EFTA00023624

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV Plaintiff, VS. JEFFREY EPSTEIN and Defendants. PLAINTIFF'S NOTICE OF SERVING SECOND AMENDED ANSWERS TO INTERROGATORIES COMES NOW the Plaintiff, M . , 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 copy of thp regoing has been furnished by e- mail this eleof October, 2009, list of counsel. JACK SC ROLA Florida Bar No.: 169440 JACK P. HILL Florida Bar No.: 0547808 Attorney for Plaintiff(s) Shipley, P.A. EFTA00023624 vs. Epstein, et al. 08-CV-80811-CIV Plaintiffs Second Amended Answers t)LITnt'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 fathers name and address. List the names and address of your parents and any brother or sister. ANSWER Nickname- West Palm Beach, FL. 33417 West Palm Beach, FL. Rome, Georgia West Palm Beach, FL. 33409 West Palm Beach, FL. 33409 Lake Park, FL SSN I have never been married. Children: Father: Address: Dates: July, 2007-Present Dates: February, 2004- July, 2007 Dates: August, 2003-February, 2004 Dates: About 21/2 years ago Dates: Approximately 1 year Dates: Unknown West Palm Beach, FL. 33407 2 EFTA00023625 . vs. Epstein, et al. Case No.: 08-CV-80811-CIV Plaintiffs Second Amended Answers to Defendant's First Interrogatories Father: Address: West Palm Beach, FL. Parents: Address Unknown West Palm Beach, FL. 33417 Siblings: West Palm Beach, FL. 33417 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. Searcy Denney Scarola Barnhart & Shipley, P.A. West Pal Beach FL 33409 Tel: Richard Willits, Esq. Richard H. Willits PA. Lake lila. Tel: Subject matter: Plaintiff. 3 EFTA00023626 vs. Epstein, et al. ase 08-CV-80811-CIV Plaintiffs Second Amended Answers IMI ant's First Interrogatories 2. Jeffrey Epstein do his attorneys: Robed Critton, Esquire Iton Lu ler & Coleman LLP est P Tel: Jack A. Goldberger, Esquire Atterbu Goldbe er & Weiss, P.A. West Palm Beach FL 33401 Tel: Bruce E. Reinhart, Esquire Bruce E. Reinhart, P.A. West Palm Bea h L 33401 Tel: Subject matter: Defendant 3. mo her and her brother, do 's attorneys: Jack Scarola, Esq. and Jack P. Hill, Esq. carola Barnhart & Shipley, P.A. West Palm Beac F 33409 Tel: Richard Willits, Esq. Ri hard . Willits P.A. Lake V ort Tel: Subject matter: a involvement with Epstein. 4 EFTA00023627 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIMMIMI 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) c/o her attorney: Theodore Leopold, Esquire eo old u i FL 33410 Te Subject matter: Victim of Epstein. 6. Jane Doe (Case No.: 502008CA020614) do her attorney: IN• Isidro M. Garcia, Esquire T eL w s & Associates, LLC Subject matter: Victim of Epstein. 7. Jane Doo #2 (Caso No.: 9:08-cv-80119-KAM) c/o hor attorney: Jeffrey M. Herman, Esquire Her Mermel Subject matter: Victim of Epstein. 8. Jane Doe #3 (Case No.: 9:08-cv-80232-KAM) c/o her attorney: EFTA00023628 Subject matter: Victim of Epstein. vs. Epstein, et al. Case No.: OB-CV-80811-CIV Plaintiffs Second Amended Answers en ant's First Interrogatories Jeffrey M. Herman, Esquire 1111111e l Subject matter: Victim of Epstein. 9. Jane Doe #5 (Case No.: 9:08-cv-80381-KAM) c/o her attorney: Jeffrey M. Herman, Esquire elstein. PA. 10. Jane Doe #4 (Case No.: 9:08-cv-80380-KAM) c/o her attorney: Jeffrey M. Herman, Esquire c an & Mermelstein P.A. Subject matter: Victim of Epstein. 11. Jane Doe (Case No.: 9:08-cv-80804-KAM) c/o her attorney: Theodore Leopold, Esquire d. Kuvin. P.A Subject matter: Victim of Epstein. EFTA00023629 M. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MAN RA OlINSON Plaintiff's Second Amended Answers to Defendant's First Interrogatories 12. Jane Doe #7 (Case No.: 9:013-cv-80993-KAM) c/o her attorney: Subject matter: Victim of Epstein. 13. (Case No.: 502008CA025129XXXXMB Al clo her attorneys: Jack Scarola, Esquire Jack P. Hill, Esquire Sears Denne carola Barnhart & Shipley, P.A. Tel: Subject matter: Victim of Epstein. 14. (Address unknown at this time) Subject matter: Jeffrey 15. Pal Be Police Department Subject matter: Investigator. EFTA00023630 flIM vs. Epstein, et al. Case No.: 08-CV-80811-CIV Plaintiffs Second Amended Answers to Defendants First Interrogatories 16. Palm Beach Count Prosecutors Office West a m eac , Tel: (561) 355-7100 Subject matter: Prosecutor. 