EFTA00023624.pdf

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80811-CIV-[REDACTED]
[REDACTED],
Plaintiff,
vs.
JEFFREY EPSTEIN and [REDACTED],
Defendants.
PLAINTIFF'S NOTICE OF SERVING SECOND AMENDED ANSWERS TO INTERROGATORIES
COMES NOW the Plaintiff, [REDACTED], 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 true copy of the foregoing has been furnished by e-mail this 28th day of October, 2009, to: See attached list of counsel.
JACK SCAROLA
Florida Bar No.: 169440
JACK P. HILL
Florida Bar No.: 0547808
Searcy Denney Scarola Barnhart & Shipley, P.A.
[REDACTED]
Attorney for Plaintiff(s)

[Page 2]
[REDACTED] vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-[REDACTED]
Plaintiff's Second Amended Answers to Defendant's First 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
Nickname-[REDACTED]
[REDACTED]
West Palm Beach, FL. 33417
Dates: July, 2007-Present
[REDACTED]
West Palm Beach, FL.
Dates: February, 2004- July, 2007
Rome, Georgia
Dates: August, 2003-February, 2004
[REDACTED]
West Palm Beach, FL. 33409
Dates: About 2 ½ years ago
[REDACTED]
West Palm Beach, FL. 33409
Dates: Approximately 1 year
[REDACTED]
Lake Park, FL
Dates: Unknown
SSN-[REDACTED] DOB-[REDACTED]
I have never been married.
Children: [REDACTED]
Father: [REDACTED]
Address: [REDACTED]
West Palm Beach, FL. 33407

[Page 3]
[REDACTED] vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-[REDACTED]
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
Father: [REDACTED]
Address: West Palm Beach, FL.
Parents: [REDACTED]
Address Unknown
[REDACTED]
West Palm Beach, FL. 33417
Siblings: [REDACTED]
[REDACTED]
West Palm Beach, FL. 33417
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. [REDACTED]
c/o her attorneys:
Jack Scarola, Esq. and Jack P. Hill, Esq.
Searcy Denney Scarola Barnhart & Shipley, P.A.
[REDACTED]
West Palm Beach, FL 33409
Tel: [REDACTED]
Richard Willits, Esq.
Richard H. Willits, P.A.
[REDACTED]
Lake Worth, FL 33461
Tel: [REDACTED]
Subject matter: Plaintiff.

[Page 4]
[REDACTED] vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-[REDACTED]
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
2. Jeffrey Epstein
c/o his attorneys:
Robert Critton, Esquire
Burman Critton Luttier & Coleman LLP
[REDACTED]
West Palm Beach, FL 33414
Tel: [REDACTED]
Jack A. Goldberger, Esquire
Atterbury, Goldberger & Weiss, P.A.
[REDACTED]
West Palm Beach, FL 33401
Tel: [REDACTED]
Bruce E. Reinhart, Esquire
Bruce E. Reinhart, P.A.
[REDACTED]
West Palm Beach, FL 33401
Tel: [REDACTED]
Subject matter: Defendant
3. [REDACTED]'s mother, [REDACTED], and her brother, [REDACTED]
c/o [REDACTED]'s attorneys:
Jack Scarola, Esq. and Jack P. Hill, Esq.
Searcy Denney Scarola Barnhart & Shipley, P.A.
[REDACTED]
West Palm Beach, FL 33409
Tel: [REDACTED]
Richard Willits, Esq.
Richard H. Willits, P.A.
[REDACTED]
Lake Worth, FL 33461
Tel: [REDACTED]
Subject matter: [REDACTED]'s involvement with Epstein.

[Page 5]
C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-[REDACTED]
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
4. [REDACTED]
(Address unknown)
Subject matter: Defendant.
5. Jane Doe (Case No.: 1:93-cv-01109-KAM)
c/o her attorney:
Theodore Leopold, Esquire
Leopold, Kuvin, P.A.
[REDACTED]
Palm Beach Gardens, FL 33410
Tel: [REDACTED]
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
[REDACTED]
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.
[REDACTED]
Subject matter: Victim of Epstein.
8. Jane Doe #3 (Case No.: 9:08-cv-80232-KAM)
c/o her attorney:

[Page 6]
[REDACTED] vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-[REDACTED]
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
Jeffrey M. Herman, Esquire
Herman & Mermelstein, P.A.
[REDACTED]
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.
[REDACTED]
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.
[REDACTED]
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.
[REDACTED]
Subject matter: Victim of Epstein.

[Page 7]
[REDACTED] vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
12. Jane Doe #7 (Case No.: 9:08-cv-80993-KAM)
c/o her attorney:
Jeffrey M. Herman, Esquire
Herman & Mermelstein, P.A.
[REDACTED]
Subject matter: Victim of Epstein.
13. [REDACTED] (Case No.: 502008CA025129XXXXMB AI
c/o her attorneys:
Jack Scarola, Esquire
Jack P. Hill, Esquire
Searcy Denney Scarola Barnhart & Shipley, P.A.
[REDACTED]
Tel: [REDACTED]
Subject matter: Victim of Epstein.
14. [REDACTED]
(Address unknown at this time)
Subject matter: Jeffrey [REDACTED].
15. [REDACTED]
Palm Beach Police Department
[REDACTED]
Subject matter: Investigator.

