EFTA00729603

Case 9:10-cv-81111-XXXX Document 1-1 Entered on FLSD Docket 09/17/2010 Page 6 of 10 
detection. Epstein's key "lieutenant" in the Palm
 branch of this national 
and possibly international organization was 
who served as both his 
scheduler and a recruiter/procurer of the girls. This was an important function, as 
the recruiting was necessary to satisfy Epstein's desire to abuse a large number of 
different minor girls with different (albeit similar) physical attributes and the 
scheduling was necessary to insure that the minor girls would be brought to 
Epstein's mansion to be sexually abused and prostituted at a time when Epstein 
was there (but not at the same time, when they might learn of other girls' 
identities and possibly become emboldened to report his activities to law 
enforcement.) Scheduling was also necessary to ensure secrecy, so that as few 
persons as possible were aware that minor girls were coming at unusual hours to 
Epstein's mansion. 
also needed (directly or indirectly) to make 
transportation arrangements for many of the irls as 
were often too young to 
drive themselves to and from the mansion. 
also served as a recruiter 
and helped Epstein satisfy his criminal sexual desires by, on occasion, 
participating in sexual abuse and prostitution of the minor girls. Epstein, 
and 
all took steps to conceal the existence of the enterprise and to 
discourage the girls from reporting the sexual abuse and prostitution to law 
enforcement or other authority figures. Epstein also used otherwise-legitimate 
business activities to help further the purpose of the criminal enterprise. These 
apparently legitimate activities provided "cover" for Epstein and his associates to 
commit the crimes. Ghislaine Maxwell and Jean Luc Brunel also helped to 
provide "cover" for the enterprise by creating the impression that there were 
legitimate modeling opportunities and other legitimate opportunities available for 
the girls if they went to see Epstein. Epstein also maintained the appearance of an 
extremely wealthy, upstanding and prominent figure to discourage the minor girls 
from reporting the abuse to law enforcement. To further impress the underage 
minor victims, he would tell them that he was a famous scientist, a brain surgeon, 
an inventor of various products including a state of the art liposuction device. He 
would also brag about the famous people with whom he was good friends. By 
projecting an image of financial power (and, relatedly, strong political 
connections to prominent politicians and current and former government officials 
and personal connections to prominent scientists), Epstein hoped to discourage 
the minor girls from reporting what he was doing to them by making it appear that 
they would not be believed. These business activities helped Epstein secure the 
financial resources to commit the crimes against the minor girls and to pay for 
prostituting them. For example, the activities paid for maintaining the mansion 
where the girls were abused and paid for the cellular telephones and other means 
of communications that were used to recruit and procure the gi
business 
activities also helped to provide the funds to pay 
and 
large 
sums of money to participate in the illegal enterprise and make payments to the 
girls for performing sexual acts. In sum, Epstein and the persons under his 
direction associated in fact and functioned as a continuing unit. This enterprise 
produced a course of conduct that lead to a pattern of criminal activity involving 
enterprise was the vehicle for Epstein to commit his crimes against 
more than 100 instances of sexual abuse and prostitution of minkrls. This
i 
and other 
6 
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Case 9:10-cv-81111-XXXX Document 1-1 Entered on FLSD Docket 09/17/2010 Page 7 of 10 
minor girls and operated on a continuing basis from June 2002 to November 2005 
(and, in regard to witness tampering and harassment, through at least early 2008). 
The enterprise enabled Epstein to sexually abuse and prostitute 
in particular 
on more than 20 occasions from February 2003 through June 2005. 
c. Epstein served as the effective leader or "C.E.O." of the enterprise. 
d. Epstein was associated with the enterprise as its effective leader or "C.E.O." 
e. Epstein directed the affairs of the enterprise and the others in the enterprise 
responded to his commands, although Ghislaine Maxwell and Jean Luc Brunel 
acted independently to advance their own interests (including sexual interests) 
along with the interests of Epstein. 
pi
f. Based on the facts that she currently possesses, 
specifically alleges and 
intends to prove both that (i) Epstein was an individual separate and disctinct 
from the enterprise and (ii) the defendant was a member of the enterprise, namely 
that he served as the effective leader of the enterprise. With regard to point (i), 
the illegal enterprise had a definite structure and operational function apart from 
Epstein. The structure is described in greater detail in this statement in answer 
5.b above. With regard to point (ii), the defendant was a member of the enterprise 
and served to execute many of the decisions and activities of the enterprise and to 
command the execution of others. Epstein personally engaged in sexual abuse of 
minor girls, including 
E stein also directed others to engage in sexual abuse 
of minor girls, including 
Epstein also procured girls for prostitution 
and caused these girls to be prostituted. Epstein also served as the leader of the 
enterprise. 
g. Epstein was a direct perpetrator of the racketeering activity. In particular, Epstein 
engaged in criminal acts of sexual abuse and prostitution with minor irls as well 
as procuring girls for prostitution. He also directed others (i.e., 
to 
engage in such criminal acts and served as the leader of the criminal enterprise. 
8. The relationship between the pattern of criminal activity and the enterprise is not completely 
known to 
at this time, and it is not known how much money or other consideration was 
generated by the enterprise through these illegal means. Through discovery, she intends to 
understand the relationship more fully. At this time, however, as described in addition in the 
complaint and parts 5, 6 and 7 in this statement, there was a criminal entity separate and apart 
from the pattern of activity in which it engaged. The pattern of criminal activity was the 
series of crimes committed by Epstein and others, and includes the specific crimes identified 
in part 5.a. above. These offenses were closely related and formed a clear pattern, as 
described in part 5.b above. These acts included acts of sexual abuse and procuring the 
prostitution of minors by Epstein personally and by 
acting at Epstein's direction. 
In contrast, the enterprise was the group of persons who associated together for the common 
purpose of engaging in the criminal course of conduct described at greater length elsewhere 
in this statement, including part 5.e above. The group of persons included Epstein, =, 
Maxwell, and Brunel and others whose identity is, at this time, unknown to 
9. In this part of the statement, M 
will provide a description of the relationship between the 
otherwise-lawful activities of the enterprise and the criminal activities of the enterprise. The 
lawful and unlawful activities of the enterprise have been described in addition in paragraphs 
10 through 18 and 42 through 43 of the complaint and previous answers found in parts 5, 6 
7 
EFTA00729644

