EFTA00728727.pdf

IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502008CA028051XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendant. I PLAINTIFF'S AMENDED RESPONSES TO DEFENDANTS SECOND REQUEST FOR PRODUCTION Plaintiff, M, hereby files her Amended Responses to Defendants Second Request for Production, pursuant to the Court Order modifying same dated October 21, 2009. 1. All documents which relate to your earnings as a prostitute or call girl. None. 2. The book containing a reference to a Bible verse on the cover which you testified contains records of youarnings as a prostitute or call girl from 2007-2008. See 's 9/24/09 Deposition Transcript at 59-60 Not in Plaintiffs possession. Plaintiff does not know the whereabouts of the book. 3. All books, journals, diaries, logs, calendars or similar documents reflecting yotarnings as a prostitute or call girl from 2006 to 2009. See 's 9/24/09 Deposition Transcript at 61-63. None. EFTA00728727 4. All books, journals, diaries, logs, calendars or similar documents reflecting the names of any individuals you brought to the home of Mr. Epstein. Not in Plaintiffs possession Plaintiff has no knowledge of whereabouts. 5. All documents reflecting the names, telephone number addresses, dates and/or income received from any individuals who paid you for sex or to engage in sexual activity. None. 6. All documents reflecting the names, telephone numbers, addresses, dates and/or income received from any individuals who paid you for a massage. None. 7. All photographs, movies, dvds and videotapes which you performed sexual acts or simulated sexual acts. None in Plaintiff's possession. Plaintiff has no knowledge of whereabouts 8. The video in which you testified you were engaged in sexual acti s) in 2007, when you were nineteen (19) years old. See Deposition transcript at 112-17. None in Plaintiffs possession. Plaintiff has no knowledge of whereabouts. 9. All photographs, movies, dvds and videotapes which depict you performing at an adult entertainment establishment. None 10. All prescription bottles, receipts or documents reflecting medication you were prescribed. Objection. Irrelevant, not reasonably calculated to lead to admissible evidence, not limited in time or scope, violation of privacy. Without waiving said objection, none in Plaintiffs possession. 11. All documents which relate to your employment in what were testified were "bunny ranch" shops, including any photographs, movies, dvds and/or videotapes. See L. M. Deposition transcript at 46. EFTA00728728 None. 12. All messages you sent or received on relate to Jeffrey Epstein or this lawsuit. None. which 13. All emails you sent or received which relate to Jeffrey Epstein or this lawsuit. None. 14. All emails you sent or received which relate to your occupation as a prostitute including all emails sent to or received from individuals paid you for sex or to engage in sexual activity. None. CERTICATE OF SERVICE I HEREBY CERTIFY that the original of the above and a copy of the foregoing has been provided this _` c7 day of February 2010 via U.S. Mail, facsimile (561) 253-0164 and email transmittal to all those on the attached service list. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, I. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954) 524-2820 (954) 524-2822 fax By: BRADLEY J. EDWARDS Florida Bar No.: 542075 EFTA00728729 SERVICE LIST Robert D. Critton, Jr. BURMAN, CRITTON, et al. 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 Jay Howell, Esq. Jay Howell & Assoc. 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 Jack Alan Goldberger, Esq. Atterbury Goldberger et al. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401 EFTA00728730