EFTA00729603

13. 
Was it your intent to harm or injure the Plaintiff when you were interacting with her? 
14. 
Describe any words or actions that you made to assure the Plaintiff that sexual activity 
with you was proper or appropriate? 
15. 
Describe what age you thought the Plaintiff was when you first had sexual activity with 
her, including your reasons for that belief. 
16. 
State the facts upon which you rely for each affirmative defense in your answer. 
EFTA00729663

17. 
Do you have any remorse for your sexual interaction with then minor Plaintiff ■ 
18. 
Do you have any remorse for interacting sexually with other minor females? 
19. 
Do you intend to interact sexually with minors in the future? 
20. 
Do you derive any income from trafficking underage minor females for sex? Please 
explain in detail how much money you have made from sex trafficking since 1998. 
EFTA00729664

21. 
On how many occasions have you committed the following acts with underage minor 
females: 
A) felt her breasts 
B) inserted your fingers into her vagina 
C) engaged in full sexual intercourse 
D) rubbed her vagina or buttock over her clothes 
E) masturbated in her presence 
F) had her pinch your nipples while you mastubated 
22. 
Provide the names, addresses and telephone numbers of all the people that know of you 
interacting sexually with underage minors. 
EFTA00729665

I have read the foregoing Answers to Interrogatories and do swear that they are true and 
correct. 
Jeffrey Epstein, Defendant 
STATE OF FLORIDA 
: ss. 
COUNTY OF 
The foregoing instrument was acknowledged before me this 
day of 
2010, by JEFFREY EPSTEIN, who is personally known to me or who has produced 
as identification. 
My Commission Expires: 
Signature of Acknowledger 
Typed/Printed Name of Acknowledger 
Title or Rank 
Serial Number, if any 
EFTA00729666

Intentionally Left Blank 
EFTA00729667

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: CASE NO.: 9: I 0-ev-81 III -DIMITROULEAS/Snow 
Plaintiff, 
vs. 
JEFFREY EPSTEIN and 
Defendants. 
NOTICE OF SERVICE OF PLAINTIFF'S FIRST SET OF INTERROGATORIES TO 
DEFENDANT 
PLEASE TAKE NOTICE that the Plaintiff, 
by and through her undersigned 
counsel, has propounded unto the Defendant, Jeffrey Epstein, her First Set of Interrogatories, 
numbered I through 16, inclusive, to be answered in writing, under oath, pursuant to the 
applicable Florida Rules of Civil Procedure. 
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been 
provided together with service of the Complaint herein. 
FARMER, JAFFE, WEISSING, 
EDWARDS, FISTOS & LEHRMAN, PL 
Attorneys for Plaintiffs) 
425 North Andrews Avenue, Suite 2 
Fort Lauderdale, Fl 33301 
(954)524-2820 TELEPHONE 
954 524-2822 Fax 
BY: 
radley J. Ed 
ds 
Florida B• 
o. 542075 
EFTA00729668

UNITED STATES SOUTHERN DISTRICT OF FLORIDA 
Case #: CASE NO.: 9:10-ev-8I III -DIMITROULEAS/Snow 
Plaintiff, 
vs. 
JEFFREY EPSTEIN and 
Defendants. 
PLAINTIFF'S FIRST SET OF 
: 
INTERROGATORIES TO DEFENDANT 
COMES NOW the Plaintiff, 
by and through her undersigned counsel, and 
propounds unto the Defendant, JEFFREY EPSTEIN, her First Set of Interrogatories, numbered 1 
through 16, inclusive, to be answered in writing, under oath, pursuant to the applicable Florida 
Rules of Civil Procedure. 
I HEREBY CERTIFY that the original and one true and correct copy of the above and 
foregoing has been provided together with service of the Complaint herein. 
FARMER, JAFFE, WEISSING, 
EDWARDS, FISTOS & LEHRMAN, PL 
Attorneys for Plaintiff(s) 
425 North Andrews Avenue, Suite 2 
Fort Lauderdale, Fl 33301 
(954)524-2820 TELEPHONE 
954 524-2822 Fax 
BY: 
Bradley J. 
wards 
Flori 
No. 542075 
EFTA00729669

