# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 08-CV-80811-CIV-

Plaintiff,

vs.

JEFFREY EPSTEIN and 
,
Defendants.

## PLAINTIFF'S NOTICE OF SERVING
SECOND AMENDED ANSWERS TO INTERROGATORIES

COMES NOW the Plaintiff, [REDACTED], by and through undersigned counsel, and hereby files this Notice with the Court that Second Amended 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 e-
mail this 28 day of October, 2009, to See attached list of counsel.
<signature>
JACK SCAROLA
Florida Bar No.: 169440
JACK P. HILL
Florida Bar No.: 0547808
Searcy Denney Scarola Barnhart & Shipley, P.A.
Attorney for Plaintiff(s)

Δ Π EXHIBIT 1
Deponent: Ms Andries
Date: 14/09
Rptr.: OH
DEPOSITORY

EFTA00023940

vs. Epstein, et al.
Case No.: 08-CV-80811-CIV
Plaintiff's Second Amended Answers to Defendant's First Interrogatories

## PLAINTIFF'S NOTICE OF SERVING
SECOND AMENDED ANSWERS TO INTERROGATORIES

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 fathers name and address. List the names and address of your parents and any brother or sister.

## ANSWER

| Field | Value | Dates |
|---|---|---|
| Nickname | [redacted] | — |
| Residence 1 | [redacted], West Palm Beach, FL 33417 | July 2007 – Present |
| Residence 2 | [redacted], West Palm Beach, FL | February 2004 – July 2007 |
| Residence 3 | Rome, Georgia | August 2003 – February 2004 |
| Residence 4 | [redacted], West Palm Beach, FL 33409 | About 2½ years ago |
| Residence 5 | [redacted], West Palm Beach, FL 33409 | Approximately 1 year |
| Residence 6 | [redacted], Lake Park, FL | Unknown |

| Personal info | Value |
|---|---|
| SSN | [redacted] |
| DOB | [redacted] |
| Marital status | I have never been married. |
| Children | [redacted] |
| Father | [redacted] |
| Father's address | West Palm Beach, FL 33407 |

2

EFTA00023941

. vs. Epstein, et al. Case No.: 08-CV-80811-CIV Plaintiffs Second Amended Answers to Defendant's First Interrogatories

Key information from the image includes:
*   Father's address: West Palm Beach, FL.
*   Parents' address: Unknown.
*   Address: West Palm Beach, FL. 33417
*   Siblings' address: West Palm Beach, FL. 33417

5. Please provide the name, address, telephone number, place of employment and job title of any person who has, claims to have or whom you believe may have knowledge or information pertaining to any fact alleged in the pleadings (as defined in Federal Rule of Civil Procedure 7(a) filed in this action, or any fact underlying the subject matter of this action).

## ANSWER

1.  [ ]

c/o her attorneys:

Jack Scarola, Esq. and Jack P. Hill, Esq.
Searcy Denney Scarola Barnhart & Shipley, P.A.
West Palm Beach, FL 33409
Tel: <empty>
Richard Willits, Esq.
Richard H. Willits, P.A.
Lake Worth, FL 33461
Tel: <empty>
Subject matter: Plaintiff.

3

EFTA00023942

vs. Epstein, et al. Case No.: 08-CV-80811-CIV Plaintiff's Second Amended Answers to Defendant's First Interrogatories

2. Jeffrey Epstein

do his attorneys:

Robert Critton, Esquire
Burman Critton Luttier & Coleman LLP

West Palm Beach, FL 33414
Tel:

Jack A. Goldberger, Esquire
Atterbu Goldbe er & Weiss, P.A.

West Palm Beach FL 33401
Tel:

Bruce E. Reinhart, Esquire
Bruce E. Reinhart, P.A.

West Palm Bea h L 33401
Tel: 

Subject matter: Defendant

3. [REDACTED]'s mother, [REDACTED], and her brother, [REDACTED]
c/o [REDACTED]'s attorneys:

Jack Scarola, Esq. and Jack P. Hill, Esq.
Searcy Denney Scarola Barnhart & Shipley, P.A.
West Palm Beach, FL 33409
Tel: <empty>

Richard Willits, Esq.
Richard H. Willits, P.A.
Lake Worth, FL 33461
Tel: <empty>

Subject matter: <empty>'s involvement with Epstein.

4

EFTA00023943

C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIMMIMI Plaintiffs Second Amended Answers to Defendant's First Interrogatories

4.
(Address unknown)

Subject matter:

Defendant.

5. Jane Doe (Case No.: 1:93-cv-01109-KAM)
c/o her attorney:
Theodore Leopold, Esquire
Leopold, Kuvin, P.A.
Palm Beach Gardens, FL 33410
Te
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

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.
Subject matter: Victim of Epstein.

