EFTA00157905.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff, vs. 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 tru copy of th egoing has been furnished by e- mail this 1.-S racof October, 2009 list of counsel. Attorney for PlaIntiff(s) 3505-045 Page I 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-86811-CIV-MARFtAkIOHNSON Plaintiffs Second Amended Answers to Defendant's Fkst Interrogatories PLAINTIFF'S NOTICE OF SERVING SECOND AMENDED ANSWERS TO INTERROGATORIES 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 2 3505-045 Page 2 of 17 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005457 EFTA00157906 vs. FriezmIn, et al. Case No.: 05-CV-80811-CIV-MARRA/JOHNSON PieInliIrs Second Amended Answers to Defendent'S Fast interrogatories 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. do her attorneys: 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 at Case No.: 08-CV-80811-C1V-MARRA/JOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories 2. Jeffrey Epstein do his attorneys: Robed Critton, Esquire Burman Critton Luttlor & Coleman LLP Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. Bruce E. Reinhart, Esquire Bruce E. Reinhart, P.A. Subject matter: Defendant 3. n mother,s and her brother, c/cIMI's attorneys: Subject matter: IMs involvement with Epstein. 4 3505-045 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-MARRNJ0HNS0N Plaintiffs Second Amended Answers to Defendants First Interrogatories 4. (A R,lin own) Subject matter: Defendant 6. Jano Doe (Case No.:1:93-cv-01109-KAM) do her attorney: Theodore Leopold, Esquire Leopold, Kuvin, P.A. Subject matter: Victim of Epstein. 6. Jane Doe (Case No.: 602008CA020614) do her attorney: Isidro M. Garcia, Esquire The Law Office of Brad Edwards & Associates, LLC Subject matter: Victim of Epstein. 7. Jane Doe #2 (Case No.: 9:08-cv-80119-KAM) do her attorney: Jeffrey M. Herman, Esquire Herman & Mermelstein, P.A. Subject matter. Victim of Epstein. 8. Jane Doe #3 (Case No.: 9:08-cv-80232-KAM) do 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 Case No.: 08-CV-80811-CIV-MARRNJOHNSON Plaintiff's Second Amended Answers to Defendant's First Interrogatories Jeffrey M. Herman, Esquire Herman & Mermelstein, P.A. Subject matter: Victim of Epstein. 9. Jane Doe #5 (Case No.: 9:08-ov-80381-KAM) c/o her attorney: Jeffrey M. Herman, Esquire Herman & Mermelstein, P.A. 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. 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. Subject matter: Victim of Epstein. 6 3505-045 Page 6 of 17 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 0000546I EFTA00157910 vs. Epstein, a al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Second Amended Answers to Defendants Fest Interrogatories 12. Jane Doe. (Case No.: 9:08-cv-80993-KAM) do her attorney: Jeffrey M. Herman, Esquire Herman & Mermolsteln, P.A. Subject matter: Victim of Epstein. 13. • (Case No.: 602008CA026129)OOOCMB Al c/o her attorneys: Jack Scarola, Esquire Jack P. Hill, Esquire Seamy Denney Scarola Barnhart & Shipley, P.A. Subject matter. Victim of Epstein. 14. Jose Alessi (Address unknown at this time) Subject matter: Jeffrey Epstein's Butler. 16. Palm Beach Police pertinent Subject matter: Investigator. 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 Plaintiffs Second Amended Answers to Defendants First Interrogatories 16. Lanaa Belohavek Palm Beach County Prosecutors Office Subject matter. Prosecutor. 17. Detective IIMIL lead investigator Palm Beach Police Department Subject matter. Investigator. 18. Subject matter: Former boyfriend of a victim of Epstein. 19. Sgt. Palm!. Police Department 20. Subject matter. Investigator. Subject matter. Plaintiff's former boyfriend. 21. supervisor 8 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.: 03-CV-80811-CIV-MARRNJOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories Subject matter: The incident which is the subject matter of this lawsuit Discovery is ongoing. 22. Major " ffice 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. Subject matter: Associate of Epstein. 25. 26. Detective Palm Beach Police Department Subject matter: Investigator. 27. Chief - Palm Beach Police Department 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-MARRADOHNSON Plaintiffs Second Amended Answers to Defendants First Intengatories Subject matter: Investigator. 28. (Address unknown at this time) Subject matter: Associate of Epstein who facilitated introductions with various victims. 29. Alfredo Rodriguez (Address unknown at this time) Subject matter: Employee of Epstein. 30. Detective- Palm Beach Police Department Subject matter: Investigator 31. Esquire First s stant .S. Attorney U.S. Dept. of Justice Subject matter: Federal prosecutor. 32. M.S.W. Federal Bureau of Investigation Subject matter: Investigator. 10 3505-045 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-MARFtNJOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories 33. 34. Assistant U.S. Attorney U.S. Dept of Justice Subject matter: Federal prosecutor. 35. S friend of 's mother (Address will be provided upon receipt) Subject matter: Friend of Ms mother. 36. friend ofd's mother (Address will be provided upon receipt) Subject matter 37. MUM, friend of (Address will be provided upon receipt) 38. Friend ofd's mother 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 39. friend of ( ress unknown at this time) 11 3505-045 Page II of 17 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005466 EFTA00157915 vs. Epstein, et at Case No.: 08-CV-80811-CIV-MARRAMOHNSON Plaintiffs Second Amended Answers to Defendants First Interrogatories 40. (last name unknown), friend of (Address unknown at this time) 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 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 11. 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 EFTA00157916 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARFtAfJOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories 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 From May or June of to August of I went to Mr. Epstein's home on average 2 times a . There were wee s 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. 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= I was to give Jeffrey Epstein a massage. I continued to prove e massages up until August of I was transported to Jeffrey Epstein's house b Yellow Cab, provided by Jeffrey Epstein my cx- boyfriend my mother .1.ny brother I was also transported via private car provided by Jeffrey Epstein. (Address will be provided upon receipt) 13 3505-045 Page 13 of17 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00005468 EFTA00157917 vs. Epstein, et al. Case No.: 08-CV480811-CIV-MARRA/JOHNSON Plaintiff's Second Amended Answers to Defendant's First Interrogatories 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 (last name unknown) (Address unknown) I was paid $100.00 (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 EFTA00157918 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAIJOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories Signature of Answering Party STATE OF Florida COUNTY OF Palm Beath ) 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-MARRNJOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories COUNSEL LIST Jack A. Goldberger Atterbu Goldber er & Weiss PA rneys orJeffrey ps n Bruce E. Reinhart, Esquire Bruce E. Reinhart, P.A. Attorneys fo_ Robert Critton Burman Critton Luther & Coleman LLP Attorneys for Jeffrey Epstein 16 I. 3505-045 Page 16 of 17 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005471 EFTA00157920 VERIFICATION being duly sworn, deposes and says that the foregoing answers to interrogatories me true and correct to the best of her knowledge, information and belief. STATE OF FLORIDA ) as COUNTY OF PALM BEACH SWORN TO AND SD identification (SFAI) SCRIBED before b day of Or-14 40 4 , 2009 by who is •e or has produced the following " cH4 z Notary - Print Name 494 Notary - Signature 3505-045 Page 17 of 17 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005472 EFTA00157921