Case 9:10-cv-81111-XXXX Document 1-1 
Entered on FLSD Docket 09/17/2010 Page 8 of 10 
and 7 above (which 
expressly incorporates into her answer here). The usual and daily 
activities of the criminal enterprise included scheduling meetings, activities, and other events 
for Epstein — including scheduling S"
ate time" in his mansion for Epstein to commit 
sexual crimes against minor girls. 
served as Epstein's scheduler, scheduling both 
otherwise-lawful activities to provide "cover" for Epstein as well as the illegal sexual 
activities. The exact fr-
cy with which the sexual crimes took place varied and is not 
known, at this time, to = 
However, when Epstein was in West Palm Beach, it often 
occurred on a weekly or daily basis (and, in some instances, took place on several times 
during a single day). The scheduling was designed to secure a private place in Epstein's 
mansion when few other persons would be present at the mansion, so as to reduce the chance 
of detection of Epstein's sexual abuse and prostitution as well as to make it more difficult for 
the minor girls to report his actions to law enforcement or other authorities. The usual 
activities of the enterprise also included maintaining the mansion and securing means of 
communication (i.e., cellular telephones) to recruit minor girls and procure them for 
prostitution. The activities further included arranging transportation for the girls to and from 
the mansion if it was necessary. The enterprise also attempted to make Epstein appear to be 
an upstanding and law-abiding member of community and a successful businessperson, for 
reasons described in paragraph 6.b above. The enterprise served as the usual way in which 
Epstein would obtain sexual gratification. 
10. Through his criminal enterprise, Epstein received perverse and unlawful sexual gratification 
from sexually abusing minor girls and engaging in acts of prostitution with them. He also 
received perverse sexual gratification from directing others (e.g., 
to sexually 
abuse and prostitute minor girls. 
11. While 
civil action alleges violations of the Florida Civil RICO statute rather than 
violations of the federal civil RICO statute, it should be noted that means of interstate 
communications were used to perpetrate the crimes against minor girls (including =, 
including cellular and other telephones that Epstein used, or caused to be used, to arrange his 
illegal sexual activities and to recruit additional minor girls to participate in these activities. 
Through his recruitment and procuring of young girls, Epstein's activities directly affected 
interstate commerce. 
12. Based on the information currently known to her
 does not allege that Epstein, who is a 
billionaire banker, used the enterprise to personally make a financial profit or to obtain the 
c 1 
on of an unlawful debt, only because that information has not yet been made available 
Epstein did, however, make payments to and prostitute the minor girls for the sexual 
gran cation that he obtained from them and to discourage them from reporting his crimes to 
law enforcement and other authorities. Epstein also has, through his criminal organization, 
prostitutes underage girls to others, and Epstein and the criminal organization gained 
valuable consideration from that activity, although it is unknown the type and amount of 
remuneration at this time. 
13. Based on the information currently known to her, Woes not allege that Epstein, who is a 
billionaire banker, used the enterprise to obtain or maintain control of a business enterprise or 
real property. 
Epstein did, however, use his West Palm Beach mansion (and his various 
other properties including his personal island) to perpetrate the crimes against the then-minor 
girls. He also used his financial success to provide "cover" for his crimes, as described in 
part 6.b above. 
14. The criminal enterprise is described in the complaint and part 6 of this statement above, 
8 
EFTA00729645