8. Jane Doe #3 (Case No.: 9:08-cv-80232-KAM) c/o her attorney:

5

EFTA00023944

vs. Epstein, et al. Case No.: 08-CV-80811-CIV- Plaintiff's Second Amended Answers to Defendant's First Interrogatories

- Case number: 08-CV-80811-CIV
- Document title: Plaintiff's Second Amended Answers to Defendant's First Interrogatories
- Attorney block present (name/firm shown but largely redacted with black bars)
- Subject matter line: "Victim of [NAME REDACTED]"
- Visual: two black rectangular redaction bars covering contact/details in the attorney block

9. Jane Doe #5 (Case No.: 9:08-cv-80381-KAM) c/o her attorney:

| Field | Value |
|---|---|
|Name|Jeffrey M. Herman, Esquire|
|Firm|Herman & Mermelstein, P.A.|
|Redacted content|Two blacked-out blocks (one long horizontal bar and one shorter bar)|
|Subject matter|Victim of Epstein.

10. Jane Doe #4 (Case No.: 9:08-cv-80380-KAM) c/o her attorney:

- Name: Jeffrey M. Herman, Esquire
- Firm: Herman & Mermelstein, P.A.
- Redactions: two blacked-out lines (likely address/contact)
- Subject matter: Victim of Epstein

11. Jane Doe (Case No.: 9:08-cv-80804-KAM)

c/o her attorney:

| Field | Value |
| --- | --- |
| Addressee line | c/o her attorney: [name redacted] |
| Attorney / firm line | [name/redacted] (law firm line present) |
| Contact/address block | [redacted — large blacked-out area] |
| Subject matter | Victim of [name redacted]

6

EFTA00023945

vs. Epstein, et al.

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON

Plaintiff's Second Amended Answers to Defendant's First Interrogatories

## 12. Jane Doe #7 (Case No.: 9:08-cv-80993-KAM)

c/o her attorney:

Jeffrey M. Herman, Esquire
Herman & Mermelstein, P.A.

Subject matter: Victim of Epstein.

## 13.

[ ]

(Case No.: 502008CA025129XXXXXMB AI
c/o her attorneys:
Jack Scarola, Esquire
Jack P. Hill, Esquire
Searcy Denney Scarola Barnhart & Shipley, P.A.
Tel: <empty>
Subject matter: Victim of Epstein.

14.
(Address unknown at this time)
Subject matter: Jeffrey .
15.
Palm Beach Police Department
Subject matter: Investigator.

7

EFTA00023946

Case No.: 08-CV-80811-CIV-R

16. [REDACTED] — Palm Beach County Prosecutor’s Office; West Palm Beach, FL 33401; Tel: (561) 355-7100. Subject matter: Prosecutor.

17. Detective [REDACTED] — Lead investigator, Palm Beach Police Department. Subject matter: Investigator.

18. [REDACTED] — Subject matter: Former boyfriend of a victim of Epstein.

19. Sgt. [REDACTED] — Palm Beach Police Department. Subject matter: Investigator.

20. [REDACTED] — Subject matter: Plaintiff’s former boyfriend.

21. [REDACTED] — Supervisor, Sanitation Bureau, Town of Palm Beach. Additional details redacted.

8

EFTA00023947

vs. Epstein, et al.

Case No.: 08-CV-80811-CIV-

Plaintiff's Second Amended Answers to Defendant's First Interrogatories

Tel:

| Item | Description | Subject Matter |
|---|---|---|
| 22. | Palm Beach County Sheriff's Office | Investigator |
| 23. | (Name Blocked), friend of (Name Blocked)  | Victim and friend of (Name Blocked) |
| 24. | Ghislane Maxwell c/o Ghislane Corp. | Associate of Epstein |
| 25. | (Name Blocked) Parent Child Center | Counselor at Parent Child Center |
| 26. | Detective (Name Blocked), Palm Beach Police Department | Investigator |
| 27. | Chief (Name Blocked), Palm Beach Police Department | N/A |
| Other | N/A | The incident which is the subject matter of this lawsuit |

9

EFTA00023948



vs. Epstein, et al.