DEFINITIONS 
1. 
The term "document" as used herein means and includes, without limitation, all 
writings of any kind, including the originals and all non-identical copies or drafts, whether 
different from the original by reason of any notation made on such copy or draft or otherwise 
including, without limitation, correspondence, memoranda, notes, diaries, statistics, letters, e-
mail, electronic computer files, telegrams, minutes, contracts, reports, studies, checks, 
statements, receipts, returns, summaries, pamphlets, books, prospectuses, interoffice 
communications, offers, notations of any sort of conversation, telephone calls, meetings or other 
communications, bulletins, printed matter, computer print-outs, teletypes, facsimiles, invoices, 
work sheets and all drafts, alterations, modifications, changes, and amendments of any of the 
foregoing, graphic or aural writs, records or representations of any kind including, without 
limitation, photographs, charts, graphs, microfiche, microfilm, videotape, recordings, motion 
pictures; and electronic, mechanical or electric records or representations of any kind including, 
without limitation, tapes, cassettes and disc recordings, and writings and printed material of 
every kind, whether or not the document is out of your possession, custody or control. 
2. 
The term "correspondence" as used herein is defined to mean any tangible object 
that conveys information or memorializes information that was conveyed in tangible or oral form 
including, but not limited to, writings, letters, memoranda, reports, notes, telegrams and 
interoffice communication. 
3. 
The term "relating to" as used herein is defined to mean evidencing, referring to, 
pertaining to, consisting of, reflecting, concerning, or in any way logically or factually connected 
with the matter discussed. 
4. 
The phrase "describe and explain" and the term "state" as used herein are intended 
to and shall be interpreted to request a full and fair statement of the fact or matter being 
described and explained, including a statement of all facts, statements, events and circumstances 
necessary to understand and evaluate the fact or matter being described and explained. 
5. 
The term "identify" as used in each of the following Interrogatories requesting an 
identification of documents is intended to be interpreted to request and require: 
A. 
The date of the document; 
B. 
The originator of the document; 
C. 
The type of document; 
D. 
The addressee of the document, if any; 
E. 
Identification of persons to whom copies of the documents were furnished; 
F. 
Details as to the custody of the document on the date the Interrogatories 
are answered; 
EFTA00729670

G. 
Specific page numbers where the information requested may be found, if 
appropriate; or, alternatively, documents may be identified by numbering each such document 
and referring to the number in the answer and providing a true copy of each such numbered 
document with the Answers to Interrogatories. 
6. 
The term "identify" as used in each of the following Interrogatories requesting the 
identification of persons is intended to be interpreted to request and require for each witness 
known: 
A. 
The full name of the individual; 
B. 
The last known address and phone number of the individual; 
C. 
The last known place, address and phone number of employment of the 
individual; 
D. 
The substance of the witness' knowledge or information relating to the 
information requested. 
INSTRUCTIONS 
Before answering the following Interrogatories, will you please make such inquiries of 
your agents, servants, employees and/or attorneys as will enable you to make full and true 
answers to the following, in accordance with the applicable Florida Rules of Civil Procedure. 
Additionally, if more space is required, please use a separate sheet of paper and attach same 
behind the sheet where the respective question appears. 
EFTA00729671

PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT 
(If answering for another person or entity, answer with respect to that person or entity, unless 
otherwise stated.) 
1. 
What is the full name and Florida address of the person answering these interrogatories, 
and, if applicable, the person's official position or relationship with the party to whom the 
interrogatories are directed? 
2. 
Who is currently in possession of the computer equipment that was removed from your 
home in 2005, just prior to the execution of the search warrant? 
3. 
List each telephone number used by you or your assistants to call minor females directly, 
or indirectly, for the purpose of scheduling a massage to take place at your house located 
at 358 El Brillo Way, West Palm Beach (includes landlines, cell phones, and private jet 
or airplane lines). For each cell phone, list the provider. 
EFTA00729672

4. 
Last known name, address, and telephone numbers of all persons that may have any 
knowledge about any of the allegations in the Complaint, including, but not limited to, 
friends, acquaintances, employees, or others to whom you have spoken about the subject 
matter which forms the basis of this Complaint or who have observed such activity. 
5. 
Provide a complete list of the names of all females with whom you interacted sexually, 
who were at the time under 18 years of age. This is meant to include interactions at any 
time or any place. 
6. 
Provide a complete list of the names of all known or suspected minors with whom you 
had sexual activities from 2002 to date. 
EFTA00729673

