Plaintiff's answers to interrogatories in C.M.A. v. Epstein, February 2009

EFTA00182959¶

Case 9:08-cv-80119-KAM Document 147-2¶

Entered on FLSD Docket 06/08/2009¶

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#281849/clw¶

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA¶

CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON¶

Plaintiff(s),¶

vs.¶

JEFFREY EPSTEIN and¶

Defendant(s).¶

NOTICE OF SERVING¶

ANSWERS TO INTERROGATORIES¶

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 furnished by mail this day of February, 2009, to: See attached list of counsel.¶

JACK SCAROLA¶

Florida Bar No.¶

JACK P. HILL¶

Florida Bar No.:¶

Searcy Denney Scarola Barnhart & Shipley, P.A.¶

2139 Palm Beach Lakes Boulevard¶

West Palm Beach, Florida 33409¶

Phone:¶

Fax:¶

Attorney for Plaintiff(s)¶

EFTA00182960¶

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vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff’s Answers to Defendant’s First Interrogatories¶

ANSWERS TO INTERROGATORIES¶

1. What is the name and address of all persons answering or assisting in answer ing these interrogatories, and, if applicable, the person’s official position or relationship with the party to whom the interrogatories are directed?

ANSWER¶

c/o her attorneys:¶

Jack Scarola, Esq. and Jack P. Hill, Esq.¶

Searcy Denney Scarola Barnhart & Shipley, P.A.¶

2139 Palm Beach Lakes Boulevard¶

West Palm Beach, FL 33409¶

With the assistance of her counsel, Searcy Denney Scarola Barnhart & Shipley, P.A. and Richard Willits, P.A.¶

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¶

Nickname-¶

2¶

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Document 147-2

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vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff’s Answers to Defendant’s First Interrogatories¶

Have never been married.¶

3¶

EFTA00182962¶

Case 9:08-cv-80119-KAM Document 147-2 Entered on FLSD Docket 06/08/2009¶

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vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

Plaintiff’s 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¶

No¶

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.¶

2139 Palm Beach Lakes Boulevard¶

West Palm Beach, FL 33409¶

Tel: [Insert phone number here]¶

Richard Willits, Esq.¶

Richard H. Willits, P.A.¶

2290 10th Avenue North, Suite 404¶

Lake Worth, FL 33461¶

Tel:¶

Subject matter: Plaintiff.¶

2. Jeffrey Epstein c/o his attorneys:

Robert Critton, Esquire¶

Burman Critton Luttier & Coleman LLP¶

4¶

EFTA00182963¶

Case 9:08-cv-80119-KAM Document 147-2 Entered on FLSD Docket 06/08/2009¶

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C.M.A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

Plaintiff’s Answers to Defendant’s First Interrogatories¶

515 North Flagler Drive, Suite 400¶

West Palm Beach, FL 33414¶

Tel: [¶

Jack A. Goldberger, Esquire¶

Atterbury, Goldberger & Weiss, P.A.¶

250 Australian Avenue South¶

West Palm Beach, FL 33401¶

Tel: [Insert phone number here]¶

Bruce E. Reinhart, Esquire¶

Bruce E. Reinhart, P.A.¶

250 South Australian Avenue¶

Suite 1400¶

West Palm Beach, FL 33401¶

Tel:¶

Subject matter: Defendant¶

3. s mother,

c/o s attorneys:¶

Jack Scarola, Esq. and Jack P. Hill, Esq.¶

Searcy Denney Scarola Barnhart & Shipley, P.A.¶

2139 Palm Beach Lakes Boulevard¶

West Palm Beach, FL 33409¶

Tel:¶

Richard Willits, Esq.¶

Richard H. Willits, P.A.¶

2290 10th Avenue North, Suite 404¶

Lake Worth, FL 33461¶

Tel:¶

Subject matter: ‘s involvement with Epstein¶

Subject matter:¶

‘s involvement with Epstein.¶

4. (Address unknown)

Subject matter: Defendant.¶

5¶

EFTA00182964¶

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C.M.A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

