EFTA01070451

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FL§D Dock.et 07/?0/2009 
JO ofa. 
Case 9:08-cv-80811-KAM 
Document 54 
Entered on FLSD Docket 04/02/2009 
Page 10 of 18 
C.M.A. v. Epstein, et el. 
Page 10 
Plaintiffs 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 Plaintiffs employment and earning history, but also provide eirldence 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 — Civil Remedies for 
Personal Injuries; Count XXXI is entitled "Sexual Battery," and Count XXXII is entitled 
"Conspiracy to Commit Tortlous 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. l 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 1si 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 
EFTA01070491

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 112f 46 
Case 9:08-cv-80811-KAM 
Document 54 
Entered on FLSD Docket 04/02/2009 
Page 11 of 18 
C.MA. v, Epstein, et al. 
Page 11 
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. 
(15t Am. Complaint, Counts I - XXX (18 U.S.C. §2255),11¶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 bnly 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, Plaintiff's 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 
EFTA01070492

Case 9:08-cv-80119-KAM 
Document 207 4 
Entered, on FLSD Docket 07/2(2/2009 
Page 12 of.48 
Case 9:08-cv-80811-KAM 
Document 54 
Entered on FLSD Docket 04/02/2009 
Page 12 of 18 
C.M.A. v. Epstein, et al. 
Page 12 
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 ago 10 (by year) 
up through your current age. Describe the nature of sexual activity, the date(e) 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 facOal 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 
686, and cases cited therein. "Parties may obtain discovery regarding any matter, not 
privileged, which is relevant to the claims or defense of any patty Involved in the 
pending action." 14. 
In accordance with Rule 26, the discovery sought regarding Plaintiffs sexual 
activity with males and the nature thereof, including whether she received any 
EFTA01070493

Case 9:08-cv-80119-KAM 
Document 2074 
Entered on FLSD Docket 07/20/2009 
Page 13 ofAt 
Case 9:08-cv-80811-KAM 
Document 54 
Entered on FLSD Docket 04/02/2009 
Page 13 of 18 
C.M.A. v. Epstein, et al. 
Page 13 
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,Land Count XXXII Is entitled 
'Conspiracy to Commit Tortlous 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 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. (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 1°1 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 
EFTA01070494

9:0atev-X1119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 . Page 14 of 46 
Case 9:08-cv-80811-KAM 
Document 54 
Entered on FLSD Docket 04/02/2009 
Page 14 of 18 
C.M,A. v. Epstein, et al. 
Page 14 
privacy and other damages ... . The then minor Plaintiff Incurred medithl and 
 psychological expenses ... dud will in the futuiu btf fur 
ditiotraHfiedleal-and 
psychological expenses. The Plaintiff C.M.R. has suffered loss of Income, a 
loss of the capacity to earn income In the future, and a loss of capacity to enjoy 
life. Those Injuries are permanent in nature and the Plaintiff, C.M.A., will 
continue to suffer these losses in the future. 
(10t Am. Complaint, Counts I — XXX (18 U.S.C. §2255), 111125, 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. §2256, 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.MA. 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. Defendant 
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. (15t 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 
EFTA01070495

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSP pgcket 07/20/2009 
Elge_15 of 46 
Case 9:08-ov-80811-KAM 
Document 54 
Entered on FLSD Docket 04/02/2009 
Page 15 of 18 
C.M.A. v. Epstein, et al. 
Page 15 
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 Bales v. Ruzzo, 703 So.2d 
1076 (Fla. 6th 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 Plaintiff's 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 againstiDefendant 
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 AI, 15th Judicial Circuit, in and For Palm Beach 
County, State of Florida, which granted Defendant's motion to compel therein directed 
3 In Batas v. Ruzzo supra, the Plaintiffs alleged a multicount complaint Including claims for 
"coercion of prostitution" pursuant to §795.09, Ma. Stat.; 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. 
EFTA01070496

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on F.L.S.Q.DOCRet 0.71.20/2009.__Page..1.6_a_46 
Case 9:08-cv-80811-KAM 
Document 54 
Entered on FLSD Docket 04/02/2009 ; Page 16 of 18 
v, Epstein, et al. 
Page 16 
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, loth 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, Plaintiffs 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. 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 
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; hiowever, as 
part of the order, Plaintiff should also be required to provide Defendant with the full 
EFTA01070497

Case 9:O-cv-iiic):119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page:17 of g,0 
Case 9:08-cv-80811-KAM 
Document 54 
Entered on FLSD Docket 04/02/2009 
Page 17 of 18 
C.M.A. v. Epstein, et al. 
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 Defendants motion to 
compel and award Defendants 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. Critfbn, Jr. 
Attorney for defendant Epstein 
Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing was 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 re 
Cigentifled on the following Service List in the 
manner specified by CM/ECF on this 'Way of  April, 2009 
EFTA01070498

Cse.9:0P-SY:§0119-KAM 
Document 207-A 
_Entered on FLSD D9PRet 07/29/21/Q9__P.age_18 91_48 
Case 9:08-cv-80811-KAM 
Document 54 
C.M.A. v. Epstein, et at 
Page 18 
Richard Horace Willits, Esq. 
Entered on FLSD Docket 04/02/2009. Page 18 of 18 
• 
Jack Alan Goldberger, Esq. 
icnarc
. 
2290 1 
Avenue North 
Suite 404 
L 33461 
Fax: 
Counse o
ff C.M.A. 
reelrhwOhotmailcom 
Jack Scarola, Esq. 
Jack P. Hill, Esq. 
Seamy Denney Scarola Barnhart 
Shipley, P.A. 
• 
2139 Palm Beach Lakes Boulevard 
ach, FL 33409 
Fax: 
jsxOsearcvlaw.com 
lohCasearcvlaw.com 
Co-Counsel for Plaintiff 
250 Australian Avenue South 
Suite 1400 
ach, FL 33401-5012 
Fax: 
jaaescebellsouth.net 
Counsel for Defendant Jeffrey Epstein 
Bruce Reinhart, Esq. 
& Bruce E. Reinhart, PA 
250 S. Australian Avenue 
Suite 1400 
ach, FL 33401 
Fax: 
ecf(khbrucerelnhartlaw. 
Counsel for Defendan 
Respectfully subm 
, 
By: 
ROBERT D. 
ITTON, JR., ESQ. 
Florida Bar 
224182 
beide 
•m 
MICHAEL J. PIKE, ESQ. 
Florida Bar #617298 
moikeabolciaw.com 
BURMAN, CRITTON, LUTTIER & COLEMAN 
515 N. Fiagler Drive, Suite 400 
h, FL 33401 
Phone 
Fax 
Counse or • efendant Jeffrey Epstein) 
EFTA01070499

iCAM 
Case 9.98-cv-801197
_.MN................ant9N0 on .FL.S4 Pgoket 0.7/2.0/20.Q9__Pagei9_af.46 
Case 9:08-cv-80811-KAM 
Document 54-2 
Entered on FLSD Docket 04/02/2009 
Page 1 of 2 
• 
C.M.N. vs. Epstein, et al. 
Case No.r. 08-CV-808 1 I-QV-MARRA/JOHNSON 
Plaintiff's Answers to Defendant's Pint Interrogatories 
School behavioral problems, received counseling prior to time 
• 
8. 
Did you consume any alcoholic beverages or take any drugs or medications 
within 12 hours before the time of each incidents) 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 Truthpets". 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 fife. 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. 
Ust the names and business addresses of each physician (Including psychiatrist, 
psychologist, chiropractor or medical provider) who has treated or examined you, 
13 
A ti 
EXHIBIT '17 
EFTA01070500