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CASE NO.: 08-CV-80811-crv-
MARRA/JOHNSON
Plaintiff(s),
vs.
JEFFREY EPSTEIN and SARAH KELLEN,
Defendant(s).
COMES NOW the Plaintiff,_, by and through undersigned counsel, and hereby
files this Notice with the Court that 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 true copy of the foregoing has been famished by mail this
(Tr" day of February, 2009, to: See attac
list of counsel.
3505-046
Page I of 20
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005473
EFTA00157922
vs. Epstein, a at
Case No.: 08-CV-80811-CIV-MARRALIOHNSON
Plaintiff's Answers to Defendant's First Interrogatories
1.
What is the name and address of all persons answering or assisting in answering
these interrogatories, and, if applicable, the person's official position or
relationship with the party to whom the interrogatories are directed?
ANSWER
do her attorneys:
2.
List the names, business addresses, telephone and cell phone numbers, dates of
employment, immediate supervisor (name and address) and rates of pay
regarding all employers, including self-employment, for whom you have worked
in the past 10 years; this includes listing all sources of income you have received.
Answer this question by year, i.e. 1998-2009.
ANSWER
Objection. Irrelevant, immaterial and not reasonably calculated to lead to
discovery of admissible evidence.
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
3505-046
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005474
EFTA00157923
vs. Epstein, 'a al.
Case No.: 08-CV-80111I-C4V-MARRAMOINSON
Plaintiff's Answers to Defendant's First Interrogatories
3
3505-046
Page 3 of 20
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005475
EFTA00157924
as. Epstein, et at
Case No • 08-CV-8081I-CIV -MARRA/JOHNSON
Plaintiffs Answers to Defendant's First Interrogatories
4.
Have you ever been convicted of a crime, other than any juvenile adjudication,
which under the law under which you were convicted was punishable by death or
imprisonment in excess of 1 year, or that involved dishonesty or a false
statement regardless of the punishment? If so, state as to each conviction the
specific crime and the date and place of conviction.
ANSWER
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.
do her attorneys:
Subject matter:
Plaintiff.
2.
Jeffrey Epstein
do his attorneys:
Robert Critton, Esquire
Burman Critton Luther & Coleman LLP
4
3505-046
Page 4 of 20
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005476
EFTA00157925
vs. Epstein, a al.
Case No.: 08-CV-8081I-CIV-MARRAMOHNSON
Plaintiff's Answers to Defendant's First Interrogatories
Jack A. Goldberger, Esquire
Atterbury, Goldberger & Weiss, P.A.
Bruce E. Reinhart, Esquire
Bruce E. Reinhart, P.A.
Subject matter:
Defendant
3.
s mother
and her brother,
do =I's
attorneys:
Subject matter:
Ms
involvement with Epstein.
4.
(Address unknown)
Subject matter:
Defendant
5
3505-046
Page 5 of 20
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005477
EFTA00157926
vs. Epstein, et al.
Case No.: 08•CV-80811-CIV-MARRA/1OIINSON
Plaintiffs Answers to Defendant's First Interrogatories
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)
do her attorney:
Isidro M. Garcia, Esquire
The Law Office of Brad Edwards & Associates, LLC
Subject matter:
Victim of Epstein.
7.
Jane Doe. (Case No.: 9:08-cv-80119-KAM)
do her attorney:
Jeffrey M. Herman, Esquire
Herman & Mermelstein, P.A.
Subject matter:
Victim of Epstein.
8.
Jane Doe M(Case No.: 9:08-cv-80232-KAM)
do her attorney:
Jeffrey M. Herman, Esquire
Herman & Mermeistein, P.A.
6
3505-046
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005478
EFTA00157927
vs. Epstein, et al.
Case No.: 08-CV-808I I-CIV-MARRA/JOHNSON
Plaintiff's Answers to Dcfendant's First Interrogatories
Subject matter:
Victim of Epstein.
9.
Jane Doe M(Case No.: 9:08-cv-80381-KAM)
do her attorney:
Jeffrey M. Herman, Esquire
Herman & Mermelsteln, P.A.