Plaintiff’s Answers to Defendant’s First Interrogatories¶

5. Jane Doe (Case No.: 1:93-cv-01109-KAM) c/o her attorney:

Theodore Leopold, Esquire¶

Leopold, Kuvin, P.A.¶

2925 P.G.A. Boulevard, Suite 200¶

Palm Beach Gardens, FL 33410¶

Tel:¶

Subject matter: Victim of Epstein.¶

6. Jane Doe (Case No.: 502008CA020614) c/o her attorney:

Isidro M. Garcia, Esquire¶

The Law Office of Brad Edwards & Associates, LLC¶

2028 Harrison Street, Suite 202¶

Hollywood, FL 33020¶

Tel: [blank]¶

Subject matter: Victim of Epstein.¶

7. Jane Doe #2 (Case No.: 9:08-cv-80119-KAM) c/o her attorney:

Jeffrey M. Herman, Esquire¶

Herman & Mermelstein, P.A.¶

18205 Biscayne Boulevard, Suite 2218¶

Miami, FL 33160¶

Tel:¶

Subject matter: Victim of Epstein.¶

8. Jane Doe #3 (Case No.: 9:08-cv-80232-KAM) c/o her attorney:

Jeffrey M. Herman, Esquire¶

Herman & Mermelstein, P.A.¶

18205 Biscayne Boulevard, Suite 2218¶

Miami, FL 33160¶

Tel:¶

6¶

EFTA00182965¶

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

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.¶

18205 Biscayne Boulevard, Suite 2218¶

Miami, FL 33160¶

Tel: [blank]¶

Subject matter: Victim of Epstein.¶

10. Jane Doe #4 (Case No.: 9:08-cv-80380-KAM) c/o her attorney:

Jeffrey M. Herman, Esquire¶

Herman & Mermelstein, P.A.¶

18205 Biscayne Boulevard, Suite 2218¶

Miami, FL 33160¶

Tel:¶

Subject matter: Victim of Epstein.¶

11. Jane Doe (Case No.: 9:08-cv-80804-KAM) c/o her attorney:

Theodore Leopold, Esquire¶

Leopold, Kuvin, P.A.¶

2925 P.G.A. Boulevard, Suite 200¶

Palm Beach Gardens, FL 33410¶

Tel:¶

Subject matter: Victim of Epstein.¶

12. Jane Doe #7 (Case No.: 9:08-cv-80993-KAM) c/o her attorney:

Jeffrey M. Herman, Esquire¶

Herman & Mermelstein, P.A.¶

7¶

EFTA00182966¶

Case 9:08-cv-80119-KAM Document 147-2 Entered on FLSD Docket 06/08/2009¶

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A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

Plaintiff’s Answers to Defendant’s First Interrogatories¶

18205 Biscayne Boulevard, Suite 2218¶

Miami, FL 33160¶

Tel:¶

Subject matter: Victim of Epstein.¶

13. (Case No.: 502008CA025129XXXXMB AI

c/o her attorneys:¶

Jack Scarola, Esquire¶

Jack P. Hill, Esquire¶

Searcy Denney Scarola Barnhart & Shipley, P.A.¶

2139 Palm Beach Lakes Boulevard¶

West Palm Beach, FL 33409¶

Tel:¶

Subject matter: Victim of Epstein.¶

14. Jose Alessi

(Address unknown at this time)¶

Subject matter: Jeffrey Epstein’s Butler.¶

Palm Beach Police Department¶

345 South County Road¶

Palm Beach, FL 33480¶

Tel:¶

Subject matter: Investigator.¶

Palm Beach County Prosecutors Office¶

401 North Dixie Highway¶

West Palm Beach, FL 33401¶

Tel:¶

Subject matter: Prosecutor.¶

17. Detective , lead investigator

8¶

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vs. Epstein, et al.

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

Plaintiff’s Answers to Defendant’s First Interrogatories¶

Palm Beach Police Department¶

345 South County Road¶

Palm Beach, FL 33480¶

Tel:¶

Subject matter: Investigator.¶

Subject matter: Former boyfriend of a victim of Epstein.¶

19. Sgt.

Palm Beach Police Department¶

345 South County Road¶

Palm Beach, FL 33480¶

Tel:¶

Subject matter: Investigator.¶

21. supervisor

Sanitation Bureau of the Town of Palm Beach¶

3101 N.W. 16th Terrace¶

Pompano Beach, FL 33064¶

Tel: (877) 46-WASTE¶

Subject matter: The incident which is the subject matter of this lawsuit. Discovery is ongoing.¶

22. Major

Palm Beach County Sheriff’s Office¶

3228 Gun Club Road¶

West Palm Beach, FL 33406¶

9¶

EFTA00182968¶

Case 9:08-cv-80119-KAM

Document 147-2

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. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
Plaintiff’s 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 c/o Ghislane Corp.

