CT DATE(S) DEFENDANT(S) VICTIM(S) STATUTES/CHARGE 25 August 2003 - February 2004 Jane Doe #18 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 26 2001 - October 2005 N ill Jane Does 1-19 18 U.S.C. § 2423(e) Conspiracy to travel in interstate commerce for the purpose of engaging in illicit sexual conduct 27 2001 - October 2005 Jane Does 1-19 18 U.S.C. § 2423(d) For the purpose of commercial advantage or private financial gain, arranging or facilitating the travel of a person knowing that the person was traveling in interstate commerce for the purpose of engaging in illicit sexual conduct 28 I Jane Ir July 16. 2004 Jane Doe #7 Doe #8 Jane Doe #9 Jane Doe #10 18 U.S.C. §§ 2423(b) and 2 Traveling in interstate commerce for the purpose of engaging in illicit sexual conduct with a minor 29 August 6. 2004 \EPSTEIN Jane Doe #9 (Fayth P.) Jane Doe #11 (Alexandra IL) 18 U.S.C. §§ 2423(b) and 2 Traveling in interstate commerce for the purpose of engaging in illicit sexual conduct with a minor Pal,e 7 of 9 EFTA00182948
CT DATE(S) DEFENDANT(S) VICTIM(S) STATUTES/CHARGE 30 August 19, 2004 - \EPSTEIN Jane Doe #9 (Alexandra H.) Jane Doe #10 (Britany B.) Jane Doe #11 18 U.S.C. §§ 2423(b) and 2 Traveling in interstate commerce for the purpose of engaging in illicit sexual conduct with a minor 31 October 29, 2004 Sill " iPSTEIN Jane Doe #10 (Britany B.) Jane Doe #11 Jane Doe #13 (Dainya N.) 18 U.S.C. §§ 2423(b) and 2 Traveling in interstate commerce for the purpose of engaging in illicit sexual conduct with a minor 32 February 21, 2005 Jane Doe #11 (Vanessa Z.) Jane Doe #14 (Felicia E.) Jane Doe #15 18 U.S.C. §§ 2423(b) and 2 Traveling in interstate commerce for the purpose of engaging in illicit sexual conduct with a minor 33 March 31, 2005 STEIN Jane Doe #11 (Saige G.) Jane Doe #14 (Vanessa Z.) Jane Doe #15 (Fayth P.) Jane Doe #16 18 U.S.C. §§ 2423(b) and 2 Traveling in interstate commerce for the purpose of engaging in illicit sexual conduct with a minor 34 September 18, 2005 STEIN Jane Doe #16 (Ashley D.) 18 U.S.C. §§ 2423(b) and 2 Traveling in interstate commerce for the purpose of engaging in illicit sexual conduct with a minor Page 8 of 9 EFTA00182949
CT DATE(S) FENDANT(S) VICTIM(S) STATUTES/CHARGE 35 September 29, 2005 TEIN Jane Doe #16 (Ashley D.) 18 U.S.C. §§ 2423(1)) and 2 Traveling in interstate commerce for the purpose of engaging in illicit sexual conduct with a minor 1 1 . Page 9 of 9 EFTA00182950
Case 9:08-cv-80119-KAM Document 147 Entered on FLSD Docket 06/08/2009 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 5, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CV-80119-MARRA/JOHNSON CASE NO.: 08-CV-80232-MARRA/JOHNSON CASE NO.: 08-CV-80380-MARRA/JOHNSON CASE NO.: 08-CV-80381-MARRA/JOHNSON EFTA00182951
Case 9:08-cv-80119-KAM Document 147 Entered on FLSD Docket 06/08/2009 Page 2 of 9 JANE DOE NO. 6, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 7, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CV-80994-MARRA/JOHNSON CASE NO.: 08-CV-80993-MARRA/JOHNSON CASE NO.: 08-CV-80811-MARRA/JOHNSON CASE NO.: 08-CV-80893-MARRA/JOHNSON EFTA00182952
Case 9:08-cv-80119-KAM Document 147 Entered on FLSD Docket 06/08/2009 Page 3 of 9 vs. JEFFREY EPSTEIN, Defendant. DOE II, CASE NO.: 09-CV-80469-MARRA/JOHNSON Plaintiff, JANE DOE NO. 101, CASE NO.: 09-CV-80591-MARRA/JOHNSON vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 102, CASE NO.: 09-CV-80656-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Plaintiff, PLAINTIFF'S RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S MOTION TO STRIKE CASES FROM CURRENT TRIAL DOCKET AND MOTION TO CONTINUE CASE AND/OR ALTERNATIVE MOTION TO MODIFY TRIAL AND SCHEDULING ORDER DEADLINES The Plaintiff, by and through undersigned counsel, files this Response to Defendant, Jeffrey Epstein's Motion to Strike Cases From Current Trial Docket And Motion to Continue Case And/Or Alternative Motion to Modify Trial and Scheduling Order (D.E. 104), and further states as follows: EFTA00182953
