EFTA00725932.pdf

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO.: 50 2008 CA 028058 XXXXMB AD Plaintiff; vs. JEFFREY EPSTEIN, Defendant. NOTICE OF SERVICE OF PLAINTIFF'S UNVERIFIED BETTER ANSWERS TO DEFENDANT'S INTERROGATORIES PLEASE TAKE NOTICE that the Plaintiff, by and through her undersigned counsel, has served her Unverified Better Answers to Defendant's Interrogatories, numbered 1 to 26, inclusive, propounded to said Plaintiff on or about December 10, 2008. I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by email transmission to all those on the attached service list, this ide day of =2009. ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Tel: (954) 522-3456 Fax: (954) 527-8663 Em By: EDWARDS, ESQ. Florida Bar No.: 542075 EFTA00725932 PLAINTIFF'S UNVERIFIED BETTER 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? with the assistance of my attorney, Edwards. Plaintiff objects to Defendant, Je Epstein, having her address, as Mr. Epstein is a registered sex offender and was a victim of his, and disclosure of her address could compromise her safety and privacy. 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 - 2008. Jul - S tember, 2008, I worked for Februar - Se tember rked for November 2007 to February 2008, I worked for March 2007 - Dece e I worked for - January 2007 - March 2007, I worked as a bartender at EFTA00725933 2. (continued) Appr 004 2006 I worked for the followiri: 'laces: ocimatel 2 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. No former names. Never married and no children. Social security number and date of birth have already been privately disclosed. The answers provided below are to the best of Plaintiff's knowledge and memory, and are in descending chronological order from most recent back. Plaintiff is unsure as to the dates when lived at each address. Current: Plaintiff objects to providing a current address as she strongly feels disclosure of such would compromise her safety; however, all other addresses are being produced. EFTA00725934 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 the place of conviction. No. EFTA00725935 5. List the names and addresses of all persons who are believed or known by you, your agents or attorneys to have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge. Plaintiff is not yet aware of addresses; however, Plaintiff believes that Defendant has all addresses. Plaintiff is not yet aware of addresses: however it is believed that Defendant has all the addresses. Knowledge of finances and defendant's sexual desire for minor girls Jean Luc Brunel Knowledge of finances and defendant's sexual desire for minor girls Wexner Knowledge of finances and defendant's sexual desire for minor_girls Mark Epstein Knowledge of finances and defendant's sexual desire for minor girls Donald Trump Knowledge of finances and defendant's sexual desire for minor girls Jennie Saunders Arranges for underage girls to go to and from Jeff's island David Copperfield Knowledge of finances and defendant's sexual desire for minor girls Ghislaine Maxwell Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Cunningham Knowledge of finances and defendant's sexual desire for minor girls Harry Beller Knowledge of finances and defendant's sexual desire for minor girls Tony Malotta Knowledge of finances and defendant's sexual desire for minor girls Egor Zanovie Knowledge of finances and defendant's sexual desire for minor girls Tagliana Knowledge of finances and defendant's sexual desire for minor girls in NY Knowledge of finances and defendant's sexual desire for minor girls Lawrence Krauss Knowledge of finances and defendant's sexual desire for minor girls Mortimer Zuckerman Knowledge of finances and defendant's c EFTA00725936 sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Mike and Knowledge of finances and defendant's sexual desire .for minor girls Vadwon Cotrin Knowledge of finances and defendant's sexual desire for minor girls a Knowledge of finances and defendant's sexual desire for minor girls lila Knowledge of finances and defendant's sexual desire for minor girls Jeffrey Epstein's mother and father Knowledge of finances and defendant's sexual desire for minor girls Lebet Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Janvz Banasiak Epstein's house manager during time our client's went to him Michael Reiter Knowledge of defendant's sexual desire for minor girls Det. Recarey Knowledge of defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Bob and Todd Meister Knowledge of finances and defendant's sexual desire for minor girls Cecelia Stein Knowledge of finances and defendant's sexual desire for minor girls Larry Visoski Knowledge of finances and defendant's sexual desire for minor girls Ronald Baron Knowledge of finances and defendant's sexual desire for minor girls Glenn Knowledge of finances and defendant's sexual desire for minor girls Amy Fortimer Knowledge of finances and defendant's sexual desire for minor girls Abigail Wexner Knowledge of finances and defendant's sexual desire for minor girls Jeffrey Goldsmith Knowledge of finances and defendant's sexual desire for minor girls EFTA00725937 Sandy Berger Knowledge of finances and defendant's sexual desire for minor girls Ofc. Munyan Knowledge of defendant's sexual desire for minor girls Ofc. Minot Knowledge of defendant's sexual desire for minor girls Sgt. Sorge Knowledge of defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Pilot David Rogers Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Alfredo