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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

EFTA00182748

256 pages
Pages 221–240 / 256
Page 221 / 256
Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 9 of 20 
i= 
vs. Epstein, et at. 
Case No.: 08-CV-80811-CIV-MARRAMOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
Palm Beach Police Department 
345 South County Road 
Palm Beach, FL 33480 
Tel: 
Subject matter: 
Investigator. 
18. 
Subject matter: 
Former boyfriend of a victim of Epstein. 
19. 
Sgt 
Palm each Police Department 
345 South County Road 
Palm Beach. FL 33480 
Tel: 
20. 
Subject matter: 
Investigator. 
21. 
supervisor 
Sat
igatBureau 
of the Town of Palm Beach 
3101 N.W. 16th Terrace 
Pompano Beach, FL 33064 
Tel: (877) 46-WASTE 
Subject matter: 
The incident which is the subject matter 
of this lawsuit. Discovery is ongoing. 
22. 
Major 
Palm Beach County Sheriffs Office 
3228 Gun Club Road 
West Palm Beach, FL 33406 
9 
EFTA00182968
Page 222 / 256
Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 10 of 20 
vs. Epstein, et al. 
Case No,: 08-CV-80811-CIV-MARRA/JOHNSON 
Plaintiff's Answers to Defendant's First Interrogatotics 
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. 
3580 Brillo Way 
Palm Beach, FL 33480 
Subject matter: 
Associate of Epstein. 
26. 
Parent Child Center 
West Palm Beach, FL 
Subject matter: 
Counselor at Parent Child Center. 
26. 
Detective 
Palm Beach Police Department 
345 South County Road 
Palm Beach. FL 33480 
Tel: 
Subject matter: 
investigator. 
27. 
Chief Michael Reiter 
Palm Beach Police Department 
345 South County Road 
Palm Beach, FL 33480 
Tel: 
28. 
Subject matter: 
Investigator. 
(Address unknown at this time) 
Subject matter: 
Associate of Epstein who facilitated introductions 
with various victims. 
10 
EFTA00182969
Page 223 / 256
Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 11 of 20 
C.M.A. vs. Epstein, et al. 
Case No.: 08-CV-80131I-CIWMARRADONNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
29. 
Alfredo Rodriguez 
(Address unknown at this time) 
Subject matter: 
Employee of Epstein. 
30. 
Detective 
Palm Beacti lliRepartment 
345 South County Road 
Pal Beach. FL 33480 
Tel: 
Subject matter: 
Investigator 
31. 
Esquire 
Lt Assiiftit-
iU .S. Attorney 
U.S. Dept. of Justice 
500 South Australian Avenue 
Suite 400 
West Palm Beach, FL 33401 
Tel: 
Subject matter: 
Federal prosecutor. 
32. 
ederal-Bureau of Investigation 
505 South Flagler Drive, Suite 500 
West Palm Beach, FL 33401 
Subject matter: 
Investigator. 
33. 
Dr. Thys 
Address will be provided upon receipt 
West Palm Beach 
Subject matter: 
s physician. 
34. 
Assistant U.S. A orney 
U.S. Dept. of Justice 
500 South Australian Avenue 
11 
EFTA00182970
Page 224 / 256
Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 12 of 20 
IN" vs. Epstein, et al. 
Case No.: 08-CV-8081I-CIV-MARRABOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
Suite 400 
West Palm Beach.  FL 33401 
Tel: 
Subject matter: 
Federal prosecutor. 
36. 
(Address will be provided upon receipt) 
Subject matter: 
Friend of 
mother. 
36. 
37. 
38. 
(Address will be provided upon receipt) 
Subject matter: 
Friend of 
s mother 
(Address will be provided upon receipt) 
Subject matter: 
Potential victim and friend of 
(Address unknown at this time) 
Subject matter: 
Associate of Epstein who may have 
nvolved 
In encounters between Epstein and 
6. 
Please state the specific nature and substance of the knowledge that you believe 
the person(s) identified in your response to Interrogatory no. 5 may have. 
ANSWER 
Please see answer to Interrogatory #5 
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 
12 
EFTA00182971
Page 225 / 256
Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 13 of 20 
vs. Epstein, et at. 
e 
08-CV-80811-CIV-MARRADOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
School behavioral problems, received counseling prior to the incident. 
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 another occasion I used cocaine powder. I do not recall the date. 
9. 
Describe each injury (physical, emotional, mental) for which you are claiming 
damages in this case, specifying the part of your body that was injured, the 
nature of the injury and as to any injuries you contend are permanent, the effects 
on you that you claim are permanent. 
ANSWER 
10. 