Case 9:08-cv-80119-KAM Document 147 Entered on FLSD Docket 06/08/2009 Page 4 of 9 1. Defendant EPSTEIN seeks to have this case (and others that are presently pending) stricken from the trial docket, or continued for at least an additional three months or have the existing pretrial deadlines extended. In light of Plaintiffs filing of her Conditional Notice of Intent to Exclusively Rely on Statutory Damages Provided by 18 U.S.C. §2255 (D.E. 113) on June 5, 2009, Plaintiff agrees to a modification of the pretrial schedule as outlined in Defendant EPSTEIN's Motion to Strike (D.E. 104); to wit, extending discovery for an additional three months from the currently set deadline of August 28, 2009, extending the current deadline of October 15, 2009 by two months to file substantive pretrial motions, extending the current deadline of December 21, 2009 by one month to mediate this matter, and extending the deadline of June 29, 2009 by one month to exchange expert witness reports) 2. EPSTEIN's requests to have this case stricken from the trial docket, or in the alternative, continued for three months, however, are not warranted under the circumstances and would unreasonably and unnecessarily delay the resolution of this case. The filing of the instant motion marks the third different way EPSTEIN has sought to delay the trial on this matter. First, it was Defendant's Motion for Stay (D.E. 33), which was denied by the Court on December 17, 2008. Next, it was Defendant's second Motion for Stay (D.E. 51), which is presently pending before the Court. Third, and unfortunately, probably not the last, is Defendant's latest attempt to delay the trial of this case. With regards to the last requested modification of the pretrial order, EPSTEIN requests "an additional month to complete the remaining deadlines under each of the Court's Trial Orders." Given that each of the other deadlines not specifically listed above are to take place 15 days or less from the calendar call date of February 19, 2010 (which is 3 days from the trial date of February 22, 2010), the only logical deadline EPSTEIN could be referring to is the expert witness report exchange. EFTA00182954
Case 9:08-cv-80119-KAM Document 147 Entered on FLSD Docket 06/08/2009 Page 5 of 9 3. In order to justify his latest attempt to delay the trial of this case, EPSTEIN argues that Plaintiff's conduct has prevented him from "conducting any meaningful discovery, including the taking of 's supervisors, co-workers, acquaintances, friends, and other third parties."(D.E. 104, pg. 7). The sworn affidavit by counsel for Defendant, Michael Pike, Esq. repeats the same allegation ("As a result, the undersigned has not had an opportunity to depose any individuals that may have information about the allegations made by Plaintiffs."(D.E. 042-2, paragraph 4). 4, Defendant's Motion and affidavit are simply not supported by the history of this case. First, this case was filed in state court on February 21, 2008. Defendant EPSTEIN was served with a summons and complaint on July 2, 2008. For reasons that are known only to himself and his counsel in this case, EPSTEIN waited a full six months before propounding any discovery of any kind upon Plaintiff. EPSTEIN filed his first set of interrogatories on January 16, 2009, and his first set of requests to produce on January 16, 2009. EPSTEIN's choice to wait a half a year before engaging in formal discovery is not the Plaintiff's fault, nor can he now be allowed to argue that the current trial setting is unworkable because of his failures. 5. Second, Plaintiff provided answers to Defendant's first set of interrogatories on February 18, 2009 (Attached as Exhibit "1"). Plaintiffs answers to interrogatories identifies thirty six (36) people, other than herself and EPSTEIN, who have or may have knowledge regarding the subject matter of the instant law suit. This list of individuals includes Plaintiff's relatives, mental health providers, a former boyfriend, her friends, other victims of EPSTEIN, members of law enforcement who investigated EPSTEIN, and former employees and/or associates of EPSTEIN. Armed EFTA00182955
