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Court Records as described by folder names.
Epstein Release Interview Victim Statements Evidence Maxwell
← Back to Doe v. Epstein, No. 9;08-cv-80119 (S.D. Fla. 2008)
Extracted Text

Case Document Entered on FLSD Docket Page of C.M.A vs Plaintiff UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO MARRA/JOHNSON JEFFREY EPSTEIN and SARAH KELLEN Defendant I NOTICE OF SERVING ANSWERS TO INTERROGATORIES COMES NOW the Plaintiff C.M.A by and through undersigned counsel and hereby files this Notice with the Court that Answers to Interrogatories propounded by the Defendant JEFFREY EPSTEIN on January have been furnished to the attorney for the Defendant I HEREBY CERTIFY that a true copy of the foregoing has been fU1sh.ed by mail this day ofFebruazy to See attac co JAciscA toLA Florida Bar No JACKP.HILL Florida Bar No Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorney for Plaintiff i PLAINTIFFS EXHIBIT Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Answers to Defendants First Interrogatories ANSWERS TO INTERROGATORIES What is the name and address of all persons answering or assisting in answering these interrogatories and if applicable the persons official position or relationship with the party to whom the interrogatories are directed ANSWER C.M.A c/o her attorneys Jack Scarola Esq and Jack Hill Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach lakes Boulevard West Palm Beach FL With the assistance of her counsel Searcy Denney Scarola Barnhart Shipley P.A and Richard Willits P.A 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 setf-employment for whom you have worked in the past years this includes listing all sources of income you have received Answer this question by year i.e ANSWER Objection Irrelevant immaterial and not reasonably calculated to lead to discovery of admissible evidence List all former names and when you were known by those names State all addresses where you have lived for the past 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 Nickname Brooke Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811-ClV-MARRA/JOHNSON Plaintiffs Answers to Defendants First Inte1TOgatories Terrace North Dates July 2007-Present West Palm Beach FL Pat Place Dates February July West Palm Beach FL Rome Georgia Dates August 2003-February Suwanee Drive Dates About years ago West Palm Beach FL Tallahassee Drive Dates Approximately year WestPalmBeach,FL.33409 SSN I have never been married Children Shawn Haught DOB Father Shawn Haught Address Plantation Lane West Palm Beach FL Brayden Gilchrest DOB Father Donald Gilchrest Address West Palm Beach FL Parents Joseph Father Address Unknown Dorothy Mother Terrace North West Palm Beach FL Siblings Joseph Brother Pasqualino Brother Terrace North West Palm Beach FL Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811..CIV-MARRA/JOHNSON Plaintiffs Answers to Defendants First Interrogatories 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 year or that involved dishonesty or a false statement regardless of the punishment If so state as to each conviction the specific crime and the date and place of conviction ANSWER No 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 a filed in this action or any fact underlying the subject matter of this action ANSWER C.M.A c/o her attorneys Jack Scarola Esq and Jack Hill Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL Tel Richard Willits Esq Richard Willits P.A 10th Avenue North Suite Lake Worth FL Tel Subject matter Plaintiff Jeffrey Epstein c/o his attorneys Robert Critton Esquire Burman Critton Luttier Coleman LLP Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Answers to Defendants First Interrogatories North Flagler Drive Suite West Palm Beach FL Tel Jack A Goldberger Esquire Atterbury Goldberger Weiss P.A Australian Avenue South West Palm Beach FL Tel Bruce Reinhart Esquire Bruce Reinhart P.A South Australian Avenue Suite West Palm Beach FL Tel Subject matter Defendant C.M.A.s mother Dorothy and her brother Joseph c/o C.M.A.s attorneys Jack Scarola Esq and Jack Hill Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL Tel Richard Willits Esq Richard Willits P.A 10th Avenue North Suite Lake Worth FL Tel Subject matter C.M.A.s involvement with Epstein Sarah Kellen Address unknown Subject matter Defendant Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811-CIV-MARRA/JOBNSON Plaintiffs Answers to Defendants First Interrogatories Jane Doe Case No c/o her attorney Theodore Leopold Esquire Leopold Kuvin P.A P.G.A Boulevard Suite Palm Beach Gardens FL Tel Subject matter Victim of Epstein Jane Doe Case No c/o her attorney Isidro Garcia Esquire The Law Office of Brad Edwards Associates LLC Harrison Street Suite Hollywood FL Tel Subject matter Victim of Epstein Jane Doe Case No c/o her attorney Jeffrey Herman Esquire Herman Mermelstein P.A Biscayne Boulevard Suite Miami FL Tel Subject matter Victim of Epstein Jane Doe Case No c/o her attorney Jeffrey Herman Esquire Herman Mermelstein P.A Biscayne Boulevard Suite Miami Fl Tel Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811-CIV-MARRNJOHNSON Plaintiffs Answers to Defendants First Inte1TOgatories Subject matter Victim of Epstein Jane Doe Case No c/o her attorney Jeffrey Herman Esquire Herman Mermelstein P.A Biscayne Boulevard Suite Miami FL Tel Subject matter Victim of Epstein Jane Doe Case No c/o her attorney Jeffrey Herman Esquire Herman Mermelstein P.A Biscayne Boulevard Suite Miami FL Tel Subject matter Victim of Epstein Jane Doe Case No c/o her attorney Theodore Leopold Esquire Leopold Kuvin P.A P.G.A