Subject matter:
Victim of Epstein.
10.
Jane Doe U (Case No.: 9:08-cv-80380-KAM)
do her attorney:
Jeffrey M. Herman, Esquire
Herman & Mermeistein, P.A.
Subject matter:
Victim of Epstein.
11.
Jane Doe (Case No.: 9:08-cv-80804-KAM)
do her attorney:
Theodore Leopold, Esquire
Leopold, Kuvin, P.A.
Subject matter:
Victim of Epstein.
12.
Jane Doe
(Case No.: 9:08-cv-80993-KAM)
c/o her attorney:
Jeffrey NI. Herman, Esquire
Herman & Mermeistein, P.A.
7
3505-046
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005479
EFTA00157928
vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/1O1INSON
Plaintiff's Answers to Defendant's First Interrogatories
Subject matter: Victim of Epstein.
13.
(Case No.: 502008CA025129)OOO(MB Al
do her attorneys:
Jack Scarola, Esquire
Jack P. Hill, Esquire
Seamy 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
Subject matter:
Investigator.
16.
Lanaa Belohavek
Palm Beach County Prosecutors Office
Subject matter:
Prosecutor.
17.
DetectiveM, lead investigator
8
3505-046
Page 8 of 20
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005480
EFTA00157929
vs. Epstein, a al.
Case Na: 08-CV-808 IL-DIV-MARRA/JOHNSON
Plaintiff's Answers to Defendant's First Inteivogatorics
Palm Beach Police Department
345 South County Road
Palm Beach, FL 33480
Subject matter:
Investigator.
18.
Subject matter:
Former boyfriend of a victim of Epstein.
19.
Sgt.
Palm Beach Police Department
345 South County Road
Palm Beach, FL 33480
20.
21.
Subject matter:
Investigator.
Subject matter:
Plaintiff's former boyfriend.
Subject matter:
The incident which is the subject matter
of this lawsuit. Discovery is ongoing.
22.
Major -
Palm Beach County Sheriff's Office
9
3505-046
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005481
EFTA00157930
vs. Epstein. et al.
Case No.: Cl8-CV-80811-CIV-MARPA/JOHNSON
Plaintiffs Answers to Defendant's First Interrogatories
Subject matter:
Investigator.
23.
friend of
(Address will be provided upon receipt)
Subject matter:
Victim and friend of=
24.
Ghislane Maxwell do Ghislane Corp.
3580 Brillo Way
Palm Beach, FL 33480
Subject matter:
Associate of Epstein.
25.
26.
Detective
Palm Beach Police Department
Subject matter:
Investigator.
27.
Chief
Palm Beach Police Department
28.
Subject matter:
Investigator.
(Address unknown at this time)
Subject matter:
Associate of Epstein who facilitated introductions
with various victims.
10
3505-046
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005482
EFTA00157931
jjjjjjjjj,vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
Plaintiffs Answers to Defendant's First interrogatories
29.
Alfredo Rodriguez
(Address unknown at this time)
Subject matter:
Employee of Epstein.
30.
Detective
Palm Beach Police Department
Subject matter:
Investigator
31.
S
Esquire
First Assistant U.S. Attorney
U.S. Dept. of Justice
Subject matter:
Federal prosecutor.
32.
M.S.W.
Federal Bureau of Investigation
Subject matter:
Investigator.
33.
34.
Assistant U.S. Attorney
U.S. Dept. of Justice
II
3505-046
Page II of 20
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005483
EFTA00157932
vs. Epstein, et al.
Case No.: 08-CV-80731I-CIV-MAR.RAIJOHNSON
Plaintiff's Answers to Defendant's First Interrogatories
Subject matter:
Federal prosecutor.
35.
friend of M's
mother
(Address will be provided upon receipt)
Subject matter:
Friend of Ms
mother.
36.
a
friend of=.'s
mother
(Address will be provided upon receipt)
Subject matter:
Friend of Ms
mother
37.
, friend of
(Address will be provided upon receipt)
Subject matter:
Potential victim and friend of
38.