Case 9:08-cv-80119-KAM Document 147 Entered on FLSD Docket 06/08/2009 Page 6 of 9 with the identities of these crucial fact witnesses for almost the last four (4) months, EPSTEIN had not set a single one of them for deposition as of the time he filed the instant motion. Defendant's claims that he has been absolutely prevented from engaging in any discovery as a result of Plaintiffs "delay tactics" are absolutely belied by the fact that he actually has much of the information he complains Plaintiff is concealing from him, but has chosen to do nothing with it over the last four months. 6. Plaintiff also filed on February 2, 2009 her Initial Disclosure which likewise identified multiple individuals who had or may have knowledge regarding the subject matter of the instant suit (Attached as Exhibit "2"). Defendant failed to set any of those indentified individuals for deposition either. 7. Once again, Defendant cannot bury his head in the sand by failing to take available discovery and then turn around and complain that he cannot get ready for trial scheduled in February of 2010. 8. Third, EPSTEIN inappropriately characterizes Plaintiff's assertions of the protections afforded to her under the applicable rules of procedure and case law with respect to unreasonably invasive and irrelevant discovery propounded by EPSTEIN as an attempt to conceal evidence from EPSTEIN and delay the discovery of same. Defendant's allegations in this regard are flat out wrong. Plaintiff, just like EPSTEIN, has certain rights and privileges with respect to the scope of permissible discovery. Plaintiff has every right to avail herself of the protections available to her under the rules of discovery without fear of claims from EPSTEIN that she is concealing or delaying anything. Indeed, it is ironic that EPSTEIN takes issue with a litigant invoking the protections available to her with regards to inappropriate and unreasonable discovery EFTA00182956
Case 9:08-cv-80119-KAM Document 147 Entered on FLSD Docket 06/08/2009 Page 7 of 9 when he himself has failed to respond to any discovery propounded to him by Plaintiff, but instead has invoked his 5th Amendment privilege. 9. Fourth, in the event that the Court rules that Plaintiff can recover the statutory damage floor established in 18 U.S.C. §2255 for each proven incident of abuse committed by EPSTEIN upon her, the discovery which EPSTEIN presently seeks will not be relevant or material in any way given Plaintiff's Conditional Notice of Intent to Exclusively Rely on Statutory Damages Provided by 18 U.S.C. §2255. 10. Defendant asserts as justification for continuing this case what can fairly be characterized as routine and ordinary discovery disputes. Nothing contained in either his motion or supporting affidavit rises to the level of "exceptional circumstances" required by Local Rule 7.6 to continue a trial setting. Any issues related to discovery can certainly be cured by extending the trial deadlines as proposed by EPSTEIN. Delaying the trial of this case is simply not necessary nor justified. EFTA00182957
Case 9:08-cv-80119-KAM Document 147 Entered on FLSD Docket 06/08/2009 Page 8 of 9 WHEREFORE, in light of the foregoing, the Plaintiff respectfully requests this Court enter an order denying Defendant, Jeffrey Epstein's Motion to Strike Cases From Current Trial Docket And Motion to Continue Case And/Or Alternative Motion to Modify Trial and Scheduling Order. Respectfully submitted, /.s/.lack P Hill JACK SCARO Florida Bar NolMil JACK P. HILL Florida Bar No.: Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach. 09 Phone: Fax: Attorneys for Plaintiff CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 8th, 2009, I electronically filed the foregoing document with the Clerk of Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified above via transmission of Notices of Electronic Filing generated by CM/ECF. /.s/lank P Hill JACK SCAROLA Florida Bar No. JACK P. HILL Florida Bar No.: Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Fl i 409 Phone: Fax: Attorneys for Plaintiff EFTA00182958
Case 9:08-cv-80119-KAM Document 147 Entered on FLSD Docket 06/08/2009 Page 9 of 9 COUNSEL LIST Robert Critton, Esquire Burman Critton Luttier & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm B Phone: II Fax: Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S. West Palm B ach. FL 33401 Phone: Richard H. Willits, Esquire Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, F Phone: Fax: Bruce E. Reinhart, Esquire Bruce E. Reinhart, P.A. 250 South Australian Avenue Suite 1400 West Palm B Phone: Fax: EFTA00182959
