNO He — i | | Doe on behalf of Decedent by Lesley Groff, 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 additional facts are ascertained, analyses are made, research is completed and contentions are made. PANISH SHEA & BOYLE LLP By: ‘¢: — Robert S. Glassman Attorneys for Plaintiff DATED: June 3, 2020 16 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. 5 EPSTEIN DOJ-OGR-00015263