(Address unknown at this time)
Subject matter:
Associate of Epstein who may have been involved
in encounters between Epstein and
6.
Please state the specific nature and substance of the knowledge that you believe
the person(s) identified in your response to interrogatory no. 5 may have.
ANSWER
Please see answer to Interrogatory #6
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
12
3505-046
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005484
EFTA00157933
vs. Epstein, et al.
Case uo. 08-CV-80811-CIV-MARRA/JOHNSON
Plaintiffs Answers to Defendant's First Interrogatories
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.
9.
Describe each injury (physical, emotional, mental) for which you are claiming
damages in this case, specifying the part of your body that was injured, the
nature of the injury and as to any injuries you contend are permanent, the effects
on you that you claim are permanent.
ANSWER
10.
Please state each item of damage that you claim, and include in your answer: the
count to which the item of damages relates; the factual basis for each item of
damages; and an explanation of how you computed each item of damages,
including any mathematical formula used.
ANSWER
I am claiming compensation for mental anguish, mental pain, psychic
trauma, and loss of enjoyment of life. These damages will be evaluated by
a jury who will provide their own methods of computation in an amount of
at least the statutory minimum established by 18 U.S.C.A. § 2265.
Discovery is ongoing.
11.
List the names and business addresses of each physician (including psychiatrist,
psychologist, chiropractor or medical provider) who has treated or examined you,
13
3505-046
Page 13 of 20
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005485
EFTA00157934
vs. Epstein, et al.
Case No.: Oft-CV-8081 I-CIV-MARRABOHNSON
Plaintiff's Answers to Defendant's First Interrogatories
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.
12.
List the names and business addresses of all other physicians, medical facilities,
rehab facilities (drug, alcohol or psychiatric) or other health care providers
including psychiatrist, psychologist, mental health counselor and chiropractors by
whom or at which you have been examined or treated in the past 10 years; and
state as to each the dates of examination or treatment and the condition or injury
for which you were examined or treated.
ANSWER
14
3505-046
Page 14 of 20
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005486
EFTA00157935
vs. Epstein, et al.
Case No.: 08-CV-8081I-CIV-MARRAJJOHNSON
Plaintiff's Answen to Defendant's First Interrogatories
13.
State the name and address of every person known to you, your agents, or your
attorneys, who has knowledge about, or possession, custody, or control of, any
model, plat, map, drawing, motion picture, video tape, or photograph pertaining
to any fact or issue involved in this controversy; and describe as to each, what
item such person has, the name and address of the person who took or prepared
it, and the date it was taken or prepared.
ANSWER
The FBI has photos taken of me at Jeffrey Epstein's ho
Jeffrey Epstein had a photo taken of me at his home by
14.
Please state if you (or parents or guardian on your behalf) have ever been a
party, either plaintiff or defendant, in a lawsuit other than the present matter, and,
if so, state whether you were plaintiff or defendant, the nature of the action, and
the date and court in which such suit was filed.
ANSWER
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
15
3505-046
Page 15 of 20
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005487
EFTA00157936
vs. Epstein, ct al.
Case No.: 08-CV-80811-CP/ -MARRA/JOHNSON
Plaintiffs Answers to Defendant's First Interrogatories
From May or June of
to August o
I went to Mr. Epstein's home
on average 2 times alit
There were wee s when I would go 4 times a
week. All my visit dates wore maintained by Jeffrey Epstein and his staff in
a phone message book kept on a table by the phone in the kitchen.
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
in 2002. I was to
iii
give Jeffre E stein a massage. I continued to provide massages up until
August of
I was transported to Jeffrey Epstein's house by Yellow
Cab, proof e
Jeffre E stein, MM,
mtoyfriend
my mother
and my brother
(A
ress will be provided upon receipt)
17.
State the amount of monies (or anything else of value, including gifts) you claim
were given or paid to you by Mr. Epstein (or someone paid/gave you on his
behalf and that person's name, address and phone number) by year from 2000-
2006.
ANSWER
$2004300 for a massage session at an average of 2 sessions a week from
May or June of 2002 to Au ust 2003.