Case 9:08-cv-80119-KAM Document 147-2 Entered on FLSD Docket 06/08/2009 Page 1 of 20 #281849/clw UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV- MARRA/JOHNSON Plaintiff(s), vs. JEFFREY EPSTEIN and Defendant(s). NOTICE OF SERVING ANSWERS TO INTERROGATORIES COMES NOW the Plaintiff, by and through undersigned counsel, and hereby files this Notice with the Court that 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 mail this (Tr- day of February, 2009, to: See attac ed list of counsel. Cc JACK SCA OLA Florida Bar No. JACK P. HILL Florida Bar No.: Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West P da 33409 Phone: Fax: Attorney for Plaint:1gs) [ PLAINTIFF'S EXHIBIT EFTA00182960
Case 9:08-cv-80119-KAM Document 147-2 Entered on FLSD Docket 06/08/2009 Page 2 of 20 vs. Epstein, et al. sa 08-CV-80811-C1V-MARRA/JOHNSON Plaintiffs Answers to Defendant's First interrogatories ANSWERS TO INTERROGATORIES 1. What is the name and address of all persons answering or assisting in answering these interrogatories, and, if applicable, the person's official position or relationship with the party to whom the interrogatories are directed? ANSWER c/o her 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 With the assistance of her counsel, Searcy Denney Scarola Barnhart & Shipley, P.A. and Richard Willits, P.A. 2. List the names, business addresses, telephone and cell phone numbers, dates of employment, immediate supervisor (name and address) and rates of pay regarding all employers, including self-employment, for whom you have worked in the past 10 years; this includes listing all sources of income you have received. Answer this question by year, i.e. 1998-2009. ANSWER Objection. Irrelevant, immaterial and not reasonably calculated to lead to .discovery of admissible evidence. 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= 2 EFTA00182961
Case 9:08-cv-80119-KAM Document 147-2 Entered on FLSD Docket 06/08/2009 Page 3 of 20 El vs. Epstein, et al. o.: 08-CV-801311-C1V-MARRA/JOHNSON Plaintiff's Answers to Defendant's First Interrogatories I have never been marriea. Children: Parents: Siblings: 3 EFTA00182962
Case 9:08-cv-80119-KAM Document 147-2 Entered on FLSD Docket 06/08/2009 Page 4 of 20 vs. Epstein, ct al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff's Answers to Defendant's First Interrogatories 4. Have you ever been convicted of a crime, other than any juvenile adjudication, which under the law under which you were convicted was punishable by death or imprisonment in excess of 1 year, or that involved dishonesty or a false statement regardless of the punishment? If so, state as to each conviction the specific crime and the date and place of conviction. • ANSWER No 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. c/o her 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 Lako Worth. FL 33461 Tel: Subject matter: Plaintiff. 2. Jeffrey Epstein do his attorneys: Robert Critton, Esquire Burman Critton Luther & Coleman LLP 4 EFTA00182963
Case 9:08-cv-80119-KAM Document 147-2 Entered on FLSD Docket 06/08/2009 Page 5 of 20 C.M.A. vs. Epstein, et al. Case No.: 08-CV-8081 I-CIV-MARRA/JOHNSON Plaintiff's Answers to Defendant's First Interrogatories 516 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 Palm Beach, FL 33401 Tel: Bruce E. Reinhart, Esquire Bruce E. Reinhart, P.A. 250 South Australian Avenue Suite 1400 West Palm Beach, FL 33401 Tel: Subject matter: Defendant 3. a mother clo 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 33461 Tel: 4. Subject matter: ress un nown) a s involvement with Epstein. Subject matter: Defendant. EFTA00182964
Case 9:08-cv-80119-KAM Document 147-2 Entered on FLSD Docket 06/08/2009 Page 6 of 20 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAJJOIINSON Plaintiff's Answers to Defendant's First Interrogatories 5. Jane Doe (Case No.: 1:93-ev-01109-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. 6. 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-cv-80119-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. 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: 6 EFTA00182965
