EFTA00611582.pdf

Mermelstein & HorowitzPA attorneys at law April 13, 2010 Via Facsimile and US Mail Robert D. Critton, Jr. Jessica D. Arbour www.sexabuseattomey.com Re: Jane Doe 8 v. Jeffiey Epstein Dear Mr. Critton: In response to your letter of March 8, 2010, regar •dna discovery responses, our client can provide the following information: 1. Yes. In addition, she has done some odd jobs fo between 1999 and the present, and has been paid in cash. 2. She is unab t f her su rvisors on her 'obs. She recalls that her supervisor a was a m e, u s to as no u er m orma on 3. 4. 5. At this point, the Plaintiff does not have a full understanding of the total extent of her damages, and it will, of course, be subject to expert opinions. To date, the Plaintiff has suffered, and may continue to suffer, anger issues, trust issues (especially with men), chemical dependency that has required multiple attempts at treatment, diminished sense of sexual boundaries, promiscuity, low self-esteem, fear, pessimism about her future, and unhealthy romantic relationships. 6. Contrary to your letter, Interrogatory No. 25 was answered in full: Yes. EFTA00611582 do Spencer Kuvin, Esq. Plaintiff has known since approximatela PlaintiffJane Doe No. 8 disclosed toMMthat she had hired an attorney to represent her in a potential claim against Epstein and told Jane Doe No. 8 that she had a claim against Epstein as well. 7. tax release authorization is attached.. 8. At this point, the full extent of=Min economic an have not been determined and will, of course, be subject to ex rt o inion. lieves she has not paid any out-of-pocket expenses for However, an expert may opine that her lack of education and lack of steady employment relates to her sexual assault by Jeffrey Epstein. That is why the Plaintiff reserved the right to amend or supplement her Answers to Interrogatories as discovery proceeds. Contrary to your letter did not attach any molds to her Answers to Interrogatory Nos. 2 & 3. 9. The Rules of Civil Procedure require a plaintiff to produce materials which are in the care, custody, or control of a party. No further explanation is required. If you would like the Plaintiff to formally amend her discovery responses with this information, please advise. V trul ours, es. a . r our JDA/ Enclosure EFTA00611583 Form 4506 Rev. Jeworr20i0l Deparerent °Mohnen' htems.R.W611.0 Sante Tip. You may be able to get you, tax return or return Information from other sources. If you had your tax return completed by a paid paperer, they should be able to proWde you a oopor of the return. The IRS can provide a Tax Return Transcript for merry returns free of serge. The tranSsrlPt provides most of the line entries from the original tax return and usually contains the information that a third party (such as a mortgage company) re: wires. See Form 4506-T, Request for Transcript of Tex Return, or you can call 1400-829-1040 to order a transcript. Request for Copy of Tax Return at Requital may be rejected if the form Is incomplete or i0egible. Owe NO. 1545-0429 S If the tax return is to be maled to a third party (such as a mortgage company), enter the third party's nein*, address, and telephone number. The IRS has no control over what the third party does with the tax return. Caution. if the tax rearrn is being ina6ed to a lined pally, ensure that you have !Med in line 6 end ane 7 before signing. Sign and date the form once you neve Need in these Noes. Completing Mese steps helps to protect your bavicy. 8 Tax return requested. Form 1040, 1120, 941, We. and a0 attachments as origkoay submitted to the IRS, including Form(s) W-2. schedules, or amended returns. Copies of Forms 1040, 1046A, and 1040EZ are goner available for 7 years from filing before they are destroyed by law. Other returns may be available for a longer period of true. Enter only one return nun . If you need more than one type of return. you mull oornotete another Form 4508. ► Note. If the copies must be certified for court or administrathe proaterfings, check here 0 7 Year or period requested. Enter the ending crate or the year or period, using the reiriddiyyyy format. If you ere requesting more than eight years or period& you must attach another Form 4506. 8 Fee. There Is a 557 tee for each return requested. Full payment must be kickided with your request or it will be rejected. Make your check or money order payable to 'United States Treasury." Enter your 8814 or ON and "Form 4506 request" on your check or money order. a Cost for each return b Number of returns requested on lino 7 e Total cost. irluttlply line 8a One 86 $ 57.00 9 II we cannot find the tax return, we will refund the fee. If the refund should go to the third party listed on Me 5, chock here 0 Signature of taxpayer(s). I declare that I am either the taxpayer whose name Is shown on Me la or 2a, or a person arthcrIzed to obtain the tax return requested. It the request wake to a Joint return, either husband or wile must sign. tf signed by a corporate officer, partner, guardian, tax matt r tr tee Or other than the taxpayer, I eerily that I have the authority to execute For td party, this form must be received within 120 days of signature date. Sig He Tor hone number of taxpa on Spouse's sor.atute Date For Privacy Act and Paperwork Reduction Act Notic0. ace page 2. Cat. NO. 41721E Form 4506 etev.14010I EFTA00611584