Please state each item of damage that you claim, and include in your answer: the 
count to which the item of damages relates; the factual basis for each Item of 
damages; and an explanation of how you computed each item of damages, 
including any mathematical formula used. 
ANSWER 
I am claiming compensation for mental anguish, mental pain, psychic 
trauma, and loss of enjoyment of life. These damages will be evaluated by 
a jury who will provide their own methods of computation in an amount of 
at least the statutory minimum established by 18 U.S.C.A. § 2266. 
Discovery is ongoing. 
11. 
List the names and business addresses of each physician (including psychiatrist, 
psychologist, chiropractor or medical provider) who has treated or examined you, 
13 
EFTA00182972
Page 226 / 256
Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 14 of 20 
C.M.A. vs. Epstein, et al. 
Case No.: 08-CV-80811-C1V-MARRA/JOHNSON 
Plaintiffs Answers to Defendant's First Interrogatories 
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 
Dr. Sem) Thys (Psychiatrist) 
216145"' Street 
West Palm Beach, FL. 33407 
(CounselorlTherapist) Date: Since high school. Ongoing. 
Parent Child Center 
2001 W. Blue Heron Boulevard 
Date: I do not recall the date. I would defer 
to the Doctor's records. 
12. 
List the names and business addresses of all other physicians, medical facilities, 
rehab facilities (drug, alcohol or psychiatric) or other health care providers 
Including psychiatrist, psychologist, mental health counselor and chiropractors by 
whom or at which you have been examined or treated In the past 10 years; and 
state as to each the dates of examination or treatment and the condition or injury 
for which you were examined or treated. 
ANSWER 
14 
EFTA00182973
Page 227 / 256
Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 15 of 20 
C.M.A. vs. Epstein, et al. 
Case No.: 08-CV-8081 I-CIV-MARRAEOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
13. 
State the name and address of every person known to you, your agents, or your 
attorneys, who has knowledge about, or possession, custody, or control of, any 
model, plat, map, drawing, motion picture, video tape, or photograph pertaining 
to any fact or issue involved in this controversy; and describe as to each, what 
item such person has, the name and address of the person who took or prepared 
it, and the date it was taken or prepared. 
ANSWER 
The FBI has photos taken of me at Jeffrey Epstein's home b 
Jeffrey Epstein had a photo taken of me at his home by 
14. 
Please state if you (or parents or guardian on your behalf) have ever been a 
party, either plaintiff or defendant, In a lawsuit other than the present matter, and, 
if so, state whether you were plaintiff or defendant, the nature of the action, and 
the date and court in which such suit was filed. 
ANSWER 
No 
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 
15 
EFTA00182974
Page 228 / 256
Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 16 of 20 
vs. Epstein, et al. 
ase o.: 08-CV-801311-CIV-MARIOVJOIENSON 
Plaintiffs Answers to Defendant's First Interrogatories 
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. 
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 fries' 
in 2002. I was to 
give Jeffrey Epstein a massage. I continued to provide massages up until 
August of 2003. I was transport I to Jeffre E)stein's house b Yellow 
ed b Jeffre E stein 
(Address will be provided upon receipt} 
17. 
State the amount of monies (or anything else of value, including gifts) you claim 
were given or paid to you by Mr. Epstein (or someone paid/gave you on hls 
behalf and that person's name, address and phone number) by year from 2000-
2006. 
ANSWER 
$200-$300 for a massage session at an average of 2 sessions a week from 
May or June of 2002 to Au ust 2003. 
$500 for a photo taken by 
at Jeffrey Epstein's house 
Paid for taxi cabs 
Concert tickets-Incubus, delivered by two girls at the concert 
Clothes and lingerie sent by FedEx 
Book-Massage for Dummies 
CD 
Flowers 
Express gift card 
16 
EFTA00182975
Page 229 / 256
Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 17 of 20 
vs. Epstein, et al. 
so 
08-CV-80B I I-CIV-MAIRRA/JOIINSON 
Plaintiff's Answers to Defendant's First Interrogatories 
18. 
List separately the names, addresses and phone numbers of all males, excluding 
Mr. Epstein, with whom you have had sexual activity since age 10 (by year) up 
through your current age. Describe the nature of sexual activity, the date(s) and 
whether you received money or other consideration from the person. 
ANSWER 
Objection. Relevance and overbroad. 
19. 
List separately the names, addresses and phone numbers of all males, excluding 
your claims against Mr. Epstein, whom you have claimed (formally or informally) 
committed sexual assault or battery on you since age 10 (by year) up through 
your current age. Describe the nature of sexual assault or battery, the date(s) 
and whether you received money or other consideration from the person. 