Rodriquez Knowledge of finances and defendant's sexual desire for minor girls Leon Black Knowledge of finances and defendant's sexual desire for minor girls Jeff Fuller Knowledge of finances and defendant's sexual desire for minor girls Ron Burkle Knowledge of finances and defendant's sexual desire for minor girls All people that visited Defendant in jail Knowledge of finances and defendant's sexual desire for minor girls, and statements made by defendant All minor females with whom Defendant has engaged in sexual activities (including, but not limited to, those provided in addendum to NPA, all Plaintiffs with sex abuse claims against Defendant, those listed in police reports and documents by Palm Beach Police) Knowledge of finances and defendant's sexual desire for minor girls Juan Alessi Knowledge of £mantes and defendant's sexual desire for minor girls Maria Alessi Knowledge of finances and defendant's sexual desire for minor girls Jim Baca Knowledge of finances and defendant's sexual desire for minor girls Janusz Banasiak Knowledge of finances and defendant's EFTA00725938 sexual desire for minor girls Keith Blumberg Knowledge of finances and defendant's sexual desire for minor girls ast name unknown at s time) Knowledge of finances and defendant's sexual desire for minor girls Campos Knowledge of finances and defendant's sexual desire for minor girls Jimmy Cayne Knowledge of finances and defendant's sexual desire for minor girls Cecelia (last name unknown at this time) Knowledge of finances and defendant's sexual desire for minor girls Maximilia Cordero Knowledge of finances and defendant's sexual desire for minor girls Ellen Cunningham Knowledge of finances and defendant's sexual desire for minor girls Dave (last name unknown at this time) Knowledge of finances and defendant's sexual desire for minor girls Ryan Dionne Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Michael Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Eric Gany Knowledge of finances and defendant's sexual desire for minor girls Hessey Knowledge of finances and defendant's sexual desire for minor girls (last name Knowledge of finances and defendant's sexual desire for minor girls unknown at this time) Karen (last name unknown at this time) Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Gary King Knowledge of finances and defendant's sexual desire for minor girls Bella Klein Knowledge of finances and defendant's sexual desire for minor girls Adam Perry Lang Knowledge of finances and defendant's sexual desire for minor girls Michael Liftman Knowledge of finances and defendant's EFTA00725939 sexual desire for minor girls Mark Lumberg Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Lynn (last name unknown at this time) Knowledge of fmances and defendant's sexual desire for minor girls Brahalcmana Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls David Mullen Knowledge of finances and defendant's sexual desire for minor girls Gary Nikolitis Knowledge of finances and defendant's sexual desire for minor girls David Norr Knowledge of finances and defendant's sexual desire for minor girls Bill Peadon Knowledge of finances and defendant's sexual desire for minor girls Francis Peadon Knowledge of finances and defendant's sexual desire for minor girls Jerome Pierre Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Governor Bill Richardson Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Alfredo Rodriguez Knowledge of finances and defendant's sexual desire for minor girls David Rogers Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Howard Rubenstein Knowledge of finances and defendant's sexual desire for minor girls Florena Rueda Knowledge of finances and defendant's sexual desire for minor girls Joseph Rueda Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Santa Fe County Sheriff Knowledge of finances and defendant's EFTA00725940 Solano sexual desire for minor girls Alan Stopeck Knowledge of finances and defendant's sexual desire for minor girls Mark Tafoya Knowledge of finances and defendant's sexual desire for minor girls Brent Tindall Knowledge of finances and defendant's sexual desire for minor girls Jojo (last name unknown at this time) Knowledge of finances and defendant's sexual desire for minor girls All girls identified in the attachment to the non- prosecution agreement that Defendant, Jeffrey Epstein, has entered with the United States and all other similarly-situated girls, whose identities Plaintiff will attempt to determine (and with regard to whom Defendant, Jeffrey Epstein, has invoked the Fifth Amendment rather than disclose their identities). Knowledge of finances and defendant's sexual desire for minor girls All other then-minor girls (those not listed in the attachment to the non- prosecution agreement), whose identities Plaintiff will attempt to determine, with whom Defendant, Jeffrey Epstein, has engaged in sexual Knowledge of finances and defendant's sexual desire for minor girls activity. Knowledge of finances and defendant's sexual desire for minor girls FBI agents, whose names, addresses and telephone numbers are unknown at this time, that investigated the criminal case(s) and the allegations made against Defendant, Jeffrey Knowledge of finances and defendant's sexual desire for minor girls EFTA00725941 Epstein. State Prosecutors, whose names, addresses and telephone numbers are unknown at this time, including but not limited to: ASA Lanna Belohlavek State