Case 9:08-cv-80119-KAM Document 147-2 Entered on FLSD Docket 06/08/2009 Page 7 of 20 vs. Epstein, et al. asc 08-CV-80811-CIV-MARRABOHNSON Plaintiff's Answers to Defendant's First Interrogatories 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: 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: 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. 12. Jane Doe #7 (Case No.: 9:08-cv-80993-KAM) cto her attorney: Jeffrey ht Herman, Esquire Herman & Mermelstein, P.A. 7 EFTA00182966
Case 9:08-cv-80119-KAM Document 147-2 Entered on FLSD Docket 06/08/2009 Page 8 of 20 1.5. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRALIOHNSON Plaintiff's Answers to Defendant's First Interrogatories 18205 Biscayne Boulevard, Suite 2218 Miami Fl 33160 Tel: Subject matter: Victim of Epstein. 13. (Case No.: 502008CA025129)OOO01/3 Al c/o her attorneys: Jack Scarola, Esquire Jack P. Hill, Esquire Seamy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard Tel: West Painfleach, FL 33409 Subject matter: Victim of Epstein. 14. Jose Alessi (Address unknown at this time) Subject matter: Jeffrey Epstein's Butler. 15. 16. Palm Beach Police Department 345 South County Road Palm Beach FL 33480 Tel: Subject matter: Investigator. Palm Beach County Prosecutors Office 401 North Dixie Highway West Palm Beach FL 33401 Tel: Subject matter: 17. Detective Prosecutor. , lead investigator 8 EFTA00182967
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
Case 9:08-cv-80119-KAM Document 147-3 Entered on FLSD Docket 06/08/2009 Page 9 of 12 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Initial Disclosure Page 9 of 12 36. (Address will be i tporrt receipt) Subject matter. Friend of 's mother 37. (Address will be provided upon receipt) Subject matter: Potential victim and friend of 38. (Address unknown at this time) Subject matter: Associate of Epstein who may ha n involved in encounters between Epstein and (B) A copy of, or description by category and location of, all documents, data compilations, and tangible things that are In the possession, custody or control of the party and that the disclosing party may use to support Its claim or defenses, unless solely for impeachment k% it r di tt ''llt: f th3A w kt ar 0 Sr .1~ • '7 '4 in t, SO0 IKI, ne , EX lb& 1 Y , 2, -1: 41e. ''. ‘ rt t y ig IyA . o kJ". l,`, flati. ... O6',L iks. c We -1 TS Nto , lit $, 1 VisitationLog \'2 Any deposition in any other case involving molestation allegations against Jeffrey Epstein 3 U.S. Department of Justice's complete file, records and evidence 4 Federal Bureau of Investigation's complete file, records and evidence 5 Palm Beach County Sheriffs Office's complete file, records and evidence 6 Palm Beach County Prosecutor's complete file, records and evidence 7 Palm Beach Police Department's complete file, records and evidence 8 Palm Beach Police Department Probable Cause Affidavits EFTA00182988
Case 9:08-cv-80119-KAM Document 147-3 Entered on FLSD Docket 06/08/2009 Page 10 of 12 vs. Epstein, et al. ase 08-CV-80811-CIV-MARRAJJOHNSON Plaintiff's Initial Disclosure Page 10 of 12 (C) A computation of any category of damages claimed by the disclosing party, making available for inspection and copying as under Rule 34 the documents or other evidentiary material, not privileged or protected from disclosure, on which such computation is based, including materials bearing on the nature and extent of Injuries suffered: All damages recoverable for personal Injury under Florida law Including the following: suffered bodily injury; pain and suffering; disability; disfigurement; mental anguish; loss of the capacity for the enjoyment of life; and Medical and nursing care and treatment. The economic damages have not yet been calculated. The noneconomic damages are for the jury's determination. Statutory damages pursuant to 18 USCA §2255. Punitive damages. (D) for inspection and copying as under Rule 34 any insurance agreement under which any person carrying on an Insurance business may be liable to satisfy part or all of a Judgment which may be entered in the action or to indemnify or reimburse for payment made to satisfy the Judgment." Fed.R.Civ.P.26(a): Plaintiff is unaware of any applicable insurance policies. Discovery is ongoing. EFTA00182989