ANSWER 
None. 
20. 
State the names, addresses and phone numbers of all males, excluding your 
claims against Mr. Epstein, whom you have claimed (formally or informally) 
committed lewd or lascivious conduct to you since age 10 (by year) up through 
your current age. Describe the lewd or lascivious conduct, the date and whether 
you received money or other consideration from the person. 
ANSWER 
None 
21. 
State the names, addresses and phone numbers of all males, excluding your 
claims against Mr. Epstein, whom you have claimed (formally or informally) 
committed lewd or lascivious exhibition to you since age 10 (by year) up through 
your current age. Describe the lewd or lascivious exhibition, the date and 
whether you received money or other consideration from the person 
ANSWER 
None 
22. 
List in detail all discussions/interviews which you had with any representative 
17 
EFTA00182976
Page 230 / 256
Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 18 of 20 
IM. vs. Epstein, et al. 
Case No.: 0 8-CV-80811-CIV-MARIWJOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
from FBI, U.S. Attorneys' Office, State Attorneys' Office (Palm Beach County), 
Palm Beach Sheriff's Office and Palm Beach Police Department regarding your 
meetings with Mr. Epstein. Include dates, who was present, the details of what 
was discussed, whether a court reporter was present and whether a taped 
statement was taken or whether you provided a written statement. 
ANSWER 
I was interviewed by the FBI and a State Attorney, they have my statement. 
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 
24. 
Please list each time you were interviewed by any state or federal law 
enforcement agent or prosecutor, who was present, whether notes were taken, 
and what you recall saying to them. 
ANSWER 
I do not recall who interviewed me. This information would be available In 
the FBI and Prosecutors office. They took notes and I was not provided 
with a copy of those notes. 
25. 
Please describe any statements made to you by any federal or state law 
enforcement agent or prosecutor regarding the availability of civil remedies 
against Mr. Epstein and regarding whether there would be any benefit from your 
voluntary cooperation with law enforcement. 
ANSWER 
None 
18 
EFTA00182977
Page 231 / 256
Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 19 of 20 
C.M.A, vs. Epstein, et al. 
Case No.: 08-CV-130811-CIV-MARRA/JOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
Signature of Answering Pare? 
STATE OF 
Florida 
COUNTY OF Palm Beach ) 
The foregoing instrument was acknowledged before me this  /7  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: 
19 
EFTA00182978
Page 232 / 256
Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 20 of 20 
vs. Epstein, et al. 
08-CV-80811-CIV-MARRMOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
COUNSEL LIST 
Jack A. Goldberger 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue S. 
West Palm Beach FL 33401 
Phone: 
Attorneys for Je&ey Epstein 
Bruce E. Reinhart, Esquire 
Bruce E. Reinhart, P.A. 
250 South Australian Avenue 
Suite 1400 
West Palm B 
FL 33401 
Phone: 
Fax: 
Attorneys or 
Robert Critton 
Duman Critton Luttier & Coleman LLP 
515 North Flagler Drive, Suite 400 
West Palm Beach, FL 33414 
Phone: 
Fax: 
Attorneys ore ey Epstein 
Richard H. Willits, Esquire
Richard H. Willits, P.A. 
2290 10th Avenue North 
Suite 404 
Lake Worth FL 33461 
Phone: 
Fax: 
Attorneys or Party 
20 
EFTA00182979
Page 233 / 256
Case 9:08-cv-80119-KAM 
Document 147-3 
Entered on FLSD Docket 06/08/2009 
Page 1 of 12 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON 
Plaintiff(s), 
VS. 
JEFFREY EPSTEIN and IM 
Defendant(s). 
PLAINTIFF'S INITIAL DISCLOSURE 
COMES NOW the Plaintiff, =, 
by and through her undersigned attorneys, 
and hereby files her Initial Disclosure In compliance with the Joint Discovery 
Plan/Scheduling Report dated August 18, 2008, as follows: 
(A) 
Name and, If known, the address and telephone number of each 
individual likely to have discoverable information that the disclosing party may 
use to support its claim or defenses, unless solely for impeachment, identifying 
the subjects of the information: 
1. 
do her attorneys: 
Jack Scarola, Esq. and Jack P. Hill, Esq. 
Searcy Denney Scarola Barnhart & Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
West P I 
ach FL 33409 
Tel: 
Richard Willits, Esq. 
Richard H. Willits, P.A. 
2290 10th Avenue North, Suite 404 
Lake Vyorth. FL 33461 
Tel: 
EFTA00182980
Page 234 / 256
Case 9:08-cv-80119-KAM 
Document 147-3 
Entered on FLSD Docket 06/08/2009 
Page 2 of 12 
vs. Epstein, et af. 