Boulevard Suite Palm Beach Gardens FL Tel Subject matter Victim of Epstein Jane Doe Case No c/o her attorney Jeffrey Herman Esquire Herman Mermelstein P.A Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Answers to Defendants First Interrogatories Biscayne Boulevard Suite Miami FL Tel Subject matter Victim of Epstein A.C Case No Al c/o her attorneys Jack Scarola Esquire Jack Hill Esquire Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL Tel Subject matter Victim of Epstein Jose Alessi Address unknown at this time Subject matter Jeffrey Epsteins Butler Janusa Banasiack Palm Beach Police Department South County Road Palm Beach FL Tel Subject matter Investigator Lanaa Belohavek Palm Beach County Prosecutors Office North Dixie Highway West Palm Beach FL Tel Subject matter Prosecutor Detective Dawson lead investigator Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Answers to Defendants First Inte1Togatories Palm Beach Police Department South County Road Palm Beach FL Tel Subject matter Investigator Anthony Figueroa Santiago Street Royal Palm Beach FL Subject matter Former boyfriend of a victim of Epstein Sgt Frich Palm Beach Police Department South County Road Palm Beach FL Tel Subject matter Investigator Shawn Haught Plantation Lane West Palm Beach FL Subject matter Plaintiffs former boyfriend Tony Higgins supervisor Sanitation Bureau of the Town of Palm Beach N.W th Terrace Pompano Beach FL Tel 46-WASTE Subject matter The incident which is the subject matter of this lawsuit Discovery is ongoing Major Kniesley Palm Beach County Sheriffs Office Gun Club Road West Palm Beach FL Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811-ClV-MARRA/JOHNSON Plaintiffs Answers to Defendants First Interrogatories Subject matter Investigator Amanda friend of C.M.A Address will be provided upon receipt Subject matter Victim and friend of C.M.A Ghislane Maxwell c/o Ghislane Corp Brillo Way Palm Beach FL Subject matter Associate of Epstein Susan Pope Parent Child Center West Palm Beach FL Subject matter Counselor at Parent Child Center Detective Joseph Recarcy Palm Beach Police Department South County Road Parm Beach FL Tel Subject matter Investigator Chief Michael Reiter Palm Beach Police Department South County Road Palm Beach FL Tel Subject matter Investigator Haley Robson Address unknown at this time Subject matter Associate of Epstein who facilitated introductions with various victims Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Answers to Defendants First Interrogatories Alfredo Rodriguez Address unknown at this time Subject matter Employee of Epstein Detective Sandman Palm Beach Police Department South County Road Palm Beach FL Tel Subject matter Investigator Jeffrey Slomon Esquire First Assistant U.S Attorney U.S Dept of Justice South Australian Avenue Suite West Palm Beach FL Tel Subject matter Federal prosecutor Twila Smith M.S.W Federal Bureau of Investigation South Flagler Drive Suite West Palm Beach FL Subject matter Investigator Dr Thys Address will be provided upon receipt West Palm Beach Subject matter C.M.A.s physician A Marie Villafana Assistant U.S Attorney U.S Dept of Justice South Australian Avenue Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Answers to Defendants First Interrogatories Suite West Palm Beach FL Tel Subject matter Federal prosecutor Kelly friend of C.M.As mother Address will be provided upon receipt Subject matter Friend of C.M.As mother Dominique friend of C.M.A.s mother Address will be provided upon receipt Subject matter Friend of C.M.A.s mother Virginia friend of C.M.A Address will be provided upon receipt Subject matter Potential victim and friend of C.M.A Nadia Marcinkova Address unknown at this time Subject matter Associate of Epstein who may have been involved in encounters between Epstein and C.M.A Please state the specific nature and substance of the knowledge that you believe the person identified in your response to interrogatory no may have ANSWER Please see answer to Interrogatory Were you suffering from physical infirmity disability disease sickness or psychiatric/psychological condition at the time of the incident described in the complaint If so what was the nature of the infirmity disability or sickness ANSWER Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811..CIV-MARRA/JOHNSON Plaintiffs Answers to Defendants First Interrogatories School behavioral problems received counseling prior to the incident Did you consume any alcoholic beverages or take any drugs or medications within hours before the time of each incident 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 On one occasion I had taken Morning Glory and Angel Trumpets I do not recall the date On another occasion I used cocaine powder I do not recall the date 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 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 U.S.C.A Discovery is ongoing List the names and business addresses of each physician including psychiatrist psychologist chiropractor or medical provider who has treated or examined you Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Answers to Defendants 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 th Street West Palm Beach FL Date I do not recall the date I would defer to the Doctors records Susan Pope Counselor/Therapist Date Since high school Ongoing Parent Child Center Blue Heron Boulevard 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 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 Child Birth Flagler Dr West Palm Beach FL St Marys Hospital DNC th Street West Palm Beach FL Gloria Hakkarainen MD Ob/Gyn th Avenue