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Court filing · Oct. 2009

Plaintiff's second amended interrogatory answers in a 2009 civil suit against Epstein

A plaintiff's sworn second amended answers to interrogatories in a civil suit against Jeffrey Epstein, listing witnesses, victims' attorneys, and defense counsel.Machine-written summary

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

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 copy of thp regoing has been furnished by email this eleof October, 2009, list of counsel.

JACK SC ROLA Florida Bar No.: 169440 JACK P. HILL Florida Bar No.: 0547808 Shipley, P.A.

Attorney for Plaintiff(s)

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

    1. 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. 33417Dates: July, 2007-Present
West Palm Beach, FL.Dates: February, 2004- July, 2007
Rome, GeorgiaDates: August, 2003-February, 2004
West Palm Beach, FL. 33409Dates: About 21/2
years ago
West Palm Beach, FL. 33409Dates: Approximately 1 year
Lake Park, FLDates: Unknown
SSN
I have never been married.
Children:
Father:
Address:		West Palm Beach, FL. 33407

. vs. Epstein, et al. Case No.: 08-CV-80811-CIV Plaintiffs Second Amended Answers to Defendant’s First Interrogatories

    1. 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

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.

vs. Epstein, et al. Case No .: 08-CV-80811-CIV-Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories

    1. Jeffrey Epstein clo his attorneys: Robert Critton, Esquire Burman Critton Luttier & Coleman LLP

West Palm Beach, FL 33414 Tel:

Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A.

West Palm Beach, FL 33401 Tel:

Bruce E. Reinhart, Esquire Bruce E. Reinhart, P.A.

West Palm Beach, FL 33401 Tel:

Subject matter: Defendant

‘s mother, and her brother, clo ‘s attorneys:

Jack Scarola, Esq. and Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A.

West Palm Beach, FL 33409 Tel:

Richard Willits, Esq. Richard H. Willits, P.A.

Lake Worth, FL 33461 Tel:

Subject matter:

‘s involvement with Epstein.

C.M.A. vs. Epstein, et al.

Case No.: 08-CV-80811-CIMMIMI

Plaintiffs Second Amended Answers to Defendant’s First Interrogatories

    1. (Address unknown) IN• Te

Subject matter: Defendant.

    1. Jane Doe (Case No.: 1:93-cv-01109-KAM) c/o her attorney: Theodore Leopold, Esquire eo old u i FL 33410

Subject matter: Victim of Epstein.

    1. Jane Doe (Case No.: 502008CA020614) do her attorney: Isidro M. Garcia, Esquire T eL w s & Associates, LLC

Subject matter: Victim of Epstein.

    1. 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.

    1. Jane Doe #3 (Case No.: 9:08-cv-80232-KAM) c/o her attorney: vs. Epstein, et al. Case No.: OB-CV-80811-CIV Plaintiffs Second Amended Answers en ant’s First Interrogatories

Subject matter: Victim of Epstein.

    1. Jane Doe #5 (Case No.: 9:08-cv-80381-KAM) c/o her attorney: Jeffrey M. Herman, Esquire elstein. PA.

Subject matter: Victim of Epstein.

    1. 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.

    1. Jane Doe (Case No.: 9:08-cv-80804-KAM) c/o her attorney: Theodore Leopold, Esquire d. Kuvin. P.A

M. vs. Epstein, et al.

Case No.: 08-CV-80811-CIV-MAN RA OlINSON Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories

    1. Jane Doe #7 (Case No.: 9:013-cv-80993-KAM) c/o her attorney:

Subject matter: Victim of Epstein.

    1. (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.

  1. (Address unknown at this time)

Subject matter: Jeffrey

Pal Be Police Department

Subject matter: Investigator.

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
a m
West
eac ,
Tel: (561) 355-7100
Subject matter:
Prosecutor.
17.lead investigator
Detective
rtment
Subject matter.
Investigator.
18.
Former boyfriend of a victim of Epstein.
Subject matter:
19.Sgt.
rtment
Subject matter:
Investigator.
20.
Plaintiffs former boyfriend.
Subject matter:
Case No .: 08-CV-80811-CIV-vs. Epstein, et al.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.Palm Beach County Sheriff’s Office
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.
Subject matter:Associate of Epstein.
25.Parent Child Center
Subject matter:Counselor at Parent Child Center.
26.Detective
Palm Beach Police Department
Subject matter:Investigator.
27.Chief
Palm Beach Police Department

.

S vs. Epstein, et al. ao.: 08-CV-80811-CIV-MARRANOHNSON Plaintiffs Second Amended Answers to Defendant’s First Interrogatories

Tel:

Subject matter: Investigator.

(Address unknown at this time)

Subject matter: Associate of Epstein who facilitated introductions with various victims.

  1. (Address unknown at this time)

Subject matter: Employee of Epstein.

  1. Detective rtrnent

Subject matter: Investigator

  1. First Assistant U.S. Attorney U.S. Tel:

Subject matter: Federal prosecutor.

Subject matter: investigator.

vs. Epstein, et al.
Case No .: 08-CV-80811-CIV-
Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories
33.Address will be provided upon receipt
West Palm Beach
’s physician.
Subject matter:
34.Assistant U.S. Attorney
U.S. Dept. of Justice
Tel:
Subject matter:
Federal prosecutor.
35.friend of
mother
(Address will be provided upon receipt)
Subject matter:
Friend of
mother.
36.’s mother
friend of
(Address will be provided upon receipt)
‘s mother
Friend of
Subject matter:
37., friend of
(Address will be provided upon receipt)
Potential victim and friend of
Subject matter:
38.(Address unknown at this time)
Associate of Epstein who may have been involved
Subject matter:
in encounters between Epstein and
39., friend of
(Address unknown at this time)

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)

    1. 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

    1. 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.
    1. On more than one occasion I used cocaine powder. I do not recall the dates.
    1. On more than one occassion I used marijuana. I do not recall the dates.
    1. 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.

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,

  1. 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.

    1. 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 my mother an my brother transported via private car provided by Jeffrey Epstein. I was also

(Address will be provided upon receipt)

vs. Epstein. et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Second Amended Answers to Defendant’s First Interrogatories

    1. 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

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 thisday of
February, 2009 bywho 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:

vs. Epsteln, et al. Case No .: 08-CV-80811-CIV-Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories

COUNSEL LIST

Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A.

Phone: Attorneys for Jeffrey Epstein

Bruce E. Reinhart, Esquire Bruce E. Reinhart, P.A.

Phone: Fax:

Attorneys for

Robert Critton Burman Critton Luttier & Coleman LLP

Phone: Fax: Attorneys for Jeffrey Epstein

Richard H. Willits, Esguire

Richard H. Willits, P.A.

Phone:

Fax: Attorneys for Party

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 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

) ss

Notary- Print Name

(SEAL)

Notary - Signature

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