08-CV-80811-CIV-MARRAJJOHNSON 
Plaintiffs Initial Disclosure 
Page 2 of 12 
Subject matter: 
Plaintiff. 
2. 
Jeffrey Epstein 
do his attorneys: 
Robert Critton, Esquire 
Burman Critton Luttier & Coleman LLP 
515 North Flagler Drive, Suite 400 
West Palm Beach, FL  33414 
Tel: 
Jack A. Goldberger, Esquire 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue South 
West P 
e ch FL 33401 
Tel: 
Bruce E. Reinhart, Esquire 
Bruce E. Reinhart, P.A. 
250 South Australian Avenue 
Suite 1400 
West P 
L 33401 
Tel: 
Subject matter. 
Defendant 
3. 
do 
's attorneys: 
Jack Scarola, Esq. and Jack P. Hill, Esq. 
Searcy Denney Scarola Barnhart & Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, FL  33409 
Tel: 
Richard Willits, Esq. 
Richard H. Willits, P.A. 
2290 10th Avenue North, Suite 404 
Lake Worth FL 33481 
Tel: 
Subject matter: 
jjjjjjjjjjjjjjjj 's involvement with Epstein. 
EFTA00182981
Page 235 / 256
Case 9:08-cv-80119-KAM 
Document 147-3 
Entered on FLSD Docket 06/08/2009 
Page 3 of 12 
vs. Epstein, et al. 
08-CV-80811-CIV-MARRA/JOHNSON 
Plaintiffs Initial Disclosure 
Page 3 of 12 
4. 
Address un
Subject matter: 
Defendant. 
5. 
Jane Doe (Case No.: 1:93-cv-01109-KAM) 
do her attorney: 
Theodore Leopold, Esquire 
Leopold, Kuvin, P.A. 
2925 P.G.A. Boulevard, Suite 200 
Palm Beach Gardens, FL 33410 
Tel: 
Subject matter: 
Victim of Epstein. 
8. 
Jane Doe (Case No.: 502008CA020614) 
c/o her attorney: 
Isidro M. Garcia, Esquire 
The Law Office of Brad Edwards & Associates, LLC 
2028 Harrison Street, Suite 202 
HoII  wood. Fl 33020 
Tel: 
Subject matter: 
Victim of Epstein. 
7. 
Jane Doe #2 (Case No.: 9:08-ov-80119-KAM) 
do her attorney: 
Jeffrey M. Herman, Esquire 
Herman & Mermeistein, P.A. 
18205 Biscayne Boulevard, Suite 2218 
Mia  I FL 33180 
Tel: 
Subject matter. 
Victim of Epstein. 
EFTA00182982
Page 236 / 256
Case 9:08-cv-80119-KAM 
Document 147-3 
Entered on FLSD Docket 06/08/2009 
Page 4 of 12 
vs. Epstein, et al. 
08-CV-80811-CIV-MARRNJOHNSON 
Plaintiff's initial Disclosure 
Page 4 of 12 
8. 
Jane Doe #3 (Case No.: 9:08-cv-80232-KAM) 
c/o her attorney: 
Jeffrey M. Herman, Esquire 
Herman & Mermelstein, P.A. 
18205 Biscayne Boulevard, Suite 2218 
Miami, FL 33160 
Tel: 
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. 
18205 Biscayne Boulevard, Suite 2218 
Miami, FL 33160 
Tel: I 
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. 
18205 Biscayne Boulevard, Suite 2218 
Miami, FL 33160 
Tel: I 
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. 
2925 P.G.A. Boulevard, Suite 200 
Palm Beach Gardens, FL 33410 
Tel: 
Subject matter: 
Victim of Epstein. 
EFTA00182983
Page 237 / 256
Case 9:08-cv-80119-KAM 
Document 147-3 
Entered on FLSD Docket 06/08/2009 
Page 5 of 12 
vs. Epstein, et al. 
06-CV-80811-CIV-MARFtA/JOHNSON 
Plaintiffs Initial Disclosure 
Page 6 of 12 
12. 
Jane Doe #7 (Case No.: 9:08-cv-80993-KAM) 
do her attorney: 
Jeffrey M. Herman, Esquire 
Herman & Mermelstein, P.A. 
18205 Biscayne Boulevard, Suite 2218 
Mia  • FL 33160 
Tel: 
Subject matter: Victim of Epstein. 
13. 