[Page 8]
[REDACTED] vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-[REDACTED]
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
16. [REDACTED]
Palm Beach County Prosecutors Office
[REDACTED]
West Palm Beach, FL 33401
Tel: (561) 355-7100
Subject matter: Prosecutor.
17. Detective [REDACTED] lead investigator
Palm Beach Police Department
[REDACTED]
Subject matter: Investigator.
18. [REDACTED]
[REDACTED]
Subject matter: Former boyfriend of a victim of Epstein.
19. Sgt. [REDACTED]
Palm Beach Police Department
[REDACTED]
Subject matter: Investigator.
20. [REDACTED]
[REDACTED]
Subject matter: Plaintiff's former boyfriend.
21. Tony Higgins, supervisor
Sanitation Bureau of the Town of Palm Beach
[REDACTED]

[Page 9]
[REDACTED] vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-[REDACTED]
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
Tel: [REDACTED]
Subject matter: The incident which is the subject matter of this lawsuit. Discovery is ongoing.
22. [REDACTED]
Palm Beach County Sheriff's Office
[REDACTED]
Subject matter: Investigator.
23. [REDACTED], friend of [REDACTED]
(Address will be provided upon receipt)
Subject matter: Victim and friend of [REDACTED].
24. Ghislane Maxwell c/o Ghislane Corp.
[REDACTED]
Subject matter: Associate of Epstein.
25. [REDACTED]
Parent Child Center
Subject matter: Counselor at Parent Child Center.
26. Detective [REDACTED]
Palm Beach Police Department
[REDACTED]
Subject matter: Investigator.
27. Chief [REDACTED]
Palm Beach Police Department

[Page 10]
[REDACTED] vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
Tel: [REDACTED]
Subject matter: Investigator.
28. [REDACTED]
(Address unknown at this time)
Subject matter: Associate of Epstein who facilitated introductions with various victims.
29. [REDACTED]
(Address unknown at this time)
Subject matter: Employee of Epstein.
30. Detective [REDACTED]
Palm Beach Police Department
[REDACTED]
Subject matter: Investigator
31. [REDACTED]
First Assistant U.S. Attorney
U.S. Dept. of Justice
[REDACTED]
Tel: [REDACTED]
Subject matter: Federal prosecutor.
32. [REDACTED]
Federal Bureau of Investigation
[REDACTED]
Subject matter: Investigator.

[Page 11]
[REDACTED] vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-[REDACTED]
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
33. [REDACTED]
Address will be provided upon receipt
West Palm Beach
Subject matter: [REDACTED]'s physician.
34. [REDACTED]
Assistant U.S. Attorney
U.S. Dept. of Justice
[REDACTED]
Tel: [REDACTED]
Subject matter: Federal prosecutor.
35. [REDACTED], friend of [REDACTED] mother
(Address will be provided upon receipt)
Subject matter: Friend of [REDACTED] mother.
36. [REDACTED] friend of [REDACTED]'s mother
(Address will be provided upon receipt)
Subject matter: Friend of [REDACTED]'s mother
37. [REDACTED], friend of [REDACTED]
(Address will be provided upon receipt)
Subject matter: Potential victim and friend of [REDACTED].
38. [REDACTED]
(Address unknown at this time)
Subject matter: Associate of Epstein who may have been involved in encounters between Epstein and [REDACTED].
39. [REDACTED], friend of [REDACTED]
(Address unknown at this time)

[Page 12]
[REDACTED] vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
40. [REDACTED] (last name unknown), friend of [REDACTED]
(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
[REDACTED]
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 more than one occasion I used cocaine powder. I do not recall the dates.
3. On more than one occassion I used marijuana. I do not recall the dates.
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
[REDACTED]
Date: I do not recall the date.
I would defer to the Doctor's records.

[Page 13]
[REDACTED] vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-[REDACTED]
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
[REDACTED]
Date: Since high school. Ongoing.
[REDACTED]
Date: I do not recall the dates,
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 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.
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 [REDACTED] 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, [REDACTED] my ex- boyfriend [REDACTED], my mother [REDACTED] and my brother [REDACTED]. I was also transported via private car provided by Jeffrey Epstein.
[REDACTED]
(Address will be provided upon receipt)

[Page 14]
[REDACTED] vs. Epstein, et al.
Case No.: 08-CV-80811-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
[REDACTED] Age: 22
[REDACTED]
I was paid $100.00
[REDACTED] (last name unknown)
(Address unknown)
I was paid $100.00
[REDACTED]
(Address unknown)
I was paid $100.00

[Page 15]
[REDACTED] vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-[REDACTED]
Plaintiff's Second Amended 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 ____ day of February, 2009 by [REDACTED] 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:

[Page 16]
[REDACTED] vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-[REDACTED]
Plaintiff's Second Amended Answers to Defendant's First Interrogatories
COUNSEL LIST
Jack A. Goldberger
Atterbury, Goldberger & Weiss, P.A.
[REDACTED]
Phone:
Attorneys for Jeffrey Epstein
Bruce E. Reinhart, Esquire
Bruce E. Reinhart, P.A.
[REDACTED]
Phone:
Fax:
Attorneys for Jeffrey Epstein
Robert Critton
Burman Critton Luttier & Coleman LLP
[REDACTED]
Phone:
Fax:
Attorneys for Jeffrey Epstein
Richard H. Willits, Esquire
Richard H. Willits, P.A.
[REDACTED]
Phone:
Fax:
Attorneys for Party

[Page 17]
VERIFICATION
[REDACTED] being duly sworn, deposes and says that the foregoing answers to interrogatories are true and correct to the best of her knowledge, information and belief.
[REDACTED]
STATE OF FLORIDA ) ss
COUNTY OF PALM BEACH )
SWORN TO AND SUBSCRIBED before me this 26 day of October, 2009 by [REDACTED] who is personally known to me or has produced the following identification _________________.
Notary Public State of Florida
Michael I Danchuk
My Commission DD610406
Expires 10/03/2013
MICHAEL DANCHUK
Notary - Print Name
(SEAL)
Notary - Signature