Attorney's Office 15th Judicial Circuit ASA Weiss State Attorney's Office 15th Judicial Circuit Knowledge of finances and defendant's sexual desire for minor girls United States' Prosecutors, whose names, addresses and telephone numbers are unknown at this time, including but not limited to: United States Attorney's Office 500 South Australian Avenue West Palm Beach, Florida 33401 Knowledge of finances and defendant's sexual desire for minor girls All accountants, bookkeepers, bankers, fmancial institutions, representatives, real estate advisors, financial planners, employees, governmental persons or entities, and unknown others that may have discoverable information related to Defendant, Jeffrey Epstein's net worth and finances. EFTA00725942 Any and all persons and/or entities identified through discovery having any knowledge of Defendant, Jeffrey Epstein's charitable, political or other donations made in the past. Any and all persons and/or entities identified through discovery that were sued in the past by Defendant, Jeffrey Epstein, and/or by any company or entity that the Defendant, Jeffrey Epstein, owned and/or managed. Reporters and other media persons, whose names, addresses and telephone numbers are unknown at this time. All other witnesses learned through discovery process. 6. 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? When I first went to Defendant, Jeffrey Epstein's House, no. I began taking pain medication before going to his house each time and I developed an addiction to pain medication. 7. Did you consume any alcoholic beverages or take any drugs or medication 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 and where you consumed them. Yes, I took various pain medications before going to Defendant, Jeffrey Epstein's house each time. I usually took 1 to 2 pills in the cab on the way to his house or with the 30 minutes before arriving. EFTA00725943 8. 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. My injuries are primarily emotional/psychological and are the direct result of Defendant, Jeffrey Epstein's actions. I was touched, battered, and fondled by Defendant, Jeffrey Epstein, during the incidents described in the complaint. I observed the Defendant touch and fondle himself. I observed the Defendant ejaculate numerous times. I was made to touch the Defendant. I also observed sexual acts and had sexual acts perpetrated on me by Defendant, Jeffrey Epstein. At various times I was unclothed, as was the Defendant and others. At all times material, I was a child, under the age of 18 years. I was a victim of various criminal acts and sexual exploitation. I was inducted and coerced by the Defendant into acts of prostitution. These injuries are further described in more detail in the factual allegations of the complaint. 9. 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. I incurred medical and psychological expenses in the past and will incur such expenses in the future. I have suffered a loss of earning capacity due to Jeffrey Epstein's influence because I was encouraged by him as a minor child to enter a life of prostitution for him. I suffered a loss of the capacity to enjoy life as a result of being coerced and induced into committing acts of prostitution and as a result of being sexually exploited. I lost self-worth, confidence and self esteem due to his control and influence. I have suffered mental anguish, emotional distress, fear, humiliation and psychological trauma as a result of the acts described in the complaint. The effect of these injuries is permanent in nature. These damages are further described in the complaint. The factual basis for these damages is described in the answer to #8 above, and in the factual allegations in the complaint. EFTA00725944 10. Do you contend that you have lost any income, benefits, or earning capacity in the past or future as a result of the incident described in the complaint? If so, state the nature of the income, benefits, or earning capacity, and the amount and the method that you used in computing the amount. I did not lose income, as I was an eighth grade student before meeting Defendant, Jeffrey Epstein. I did lose earning capacity, in that Defendant encouraged me into his deviant sexual world and influenced me away from a normal school life and into taking my clothes off and sexually pleasing him for money. As such, I do not have the education I would like to have and cannot obtain employment in a traditional profession. 11. List the names and business addresses of each physician (including psychiatrist, psychologist, etc.) or medical provider (including chiropractors) 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. M.S. LMHC (Licensed Therapist) Palm Beach County Public Safety Department Victim Services Division 205 North Dixie Highway Suite 5.1100 West Palm Beach, FL 33401 561 355 2428 Office Palm Beach Doctors (Dr. Rishard) in West Palm Beach treated me for anxiety and depression, which are related to the abuse inflicted by Defendant, Jeffrey Epstein EFTA00725945 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. Dr. Rishard Office Palm Beach Doctors West Palm Beach, Florida JFK Medical Center 5301 South Congress Avenue Atlantis, Florida 33462 M.S. LMHC (Licensed Therapist) Palm Beach County Public Safety Department Victim Services Division 205 North Dixie Highway Suite 5.1100 West Palm Beach, FL 33401 561 355 2428 Bethesda Memorial Hospital 2815 South Seacrest Boulevard Boynton Beach, Florida 33435 CARP, Inc. 5400 East Avenue West Palm Beach, Florida (drug rehabilitation center) St. Mary's Medical Center 901 - 45th Street West Palm Beach, Florida 33407 A Fort Lauderdale hospital for mental health evaluation (I cannot remember which hospital) EFTA00725946 13. State the name and address of every person known to you, your agents, or 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 described 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. None, other than those police officers or other investigators mentioned in criminal discovery previously disclosed to Defendant, Jeffrey Epstein. 