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Case 9:08-cv-80811-KAM 
Document 54 
Entered on FLSD Docket 04/02/2009 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CIV-80811-MARRAMOHNSON 
C.M. A., 
Plaintiff, 
v. 
III
EPSTEIN and'''. 
Defendants, 
DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF C.M.A. TO RESPOND TO 
DEFENDANT'S FIRST REQUEST TO PRODUCE AND ANSWER DEFENDANTS 
FIRST SET OF INTERROGATORIES, AND TO OVERRULE OBJECTIONS. AND FOR 
AN AWARD OF DEFENDANTS REASONABLE EXPENSES 
Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, 
moves this Court for an order compelling Plaintiff, C.M.A. to respond to Defendant's 
First Request To Produce and to answer Defendant's First Set of Interrogatories, and to 
overrule her objections asserted in Plaintiffs Response To Defendant's First Request 
To Produce, dated February 13, 2009, and in Plaintiffs Notice of Serving Answers To 
Interrogatories, dated February 18, 2009. Defendant further seeks an award of his • 
reasonable expenses, Including expenses, associated with the making of this motion. 
Rule 37, Fed.R.Civ.P. (2008); Local Gen. Rules 7.1 and 26.1 H (S.D. Fla. 2008). In 
support of his motion, Defendant states: 
Prior to the filing of this motion, on April 1, 2009, Defendants counsel 
communicated by telephone with Plaintiffs counsel In a good faith effort to resolve the 
discovery Issues herein. This motion addresses those discovery items which remain at 
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Case 9:08-cv-80811-ICAM 
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issue. 
Also, rather than file 2 separate motions to compel, Defendant filed one 
addressing the production requests and interrogatories because the discovery issues 
overlap. 
Motion To Compel Responses to Production Requests Nos.1, 2, 4. 5, and 19, 
and Answers to Interrogatories Nos. 2, 18. and 23. 
Production Request No. 1 
1. 
Individual and/or Joint income tax returns and supporting documentation 
including W-2 and 1099 forms for 2002-2007 and, as well as all records or 
documentation relative to the Plaintiffs earnings for the current year. 
Response: 
Objection. Irrelevant, immaterial and not reasonably calculated to lead to the discovery 
of admissible information. 
Legal Argument Supporting Entitlement to Discovery 
Plaintiffs tax returns and supporting documentation are relevant to Plaintiffs 
damages claims and, thus, discoverable. Plaintiffs complaint alleges in part that 
"beginning in approximately late May or early June of 2002, and continuing until 
approximately August of 2003, the Defendant coerced and enticed the Impressionable, 
vulnerable, and economically deprived then minor Plaintiff to commit various acts of 
sexual misconduct." 
f t Am. Complaint, ¶13. 
(Plaintiff also refused to answer 
interrogatory no. 2 which sought her employment history for the past ten years asserting 
the same general objection). 
Such information is both relevant and reasonably calculated to lead to the 
discovery of admissible evidence. 
It is well settled that relevant Information Is 
discoverable, even if not admissible at trial, so long as the discovery is reasonably 
calculated to lead to the discovery of admissible evidence. Rule 28(b)(1), Fed.R.Civ.P.; 
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Donahav v. Palm Beach Tours & trans.. Inc., 242 F.R.D. 685 (S.D. Fla. 2007). 
Discoverability of such Information Is governed by Rule 26, Fed.R.Civ.P., pursuant to 
which the scope of discovery Is broad. Donahav, supra, at 686, and cases cited therein. 
"Parties may obtain discovery regarding any matter, not privileged, which Is relevant to 
the claims or defense of any party involved in the pending action? Id. 
Plaintiff's tax returns, along with the requested supporting documentation, for the 
six year period, and documents relevant to her current earnings, are relevant to 
Plaintiff's damagep claims detailed below herein. 
Such information would show 
Plaintiff's employment and earning history, as well as provide evidence as to how 
Plaintiff has been able to function in her daily life before, during and after the alleged 
incidents. Was she setf-sufficient? Was she able to get out of bed each morning and 
support herself? What type of Job did she holed? One's ability to earn a living and be 
self-supporting 
has 
not 
only 
a 
financial 
component, 
but 
also 
an 
emotional/psychologicamental component. 