North Suite Palm Springs FL Theodore Ritota DDS Dentist Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Answers to Defendants First Interrogatories South Federal Highway Delray Beach FL Palm Beach County Healthcare Department Flu Shots th Street WestPalmBeach,FL.33407 FAU Wellness Center Osceola Drive West Gate FL 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 Epsteins home by Sarah Kellen Jeffrey Epstein had a photo taken of me at his home by Sarah Kellen Please state if you or parents or guardian on your behalf have ever been a party either plaintiff or defendant in a lawsuit other than the present matter and if so state whether you were plaintiff or defendant the nature of the action and the date and court in which such suit was filed ANSWER No List all dates you allege you were at Mr Epsteins home in Florida include date time arrived and left the name of anyone who went with you to the home when you were there the time spent with Mr Epstein and the name and address of any individuals who were present in the home with Mr Epstein and you ANSWER Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 80811-ClV-MARRA/JOHNSON Plaintifrs Answers to Defendants First Interrogatories From May or June of to August of I went to Mr Epsteins home on average times a week There were weeks when I would go times a week All my visit dates were maintained by Jeffrey Epstein and his staff in a phone message book kept on a table by the phone in the kitchen Discovery is ongoing State in detail how you came to be at Mr Epsteins home on each occasion i.e did someone bring you or ask you if you would or wanted to go if so state the name and address of that individual and what he/she told you and the purpose of your visit ANSWER I was introduced to Jeffrey Epstein by my friend Virginia in I was to give Jeffrey Epstein a massage I continued to provide massages up until August of I was transported to Jeffrey Epsteins house by Yellow Cab provided by Jeffrey Epstein Virginia my ex boyfriend Shawn Haught my mother Dorothy Groenert and my brother Joseph Virginia Address will be provided upon receipt 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 persons name address and phone number by year from ANSWER for a massage session at an average of sessions a week from May or June of to August for a photo taken by Sarah Kellen at Jeffrey Epsteins 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 Case Document Entered on FLSD Docket Page of C.MA vs Epstein et al Case No 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Answers to Defendants First Interrogatories List separately the names addresses and phone numbers of all males excluding Mr Epstein with whom you have had sexual activity since age by year up through your current age Describe the nature of sexual activity the date and whether you received money or other consideration from the person ANSWER Objection Relevance and overbroad 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 by year up through your current age Describe the nature of sexual assault or battery the date and whether you received money or other consideration from the person ANSWER None State the names 267addresses 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 by year up through your current age Describe the lewd or lascivious conduct the date and whether you received money or other consideration from the person ANSWER None 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 by year up through your current age Describe the lewd or lascivious exhibition the date and whether you received money or other consideration from the person ANSWER None List in detail all discussions/interviews which you had with any representative Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Answers to Defendants First Interrogatories from FBI U.S Attorneys Office State Attorneys Office Palm Beach County Palm Beach Sheriffs Office and Palm Beach Police Department regarding your meetings with Mr Epstein Include dates who was present the details of what was discussed whether a court reporter was present and whether a taped statement was taken or whether you provided a written statement ANSWER I was interviewed by the FBI and a State Attorney they have my statement State the names addresses ages phone numbers and dates of all females whom you claim were brought by you to Mr Epsteins 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 West Palm Beach FL I was paid 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 reca11 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 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 Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Answers to Defendants First Interrogatories STATE OF Florida COUNTY OF Palm Beach The foregoing instrument was aclmowledged before me this fl_ day of February by Carolyn Andriana 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 Case Document Entered on FLSD Docket Page of C.M.A vs Epstein et al Case No 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Answers to Defendants First Interrogatories COUNSEL LIST Jack A Goldberger Atterbury Goldberger Weiss P.A Australian A venue West Palm Beach FL Phone Attorneys for Jeffrey Epstein Bruce Reinhart Esquire Bruce Reinhart P.A South Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Sarah Kellen Robert Critton Bu1man Critton Luttier Coleman LLP North Flagler Drive Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Richard Willits Esquire lawyerwillits aol.com Richard Willits P.A 10th Avenue North Suite Lake Worth FL Phone Fax Attorneys for Party
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