14. Please state if you (or parents or guardians 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. 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. I was a minor child at all times that I went to Defendant, Jeffrey Epsiein's house and have not been since approximately September 2005; to the best of my Im and recollection. I went for the first time in July 2002, and I went there with'. and Aside from Defendant, Jeffrey Epstein, there were usually other persons employed by Epstein at the house, and Defendant Epstein knows all the names and I did not keep any record. After the first time in July 2002 through the last time in September 2005, I went to Defendant, Jeffrey Epstein's house more than 100 times and Defendant, Jeffrey Epstein, would have a much more accurate c sits, and more documentation of the times I was there because he and kept a schedule. Because Defendant, Jeffrey Epstein, paid me to bring him other underage minor girls, I brought him more than 50 minor girls and I went to his house with them. I do not know all of their names, although Defendant, Jeffrey Epstein, does. 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. The first time, took Defendant, Jeffrey EsSal's house and I accompanied them, but I did not see him. Subsequently, ME brought me to Jeffrey Epstein, and I was told that I would have to get undressed and give him a EFTA00725947 massage. After that, I went to his house with various people and sometimes alone and usually in a cab. 17. State the date you began engaging in prostitution, where (City and State), and whether you are still engaged in prostitution. The only prostitution I have ever engaged in was with Jeffrey Epstein. 18. 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. Defendant, Jeffrey Epstein, paid me $200 for each time I went to his house and he sexually touched and/or fondled me. One time he gave me $300 instead of $200. Additionally, he paid me $200 each time I brought another minor girl to his house and he sexually molested or abused them too. I went to his house more than 100 times. 19. List separately the names, address and phone number 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. Objection, harassing; irrelevant, not reasonably calculated to lead to admissible evidence, violation of privacy interests and rights of Plaintiff and other innocent persons. 20. 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. Jeffrey Epstein was the only person. 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 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. Jeffrey Epstein was the only person. EFTA00725948 22. 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. Jeffrey Epstein was the only person. 23. List in detail all discussions/interviews which you had with any representative from FBI, U.S. Attorneys' Office, State Attorneys' Office (Palm Beach County), Palm Beach Sheriff's Office and Palm Beach Police Department regarding your meeting 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. In 2007 and 2008 I spoke with the F.B.I. and/or the U.S. Attorney's Office or representatives from those agencies on several occasions (approximately 8-10 times total). I believe that one statement may have been taped. I told them about Defendant, Jeffrey Epstein, sexually abusing me and paying me. I also told them about the time that Defendant, Jeffrey Epstein, sent his investigators to my house to bang on my door and take pictures of my house and car. The primary F.B.I. agents that I spoke to were Nezbit and Jason. 24. State the names, addresses, ages and phone numbers of all females whom you claim were brought by you to Mr. Epstein's home to give him a massage. As to each female, state the amount of money you claim you were paid to bring each female. I brought approximate] 50 iris in total between July 2002 and September 2005. The ones I remember are EFTA00725949 25. 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. I was interviewed approximately 8-10 times by the F.B.I. and/or the U.S. Attorney's Office. I believe notes were taken most times and I told them about Defendant, Jeffrey Epstein, sexually touching and fondling me and paying me to bring him other minor girls. 26. 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. No such statements were ever made to me. EFTA00725950 Plaintiff I, counsel for swear Plaintiff herein, personally witnessed the Plaintiff execute this jurat page and do swear t at M. is personally known to me, is the individual identified in the foregoing answers and is the same individual whose identify has been previously disclosed, under seal, to the Defendant's counsel. Edwards STATE OF FLORIDA COUNTY OF BROWARD :ss SWORN TO AND SUBSCRIBED before me this day of , 2009 by MI EDWARDS, who is personally known to me. Print Name Signature NOTARY PUBLIC - STATE OF FLORIDA Commission Number: My commission expires: (Notarial Seal) EFTA00725951