3580 Brillo Way¶

Palm Beach, FL 33480¶

Subject matter: Associate of Epstein.¶

Parent Child Center¶

West Palm Beach, FL¶

Subject matter: Counselor at Parent Child Center.¶

26. Detective

Palm Beach Police Department¶

345 South County Road¶

Palm Beach, FL 33480¶

Tel:¶

Subject matter: Investigator.¶

27. Chief Michael Reiter

Palm Beach Police Department¶

345 South County Road¶

Palm Beach, FL 33480¶

Tel:¶

Subject matter: Investigator.¶

28. (Address unknown at this time)

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

10¶

EFTA00182969¶

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C.M.A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

Plaintiff’s 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¶

345 South County Road¶

Palm Beach, FL 33480¶

Tel:¶

Subject matter: Investigator¶

31. Esquire

First Assistant U.S. Attorney¶

U.S. Dept. of Justice¶

500 South Australian Avenue¶

Suite 400¶

West Palm Beach, FL 33401¶

Tel:¶

Subject matter: Federal prosecutor.¶

Federal Bureau of Investigation¶

505 South Flagler Drive, Suite 500¶

West Palm Beach, FL 33401¶

Subject matter: Investigator.¶

33. Dr. Thys

Address will be provided upon receipt¶

West Palm Beach¶

Subject matter: Your physician.¶

Assistant U.S. Attorney¶

U.S. Dept. of Justice¶

500 South Australian Avenue¶

11¶

EFTA00182970¶

Case 9:08-cv-80119-KAM

Document 147-2

Entered on FLSD Docket 06/08/2009

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1. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
Plaintiff’s Answers to Defendant’s First Interrogatories

Suite 400¶

West Palm Beach, FL 33401¶

Tel: [blank]¶

Subject matter: Federal prosecutor.¶

35. (Address will be provided upon receipt)

Subject matter: Friend of mother.¶

36. (Address will be provided upon receipt)

Subject matter: Friend of ‘s mother¶

(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 .¶

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 #5¶

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¶

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vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff’s Answers to Defendant’s First Interrogatories¶

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 another occasion I used cocaine powder. I do not recall the date.

3. 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. § 2255.¶

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¶

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C.M.A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

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.¶

ANSWER¶

Dr. Serge Thys (Psychiatrist)¶

2151 45th Street¶

West Palm Beach, FL. 33407¶

Date: I do not recall the date. I would defer to the Doctor’s records.¶

(Counselor/Therapist) Date: Since high school. Ongoing.¶

Parent Child Center¶

2001 W. Blue Heron Boulevard¶

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¶

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C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff’s Answers 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 home by 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¶

No¶

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¶

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Case 9:08-cv-80119-KAM Document 147-2 Entered on FLSD Docket 06/08/2009 Pr¶

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vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff’s Answers to Defendant’s First Interrogatories¶

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.¶

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 give Jeffrey Epstein a massage. I continued to provide massages up until August of 2003. I was transported to Jeffrey Epstein’s house by Yellow Cab, provided by Jeffrey Epstein,¶

(Address 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¶

$200-$300 for a massage session at an average of 2 sessions a week from May or June of 2002 to August 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¶

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vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff’s 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¶

None.¶

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¶

None¶

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¶

None¶

22. List in detail all discussions/interviews which you had with any representative

17¶

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vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

Plaintiff’s 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¶

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C.M.A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

Plaintiff’s 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 17 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:¶

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| vs. Epstein, et al. |¶

| :--- |¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

Plaintiff’s Answers to Defendant’s First Interrogatories¶

Jack A. Goldberger¶

Atterbury, Goldberger & Weiss, P.A.¶

250 Australian Avenue S.¶

West Palm Beach, FL 33401¶

Phone: [隐藏]¶

Attorneys for Jeffrey Epstein¶

COUNSEL LIST¶

Bruce E. Reinhart, Esquire¶

Bruce E. Reinhart, P.A.¶

250 South Australian Avenue¶

Suite 1400¶

West Palm Beach, FL 33401¶

Phone: [blank]¶

Fax: [blank]¶

Attorneys for [blank]¶

Robert Critton¶

Burman Critton Luttier & Coleman LLP¶

515 North Flagler Drive, Suite 400¶

West Palm Beach, FL 33414¶

Phone: [hidden]¶

Fax: [hidden]¶

Attorneys for Jeffrey Epstein¶

Richard H. Willits, Esquire¶

Richard H. Willits, P.A.¶

2290 10th Avenue North¶

Suite 404¶

Lake Worth, FL 33461¶

Phone:¶

Fax:¶

Attorneys for Party¶

20¶