EFTA00157922

P4P 
#281849/clw 
UNWED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80811-crv-
MARRA/JOHNSON 
Plaintiff(s), 
vs. 
JEFFREY EPSTEIN and SARAH KELLEN, 
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 famished by mail this 
(Tr" day of February, 2009, to: See attac 
list of counsel. 
3505-046 
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EFTA_00005473 
EFTA00157922

vs. Epstein, a at 
Case No.: 08-CV-80811-CIV-MARRALIOHNSON 
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 
do her attorneys: 
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 
3505-046 
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EFTA_00005474 
EFTA00157923

vs. Epstein, 'a al. 
Case No.: 08-CV-80111I-C4V-MARRAMOINSON 
Plaintiff's Answers to Defendant's First Interrogatories 
3 
3505-046 
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EFTA_00005475 
EFTA00157924

as. Epstein, et at 
Case No • 08-CV-8081I-CIV -MARRA/JOHNSON 
Plaintiffs 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 
5. 
Please provide the name, address, telephone number, place of employment and 
job title of any person who has, claims to have or whom you believe may have 
knowledge or information pertaining to any fact alleged in the pleadings (as 
defined in Federal Rule of Civil Procedure 7(a) filed in this action, or any fact 
underlying the subject matter of this action). 
ANSWER 
1. 
do her attorneys: 
Subject matter: 
Plaintiff. 
2. 
Jeffrey Epstein 
do his attorneys: 
Robert Critton, Esquire 
Burman Critton Luther & Coleman LLP 
4 
3505-046 
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EFTA_00005476 
EFTA00157925

vs. Epstein, a al. 
Case No.: 08-CV-8081I-CIV-MARRAMOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
Jack A. Goldberger, Esquire 
Atterbury, Goldberger & Weiss, P.A. 
Bruce E. Reinhart, Esquire 
Bruce E. Reinhart, P.A. 
Subject matter: 
Defendant 
3. 
s mother 
and her brother, 
do =I's 
attorneys: 
Subject matter: 
Ms 
involvement with Epstein. 
4. 
(Address unknown) 
Subject matter: 
Defendant 
5 
3505-046 
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EFTA_00005477 
EFTA00157926

vs. Epstein, et al. 
Case No.: 08•CV-80811-CIV-MARRA/1OIINSON 
Plaintiffs Answers to Defendant's First Interrogatories 
5. 
Jane Doe (Case No.: 1:93-cv-01109-KAM) 
do her attorney: 
Theodore Leopold, Esquire 
Leopold, Kuvin, P.A. 
Subject matter: 
Victim of Epstein. 
6. 
Jane Doe (Case No.: 502008CA020614) 
do her attorney: 
Isidro M. Garcia, Esquire 
The Law Office of Brad Edwards & Associates, LLC 
Subject matter: 
Victim of Epstein. 
7. 
Jane Doe. (Case No.: 9:08-cv-80119-KAM) 
do her attorney: 
Jeffrey M. Herman, Esquire 
Herman & Mermelstein, P.A. 
Subject matter: 
Victim of Epstein. 
8. 
Jane Doe M(Case No.: 9:08-cv-80232-KAM) 
do her attorney: 
Jeffrey M. Herman, Esquire 
Herman & Mermeistein, P.A. 
6 
3505-046 
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EFTA_00005478 
EFTA00157927

vs. Epstein, et al. 
Case No.: 08-CV-808I I-CIV-MARRA/JOHNSON 
Plaintiff's Answers to Dcfendant's First Interrogatories 
Subject matter: 
Victim of Epstein. 
9. 
Jane Doe M(Case No.: 9:08-cv-80381-KAM) 
do her attorney: 
Jeffrey M. Herman, Esquire 
Herman & Mermelsteln, P.A. 
Subject matter: 
Victim of Epstein. 
10. 
Jane Doe U (Case No.: 9:08-cv-80380-KAM) 
do her attorney: 
Jeffrey M. Herman, Esquire 
Herman & Mermeistein, P.A. 
Subject matter: 
Victim of Epstein. 
11. 
Jane Doe (Case No.: 9:08-cv-80804-KAM) 
do her attorney: 
Theodore Leopold, Esquire 
Leopold, Kuvin, P.A. 
Subject matter: 
Victim of Epstein. 
12. 
Jane Doe
 (Case No.: 9:08-cv-80993-KAM) 
c/o her attorney: 
Jeffrey NI. Herman, Esquire 
Herman & Mermeistein, P.A. 
7 
3505-046 
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EFTA_00005479 
EFTA00157928

vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/1O1INSON 
Plaintiff's Answers to Defendant's First Interrogatories 
Subject matter: Victim of Epstein. 
13. 
(Case No.: 502008CA025129)OOO(MB Al 
do her attorneys: 
Jack Scarola, Esquire 
Jack P. Hill, Esquire 
Seamy Denney Scarola Barnhart & Shipley, P.A. 
Subject matter: 
Victim of Epstein. 
14. 
Jose Alessi 
(Address unknown at this time) 
Subject matter: 
Jeffrey Epstein's Butler. 
15. 
Palm Beach Police Department 
Subject matter: 
Investigator. 
16. 
Lanaa Belohavek 
Palm Beach County Prosecutors Office 
Subject matter: 
Prosecutor. 
17. 
DetectiveM, lead investigator 
8 
3505-046 
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EFTA_00005480 
EFTA00157929

