Valikko
Etusivu Tilaa päivän jae Raamattu Raamatun haku Huomisen uutiset Opetukset Ensyklopedia Kirjat Veroparatiisit Epstein Files YouTube Visio Suomi Ohje

This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →

FBI VOL00009

EFTA00157905

17 pages
Page 1 / 17
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
Page 2 / 17
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
Page 3 / 17
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
Page 4 / 17
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
Page 5 / 17
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
Page 6 / 17
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
Page 7 / 17
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
Page 8 / 17
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
Page 9 / 17
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
Page 10 / 17
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
Page 11 / 17
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
Page 12 / 17
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
Page 13 / 17
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
Page 14 / 17
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
Page 15 / 17
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
Page 16 / 17
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
Page 17 / 17
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