Case 9:08-cv-80119-KAM Document 147-3 Entered on FLSD Docket 06/08/2009 Page 11 of 12 vs. Epstein, et al. ase o.:08•CV-80811-CIV-MARRNJOHNSON Plaintiffs initial Disclosure Page 11 of 12 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to all counsel on the attached list, this 2nd day of February, 2009. Jack $CPI ola Florida Bar No.: Florida Bar No.: Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm B 409 Phone: Fax: Attorneys for Plaintiff EFTA00182990
Case 9:08-cv-80119-KAM Document 147-3 Entered on FLSD Docket 06/08/2009 Page 12 of 12 . .sivs. Epstein, et al. ase o.: 08-CV-80811-CIV-MARRNJOHNSON Plaintiff's InlUal Disclosure Page 12 of 12 SERVICE LIST Richard H. Willits, Esquire Richard H. Willits, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, F Phone: Fax: Robert Critton, Esquire Burman Critton Luttler & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm B Phone: Fax: Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South West Palm B .h FL 3340 Phone: Bruce E. Reinhart, Esquire Bruce E. Reinhart, P.A. 250 South Australian Avenue Suite 1400 West Palm B Phone: Fax: EFTA00182991
Case 9:08-cv-80119-KAM Document 141 Entered on FLSD Docket 06/05/2009 Page 1 of 6 vs. JEFFREY EPSTEIN Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-cv-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, CASE NO.: 08-CV-80380-MAIRRA/JOHNSON JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN Defendant. EFTA00182992
Case 9:08-cv-80119-KAM Document 141 Entered on FLSD Docket 06/05/2009 Page 2 of 6 CASE NO.: 08-CV-80381-MARRA/JOHNSON JANE DOE NO. 5, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80994-CIV-MARRA/JOHNSON JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80993-CIV-MARRA/JOHNSON JANE DOE NO. 7, Plaintiff, JEFFREY EPSTEIN Defendant. CASE NO.: 08-80811-CIV-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN Defendant. EFTA00182993
Case 9:08-cv-80119-KAM Document 141 Entered on FLSD Docket 06/05/2009 Page 3 of 6 JANE DOE, CASE NO.: 08-80893-CIV-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN et al, Defendants. DOE II, CASE NO.: 09-80469-CIV-MARRA-JOHNSON Plaintiff, JEFFREY EPSTEIN et al, Defendants. JANE DOE NO. 101, CASE NO.: 09-80591-CIV-MARRA-JOHNSON Plaintiff, JEFFREY EPSTEIN Defendant. JANE DOE NO. 102, CASE NO.: 09-80656-CIV-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. NOTICE OF SUPPLEMENTAL AUTHORITY IN CONNECTION WITH DEFENDANT'S VARIOUS MOTIONS TO COMPEL AND REPLIES THERETO EFTA00182994
Case 9:08-cv-80119-KAM Document 141 Entered on FLSD Docket 06/05/2009 Page 4 of 6 Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, hereby gives notice of his intent to rely on the following case as supplemental authority in connection with the above referenced Motions to Compel and Replies thereto: 1. Doe v. Evans, 202 F.R.D. 173, 176 (E.D. P.A. 2001) (denying protective order where alleged sexual assault victim did not demonstrate a serious specific injury and allowing Defendants to identify Plaintiff in discovery because holding otherwise would "chill defendants ability to conduct discovery"). Certificate of Service • I HEREBY CERTIFY that a true copy of the foregoing w s electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 5. day of , 2009 Respectfully s By: RO RT D. CR Florida Bar No. MICHAEL I.... a mPIKE ESQ. Florida Bar Q. BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 Phone Fax (Counsel for Defendant Jeffrey Epstein) EFTA00182995
Case 9:08-cv-80119-KAM Document 141 Entered on FLSD Docket 06/05/2009 Page 5 of 6 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami. FL 33160 Counsel for Plaintiffs In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. 229010th Avenue North Suite 404 Lake Worth, FL 33461 Fax: Counsel for Plaintiff in Related Case No. 08-80811 Jack Scarola, Esq. Jack P. Hill, Esq Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Fax: Counsel for Plaintiff, =. Bruce Reinhart, Esq. Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Phone: Fax: Counsel for P ainti in Related Case No. 08-80893 Paul G. Cassell, Esq. Pro Hac Vice 332 South 1400 E, Room 101 Salt Lake Cit , UT 84112 Co-counsel Jane Doe Isidro M. Garcia, Esq. Garcia Law Finn, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 08-80469 in elated Case No. Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 Counsel for Plaintiffs in Related Cases EFTA00182996