17. Detective 18. lead investigator rtment Subject matter. Investigator. Subject matter: 19. Sgt. 20. Former boyfriend of a victim of Epstein. rtment Subject matter: Investigator. Subject matter: Plaintiffs former boyfriend. 21. Tony Higgins, supervisor e Town of Palm Beach EFTA00023631 vs. Epstein, et al. se o.:08-CV-80811-CIV Plaintiff's Second Amended Answe a RciNnts First Interrogatories Tel: ( M Subject matter: The incident which is the subject matter of this lawsuit Discovery is ongoing. 22. Palm Beach Coun Sheriffs Office Subject matter Investigator. 23. friend of (Address will be provided upon receipt) Subject matter. Victim and friend of =. 24. Ghislane Maxwell do Ghislane Corp. 25. Subject matter. Associate of Epstein. aren i enter Subject matter: Counselor at Parent Child Center. 26. Detective Palm Bea h oil e Department Subject matter: Investigator. 27. Chief Palm Beach Police De artment EFTA00023632 S vs. Epstein, et al. ao.: 08-CV-80811-CIV-MARRANOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories Tel: Subject matter: Investigator. 28. (Address unknown at this time) Subject matter: Associate of Epstein who facilitated introductions with various victims. 29. (Address unknown at this time) Subject matter: Employee of Epstein. 30. Detective rtrnent Subject matter: Investigator 31. 32. First Assistant U.S. Attorney U.S. Tel: Subject matter: Federal prosecutor. Subject matter: investigator. 10 EFTA00023633 vs. Epstein, et al. ase o.. 08-CV-80811-CIV Plaintiffs Second Amended Answers o e en ant's First Interrogatories 33. Address will be provided upon receipt West Palm Beach Subject matter: =.'s physician. 34. Assistant U.S. Attorney U.S. De t. of Justice Tel: Subject matter: Federal prosecutor. 35. friend of mother (Address will be provided upon receipt) Subject matter: Friend of mother. 36. friend of lip's mother prowe u (Address will be prow receipt) Subject matter: Friend of es mother 37. , friend of (Address will be provi ed upon receipt) Subject matter: Potential victim and friend of 38. A ress un nown at this time) Subject matter: Associate of Epstein who may have been involved in encounters between Epstein and Ill Ic 39. , friend of ress unknown at t is ime) 11 EFTA00023634 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Second Amended Answers to Defendants First Interrogatories 40. IMI(last name unknown), friend of MI (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 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 EFTA00023635 goo vs. Epstein, et al. Case No.: OS-CV-80811-CW Plaintiffs Second Amended Answers to Defendant's First Interrogatories Date: Since high school. Ongoing. 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 I was introduced to Jeffrey Epstein by my friend...lin 2002. I was to give Jeffrey Epstein a massage. I continued to provide massages up until August of 2003. I was transported to Jeffrey Epstein's h. Cab, providet my ex- b mother an my my brother transported via private car provided by Jeffrey Epstein. (Address will be provided upon receipt) 13 I was also EFTA00023636 vs. Epstein. et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs 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 A e: 22 I was pa 0 . last name unknown) (Address unknown) I was paid $100.00 (Address unknown) I was paid $100.00 14 EFTA00023637 vs. Epstein, et al. Case No.: e 08-CV-80811-CIV-Mill Plaintiffs Second Amended Answers ant'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 EFTA00023638 vs. Epstein, et al. ase No.: 08-CV-80811-CIV Plaintiffs Second Amended Answers to Defendant's First Interrogatories COUNSEL LIST Jack A. Goldberger Atterb G eiss, P.A. Phone: Attorneys for Jeffrey Epstein Bruce E. Reinhart, Esquire Bruce Robert Critton Burman Critto er & Coleman LLP Pho Fax: Attorneys for Jeffrey Epstein Richard H. Willits Es uire Richard H. Willits. P.A Phone: Fax: Attorneys for Party 16 EFTA00023639 VERIFICATION being duly sworn, deposes and says that the foregoing answers to interrogatories are true and correct to the best of her knowledge, information and belief. STATE OF FLORIDA ) ss COUNTY OF PALM BEACH ) SWORN TO AND SUBSCRIBED before me this 6 day of Oc- to I Q 4 , 2009 by who is identification e or has produced the following Notary- Print Name (SEAL) Notary - Signature EFTA00023640