EFTA00724089.pdf

Mermelstein & HorowitzPA attorneys at law April 13, 2010 Via Facsimile and US Mail Robert D. Critton, Jr. Human, Critton, Luttier & Coleman Jessica D. Arbour Tel 18205 Biscayne Blvd. Suito 2218 Miami, Florida 33160 www.sexabusealtomey.com Re: Jane Doe 8 v. Jeffiey Epstein Dear Mr. Critton: In response to your letter of March 8, 2010, regarding discovery responses, our client can provide the following information: 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: EFTA00724089 t s point, extent o conomic damages, if any, have not been determined and will, of course, be subject to expert opinion. Ms. Morgan believes she has not 'd an out-of- ocket e • nses for to date. That is why the Plaintiff reserved the right to ame t her Answers to Interrogatories as discovery proceeds. Contrary to your letter did not attach any !words to her Answers to Interrogatory NUS. 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. JDA/ Enclosure EFTA00724090 Form 4506 Rev. Jewory 20101 Depererent el the Reeser, Interne RoVerille Se Tip. You may be able to get your tax return or return Information from other settees. If you had your tax return completed by a paid preparer, they should be able to provide you a copy of the return. The IRS can provide a Tax Return Transcript for many returns free of charge. The transcript proWdes most of the line entries from the original tax return and usually contains that a third party (such as a mortgage company) ramieres. See Form 4506-T, Request for Transcript of Tax Return, or you can call 1 to order a transcript. Request for Copy of Tax Return et Request may be rejected if the form Is incomplete or illegible. Omit no. 1545-0429 1 a blame shown on tax return. II a joint return, enter the name shown first. lb flit social security number on tax return or Instructions) tax return r i a . room, or suite no.), . state, and ZIP code • 4 Previous address s non the last return edIfferent from the 3 5 If the tax return is to be mailed to a third party (such as a mortgage company), enter the third party's name. 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 nahleci to a fled party, ensure that you have !Med in One 6 end ene 7 before signing. Sign and date the form once you nave Med in these Noes. Completing des* steps helps to protect yourbrivicy. 8 Tax return requested. Form 1040, 1120, 941, etc. and all attachments as origkWy submitted to the IRS, including Form(s) W-2. schedules, or amended returns. Copies of Forms 1040, 1049A, and 1040EZ are goner available for 7 years from filing before they are destroyed by law. Other returns may be available (Cr a longer period of tree. Enter only one return number. If you need more than one type of return you mull complete another Form 4508. w Note. If the copies must be certified for cowl or edministrathe proceedings, check here 0 7 Year or period requested. Enter the ending date el the year or period, using the rivridcloyyyy format. 11 you ere requesting more than eight years or periods, you must attach another Form 4506. 8 Fee. Thee is a 557 fee for each return requested. Full payment must be included with your request or it will be rejected. Make your chock or money order payable to 'United States Treasury." Enter your SSP or ON and "Form 4506 request" on your check or money order. a Cost tor each return t 57.00 0 Number of returns requested on lino 7 c Total cost. kititIpty Ilne 8a by !the 8b 9 If we me net and the tax return, we will refund the fee. If the refund should go to the third patty listed on Me 5, check here 0 Signature of taxpayer(s). I declare that I am ekher the taxpayer whose name Is shown on Me la or 2a, or a person aithcrIZed to obtain the tax return requested. If the request applies to a joint return, ether hoSband or wile must sign. If signed by a corporate officer, partner, guardian, tax matters panne. executor, receiver, administrator, trustee, or party other then the taxpayer, I certify that I have the authority to execute Form 45 this form must be received wither, 120 days of &posture data Sign Here &Pause's sor.ature Dale 2J 2-4/20 10111111 For Privacy Act and Paperwork Reduction Act Notice, see page 2. Cat. No. 41721E From 4506 olive. 1-20101 EFTA00724091