C.M.A.'s First Amended Complaint attempts to allege 32 counts. Counts I 
through XXX are purportedly brought pursuant to 18 U.S.C. §2255 — Civil Remedies for 
Personal Injuries; Count XXXI is entitled 'Sexual Battery," and Count XXXII. is entitled 
"Conspiracy to Commit Tortbus Assault only against Defendant, 
in her answers to interrogatory nos. 9 and 10, which seek Information about 
C.M.A.'s damages claims, Plaintiff answered that: 
' Defendant's Motion To Dismiss directed to Plaintiffs First Amended Complaint Is pending. 
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I have bi-polar 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. (lnterrog. No. 9). 
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. (Interrog. No. 10). 
In her 1st Amended Complaint, relevant to her damages claims, Plaintiff, alleges: 
C.M.A., has in the past suffered, and will in the future suffer, physical Injury, 
pain and suffering, emotional distress, psychological trauma, mental anguish, 
humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her 
privacy and other damages ... . The then minor Plaintiff incurred medical and 
psychological expenses ... and will in the future suffer additional medical and 
psychological expenses. The Plaintiff C.M.A. has suffered loss of income, a 
toss of the capacity to earn Income in the future, and a loss of capacity to enjoy 
life. These injuries are permanent in nature and the Plaintiff, C.M.A., will 
continue to suffer these losses in the future. 
(1st Am. Complaint, Counts I - XXX (18 U.S.C. §2255), ¶¶25, 31, 37, 43, 49, 55, 
61, 67, 73, 79, 85, 91, 97, 103, 109, 115, 121, 127, 133, 139, 145, 151, 157, 
163, 169, 175, 181, 187, 193; Count XXXI (Sexual Battery), ¶199.) 
In each of her 'Wherefore" clauses, Plaintiff seeks "compensatory damages of at 
least the minimum provided by law." 18 U.S.C. §2255, pursuant to which Plaintiff 
attempts to bring certain of her claims, allows for recovery of "actual damages." See fn. 
2 herein for applicable statutory text.2
As discussed above, the tax returns, and supporting documentation, will provide 
direct evidence as to Plaintiffs claimed damages. Such Information does not only go to 
(a) 
2 Any minor who is a victim of a violation of section 2241(c), 2242, 2243, 2251, 
2251A, 2252, 2252A, 2280, 2421, 2422, or 2423 of this title and who suffers personal Injury 
as a result of such violation may sue in any appropriate United States District Court and 
shall recover the actual damages such minor sustains and the cost of the suit, including 
a reasonable attorney's fee. Any minor as described In the preceding sentence shall be 
deemed to have sustained damages of no less than $50,000 in value. ]Emphasis added.] 
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compensatory or actual damages or loss of income/loss of capacity to earn income type 
damages, but also her emotional/psychological/mental health type damages. In the 
telephone communication between counsel for the respective parties, Plaintiffs counsel 
indicated that Plaintiff was not seeking loss of income/earning capacity type damages; 
(Defendant is not aware that there has been any formal withdrawal of such, damages 
claimed); notwithstanding, the information sought Is still relevant and discoverable 
based on the additional damages claimed by Plaintiff. The time period will allow 
Defendant to compare how Plaintiff was doing In her life prior to, during, and after the 
alleged incident. Again, the type of jobs Plaintiff has been able to hold and her earnings 
and ability to support herself clearly have not only a financial component, but an 
emotional/psychological/mental health component as well. 
Accordingly, Plaintiffs 
objection is required to be overruled, and Defendant is entitled to the documents 
requested. 
Production Request No. 2 
2. 
All bills/expenses from any medical doctor, chiropractor, psychologists, 
psychiatrists, mental health counselors (Including any members of the healing arts and 
related fields, i.e. drugs, prescriptions, etc.) you claim you incurred as a result of the 
injuries which are or may be the subject matter of this lawsuit 
Response: 
None in our possession. These will be provided upon receipt. Discovery Is ongoing. 
Legal Argument Supporting Entitlement to Discovery 
Plaintiff makes no objection to the documents requested, but has failed to 
produce any documents responsive to this request. Clearly, the documents are relevant 
and discoverable as they go to proof of Plaintiffs claimed injuries. In the April 1, 2009, 
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telephone communication Plaintiffs counsel Indicated that Plaintiff was still not in 
possession of such documents. 