7. 
Describe with as much specificity as possible where you resided from August 2002 
through the present (this interrogatory is meant to include time spent at each of your 
houses since August 2002). 
8. 
List of all employees, servants, cleaning staff, personal staff or assistants employed by 
you or your companies who worked out of or visited your residence in West Palm Beach 
between August 2002 and the present, including their dates of employment, their job 
duties and title, and their last known address and telephone numbers. 
9. 
State with as much specificity as possible when you met the Plaintiff, and include in your 
answer the following: (a) the circumstances and location of how and where you met, (b) 
describe the nature of your relationship; (c) describe how many occasions she was with 
you at your residence located at 358 El Brillo Way in West Palm Beach, Florida. 
EFTA00729674

. 
EFTA00729675

10. 
Was there ever an employment or business relationship between you and the Plaintiff, 
and if so specify the duration of this relationship and how this relationship ended, 
including the nature of the remuneration to Plaintiff and what evidence or documentation 
exists of that relationship. 
II. 
Describe in your own words the method you used to procure females to provide you with 
massages. Include in your response the specific role
loshmitecir, 
includi 
Silo 
- 
hi lain Maxwell, 
your housekeepers, Jean Luc Brunel, or any 
others. 
12. 
Did you ever engage in sexual activity of any kind whatsoever with the Plaintiff, and 
include in your answer what type of sexual activity took place, where it took place, and 
the dates or general timeframe when this activity occurred. 
1 
EFTA00729676

13. 
Was it your intent to harm or injure the Plaintiff when you were interacting with her? 
14. 
Describe any words or actions that you made to assure the Plaintiff that sexual activity 
with you was proper or appropriate? 
15. 
Describe what age you thought the Plaintiff was when you first had sexual activity with 
her, including your reasons for that belief. 
16. 
State the facts upon which you rely for each affirmative defense in your answer. 
EFTA00729677

17. 
Do you have any remorse for your sexual interaction with then minor Plaintiff 
18. 
Do you have any remorse for interacting sexually with other minor females? 
19. 
Do you intend to interact sexually with minors in the future? 
20. 
Do you derive any income from trafficking underage minor females for sex? Please 
explain in detail how much money you have made from sex trafficking since 1998. 
EFTA00729678

21. 
On how many occasions have you committed the following acts with underage minor 
females: 
A) felt her breasts 
B) inserted your fingers into her vagina 
C) engaged in full sexual intercourse 
D) rubbed her vagina or buttock over her clothes 
E) masturbated in her presence 
F) had her pinch your nipples while you mastubated 
22. 
Provide the names, addresses and telephone numbers of all the people that know of you 
interacting sexually with underage minors. 
EFTA00729679

I have read the foregoing Answers to Interrogatories and do swear that they are true and 
correct. 
Jeffrey Epstein, Defendant 
STATE OF FLORIDA 
: ss. 
COUNTY OF 
The foregoing instrument was acknowledged before me this 
day of 
, 
2010, by JEFFREY EPSTEIN, who is personally known to me or who has produced 
as identification. 
My Commission Expires: 
Signature of Acknowledger 
Typed/Printed Name of Acknowledger 
Title or Rank 
Serial Number, if any 
4 
EFTA00729680

Intentionally Left Blank 
EFTA00729681

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 9:10-cv-81111 -DIMITROULEAS/Snow 
Plaintiff, 
vs. 
JEFFREY EPSTEIN and 
Defendants. 
NOTICE OF VIDEO DEPOSITION OF JEFFREY EPSTEIN 
PLEASE TAKE NOTICE that the attorney for the plaintiff in the above-styled 
cause will take the video deposition of Jeffrey Epstein on Wednesday, November 10, 
2010 at 10:00 a.m. for the purposes of discovery at the following location: 
US LEGAL SUPPORT 
444 West Railroad Avenue, Suite 300 
%Vest Palm Beach, FL 33401 
Said deposition will be taken before US Legal Support, a Notary Public or any officer 
authorized to administer oaths by the laws of the State of Florida, and a person who is 
neither a relative, nor employee, nor attorney, nor counsel of any of the parties and who 
is neither a relative nor employee of such attorney or counsel, and who is not financially 
interested in the action. 
Said deposition will be taken pursuant to Florida Rules of Civil Procedure in such 
cases provided. Said oral examination will continue from hour to hour and from day to 
day until completed. 
EFTA00729682