Case 9:08-cv-80119-KAM Document 141 Entered on FLSD Docket 06/05/2009 Page 6 of 6 Bruce E. Reinhart, P.A. 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 33401 Counsel for Defendant Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Fax: Counsel for Plaintiff in Related Case No. 08-08804 Nos. 09-80591 and 09-80656 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Counsel for Defendant Jeffrey Epstein EFTA00182997
Case 9:08-cv-80119-KAM Document 141 Entered on FLSD Docket 06/05/2009 Page 1 of 6 vs. JEFFREY EPSTEIN Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-cv-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, CASE NO.: 08-CV-80380-MAIRRA/JOHNSON JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN Defendant. EFTA00182998
Case 9:08-cv-80119-KAM Document 141 Entered on FLSD Docket 06/05/2009 Page 2 of 6 CASE NO.: 08-CV-80381-MARRA/JOHNSON JANE DOE NO. 5, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80994-CIV-MARRA/JOHNSON JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80993-CIV-MARRA/JOHNSON JANE DOE NO. 7, Plaintiff, JEFFREY EPSTEIN Defendant. CASE NO.: 08-80811-CIV-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN Defendant. EFTA00182999
Case 9:08-cv-80119-KAM Document 141 Entered on FLSD Docket 06/05/2009 Page 3 of 6 JANE DOE, CASE NO.: 08-80893-CIV-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN et al, Defendants. DOE II, CASE NO.: 09-80469-CIV-MARRA-JOHNSON Plaintiff, JEFFREY EPSTEIN et al, Defendants. JANE DOE NO. 101, CASE NO.: 09-80591-CIV-MARRA-JOHNSON Plaintiff, JEFFREY EPSTEIN Defendant. JANE DOE NO. 102, CASE NO.: 09-80656-CIV-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. NOTICE OF SUPPLEMENTAL AUTHORITY IN CONNECTION WITH DEFENDANT'S VARIOUS MOTIONS TO COMPEL AND REPLIES THERETO EFTA00183000
Case 9:08-cv-80119-KAM Document 141 Entered on FLSD Docket 06/05/2009 Page 4 of 6 Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, hereby gives notice of his intent to rely on the following case as supplemental authority in connection with the above referenced Motions to Compel and Replies thereto: 1. Doe v. Evans, 202 F.R.D. 173, 176 (E.D. P.A. 2001) (denying protective order where alleged sexual assault victim did not demonstrate a serious specific injury and allowing Defendants to identify Plaintiff in discovery because holding otherwise would "chill defendants ability to conduct discovery"). Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing w s electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this day of , 2009 Respectfully s MICHAEL J. PIKE, ESQ. Florida Bar SIM JR., ESQ. BURMAN, CRITTON, LUTHER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 Phone Fax (Counsel for Defendant Jeffrey Epstein) EFTA00183001
Case 9:08-cv-80119-KAM Document 141 Entered on FLSD Docket 06/05/2009 Page 5 of 6 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami. FL 33160 Counsel for Plaintiffs In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. 229010'" Avenue North Suite 404 Lake Worth, FL 33461 Fax: Counsel for Plaintiff in Related Case No. 08-80811 Jack Scarola, Esq. Jack P. Hill, Esq Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Fax: Counsel for Plaintiff, =. Bruce Reinhart, Esq. Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Phone: Fax: Counsel for P ainti in Related Case No. 08-80893 Paul G. Cassell, Esq. Pro Hac Vice 332 South 1400 E, Room 101 Salt Lake Cit , UT 84112 Co-counsel Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 Counse 08-80469 in elated Case No. Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 ax: or .9 in Related Cases EFTA00183002
Case 9:08-cv-80119-KAM Document 141 Entered on FLSD Docket 06/05/2009 Page 6 of 6 Bruce E. Reinhart, P.A. 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 33401 Counsel for Defendant Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Fax: Counsel for Plaintiff in Related Case No. 08-08804 Nos. 09-80591 and 09-80656 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Counsel for Defendant Jeffrey Epstein EFTA00183003

