The First Request for Production was served on 
Plaintiff on January 16, 2009. In her answer to interrogatory no. 11, (Notice ;of Serving 
Answers, dated February 18, 2009, identifies a psychiatrist and a counselor/therapist 
from whom she claims she is receiving "treatment or examination for the injuries for 
which [she] seeks damages° See Exhibit A hereto for copy C.M.A.'s answer to 
interrogatory no. 11. Regarding the date of treatment from the psychiatrist — she 
asserts "I would defer to the Doctor's records' She claims the treatment from the 
counselor/therapist has been "since high school" and "ongoing." Defendant is entitled to 
the documents sought and Plaintiff is in control of and has the ability to obtain the 
requested medical bills and expenses she claims were incurred as result of her injuries 
claimed in this action. Plaintiff should be required to immediately produce the. requested 
documents to Defendant. 
Production Request No. 4 
4. 
All reports, evaluations, recommendations and/or analysis submitted by 
any expert which relate to or cover the Incident which is the subject matter of this 
lawsuit and/or any injuries, damages or losses you allege were caused by the incident. 
Response: 
Any reports generated by any retained experts not yet disclosed are protected by the 
work product privilege. Notwithstanding same, none. 
Legal Argument Supporting Entitlement to Discovery 
Plaintiff, through counsel, in the April 1, 2009, telephone communication, 
indicated that she does not have any responsive documents and stands by her 
objection. Rule 26 provides In relevant part — 
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2) Disclosure of Expert Testimony. 
(A) In General. In addition to the disclosures required by Rule 26(a)(1), a party must 
disclose to the other parties the Identity of any witness it may use at trial to present 
evidence under Federal Rule of Evidence 702, 703, or 705. 
(B) Written Report. Unless otherwise stipulated or ordered by the court, this 
disclosure must be accompanied by a written report--prepared and signed by the witness—if 
the witness is one retained or specially employed to provide expert testimony in the 
case or one whose duties as the party's employee regularly involve giving expert testimony. 
The report must contain: 
(i) a complete statement of all opinions the witness will express and the basis and 
reasons for them; 
(Ii) the data or other information considered by the witness in forming them; 
(iii) any exhibits that will be used to summarize or support them; 
(iv) the witness's qualifications, Including a list of all publications authored In the 
previous 10 years; 
(v) a list of all other cases in which, during the previous four years, the witness 
testified as an expert at trial or by deposition; and 
(vi) a statement of the compensation to be paid for the study and testimony in the 
case. 
(C) Time to Disclose Expert Testimony. A party must make these disclosures at the 
times and in the sequence that the court orders. Absent a stipulation or a court order, the 
disclosures must be made: 
(i) at least 90 days before the date set for trial or for the case to be ready for trial; or 
(ii) if the evidence is intended solely to contradict or rebut evidence on the same 
subject matter identified by another party under Rule 26(a)(2)(8), within 30 days after the 
other party's disclosure. 
(e) Supplementing Disclosures and Responses. 
(1) In General. A party who has made a disclosure under Rule 26(a)--or who has 
responded to an interrogatory, request for production, or request for admission--must 
supplement or correct its disclosure or response: 
(A) in a timely manner If the party learns that in some material respect the 
disclosure or response is incomplete or Incorrect, and if the additional or corrective 
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information has not otherwise been made known to the other parties during the 
discovery process or in writing; or 
(B) as ordered by the court. 
(2) Expert Witness. For an expert whose report must be disclosed under Rule 
26(a)(2)(0), the party's duty to supplement extends both to information included in 
the report and to information given during the expert's deposition. Any additions or 
changes to this Information must be disclosed by the time the party's pretrial disclosures 
under Rule 26(a)(3) are due. 
Accordingly, Defendant requests that should Plaintiff be in possession of any 
such reports, evaluations, recommendations and/or analysis prepared by an expert 
expected to testify at trial or deposition, or to be used by an expert expected to testify at 
trial or deposition, that such documents be produced as required by Rule 26, 
Fed.R.Civ.P. quoted above. 
Production Request No. 5 
5. 
All medical reports and/or records from doctors, physicians, (including 
psychologists, psychiatrists, mental health counselors), hospitals, drug or alcohol 
facilities or any other person or entity who has rendered treatment to or examined you 
for any reason after the incident(s) which is the subject matter of this lawsuit. 
Response: 
None in our possession. Discovery is ongoing. 
Legal Argument Supporting Entitlement to Discovery 
Once again, Plaintiff should be required to immediately produce the requested 
documents. In support of ordering immediate production, Defendant realleges and 
incorporates his "Legal Argument Supporting Entitlement To Discovery" to request no. 5 
above herein. 