Case 9:10-cv-81111-XXXX Document 1-1 
Entered on FLSD Docket 09/17/2010 Page 9 of 10 
which description 
incorporates here. 
a. The enterprise including persons unkn 
but at least included Epstein and his 
paid assistants 
and 
as well as associates of Epstein (who 
were free to act in ependently and to advance their own interests) Ghislaine Maxwell and 
Jean Luc Brunel 
b. Under the direction of Epstein, MI, 
and others whose names 
are unknown to M.J. arranged for minor girls to come to Epstein's mansion where he 
could sexual abuse them and prostitute them to satisfy his perverse sexual des' s 
well 
as the perverse sexual desires of Ghislaine Maxwell and Jean Luc Brunel. 
and 
were responsible for recruiting the girls and procuring them for prostitution. 
was also responsible for scheduling a time when both Epstein and the minor girl 
cold—meet 
meet together at Epstein's mansion for the sexual abuse and for making travel 
arrangements (if necessary) for the girls. 
was also responsible for ensuring the 
privacy of the room in Epstein's mansion where Epstein would sexually abuse the girls. 
would articipate in abusin and prostituting the girls for Epstein's sexual 
grati ication. 
and 
received payments and other forms of 
compensation from ps 
illegal activities and for participating in 
the enterprise. Epstein, 
and 
also all took steps to discourage the girls 
from reporting these crimes to law en orcement, including making cash payments to the 
girls. Ghislaine Maxwell and Jean Luc Brunel helped to persuade the girls that legitimate 
modeling opportunities could be had if they went tlat  Epstein. 
c. As a result of the criminal enterprise, ME (then a minor) suffered criminal 
sexual abuse at the hands of Epstein. As alleged in greater detail in the complaint, this 
abuse lead to significant past and future physical injury, pain and suffering, emotional 
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-
esteem, loss of dignity, invasion of privacy, and other damages, including consequential 
damages from Epstein controlling, manipulating and coercing her into a perverse and 
unconventional way of life for a minor. In addition, the time involved in the abuse 
created lost opportunities to pursue other activities (indult economic activities) and 
lead to past and fu 
ncial and proprietary losses to 
as well as the need for 
psychiatric service:11a has also suffered a loss of income, a loss of capacity to earn 
income in the future, and a loss of the capacity to enjoy life. It has also lead to the need 
to file this civil suit, with consequent attorney's fees. All of these damages were caused 
by, and proximately caused by, the criminal enterprise and its criminal acts. All of these 
injuries were inflicted directly on 
and occurred by reason of the criminal acts of the 
enterprise, including the acts of sexual abuse by Epstein. 
d. The defendant "person" in the Florida Civil RICO action is, at this time, only 
defendant Epstein. 
Defendant Epstein is associated with a criminal enterprise that 
conducted and participated, both directly and indirectly, in a pattern of criminal activity 
in violation of both Florida and federal criminal law. The exact relationship between 
Epstein and the criminal enterprise is described in greater detail in parts 5 and 6 above. 
15. The criminal conspiracy involving the enterprise is described in the complaint as well as 
parts 5, 6, and 7 above.
expressly so 
information into her statement here. 
The conspiracy was formed of Epstein, 
and many others, who agreed to 
arrange for illegal sexual gratification by Epstein through t 
use and prostitution of 
minor girls both by Epstein personally and by others (i.e., 
while he watched, as 
9 
EFTA00729646

