EFTA00157834.pdf

CLAIM ID: 26H9-2VPP UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARFtA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN and Defendants. PLAINTIFF'S SUPPLEMENTAL RESPONSE TO DEFENDANT'S FIRST REQUEST TO PRODUCE DATED JANUARY 16. 2009 Plaintiff, by and through the undersigned attorney and pursuant to Rule 1.350, Florida Rules of Civil Procedure, hereby supplements her response to Defendant, JEFFREY EPSTEIN's, First Request to Produce dated January 16, 2009 as follows: 1. Individual and/or joint income tax returns and supporting documentation including W-2 and 1099 forms for 2002-2007 and, as well as all records or documentation relative to the Plaintiffs earnings for the current year. ANSWER: 7. Legible copies of the front and back of any and all insurance identification cards, union employment identification cards which would depict the name, address, policy number, claim number, identification number of any insurance companies and/or employers which may provide you with any benefits to compensate you for any of the damages that you are alleging as a result of the incident(s), which is the subject matter of this lawsuit. ANSWER: 3505-042 Page I of 4 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005342 EFTA00157834 CLAIM ID: 26H9-2VPP vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Amended Response to Request to Produce 10. All photographs, movies, dvds, and videotapes in which you performed sexual acts or simulated sexual acts. ANSWER: None. 11. All photographs, movies, dvds, and videotapes in which you performed sexual acts or simulated sexual acts in exchange for money or other consideration. ANSWER: None. 17. All documents reflecting the names and addresses of other individuals with whom you have had sexual activity from January 1, 2000 December 31, 2005. ANSWER: 18. All documents reflecting the names and addresses of other individuals with whom you have had sexual activity from January 1, 2006 through November 30, 2008. ANSWER: 2 3505-042 Page 2 of 4 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005343 EFTA00157835 furnished by e-mail to all Counsel on the attached list, this December 2009. Attorney for Plaintiff, CMA 3 CLAIM ID: 26H9-2VPP vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRALIOHNSON Plaintiffs Amended Response to Request to Produce I HEREBY CERTIFY that a true and correct copy of the foregoing has been 51t..no day of 3505-042 Page 3 of 4 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005344 EFTA00157836 CLAIM ID: 26H9-2VPP vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Amended Response to Request to Produce COUNSEL LIST Robert Critton, Esquire Burman, Critton, Luttier & Coleman LLP Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. Attorney For: Jeffrey Epstein Bruce E. Reinhart, Esquire Bruce E. Reinhart, P.A. 4 3505-042 Page 4 of 4 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005345 EFTA00157837