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Interrogatory No. 
2. 
List the names, business addresses, telephone and cell phone numbers, 
dates of employment, Immediate supervisor (name and address) and rates of pay 
regarding ail 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. 
j..egal Argument Supporting Entitlement to Discovery 
Such Information is clearly relevant to the damages and Injuries Claimed by 
Plaintiff In this action. 
Plaintiffs complaint alleges in part that "beginning In 
approximately late May or early June of 2002, and continuing until approximately 
August of 2003, the Defendant coerced and enticed the impressionable, vulnerable, and 
economically deprived then minor Plaintiff to commit various acts of sexual misconduct." 
1st Am. Complaint, ¶13. (See discussion of Production Request no. 1 above herein). 
Such information Is both relevant and reasonably calculated to lead to the 
discovery of admissible evidence. 
It is well settled that relevant information is 
discoverable, even if not admissible at trial, so long as the discovery is reasonably 
calculated to lead to the discovery of admitsible evidence. Rule 26(b)(1), Fed.R.Civ.P.; 
Donahav v. Palm Beach Tours & trans., Inc., 242 F.R.D. 685 (S.D. Fla. 2007). 
Discoverability of such information is governed by Rule 26, Fed.R.C1v.P., pursuant to 
which the scope of discovery is broad. Donahav, supra, at 688, and cases cited therein. 
Parties may obtain discovery regarding any matter, not privileged, which is relevant to 
the claims or defense of any party involved in the pending action." IA. 
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Plaintiff's employment and earnings history prior to and after the alleged 
Incidents are relevant to her claimed damages and Injuries. Such Information would not 
only evidence Plaintiff's employment and earning history, but also provide evidence as 
to how Plaintiff has been able to function in her daily life before, during and after the 
alleged incidents. Was she self-sufficient? Was she able to get out of bed each 
morning and support herself? What type of Job did she hold? One's ability to earn a 
living and be self-supporting has not only a financial component, but also an 
emotional/psychological/mental component. 
C.M.A.'s First Amended Complaint attempts to allege 32 counts. Counts I 
through XXX are purportedly brought pursuant to 18 U.S.C. §2255 — CMI Remedies for 
Personal Injuries; Count XXXI is entitled °Sexual Battery," and Count XXXII is entitled 
"Conspiracy to Commit Tortious Assault only against Defendant, =It 
In her answers to interrogatory nos. 9 and 10, which seek information about 
C.M.A.'s damages claims, Plaintiff answered that 
I have bi-polar 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. (interrog. No. 9). 
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. (lnterrog. No. 10). 
In her 1st Amended Complaint, relevant to her damages claims, Plaintiff alleges: 
C.M.A., has in the past suffered, and will in the future suffer, physical injury, 
pain and suffering, emotional distress, psychological trauma, mental anguish, 
humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her 
privacy and other damages ... . The then minor Plaintiff incurred medical and 
psychological expenses ... and will in the future suffer additional medical and 
psychological expenses. The Plaintiff C.M.A. has suffered loss of income, a 
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loss of the capacity to earn income in the future, and a loss of capacity to enjoy 
life. These injuries are permanent in nature and the Plaintiff, C.M.A., will 
continue to suffer these losses in the future. 
(1st Am. Complaint, Counts I - XXX (18 U.S.C. §2255), ¶¶25, 31, 37, 43, 49, 55, 
61, 67, 73, 79, 85, 91, 97, 103, 109, 115, 121, 127, 133, 139, 145, 151, 157, 
163, 169, 175, 181, 187, 193; Count XXXI (Sexual Battery), ¶199.) 
In each of her "Wherefore" clauses, Plaintiff seeks "compensatory damages of at 
least the minimum provided by law." 18 U.S.C. §2255, pursuant to which Plaintiff 
attempts to bring certain of her claims, allows for recovery of "actual damages." See fn. 
2 herein for applicable statutory text. 
As discussed above, C.M.A.'s employment and earnings history will provide direct 
evidence as to Plaintiffs claimed damages. Such information does not Only go to 
compensatory or actual damages or loss of income/loss of capacity to earn income type 
damages, but also her emotional/psychological/mental health type damages. In the 
telephone communication between counsel for the respective parties, Plaintiffs counsel 
indicated that Plaintiff was not seeking loss of income/earning capacity type, damages; 
(Defendant Is not aware that there has been any formal withdrawal of such damages 
claimed); notwithstanding, the information sought is still relevant and discoverable 
based on the additional damages claimed by Plaintiff. The time period will allow 
Defendant to compare how Plaintiff was doing In her life prior to, during, and after the 
alleged Incident. Again, the type of Jobs Plaintiff has been able to hold and her earnings 
and ability to support herself clearly have not only a financial component, but an 
emotional/psychological/mental health component as well. 
