EFTA02728383

CLAIM ID: 26H9-2VPP UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARFtA/JOHNSON Plaintiff, VS. JEFFREY EPSTEIN and Defendants. PLAINTIFF'S NOTICE OF SERVING SECOND AMENDED ANSWERS TO INTERROGATORIES COMES NOW the Plaintiff, ., by and through undersigned counsel, and hereby files this Notice with the Court that Second Amended Answers to Interrogatories propounded by the Defendant, JEFFREY EPSTEIN, on January 16, 2009, have been furnished to the attorney for the Defendant. I HEREBY CERTIFY that a tru mail this copy of the foregoing has been furnished by e- ay of October, 2009, d list of counsel. JACK SC ROLA Florida Bar No.: 169440 JACK P. HILL Florida Bar No.: 0547808 B r i i Shipley, P.A. Phone: Fax: Attorney for Plaintiff(s) EFTA02728383 CLAIM ID: 26H9-2VPP vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories PLAINTIFF'S NOTICE OF SERVING SECOND AMENDED ANSWERS TO INTERROGATORIES 3. List all former names and when you were known by those names. State all addresses where you have lived for the past 10 years, the dates you lived at each address, your Social Security number, your date of birth, and, if you are or have ever been married, the name of your spouse or spouses. List any children by name, date of birth and the father's name and address. List the names and address of your parents and any brother or sister. ANSWER 2 EFTA02728384 CLAIM ID: 26H9-2VPP vs. Epstein, et al. Case No.: 08-CV-80611-CIV-MARRAMOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories 5. Please provide the name, address, telephone number, place of employment and job title of any person who has, claims to have or whom you believe may have knowledge or information pertaining to any fact alleged in the pleadings (as defined in Federal Rule of Civil Procedure 7(a) filed in this action, or any fact underlying the subject matter of this action). ANSWER 1. • c/o her attorneys: Jack Scarola, Esq. and Jack P. Hill, Esq. Searc Denne Scarola Barnhart & Shipley, P.A. Richard Willits, Esq. Richard H. Willits, P.A. Tel: Subject matter: Plaintiff. EFTA02728385 CLAIM ID: 26H9-2VPP . vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories 2. Jeffrey Epstein c/o his attorneys: Robert Griffon, Esquire Burman Griffon Luther & Coleman LLP Tel: Jack A. Goldberger, Esquire Atterbur Goldber. er & Weiss, P.A. Tel: Bruce E. Reinhart, Esquire Bruce E. Reinha P.A. Subject matter: Defendant 3. s mother and her brother, c/o MI's a orneys: Jack Scarola, Esq. and Jack P. Hill, Esq. Searc Denne Scarola Barnhart & Shi • ley, P.A. Tel: Richard Willits, Esq. Richard H. Willits, P.A. e: Subject matter: 's involvement with Epstein. 4 EFTA02728386 CLAIM ID: 26H9-2VPP vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories 4. (Address unknown) Subject matter: Defendant. 5. Jane Doe (Case No.: 1:93-cv-01109-KAM) do her attorney: Theodore Leopold, Esquire Leopold, Kuvin, P.A. Subject matter: Victim of Epstein. 6. Jane Doe (Case No.: 502008CA020614) c/o her attorney: Isidro M. Garcia, Esquire ffi of Brad Edwards & Associates, LLC Tel: Subject matter: Victim of Epstein. 7. Jane Doe #2 (Case No.: 9:08-cv-80119-KAM) do her attorney: Jeffrey M. Herman, Esquire rman & Mermelstein P.A. Tel: Subject matter: Victim of Epstein. 8. Jane Doe #3 (Case No.: 9:08-cv-80232-KAM) do her attorney: EFTA02728387 CLAIM ID: 26H9-2VPP . vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAIJOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories Jeffrey M. Herman, Esquire Tel Subject matter: Victim of Epstein. 9. Jane Doe #5 (Case No.: 9:08-cv-80381-KAM) c/o her attorney: Jeffrey M. Herman, Esquire Herman & Mermelstein, P.A. Tel: Subject matter: Victim of Epstein. 10. Jane Doe #4 (Case No.: 9:08-cv-80380-KAM) c/o her attorney: Jeffrey M. Herman, Esquire A Subject matter: Victim of Epstein. 11. Jane Doe (Case No.: 9:08-cv-80804-KAM) c/o her attorney: Theodore Leopold, Esquire Subject matter: Victim of Epstein. 6 EFTA02728388 CLAIM ID: 26H9-2VPP vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAMOHNSON Plaintiffs Second Amended Answers to Defendants First Interrogatories 12. Jane Doe #7 (Case No.: 9:08-cv-80993-KAM) c/o her attorney: Tel: Subject matter: Victim of Epstein. 