vs. Epstein, a al. 
Case Na: 08-CV-808 IL-DIV-MARRA/JOHNSON 
Plaintiff's Answers to Defendant's First Inteivogatorics 
Palm Beach Police Department 
345 South County Road 
Palm Beach, FL 33480 
Subject matter: 
Investigator. 
18. 
Subject matter: 
Former boyfriend of a victim of Epstein. 
19. 
Sgt. 
Palm Beach Police Department 
345 South County Road 
Palm Beach, FL 33480 
20. 
21. 
Subject matter: 
Investigator. 
Subject matter: 
Plaintiff's former boyfriend. 
Subject matter: 
The incident which is the subject matter 
of this lawsuit. Discovery is ongoing. 
22. 
Major -
Palm Beach County Sheriff's Office 
9 
3505-046 
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EFTA_00005481 
EFTA00157930

vs. Epstein. et al. 
Case No.: Cl8-CV-80811-CIV-MARPA/JOHNSON 
Plaintiffs Answers to Defendant's First Interrogatories 
Subject matter: 
Investigator. 
23. 
friend of 
(Address will be provided 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. 
26. 
Detective 
Palm  Beach Police Department 
Subject matter: 
Investigator. 
27. 
Chief 
Palm Beach Police Department 
28. 
Subject matter: 
Investigator. 
(Address unknown at this time) 
Subject matter: 
Associate of Epstein who facilitated introductions 
with various victims. 
10 
3505-046 
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EFTA_00005482 
EFTA00157931

jjjjjjjjj,vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON 
Plaintiffs Answers to Defendant's First interrogatories 
29. 
Alfredo Rodriguez 
(Address unknown at this time) 
Subject matter: 
Employee of Epstein. 
30. 
Detective 
Palm Beach Police Department 
Subject matter: 
Investigator 
31. 
S 
Esquire 
First Assistant U.S. Attorney 
U.S. Dept. of Justice 
Subject matter: 
Federal prosecutor. 
32. 
M.S.W. 
Federal Bureau of Investigation 
Subject matter: 
Investigator. 
33. 
34. 
Assistant U.S. Attorney 
U.S. Dept. of Justice 
II 
3505-046 
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EFTA_00005483 
EFTA00157932

vs. Epstein, et al. 
Case No.: 08-CV-80731I-CIV-MAR.RAIJOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
Subject matter: 
Federal prosecutor. 
35. 
friend of M's 
mother 
(Address will be provided upon receipt) 
Subject matter: 
Friend of Ms 
mother. 
36. 
a 
friend of=.'s 
mother 
(Address will be provided upon receipt) 
Subject matter: 
Friend of Ms 
mother 
37. 
, friend of 
(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 have been involved 
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 #6 
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 
3505-046 
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EFTA_00005484 
EFTA00157933

vs. Epstein, et al. 
Case uo. 08-CV-80811-CIV-MARRA/JOHNSON 
Plaintiffs Answers to Defendant's First Interrogatories 
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. 
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. § 2265. 
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 
3505-046 
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EFTA_00005485 
EFTA00157934

vs. Epstein, et al. 
Case No.: Oft-CV-8081 I-CIV-MARRABOHNSON 
Plaintiff's 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. 
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 
3505-046 
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EFTA_00005486 
EFTA00157935

vs. Epstein, et al. 
Case No.: 08-CV-8081I-CIV-MARRAJJOHNSON 
Plaintiff's Answen 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 ho 
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 
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 
3505-046 
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EFTA_00005487 
EFTA00157936

vs. Epstein, ct al. 
Case No.: 08-CV-80811-CP/ -MARRA/JOHNSON 
Plaintiffs Answers to Defendant's First Interrogatories 
From May or June of 
to August o 
I went to Mr. Epstein's home 
on average 2 times alit 
There were wee s when I would go 4 times a 
week. All my visit dates wore 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 
in 2002. I was to 
iii
give Jeffre E stein a massage. I continued to provide massages up until 
August of 
I was transported to Jeffrey Epstein's house by Yellow 
Cab, proof e 
Jeffre E stein, MM, 
mtoyfriend 
my mother 
and my brother 
(A 
ress 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 
$2004300 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 
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EFTA_00005488 
EFTA00157937

vs. Epstein, et at. 
Case No.: 08-CV-80811-CIV-MARRAD0HNS0N 
Plaintiffs 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 
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 
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 
22. 
List in detail all discussions/interviews which you had with any representative 
17 
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EFTA_00005489 
EFTA00157938

vs. Epstein, a al. 
Case No.: 08-CV-808I I-CIV-MARRADOHNSON 
Plaintiffs 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 
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EFTA_00005490 
EFTA00157939

vs. Epstein, et al. 
Case No.: 08-CV-8081 I -CIV-MARRAIJ0HNS0N 
Plaintiffs Answers to Defendant's First Intarogatories 
oiwzatur c an russwcs it% r at L.),
STATE OF 
Florida 
COUNTY OF Palm Beach 
) 
by 
The foregoing instrument was acknowledged before me this  17  day of February, 2009 
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 
3505-046 
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EFTA_00005491 
EFTA00157940

vs. Epstein, et aL 
Case No.: 08-CV-80811-CIV-MARRAflOHNSON 
Plaintiff's Answers to Defendant's First Interrogatories 
COUNSEL LIST 
Jack A. Goldberger 
Atterburv. Goldberger & Weiss. P.A. 
Attorneys for Jcffiey Epstein 
Bruce E. Reinhart, Esquire 
Bruce E. Reinhart, PA. 
r. 41' 
Robert Critton 
V.!• t  -
Burman Critton Luther & Coleman LLP 
Attorneys for Jeffrey Epstein 
ttomeys for Party 
20 
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EFTA_00005492 
EFTA00157941