Accordingly, Plaintiffs 
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objection is required to be overruled, and Defendant is entitled to the information sought 
in the Interrogatory. 
Interrogatory No. 18 
• 
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. 
Legal Argument Supporting Entitlement to Discovery 
Plaintiffs only objection is relevancy and overbroad, without any factual support 
or showing as required by Rule 26(c) and Local Gen. Rule 26.1 H (S.D. Fla. 2008). 
Nowhere does C.M.A. explain how such interrogatory is overbroad. 
It is well settled that relevant information is discoverable, even if not admissible at 
trial, so long as the discovery is reasonably calculated to lead to the discovery of 
admissible evidence. Rule 26(b)(1), Fed.R.Civ.P.; Donahay v. Palm Beach Tours & 
trans.. Inc., 242 F.R.D. 685 (S.D. Fla. 2007). 
Discoverability of an alleged 
victim's/plaintiffs sexual conduct or activity in civil cases is governed by Rule 26, 
Fed.R.Civ.P., pursuant to which the scope of discovery is broad. Donahav, supra, at 
886, and cases cited therein. Parties may obtain discovery regarding any matter, not 
privileged, which is relevant to the claims or defense of any party involved in the 
pending action." Id. 
In accordance with Rule 26, the discovery sought regarding Plaintiffs sexual 
activity with males and the nature thereof, including whether she received any 
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compensation or consideration therefore, in interrogatory no. 18, are all relevant to 
Plaintiffs damages claims and the type of injury she claims she has, suffered. 
Defendant has no other means of obtaining such information and obtaining such 
information through Plaintiff will better protect the confidentiality until the Court can 
make a determination in accordance with the procedures under Rule 412(c) whether 
such information will be admissible at trial. See Rule 412(c), Fed.R.Civ.P. Defendant 
will agree to an order keeping the confidentiality of the information obtained through 
discovery. 
The evidence sought is relevant based on the facts and theories of this action. 
C.M.A.'s First Amended Complaint attempts to allege 32 counts. Counts I through XXX 
are purportedly brought pursuant to 18 U.S.C. §2255 — Civil Remedies for Personal 
Injuries; Count XXXI is entitled "Sexual Battery," and Count XXXII Is entitled 
"Conspiracy to Commit Tortious Assault only against Defendant 
In her answers to Interrogatory nos. 9 and 10, which seek information about 
C.M.A.'s damages claims, Plaintiff answered that 
I have bi-polar 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. (Interrog. No. 9). 
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. (Interrog. No. 10). 
In her f t Amended Complaint, relevant to her damages claims, Plaintiff alleges: 
C.MA, has In the past suffered, and will in the future suffer, physical injury, 
pain and suffering, emotional distress, psychological trauma, mental anguish, 
humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her 
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privacy and other damages ... . The then minor Plaintiff incurred medical and 
psychological expenses ... and will in the future suffer additional medical and 
psychological expenses. The Plaintiff C.M.A. has suffered loss of income, a 
loss of the capacity to earn income In the future, and a loss of capacity to enjoy 
life. These Injuries are permanent in nature and the Plaintiff, C.M.A., will 
continue to suffer these losses In the future. 
(1st Am. Complaint, Counts I — XXX (18 U.S.C. §2255),1125, 31, 37, 43, 49, 55, 
61, 67, 73, 79, 85, 91, 97, 103, 109, 115, 121, 127, 133, 139, 145, 151, 157, 
163, 169, 175, 181, 187, 193; Count XXXI (Sexual Battery), ¶199.) 
In each of her "Wherefore" clauses, Plaintiff seeks "compensatory daMages of at 
least the minimum provided by law." 18 U.S.C. §2255, pursuant to which Plaintiff 
attempts to bring certain of her claims, allows for recovery of "actual damages? See fn. 