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON

Plaintiff's Second Amended Answers to Defendant's First Interrogatories

| No. | Name (redacted) | Affiliation / position (if shown) | Address / contact | Subject matter / role |
|-----|------------------|-----------------------------------:|-------------------|----------------------|
| 28  | [redacted]       | —                                  | Address unknown at this time | Associate of Epstein who facilitated introductions with various victims |
| 29  | [redacted]       | —                                  | Address unknown at this time | Employee of Epstein |
| 30  | Detective [redacted] | Palm Beach Police Department    | Contact redacted | Investigator |
| 31  | [redacted]       | First Assistant U.S. Attorney, U.S. Dept. of Justice | Tel: [redacted] | Federal prosecutor |
| 32  | [redacted]       | Federal Bureau of Investigation    | Contact redacted | Investigator |

10

EFTA00023949

vs. Epstein, et al. ase o.. 08-CV-80811-CIV Plaintiffs Second Amended Answers o e en ant's First Interrogatories

| Item | Description |
|---|---|
| 33 | Address (West Palm Beach) to be provided upon receipt, subject matter is someone's physician. |
| 34 | Assistant U.S. Attorney, U.S. Dept. of Justice, Federal prosecutor. |
| 35 | Friend of someone's mother, address to be provided upon receipt. |
| 36 | Friend of someone's mother, address to be provided upon receipt. |
| 37 | Friend of someone, address to be provided upon receipt, potential victim and friend of someone. |
| 38 | Address unknown, associate of Epstein in encounters between Epstein and someone. |
| 39 | Friend of someone, address unknown. |

39.
<empty>, friend of <empty>
(Address unknown at this time)

11

EFTA00023950

... vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
Plaintiff's Second Amended Answers to Defendant's First Interrogatories

40. <empty>(last name unknown), friend of <empty>
(Address unknown at this time)

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:<empty>

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 more than one occasion I used cocaine powder. I do not recall the dates.

	3. On more than one occassion I used marijuana. I do not recall the dates.

11. List the names and business addresses of each physician (including psychiatrist, psychologist, chiropractor or medical provider) who has treated or examined you, 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
Date: I do not recall the date.
I would defer to the Doctor's records.

12

EFTA00023951

vs. Epstein, et al. Case No.: 08-CV-80811-CIV-1 Plaintiff's Second Amended Answers to Defendant's First Interrogatories

- Document context (provided): vs. Epstein, et al. — Case No.: 08-CV-80811-CIV-1; Plaintiff's Second Amended Answers to Defendant's First Interrogatories. Date (provided): "Since high school. Ongoing."
- Image content: three heavily redacted text lines/paragraphs.
  - No readable words; nearly entire lines are black redaction bars.
  - Small unredacted fragments/white gaps appear within the first and third redacted lines but contain no legible text.
- Key takeaway: content is redacted and not extractable beyond its format (three answer lines with limited visible fragments).

Date: Since high school. Ongoing.

Date: I do not recall the dates,

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

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.

Please refer to #5 above and #16 below.

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 <empty> 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, provided by Jeffrey Epstein, <empty> my ex-boyfriend <empty>, my mother <empty> and my brother <empty>. I was also transported via private car provided by Jeffrey Epstein.



(Address will be provided upon receipt)

13

EFTA00023952

vs. Epstein. et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories

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

*   Person 1: Age 22, Paid $100.00
*   Person 2: Last name unknown, Address unknown, Paid $100.00
*   Person 3: Address unknown, Paid $100.00

14

EFTA00023953

vs. Epstein, et al. Case No.: 08-CV-80811-CIV- Plaintiff's Second Amended Answers to Defendant's First Interrogatories

Signature of Answering Party:<empty>

STATE OF Florida )

COUNTY OF Palm Beach )

The foregoing instrument was acknowledged before me this ______ day of February, 2009 by _______ who is personally known to me or who has produced __________ (type of identification) as identification and who did/did not take an oath.

Notary Public
State of Florida at Large
My Commission expires:
Commission No:

15

EFTA00023954

vs. Epstein, et al. ase No.: 08-CV-80811-CIV Plaintiffs Second Amended Answers to Defendant's First Interrogatories

## COUNSEL LIST

Here are the attorneys mentioned in the image:

*   Jack A. Goldberger: Atterbury, Goldberger & Weiss, P.A.
*   Bruce E. Reinhart, Esquire: Bruce E. Reinhart, P.A.
*   Robert Critton: Burman Critton Luttier & Coleman LLP

Jack A. Goldberger and Robert Critton acted as attorneys for Jeffrey Epstein.

Richard H. Willits, Esquire of Richard H. Willits, P.A., is identified as "Attorneys for Party." Contact information like phone and fax are obscured.

16

EFTA00023955

## VERIFICATION

being duly sworn, deposes and says that the foregoing answers to interrogatories are true and correct to the best of her knowledge, information and belief.

STATE OF FLORIDA )
) ss
COUNTY OF PALM BEACH )

SWORN TO AND SUBSCRIBED before me this 26 day of October , 2009 by
<empty> , who is personally known to me or has produced the following
identification <empty> .



Notary Public State of Florida
Michael Danchuk
My Commission DD810405
Expires 10/03/2018

(SEAL)

Notary - Print Name: MICHAEL DANCHUK
Notary - Signature: <signature>

EFTA00023956