UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA¶
CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON¶
Plaintiff,¶
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 true copy of the foregoing has been furnished by e-mail this day of October, 2009, to See attached list of counsel.¶
Attorney for Plaintiff(s)¶
Δ π EXHIBIT ___¶
Deponent ___¶
Date ___ Rptr.___¶
PENDBOOK¶
3505-045¶
Page 1 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00005456¶
EFTA00157905¶
| vs. Epstein, et al. | |
| Case No.: 08-CV-B0811-CIV-MARRA/JOHNSON | |
| Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories |
PLAINTIFF’S NOTICE OF SERVING SECOND AMENDED ANSWERS TO INTERROGATORIES¶
- 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¶
3505-045¶
Page 2 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
| EFTA_00005457 | | :--- | :--- |¶
This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text.¶
EFTA00157906¶
| vs. Epstein, et al. | |
| Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | |
| Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories |
- 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¶
Subject matter: Plaintiff.¶
3¶
3505-045¶
Page 3 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00005458¶
EFTA00157907¶
| vs. Epstein, et al. | |
| Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | |
| Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories |
Page 4 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00005459¶
EFTA00157908¶
| vs. Epstein, et al. | |
| Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | |
| Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories |
- (Address unknown)
Subject matter: Defendant.¶
- Jane Doe (Case No.: 1:93-cv-01109-KAM) c/o her attorney:
Theodore Leopold, Esquire¶
Leopold, Kuvin, P.A.¶
Subject matter: Victim of Epstein.¶
- Jane Doe (Case No.: 502008CA020614) c/o her attorney:
Isidro M. Garcia, Esquire¶
The Law Office of Brad Edwards & Associates, LLC¶
Subject matter: Victim of Epstein.¶
- Jane Doe #2 (Case No.: 9:08-cv-80119-KAM) c/o her attorney:
Jeffrey M. Herman, Esquire¶
Herman & Mermelstein, P.A.¶
Subject matter: Victim of Epstein.¶
- Jane Doe #3 (Case No.: 9:08-cv-80232-KAM) c/o her attorney:
5¶
3505-045¶
Page 5 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00005460¶
EFTA00157909¶
| vs. Epstein, et al. | |
| Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | |
| Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories |
Subject matter: Victim of Epstein.¶
- Jane Doe #5 (Case No.: 9:08-cv-80381-KAM) c/o her attorney:
Jeffrey M. Herman, Esquire¶
Herman & Mermelstein, P.A.¶
Subject matter: Victim of Epstein.¶
- Jane Doe #4 (Case No.: 9:08-cv-80380-KAM) c/o her attorney:
Jeffrey M. Herman, Esquire¶
Herman & Mermelstein, P.A.¶
Subject matter: Victim of Epstein.¶
- Jane Doe (Case No.: 9:08-cv-80804-KAM) c/o her attorney:
Theodore Leopold, Esquire¶
Leopold, Kuvin, P.A.¶
Subject matter: Victim of Epstein.¶
6¶
Page 6 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00005461¶
EFTA00157910¶
| vs. Epstein, et al. | |
| Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | |
| Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories |
Subject matter: Victim of Epstein.¶
- (Case No.: 502008CA025129XXXXMB AI c/o her attorneys:
Jack Scarola, Esquire¶
Jack P. Hill, Esquire¶
Searcy Denney Scarola Barnhart & Shipley, P.A.¶
Subject matter: Victim of Epstein.¶
- Jose Alessi
(Address unknown at this time)¶
Subject matter: Jeffrey Epstein’s Butler.¶
7¶
3505-045¶
Page 7 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00005462¶
EFTA00157911¶
| vs. Epstein, et al. | |
| Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | |
| Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories |
3505-045¶
Page 8 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00005463¶
EFTA00157912¶
| vs. Epstein, et al. | |
| Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | |
| Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories |
Subject matter: The incident which is the subject matter of this lawsuit. Discovery is ongoing.¶
Subject matter: Investigator.¶
- , friend of (Address will be provided upon receipt)
Subject matter: Victim and friend of¶
- Ghislane Maxwell c/o Ghislane Corp.
Subject matter: Associate of Epstein.¶
9¶
3505-045¶
Page 9 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00005464¶
EFTA00157913¶
| vs. Epstein, et al. | |
| Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | |
| Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories |
Subject matter: Investigator.¶
Subject matter: Associate of Epstein who facilitated introductions with various victims.¶
- Alfredo Rodriguez
(Address unknown at this time)¶
Subject matter: Employee of Epstein.¶
Subject matter: Investigator.¶
10¶
Page 10 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00005465¶
EFTA00157914¶
| vs. Epstein, et al. | |
| Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | |
| Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories |
-
friend of ‘s mother (Address will be provided upon receipt) Subject matter: Friend of ‘s mother.
-
friend of ‘s mother (Address will be provided upon receipt)
Subject matter: Friend of ‘s mother¶
- friend of (Address will be provided upon receipt)
Subject matter: Potential victim and friend of¶
(Address unknown at this time)¶
Subject matter: Associate of Epstein who may have been involved in encounters between Epstein and¶
- friend of (Address unknown at this time)
11¶
Page 11 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00005466¶
EFTA00157915¶
| vs. Epstein, et al. | |
| Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | |
| Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories |
40. （last name unknown), friend of (Address unknown at this time)¶
- 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¶
- 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¶
- 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¶
12¶
3505-045¶
Page 12 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
| EFTA_00005467 | | :--- | :--- |¶
This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text.¶
EFTA00157916¶
| vs. Epstein, et al. | |
| Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | |
| Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories |
- 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 to August of 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.¶
- 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 I was to give Jeffrey Epstein a massage. I continued to provide massages up until August of I was transported to Jeffrey Epstein’s house by Yellow Cab, provided by Jeffrey Epstein, my ex-boyfriend my mother and my brother. I was also transported via private car provided by Jeffrey Epstein.¶
(Address will be provided upon receipt)¶
13¶
Page 13 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00005468¶
EFTA00157917¶
| vs. Epstein, et al. | |
| Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | |
| Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories |
- 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 |
14¶
3505-045 Page 14 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
| EFTA_00005469 | | :--- | :--- |¶
This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text.¶
EFTA00157918¶
| vs. Epstein, et al. | |
| Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | |
| Plaintiff’s 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¶
3505-045¶
Page 15 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00005470¶
EFTA00157919¶
| | |¶
| :--- | :--- |¶
| vs. Epstein, et al. | |¶
| Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | |¶
| Plaintiff’s Second Amended Answers to Defendant’s First Interrogatories | |¶
COUNSEL LIST¶
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¶
16¶
3505-045¶
Page 16 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
| EFTA_00005471 | | :--- | :--- |¶
This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text.¶
EFTA00157920¶
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 26 day of Oct 10, 2009 by who is personally known to me or has produced the following identification___¶
[SEAL]¶
Notary - Print Name¶
Notary - Signature¶
3505-045¶
Page 17 of 17¶
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00005472¶
EFTA00157921¶