2 herein for applicable statutory text 
C.M.A. also alleges that Defendant's conduct was "sexual assault and child 
abuse of a then minor? ¶2. She alleges that "beginning in approximately late May or 
early June of 2002, and continuing until approximately August of 2003, the.Defenclant 
coerced and enticed the Impressionable, vulnerable, and economically deprived then 
minor Plaintiff to commit various acts of sexual misconduct." ¶13. 
... These acts included, but were not limited to, fondling and inappropriate and 
Illegal sexual touching of the then minor Plaintiff, sexual misconduCt and 
masturbation of the Defendant In the presence of the then minor Plaintiff, 
soliciting and enticing the then minor Plaintiff to engage in sexual acts with 
another female in EPSTEIN's presence, and encouraging the then minor 
Plaintiff to become involved in prostitution; Defendant committed numerous 
criminal sexual offenses against the then minor Plaintiff including, but not 
limited to, sexual battery, solicitation or prostitution, procurement of a minor for 
the purpose of prostitution, and lewd and lascivious assaults upon the person of 
the then minor plaintiff. (1'4 Am. Complaint ¶13). 
The information sought Is clearly relevant to the injuries and damages claimed by 
Plaintiff. The nature of her claimed injuries and damages are such that Defendant is 
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entitled to evidence which would show the nature of her relationship with males, 
whether she has suffered or engaged in other acts of sexual misconduct or activity as 
alleged in her complaint, and whether she suffered injury and damages as a result of 
the other claimed sexual misconduct or activity. See United States v. Bear Stops, 997 
F.2d 451 (8th Cir. 1993)(Defendant charged with sexual abuse of six year old boy was 
entitled to admission of evidence relating to victim's sexual assault by 3 older boys to 
establish alternative explanation for why victim exhibited behavioral manifestations of 
sexually abused child.). 
In further support of Defendant's motion, a copy of )3alas v. Ruzzo, 703 So.2d 
1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), is attached hereto as 
Exhibit B as it is on point to the discovery Issues in this action, and the relevancy and 
discoverability of Plaintiffs history of sexual activity and any payment, therefore. See 
interrogatories 8, 22 and 30 propounded in the Balas case and footnote 1 herein. 3
Additionally and significantly, in other pending state court civil actions against Defendant 
EPSTEIN attempting to assert similar claims and damages, the Circuit Court Judges 
have already ruled that such information is discoverable as it is relevant to the damages 
claims of Plaintiff. See Composite Exhibits C and D hereto. Composite Exhibit C 
are the Orders, dated February 23, 2009, entered in the case of A.C. v. Epstein, and 
Case No. 502008CA025129 MB Al, 15th Judicial Circuit, In and For Palm Beach 
County, State of Florida, which granted Defendant's motion to compel therein directed 
In Pales v. Ruzzo, supra, the Plaintiffs alleged a multicount complaint including claims for 
"coercion of prostitution" pursuant to §796.09, Fla. Slat; for battery for the unwanted and 
offensive touching of petitioners' bodies; false imprisonment for physically confining the 
petitioners against their will; invasion of privacy, and intentional infliction of emotional distress. 
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to discovery identical to interrogatory no. 18 above. (In the A.C. case, the Plaintiff 
answered without objection Interrogatories identical to nos. 19, 20, and 21 herein.) 
Composite Exhibit D is a portion the transcript from a March 3, 2009 hearing on 
Defendant's motion to compel discovery in the case of Jane Doe II v. Epstein, and 
, Case No. 502008CA020614 MB AF,15t  Judicial Circuit Court, In and For Palm 
Beach County, State of Florida. Again, the Circuit Court Judge determined that the 
information sought Is relevant to the Issue of damages and, thus, discoverable. 
Accordingly, Plaintiff's objections are required to be overruled and Defendant is 
entitled to the discovery sought. 
Interrogatory No. 23 
23. 
State the names, addresses, ages, phone numbers and dates of all 
females whom you claim were brought by you to Mr. Epsteln'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 
Legal Argument Supporting Entitlement to Discovery 
Counsel for the respective parties also discussed this Interrogatory in an effort to 
come to a resolution. Plaintiff does not object to the discovery requested. Plaintiffs 
counsel Indicated that he had a "problem" disclosing the identity of A.L. to the extent 
she was a minor at the time. Defendant would agree to an order protecting public 
disclosure of the true identity of A.L. if she were indeed a minor at the time; however, as 
part of the order, Plaintiff should also be required to provide Defendant with the full 
EFTA01070422

Case 9:08-cv-80811-KAM 
Document 54 
Entered on FLSD Docket 04/02/2009 
Page 17 of 18 
c.MA. v. Epstein, et S. 