Case 9:10-cv-81111-XXXX Document 1-1 Entered on FLSD Docket 09/17/2010 Page 10 of 
10 
well as to provide illegal sexual gratification to Ghislaine Maxwell and Jean Luc Brunel. 
Certain other names of other criminal enterprise members and co-conspirators are known yet 
currently unnamed, and many other names are currently unknown but Plaintiff intends to 
learn the names and roles of all involved in the criminal activity of this enterprise. The many 
enterprise members conspired to commit similar crimes and to conceal those crimes also in 
furtherance of the criminal enterprise. The object and substance of the conspiracy was to 
obtain minor girls for Epstein so that he could satisfy his perverse sexual interest in minor 
girls, to recruit minor girls to be abused and prostituted for his gratification, to keep the 
existence of the sexual abuse from being learned by law enforcement and other authorities, 
and to discourage the victims from reporting the abuse to authorities, as well as to provide 
sexual gratification to Maxwell and Brunel. The conspiracy started in approximately June 
2002 in West Palm Beach, Florida, and other locations. The sexual abuse of the minor girls 
appears to have, at least temporarily, ceased in approximately 2005. 
The conspiracy 
extended beyond November 2005 to early 2008 (and perhaps later) in its efforts to keep the 
criminal conspiracy unknown, as described in n 5.f above. The conspiracy committed 
numerous overt acts. For example, 
and 
arranged for minor girls to be 
brought to Epstein's West Palm Beach mansion so that he could sexually abuse the girls and 
obtain sexual gratification. Epstein sexually abused minor girls at his mansion and made 
wilts 
to them and otherwise prostituted them there. 
16. 
suffered injuries, including financial and proprietary injuries, as described in part I3.0 
above. 
17. The enterprise injured ■ 
and the other minor girls by enabling Epstein to sexually abuse 
and prostitute the girls. 
18. Defendant Epstein is liable for all the damages for his criminal activity and the activity of his 
criminal enterprise. (If additional defendants are added to the complaint, these other 
defendants may also be jointly and severable liable for the damages.) The damages for 
which Epstein is liable include compensatory damages (including damages for emotional 
distress as well as damages for financial and proprietary losses), attorney's fees, and such 
further relief as the Court deems just and proper. 
The amount of these damAges is 
significant. These damages are trebled by operation of Florida Statutes 772.104. =is 
aware of the provision in Florida Statutes 772.104(3) ("In no event shall punitive damages be 
awarded under this section"), but is nonetheless entitled to punitive damages by virtue of her 
other counts in her complaint. She is seeking punitive damages for Epstein's outrageous and 
egregious conduct and crimes under other provisions of law in this lawsuit. 
19. All o 
bove answers must be read in light of the complaint that has been filed in this 
case. 
xpressly incorporates by reference her complaint as part of the answer to each of 
the above questions. Whenever the word "include" or its variations appears in this statement, 
the information that follows is not intended to be an exclusive listing. 
10 
EFTA00729647

Intentionally Left Blank 
EFTA00729648

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: CASE NO.: 9: I O-CV-81111 -DIMITROULEAS/SNOW 
Plaintiff, 
VS. 
JEFFREY EPSTEIN and 
Defendants. 
PLAINTIFF'S FIRST REQUEST FOR PRODUCTION TO DEFENDANT 
COMES NOW the Plaintiff by and through her undersigned counsel, and requests 
the Defendant, Jeffrey Epstein, to produce the original or best copy of the items listed 
hereinbelow, at the offices of the Plaintiff's undersigned counsel, for inspection and/or copying, 
pursuant to the applicable Florida Rules of Civil Procedure, the following: 
DEFINITIONS 
The term "documents" 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. 
EFTA00729649