$500 for a photo taken by
at Jeffrey Epstein's house
Paid for taxi cabs
Concert tickets-Incubus, delivered by two girls at the concert
Clothes and lingerie sent by FedEx
Book-Massage for Dummies
CD
Flowers
Express gift card
16
3505-046
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005488
EFTA00157937
vs. Epstein, et at.
Case No.: 08-CV-80811-CIV-MARRAD0HNS0N
Plaintiffs Answers to Defendant's First Interrogatories
18.
List separately the names, addresses and phone numbers of all males, excluding
Mr. Epstein, with whom you have had sexual activity since age 10 (by year) up
through your current age. Describe the nature of sexual activity, the date(s) and
whether you received money or other consideration from the person.
ANSWER
Objection. Relevance and overbroad.
19.
List separately the names, addresses and phone numbers of all males, excluding
your claims against Mr. Epstein, whom you have claimed (formally or informally)
committed sexual assault or battery on you since age 10 (by year) up through
your current age. Describe the nature of sexual assault or battery, the date(s)
and whether you received money or other consideration from the person.
ANSWER
20.
State the names, addresses and phone numbers of all males, excluding your
claims against Mr. Epstein, whom you have claimed (formally or informally)
committed lewd or lascivious conduct to you since age 10 (by year) up through
your current age. Describe the lewd or lascivious conduct, the date and whether
you received money or other consideration from the person.
ANSWER
21.
State the names, addresses and phone numbers of all males, excluding your
claims against Mr. Epstein, whom you have claimed (formally or informally)
committed lewd or lascivious exhibition to you since age 10 (by year) up through
your current age. Describe the lewd or lascivious exhibition, the date and
whether you received money or other consideration from the person
ANSWER
22.
List in detail all discussions/interviews which you had with any representative
17
3505-046
Page 17 of 20
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005489
EFTA00157938
vs. Epstein, a al.
Case No.: 08-CV-808I I-CIV-MARRADOHNSON
Plaintiffs Answers to Defendant's First Interrogatories
from FBI, U.S. Attorneys' Office, State Attorneys' Office (Palm Beach County),
Palm Beach Sheriff's Office and Palm Beach Police Department regarding your
meetings with Mr. Epstein. Include dates, who was present, the details of what
was discussed, whether a court reporter was present and whether a taped
statement was taken or whether you provided a written statement.
ANSWER
I was interviewed by the FBI and a State Attorney, they have my statement
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
24.
Please list each time you were interviewed by any state or federal law
enforcement agent or prosecutor, who was present, whether notes were taken,
and what you recall saying to them.
ANSWER
I do not recall who interviewed me. This information would be available in
the FBI and Prosecutors office. They took notes and I was not provided
with a copy of those notes.
25.
Please describe any statements made to you by any federal or state law
enforcement agent or prosecutor regarding the availability of civil remedies
against Mr. Epstein and regarding whether there would be any benefit from your
voluntary cooperation with law enforcement.
ANSWER
None
18
3505-046
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005490
EFTA00157939
vs. Epstein, et al.
Case No.: 08-CV-8081 I -CIV-MARRAIJ0HNS0N
Plaintiffs Answers to Defendant's First Intarogatories
oiwzatur c an russwcs it% r at L.),
STATE OF
Florida
COUNTY OF Palm Beach
)
by
The foregoing instrument was acknowledged before me this 17 day of February, 2009
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:
19
3505-046
Page 19 of 20
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005491
EFTA00157940
vs. Epstein, et aL
Case No.: 08-CV-80811-CIV-MARRAflOHNSON
Plaintiff's Answers to Defendant's First Interrogatories
COUNSEL LIST
Jack A. Goldberger
Atterburv. Goldberger & Weiss. P.A.
Attorneys for Jcffiey Epstein
Bruce E. Reinhart, Esquire
Bruce E. Reinhart, PA.
r. 41'
Robert Critton
V.!• t -
Burman Critton Luther & Coleman LLP
Attorneys for Jeffrey Epstein
ttomeys for Party
20
3505-046
Page 20 of 20
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00005492
EFTA00157941