13. A.C. (Case No.: 502008CA025129XXXXMB Al c/o her attorneys: Jack Scarola, Esquire Jack P. Hill, Esquire Searcy Denney Scarola Barnhart & Shipley, P.A. Subject matter: Victim of Epstein. 14. Jose Alessi (Address unknown at this time) Subject matter: Jeffrey Epstein's Butler. 15. Palm Beach Police Department Tel: Subject matter: Investigator. 7 EFTA02728389 CLAIM ID: 26H9-2VPP vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff's Second Amended Answers to Defendant's First Interrogatories 16. Par ...My Prosecutors Office 401 North Dixie Highway West Palm Beach. FL 33401 Tel: Subject matter: Prosecutor. 17. Detective lead investigator Palm Beac o Ice Department 345 South County Road Palm Beach FL 33480 Tel: Subject matter: Investigator. 18. Anthon Figueroa FL == Subject matter: Former boyfriend of a victim of Epstein. 19. Sgt. Palm Beach Police Department 345 South County Road Pal 80 Tel: 20. Subject matter: Investigator. Subject matter: Plaintiffs former boyfriend. 21. Tony Higgins, supervisor Sanitation Bureau of the Town of Palm Beach 3101 N.W. 16th Terrace Pompano Beach, FL 33064 8 EFTA02728390 CLAIM ID: 26H9-2VPP . vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAJJ0HNS0N Plaintiff's Second Amended Answers to Defendant's First Interrogatories Tel: Subject matter: The incident which is the subject matter of this lawsuit. Discovery is ongoing. 22. Major Palm eac ounty Sheriff's Office 3228 Gun Club Road West Palm Beach, FL 33406 Subject matter: Investigator. 23. , friend of (Address will be provided upon receipt) Subject matter: Victim and friend of 24. Ghislane Maxwell c/o Ghislane Corp. 3580 Brillo Way Palm Beach, FL 33480 Subject matter: Associate of Epstein. 25. Parent MC I Hil Center West Palm Beach, FL Subject matter: Counselor at Parent Child Center. 26. Detective Joseph Recarcy Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 Tel: (561) 838-5480 Subject matter: Investigator. 27. Chief Palm Beach Police Department 345 South County Road 9 EFTA02728391 CLAIM ID: 26H9-2VPP . vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRNJOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories Palm Beach, FL 33480 Tel: (561) 838-5480 Subject matter: Investigator. 28. (Address un nown at this time) Subject matter: Associate of Epstein who facilitated introductions with various victims. 29. ress unknown at this time) Subject matter: Employee of Epstein. 30. Palm Beach Police Department 345 South County Road B ach FL 33480 Subject matter: Investigator 31. Esquire First Assistant U.S. Attorney U.S. De t. of Justice Tel: Subject matter: Federal prosecutor. 32. , M.S.W. Federal Bureau of Investi ation Subject matter: Investigator. 10 EFTA02728392 CLAIM ID: 26H9-2VPP vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories 33. Address will be provided upon receipt West Palm Beach Subject matter: =.'s physician. 34. Assistant U.S. Attorney U.S. Dept. of Justice 500 South Australian Avenue Suite 400 FL 33401 Subject matter: Federal prosecutor. 35. friend of C.M.A's mother (Address will be provided upon receipt) Subject matter: Friend of C.M.A's mother. 36. , friend of mother (Address will be provided upon receipt) Subject matter: Friend of M.'s mother 37. , friend of (Address will be provided upon receipt) Subject matter: Potential victim and friend of C.M.A. 38. (Address unknown at this time) Subject matter: Associate of Epstein who may have been involved in encounters between Epstein and 39. friend of (Address unknown at this time) 1 1 EFTA02728393 CLAIM ID: 26H9-2VPP ase M vs. Epstein, et al. o.: 08-CV-80811-CIV-MARFtNJOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories 40. (last name unknown), friend of (Address unknown at this time) 7. Were you suffering from physical infirmity, disability, disease, sickness, or psychiatric/psychological condition at the time of the incident(s) described in the complaint? If so, what was the nature of the infirmity, disability, or sickness? ANSWER School behavioral problems, received counseling prior to the incident. 