The term "correspondence" means 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. 
DOCUMENTS REQUESTED 
1. 
Copies of all telephone records in your or your attorneys' possession from 2002 —
2005 that in any way relate to you (including all phone lines owned by you or that were used to 
contact girls for the purposes of scheduling massages for you). 
2. 
All massage appointment books, diaries, computer calendars or scheduling 
entries, scheduling books or any other writing or correspondence that contains the names of any 
of the girls that were called, contacted, scheduled, or who otherwise went to your home located 
at 358 El Brillo Way, West Palm Beach, Florida, for the purpose of giving you a massage. 
3. 
Any and all documentation in your possession that contains Plaintiff's name or 
that refers to Plaintiff, directly or indirectly, (including but not limited to emails, letters, message 
pads, diaries, appointment books, computer print outs). 
4. 
Any and all photos, videos, downloaded digital prints or any other visual 
depiction of Plaintiff or other known or suspected minor females introduced to you, directly or 
indirectly, by Plaintiff. 
5. 
Photos of the inside of your home located at 358 El Brillo Way, West Palm 
Beach, Florida, that depict the room(s) where the massages took place (including massage table). 
6. 
Any and all documentation of cancelled checks or evidence of payment to 
Plaintiff of any kind and for any reason whatsoever. 
7. 
All information obtained by you or your attorneys as a result of the exchange of 
information with law enforcement or prosecuting agencies relating to the State criminal case 
against you or the Federal investigation against you. 
EFTA00729650

8. 
Tax returns filed with the United States Internal Revenue Service from 2002 
through the present. 
9. 
Photocopies of your passport, including any supplemental pages reflecting visa's 
or entries to locations outside of the 50 United States. 
10. 
Any documents, photographs, witness interviews, summaries of investigations. 
police reports, and all other materials provided by local, state, or federal law enforcement 
investigators or local, state or federal prosecutors investigating you for sexual offenses against 
minors, including all such materials related to the guilty pleas you entered in state court and the 
non-prosecution agreement you executed with the U.S. Attorney's Office for the Southern 
District of Florida. 
11. 
All documents and correspondence between you, your agents, and your attorneys 
and (a) state or federal law enforcement officials and (b) local, state, and federal prosecutors 
(including, but not limited to, letters and e-mails to and from the State Attorney's office or any 
agents thereof and letters and e-mails to and from the U.S. Attorney's office or any agents 
thereof). 
12. 
All medical records of Defendant Epstein from any psychologist or psychiatrist, 
including but not limited to Dr. Stephan Alexander or any court appointed doctor. 
13. 
All medical records from any other doctor who has treated Defendant Epstein for 
sexual issues or who has provided prescriptions for Epstein related to sex issues. 
14. 
All bank and financial records and documents for bank accounts, checking 
accounts, savings accounts, stocks and bonds, and any other financial instruments or assets 
controlled, directly or indirectly, by Defendant Epstein for the period 2002 to the present. 
EFTA00729651

15. 
All records and documents reflecting ownership, directly or indirectly, of any real 
properties, vehicles, boats, and aircraft by Defendant Epstein for the period 2002 to the present. 
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 Plaintiff(s) 
425 North Andrews Avenue, Suite 2 
Fort Lauderdale, Fl 33301 
(954)524-2820 TELEPHONE 
954)524-2822 Fax 
BY: 
/ era Bradley J. Ed 
icC Florida BafNo. 542075 
EFTA00729652

Intentionally Left Blank 
EFTA00729653

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: CASE NO.: 9: I 0-cv-8 
-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 Plaintiff(s) 
425 North Andrews Avenue, Suite 2 
Fort Lauderdale, Fl 33301 
(954)524-2820 TELEPHONE 
BY: 
5,4,O 
radley J. Ed 
s 
Florida B 
o. 542075 
EFTA00729654

UNITED STATES SOUTHERN DISTRICT OF FLORIDA 
Case #: CASE NO.: 9:10-cv-III 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 
BY: 
wards 
Florida ar No. 542075 
EFTA00729655

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; 
EFTA00729656

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. 
EFTA00729657

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.) 
I. 
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. 
EFTA00729658

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. 
EFTA00729659

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. 
EFTA00729660

. 
. 
EFTA00729661

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. 
11. 
Describe in your own words the method you used to procure females to provide you with 
but not limited to — Ghislaine Maxwell, 
massages. Include in your response the specific roles of eachitoshat assisted you, 
Ellt 
joss
, your housekeepers, Jean Luc Brunel, or any 
of ers. 
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. 
4 
EFTA00729662