(Case No.: 502008CA025129XXXXMB Al 
c/o her attorneys: 
Jack Scarola, Esquire 
Jack P. Hill, Esquire 
Searcy Denney Scarola Barnhart & Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach. FL 33409 
Tel: 
Subject matter: 
Victim of Epstein. 
14. 
Jose Alessi 
(Address unknown at this time) 
Subject matter: 
Jeffrey Epstein's Butler. 
15. 
Palm Beach Police Department 
345 South County Road 
Pal  Beach. FL 33480 
Tel: 
Subject matter: 
Investigator. 
16. 
Palm Beach County Prosecutors Office 
401 North Dixie Highway 
West Palm Reach  L 33401 
Tel: 
Subject matter: 
Prosecutor. 
EFTA00182984
Page 238 / 256
Case 9:08-cv-80119-KAM 
Document 147-3 
Entered on FLSD Docket 06/08/2009 
Page 6 of 12 
vs. Epstein, et al. 
ase 
08-CV-80811-CIV-MARRAAJOHNSON 
Plaintiffs Initial Disclosure 
Page 8 of 12 
17. 
Detective 
lead Investigator 
Palm Belli 
Department 
345 South County Road 
Palm Beach, FL 33480 
Tel:
Subject matter: 
Investigator. 
18. 
FL 33411-1228 
Subject matter: 
Former boyfriend of a victim of Epstein. 
19. 
Sgt. 
Palm each Police Department 
345 South County Road 
Palm Beach, FL 33480 
Tel: 
20. 
Subject matter: 
Investigator. 
Subject matter: 
Plaintiffs former boyfriend. 
21. 
supervisor 
Sanitation Bureau of the Town of Palm Beach 
3101 N.W. 161h Terrace 
Pompano Beach, FL 33064 
Tel: (877) 46-WASTE 
Subject matter: 
The incident which is the subject matter 
of this lawsuit. Discovery is ongoing. 
22. 
Major 
Palm IMounty Sheriffs Office 
3228 Gun Club Road 
West Palm Beach, FL 33406 
Subject matter: 
Investigator. 
EFTA00182985
Page 239 / 256
Case 9:08-cv-80119-KAM 
Document 147-3 
Entered on FLSD Docket 06/08/2009 
Page 7 of 12 
vs. Epstein, et al. 
ase o.: 08-CV-80811-CIV-MARRNJOHNSON 
Plaintiffs Initial Disclosure 
Page 7 of 12 
23. 
Amanda, friend of 
(Address will be prov ed upon receipt) 
Subject matter: 
Victim and friend of 
24. 
Ghislane Maxwell do Ghislane Corp. 
3580 Brillo Way 
Palm Beach, FL 33480 
Subject matter: 
Associate of Epstein. 
25. 
Parent Child Center 
West Palm Beach, FL 
Subject matter: 
Counselor at Parent Child Center. 
26. 
Detective 
Palm Beach Police Department 
345 South County Road 
Pal  Beach. FL 33480 
Tel: 
Subject matter: 
Investigator. 
27. 
Chief Michael Reiter 
Palm Beach Police Department 
345 South County Road 
Tel Beach FL 33480 
Tel: 
28. 
Subject matter: 
Investigator. 
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. 
EFTA00182986
Page 240 / 256
Case 9:08-cv-80119-KAM 
Document 147-3 
Entered on FLSD Docket 06/08/2009 
Page 8 of 12 
vs. Epstein, et al. 
08-CV-80811-CIV-MARRA/JOHNSON 
Plaintiffs Initial Disclosure 
Page 8 of 12 
30. 
Detective 
Palm Beacti l.Department 
345 South County Road 
Palm Beach, FL 33480 
Tel: 
Subject matter: 
Investigator 
31. 
 
 Esquire 
first Assistant U.S. Attorney 
U.S. Dept of Justice 
500 South Australian Avenue 
Suite 400 
West Palm Beach, FL 33401 
Tel: 
Subject matter: 
Federal prosecutor. 
32. 
ederal Bureau of Investigation 
505 South Flagler Drive, Suite 500 
West Palm Beach, FL 33401 
Subject matter: 
Investigator. 
33. 
Dr. Thys 
Address will be provided upon receipt 
West Palm Beach 
Subject matter: 
Ms 
physician. 
34. 
Assistant U.S. Attorney 
U.S. Dept. of Justice 
500 South Australian Avenue 
Suite 400 
West Palm Beach. FL 33401 
Tel: 
Subject matter: 
Federal prosecutor. 
35. 
(Address will be provided upon receipt) 
Subject matter: 
Friend of C.M.A's mother. 
EFTA00182987
Pages 221–240 / 256