8. Did you consume any alcoholic beverages or take any drugs or medications within 12 hours before the time of each incident(s) described in the complaint? If so, state the type and amount of alcoholic beverages, drugs, or medication which were consumed, and when (dates) and where you consumed them. ANSWER 1. On one occasion I had taken "Morning Glory" and "Angel Trumpets". I do not recall the date. 2. On more than one occasion I used cocaine powder. I do not recall the dates. 3. On more than one occassion I used marijuana. I do not recall the dates. 11. List the names and business addresses of each physician (including psychiatrist, psychologist, chiropractor or medical provider) who has treated or examined you, and each medical facility where you have received any treatment or examination for the injuries for which you seek damages in this case; and state as to each the date of treatment or examination and the injury or condition for which you were examined or treated. ANSWER Date: I do not recall the date. I would defer to the Doctor's records. 12 EFTA02728394 CLAIM ID: 26H9-2VPP vs. Epstein, et at Case No.: 08-CV-50811-CIV-MARRAIJOHNSON Plaintiff's Second Amended Answers to Defendant's First Interrogatories Date: Since high school. Ongoing. C Date: I do not recall the dates, 15. List all dates you allege you were at Mr. Epstein's home in Florida, include date, time arrived and left, the name(s) of anyone who went with you to the home when you were there, the time spent with Mr. Epstein and the name(s) and address of any individuals who were present in the home with Mr. Epstein and you. ANSWER From May or June of 2002 to August of 2003 I went to Mr. Epstein's home on average 2 times a week. There were weeks when I would go 4 times a week. All my visit dates were maintained by Jeffrey Epstein and his staff in a phone message book kept on a table by the phone in the kitchen. Please refer to #5 above and #16 below. Discovery is ongoing. 16. State in detail how you came to be at Mr. Epstein's home on each occasion, i.e. did someone bring you or ask you if you would or wanted to go; if so, state the name and address of that individual and what he/she told you and the purpose of your visit. ANSWER (Address will be provided upon receipt) 1 3 EFTA02728395 CLAIM ID: 26H9-2VPP vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRNJOHNSON Plaintiff's Second Amended Answers to Defendant's First Interrogatories 23. State the names, addresses, ages, phone numbers and dates of all females whom you claim were brought by you to Mr. Epstein's home to give him a massage or for any other reason. As to each female, state the amount of money you claim you were paid to bring each female. ANSWER Age: 22 West Palm Beach, FL. I was paid $100.00 (last name unknown) (Address unknown) I was paid $100.00 (Address unknown) I was paid $100.00 14 EFTA02728396 CLAIM ID: 26H9-2VPP M. vs. Epstein, et al. Case No.: 08-CV-130811-CIV-MARRA/JOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories Signature of Answering Party STATE OF Florida COUNTY OF Palm Beach ) The foregoing instrument was acknowledged before me this day of February, 2009 by who is personally known to me or who has produced (type of identification) as identification and who did/did not take an oath. Notary Public State of Florida at Large My Commission expires: Commission No: 15 EFTA02728397 CLAIM ID: 26H9-2VPP vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARFtA/JOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories COUNSEL LIST Jack A. Goldberger Atterbury. Goldberger & Weiss, P.A. Attorneys for Jeffrey Epstein Bruce E. Reinhart, Esquire Bruce E. Reinhart P.A. Attorneys for Robert Critton Burman Critton Luttier & Coleman LLP Attorneys for Jeffrey Epstein Richard H. Willits Es uire orneys or a 16 EFTA02728398 CLAIM ID: 26H9-2VPP VERIEVATION MMIMEneing duly sworn, deposes and says that the foregoing answers to interrogatories are true and correct to the best of her imowled le information and belief. STATE OF FLORIDA ) ss COUNTY OF PALM BEACH SWORN TO AND SUBSCRIBED before me this 6 day of 0'- 10 4 , 2009 by who is r rsonally 1 own to 11 e or has produced the following identification eNi, iii,ocifi i zsPritst:c4 Florida y 1/4-0 Michael (SEAL) My Commission D0910400 Expires 10/0312013 /h, 4 e z 44 ^' ,-/A‘ Notary - Print Name Notary - Signature EFTA02728399