EFTA00221846

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 
C.M.A., 
Plaintiff(s), 
vs. 
JEFFREY EPSTEIN and SARAH KELLEN, 
Defendant(s). 
NOTICE OF SERVING 
ANSWERS TO INTERROGATORIES 
COMES NOW the Plaintiff, C.M.A., 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 
IT .74%. day of February, 2009, to: See attacked list of counsel. 
CL 
JACK SCAC.OLA 
Florida Bar No.: 169440 
JACK P. HILL 
Florida Bar No.: 0547808 
Searcy Denney Scarola Barnhart & Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, Florida 33409 
Phone: (561) 686-6300 
Fax: 
(561) 383-9410 
Attorney for Plaintiff(s) 
PLAINTIFF'S 
EXHIBIT 
EFTA00221846

Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 2 of 20 
C.M.A. vs. Epstein, et al. 
Case No.: 08-CV-8081l-C1V-MARRA/JOHNSON 
Plaintiff's 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.M.A. 
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 
2 
EFTA00221847

Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 3 of 20 
C.M.A. vs. Epstein, et al. 
Case No.: 08-CV-1301311-CIV-MARRA/JOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
3 
EFTA00221848

Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 4 of 20 
C.M.A. vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARIWJOHNSON 
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.M.A. 
do 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: 
(561) 686-6300 
Richard Willits, Esq. 
Richard H. Willits, P.A. 
2290 10th Avenue North, Suite 404 
Lake Worth, FL 33461 
Tel: 
(561) 582-7600 
Subject matter: 
Plaintiff. 
2. 
Jeffrey Epstein 
c/o his attorneys: 
Robert Critton, Esquire 
Burman Critton Luther & Coleman LLP 
4 
EFTA00221849

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-80811-CIV-MARRA/JOHNSON 
Plaintiff's Answers to Defendant's First interrogatories 
515 North Flagler Drive, Suite 400 
West Palm Beach, FL 33414 
Tel: 
(561) 842-2820 
Jack A. Goldberger, Esquire 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue South 
West Palm Beach, FL 33401 
Tel: 
(561) 863-9100 
Bruce E. Reinhart, Esquire 
Bruce E. Reinhart, P.A. 
250 South Australian Avenue 
Suite 1400 
West Palm Beach, FL 33401 
Tel: 
(561) 202-6360 
Subject matter: 
Defendant 
3. 
C.M.A.'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: 
(561) 686-6300 
Richard Willits, Esq. 
Richard H. Willits, P.A. 
2290 10th Avenue North, Suite 404 
Lake Worth, FL 33461 
Tel: 
(561) 582-7600 
Subject matter: 
C.M.A.'s involvement with Epstein. 
4. 
Sarah Kellen 
(Address unknown) 
Subject matter: 
Defendant. 
5 
EFTA00221850

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-MARRA/JOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
5. 
Jane Doe (Case No.: 1:93-cv-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: (561) 515-1400 
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 
Hollywood, FL 33020 
Tel: (954) 414-8033 
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: (305) 931-2200 
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: (305) 931-2200 
6 
EFTA00221851

Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06'08'2009 
Page 7 of 20 
C.M.A. vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRABOIINSON 
PlaintifFs 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: (305) 931-2200 
Subject matter: 
Victim of Epstein. 
10. 
Jane Doe #4 (Case No.: 9:08-cv-80380-KAM) 
do her attorney: 
Jeffrey M. Herman, Esquire 
Herman & Mermelstein, P.A. 
18205 Biscayne Boulevard, Suite 2218 
Miami, FL 33160 
Tel: (305) 931-2200 
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: (561) 515-1400 
Subject matter: 
Victim of Epstein. 
12. 
Jane Doe #7 (Case No.: 9:08-cv-80993-KAM) 
do her attorney: 
Jeffrey M. Herman, Esquire 
Herman & Mermelstein, P.A. 
7 
EFTA00221852

Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06'08'2009 
Page 8 of 20 
C.M.A. vs. Epstein, et al. 
Case No.: 08-CV-808I I -CIV-MARRA/JOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
18205 Biscayne Boulevard, Suite 2218 
Miami, FL 33160 
Tel: (305) 931-2200 
Subject matter: Victim of Epstein. 
13. 
A.C. (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: (561) 686-6300 
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 
Palm Beach, FL 33480 
Tel: (561) 838-5480 
Subject matter: 
Investigator. 
16. 
Lanaa Belohavek 
Palm Beach County Prosecutors Office 
401 North Dixie Highway 
West Palm Beach, FL 33401 
Tel: (561) 355-7100 
Subjoct matter: 
Prosecutor. 
17. 
t 
, lead investigator 
8 
EFTA00221853

Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06'08'2009 
Page 9 of 20 
C.M.A. vs. Epstein, et al. 
Case No.: 08-CV-BOSH -CIV-MARRABOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
Palm Beach Police Department 
345 South County Road 
Palm Beach, FL 33480 
Tel: (561) 838-5480 
Subject matter: 
Investigator. 
18. 
Anthony Figueroa 
155 Santiago Street 
Royal Palm Beach, FL 33411-1228 
Subject matter: 
Former boyfriend of a victim of Epstein. 
19. 
Palm Beach Police Department 
345 South County Road 
Palm Beach, FL 33480 
Tel: (561) 838-5480 
Subject matter: 
Investigator. 
20. 
Shawn W. Haught 
1603 Plantation Lane 
West Palm Beach, FL 33417 
Subject matter: 
Plaintiffs former boyfriend. 
21. 
Tony Higgins, supervisor 
Sanitation Bureau 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. 
Palm Beach County Sheriff's Office 
3228 Gun Club Road 
West Palm Beach, FL 33406 
(561) 666-3000 
9 
EFTA00221854

Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 10 of 20 
C.M.A. vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRALIOFINSON 
Plaintiffs Answers to Defendant's First Interrogatories 
Subject matter: 
Investigator. 
23. 
(Address will be provided upon receipt) 
Subject matter: 
Victim and friend of C.M.A. 
24. 
Ghislane Maxwell c/o Ghislane Corp. 
3580 Brillo Way 
Palm Beach, FL 33480 
Subject matter: 
Associate of Epstein. 
25. 
Susan Pope 
Parent Child Center 
West Palm Beach, FL 
26. 
27. 
Subject matter: 
Counselor at Parent Child Center. 
Palm Beach Police Department 
345 South County Road 
Palm Beach, FL 33480 
Tel: (561) 838-5480 
Subject matter: 
Investigator. 
Palm Beach Police Department 
345 South County Road 
Palm Beach, FL 33480 
Tel: (561) 838-5480 
Subject matter: 
Investigator. 
28. 
Haley Robson 
(Address unknown at this time) 
Subject matter: 
Associate of Epstein who facilitated introductions 
with various victims. 
10 
EFTA00221855

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-8081 I -CIV-MARRABOITNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
29. 
Alfredo Rodriguez 
(Address unknown at this time) 
Subject matter: 
Employee of Epstein. 
30. 
31. 
32. 
Palm Beach Police Department 
345 South County Road 
Palm Beach, FL 33480 
Tel: (561) 838-5480 
Subject matter: 
Investigator 
First Assistant U.S. Attorney 
U.S. Dept. of Justice 
500 South Australian Avenue 
Suite 400 
West Palm Beach, FL 33401 
Tel: (561) 820-8711 
Subject matter: 
Federal prosecutor. 
Federal 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 
34. 
Subject matter: 
C.M.A.'s physician. 
Assistant U.S. Attorney 
U.S. Dept. of Justice 
500 South Australian Avenue 
11 
EFTA00221856

Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 12 of 20 
C.M.A. vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/MHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
Suite 400 
West Palm Beach, FL 33401 
Tel: (561) 820-8711 
Subject matter: 
Federal prosecutor. 
36. 
36. 
37. 
(Address will be provided upon receipt) 
Subject matter: 
Friend of C.M.A's mother. 
IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIM 
(Address will be provided upon receipt) 
Subject matter: 
Friend of C.M.A.'s mother 
IIIIIIIIIIIIIIIIIIIIIII 
(Address will be provided upon receipt) 
Subject matter: 
Potential victim and friend of C.M.A. 
38. 
Nadia Marcinkova 
(Address unknown at this time) 
Subject matter: 
Associate of Epstein who may have been involved 
in encounters between Epstein and C.M.A. 
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 
EFTA00221857

Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 13 of 20 
C.M.A. vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRAffOHNSON 
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 
I have bipolar disorder and manic depression. I lost my self-esteem. I 
began cutting myself on my arms and legs and developed drug problems. 
Permanent injuries are psychological. 
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. § 2255. 
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 
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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-CIV-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. Serge Thys (Psychiatrist) 
2151 45th Street 
West Palm Beach, FL. 33407 
Date: I do not recall the date. I would defer 
to the Doctor's records. 
Susan Pope (Counselor/Therapist) Date: Since high school. Ongoing. 
Parent Child Center 
2001 W. Blue Heron Boulevard 
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 
Good Samaritan Hospital (3/12/04, 3/25/08) 
Child Birth 
1309 N Flagler Dr 
West Palm Beach, FL 33401 
St. Mary's Hospital (4107) 
DNC 
901 45th Street 
West Palm Beach, FL 33407 
Gloria C. Hakkarainen, MD 
Ob/Gyn 
2925 10th Avenue North, Suite 305 
Palm Springs, FL. 33461 
Theodore Ritota, DDS 
Dentist 
14 
EFTA00221859

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-80811-CIV-MARRA/JOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
3401 South Federal Highway 
Delray Beach, FL. 33483 
Palm Beach County Healthcare Department 
Flu Shots 
45th Street 
West Palm Beach, FL. 33407 
FAU Wellness Center 
1650 Osceola Drive 
West Gate, FL. 33407 
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 by Sarah Kellen. 
Jeffrey Epstein had a photo taken of me at his home by Sarah Kellen. 
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 
EFTA00221860

Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 16 of 20 
C.M.A. vs. Epstein, et al. 
Case No.: 08-CV-80811-C1V-MARRAHOHNSON 
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 friend Virginia in 2002. I was to 
give Jeffrey Epstein a massage. I continued to provide massages up until 
August of 2003. I was transported to Jeffrey Epstein's house by Yellow 
Cab, provide b Jeffre E stein Vir Inia m ex- bo friend Shawn Haught, 
my mother 
Virginia 
(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 his 
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 August 2003. 
$500 for a photo taken by Sarah Kellen 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 
EFTA00221861

Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 17 of 20 
C.M.A. vs. Epstein, et aL 
Case No.: 08-CV-801311-CIV-MARRA/JOHNSON 
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 
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Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 18 of 20 
C.M.A. vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRAffOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
from FBI, U.S. Attorneys' Office, State Attorneys' Office (Palm Beach County), 
Palm Beach Sheriffs 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 
A.L. 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 
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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.: O8-CV-8O81l-CIV-MARREJOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
Signature of Answering Party 
STATE OF 
Florida 
COUNTY OF Palm Beach 
) 
The foregoing instrument was acknowledged before me this  /7  day of February, 2009 
by Carolyn Andriano 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: 
niDa 
Nan WC • (gat al WAS 
vs cteasatems Ian 
Qatar ita 
Izakil 
Stara 
km 
19 
EFTA00221864

Case 9:08-cv-80119-KAM 
Document 147-2 
Entered on FLSD Docket 06/08/2009 
Page 20 of 20 
C.M.A. vs. Epstein, et al. 
Case No.: 08-CV-8 08 I 1-CIV-MARRABOHNSON 
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: (561) 863-9100 
Attorneys for Jeffrey Epstein 
Bruce E. Reinhart, Esquire 
Bruce E. Reinhart, P.A. 
250 South Australian Avenue 
Suite 1400 
West Palm Beach, FL 33401 
Phone: (561)-202-6360 
Fax: (561)-828-0983 
Attorneys for Sarah Kellen 
Robert Critton 
Burman Critton Luttier & Coleman LLP 
515 North Flagler Drive, Suite 400 
West Palm Beach, FL 33414 
Phone: (561)-842-2820 
Fax: (561)-844-6929 
Attorneys for Jeffrey Epstein 
Richard H. Willits, Esquire 
lawyerwillits@aol.com 
Richard H. Willits, P.A. 
2290 10th Avenue North 
Suite 404 
Lake Worth, FL 33461 
Phone: (561)-582-7600 
Fax: (561)-588-8819 
Attorneys for Party 
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