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Epstein’s Obstruction of Normal Discovery and Attacks on His Victims 53. | Once Edwards filed his civil complaints for his three clients, he began the normal process of discovery for cases such as these. He sent standard discovery requests to Epstein about his sexual abuse of the minor girls, including requests for admissions, request for protinetion, and interrogatories. See Edwards Affidavit, Exhibit “N”, at 11-19 and 25. Rather than answer any substantive questions about his sexual abuse and his conspiracy for procuring minor girls for him to abuse, Epstein invoked his 5th amendment right against self- incrimination. An example of Epstein’s refusal to answer is attached as Composite Exhibit “Z” (original discovery propounded to Epstein and his responses invoking Sth amendment). 54. During the discovery phase of the civil cases filed against Epstein, Epstein’s deposition was taken at least five times. During all of those depositions, Epstein refused to answer any substantive questions about his sexual abuse of minor girls. See, e.g., Deposition Attachments 1, 6 and 7. 55. During these depositions, Epstein further attempted to obstruct legitimate questioning by inserting a variety of irrelevant information about his case. As one of innumerable examples, on March 8, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 2-8, asked, "Q: In 2004, did you rub Jane Doe 3's vagina? A: Excuse me. I'd like to answer that question, as I would like to answer mostly every question you've asked me here today; however, upon advice of counsel, I cannot answer that question. They've advised me I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment Rights against self--excuse me, against--under the Constitution. And though your partner, Jeffrey Herman, was disbarred after filing this lawsuit [a statement that was untrue], Mr. Edwards! partner sits in jail for 21 HOUSE_OVERSIGHT_010586