Page 17 
name of A.L. so that Defendant may conduct meaningful discovery. It is Plaintiff who 
claims she brought A.L. to Epstein's home as part of the alleged "scheme." in addition, 
Plaintiff failed to provide any date or dates as to when she brought A.L. to Epstein's 
home. Plaintiffs counsel indicated they would attempt to provide this information. 
Accordingly, in granting Defendant's motion to compel discovery, with respect t 
this interrogatory, Plaintiff should be required to provide the full name of A.L. (which 
Defendant agrees to keep confidential at this time), the date or dates which she brought 
A.L. or any female to Epstein's home, and how much she was allegedly paid each time. 
WHEREFORE, Defendant requests that this Court grant Defendant's motion to 
compel and award Defendant's reasonable expenses, including attorney's fees, 
associated with this motion. 
Rule 7.1 Certification 
I hereby certify that counsel for the respective parties communicated by 
telephone in a good faith effort to resolve the discovery issues prior to the filing of this 
motion to compel. Some of the issues were resolved or in the process of being 
resolved. 
Robert D. Cri n, Jr. 
Attorney for °fondant Epstein 
Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with 
the Clerk of the Court using CWECF. I also certify that the foregoing document Is being 
served this day on all counsel of r 
entitled on the following Service List in the 
manner specified by CM/ECF on this 
y of  April, 2009 
EFTA01070423

Case 9:08-cv-80811-KAM 
Document 54 
Entered on FLSD Docket 04/02/2009 
C.M.A. v. Epstein, et al. 
Page 18 
Richard Horace Willits, Esq. 
Richard H. Willits, P.A. 
2290 10th Avenue North 
Suite 404 
L 33461 
ax: 
Counsel for Plaintiff C.MA. 
reelrhwa hotmail.com 
Jack Scarola, Esq. 
Jack P. Hill, Esq. 
Seamy Denney 
Scarola Barnhart 
Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
ach, FL 33409 
Fax: 
Jsx
searcvlaw.com 
ioh@searcvlaw.corn 
Co-Counsel for Plaintiff 
Page 18 of 18 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
ch, FL 33401-5012 
net 
Counsel for Defendant Jeffrey Epstein 
Bruce Reinhart, Esq. 
& Bruce E. Reinhart, P.A. 
250 S. Australian Avenue 
Suite 1400 
ach, FL 33401 
ecfe.•rucere n a law. 
Counsel for Defendant... 
Respectfully subm 
By: 
ROBERT D. 
ITTON, JR., ESQ. 
Florida Bar 
224162 
rc 
bcicla .co 
MICHAEL J. PIKE, ESQ. 
Florida Bar #617296 
nnolkealbolc.law.cotp 
BURMAN, CRITTON, LUTTIER & COLEMAN 
515 N. Flagler Drive, Suite 400
ach, FL 33401 
Phone 
Fax 
Counse or efendant Jeffrey Epstein) 
EFTA01070424

Case 9:08-cv-80811-KAM 
Document 54-2 
Entered on FLSD Docket 04/02/2009 
Page 1 of 2 
C.M.A. vs. Epstein, eta 
Oise No.: 08-CV-80811-CIV-MARRAIJOHNSON 
Plaintiffs 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 bi-polar 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. § 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 
ti
tanA 
EXHIBIT : 
EFTA01070425

. 
Case 9:08-cv-80811-KAM 
Document 54-2 
Entered on FLSD Docket 04/02/2009 
Page 2 of 2 
C.M.A. vs. Epstein, et aL 
CaseNo.: 08-CV-8081I-CIV-MARRAB0HNS0N 
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. 
ANSWER 
Dr. Serge Thys (Psychiatrist) 
Date: I do not recall the date. I would defer 
216145°  Street 
to the Doctor's records. 
West Palm Beach, FL 33407 
all Pope (CounselorlTherapist) 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 t 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 (3112104, 3126108) 
Child Birth 
1309 N Flagler Dr 
West Palm Beach, FL 33401 
St. Mary's Hospital (4107) 
DNC 
901 46th Street 
West Palm Beach, FL 33407 
Gloria C. Hakkarainen, MD 
Ob/Gyn 
292610th Avenue North, Suite 306 
Palm Springs, FL. 33461 
Theodore Ritota, DDS 
Dentist 
14 
EFTA01070426