INTERROGATORY NO Identif he existence cus todi an a nd loc ation of and genera ll describe all IO document and ommu i cat io ns oncer ni ng the subject matter of thi litigation RESPONSE TO INTERROGATORY Do identifie the foll ow ing ich includ es but i not limi ted to Flight eco rd from Dece dent Jeffrey Eps te in ri va anes howing Jan Doe as a pa ssenger Phon records fro a nen Indyke show ing calls mad by him to Jan Do a nd records of the followin cas payments to Doe rent paym ents made fo Doe apartment car rip for Doe by Decedents driv ers includ i ng Juan Alessi plan tickets plane trips via ece den ts priva te jet ticket to Broadway shows tuition payments to th Prof ess ional hildr ens School cloth in i ncl uding underwe a and bras book voice lessons with acting classe at Herbert Berkoff Sh1dios and at The Acting Studio payme for ummer camp on behalf of Plain iff at Interla hen Arts Camp and Bo st on University Tanglewood In st itu te and Plaintiffs broth at Interlach Arts Camp set of Bobbi own makeup rus es and seve ral sess ion ith photographer po info1n1ation and li ef Plaintiff a lso id ntifi es photographs of her as a minor tak of without her knowledge by Decedent Jeffrey Epste i that are currently in the custo and co ntrol of he fede ra governme nt iscove and invest i gation continues an Plaintiff reserves the right to upplement all di sc ov ery respo ses up to nd in ludi ng the time of tri a as PLAINTIFFS RESPONSE TO IR ST a dd it ional facts are ascerta in ed analyses are made research is com leted a nd conten tion are made INTERROGATORY NO Identify eac mplo yee of agent of or ot er in di vi dual associated ith Dec edent ith whom you co mmunicated or i nteracted and ident i fy the date of and describe the ature of each uch co mmunicati or interaction RESPONSE INTERROGATORY NO Ghislaine Maxwell a Doe interacted with Maxwell repeatedly between a nd Durin that time Maxwell facilitated Decedents sex ual ab se of IO Doe and was fr qu ently pr ese nt Decedents sexua abuse of Do occur ed Juan Alessi drove i nor ane Doe fro her born i West al each Florida to ece nt home in Palm Beach Florida multiple ti mes betwee and Danen Indyke ca ll Jane oe in threatening th at Ja Doe owed ecedent for rent ece en paid the a artment Ja ne lived in at rior to er ov in to Los A ge es CA Adam ry Lang Jane Doe travelled with Adam Perry ang a nd ece on at ast occasion between and esley Groff Doe i nt rac te with Groff multipl tim es in New York Groff facilitated eet in gs between Doe and ece ent Groff also bought i fts for oe on behalf of Decedent including a se makeup brushes Mark Epstein Mark ste in Decedent younge brother was pr esent ith ece and Do on multiple occas ion etwee and Sarah Kellen Doe interacted ith Kellen mul ipl times i New York betw een and Ke ll en facilitated mee ings betwee Doe a nd Decedent Pla in iff also believes she commun ic ated with elly Bovino Umekubo and DOJ REDACT ION onc erni Decedent Epstein PLAINTIFFS RESPONSE TO FLRST r.rl __ i:Q 5M r.rl ai a Cl oc INTERROGATORY NO Identify all persons other than Decedent who have ever committed or attempted to commit sex ual mi sconduct or offenses against or otherwise concerning you including without limitation any unwelcome behavior of a sex ual nature sexual abuse sexual assault threats or intimidation of a sexual nature or sexual exploitation regardless of whether the misconduct or offenses involv ed physical touching For each person identified identify the misconduct or offense committed and the date and loc at ion of the misconduct or offense RESPONSE TO INTERROGATORY NO None PLAINTIFFS RESPONSE TO FIRST lg l,J:l Eo UV l,Il ijj a Ol Co Do on ha of ecedent by esley Groff an seve ral sessions with photogr aphe rs Upon inf01mation and belief Plaintiff also identifie photographs of her as a minor taken of her without her know edge by ece ent effrey Ep ste in that are cun-ently in the custody and control of the federa government Di sc over and investigation continues an Plain iff re se ves th right to uppl nt a ll di scove ry espo ses up to and includin th time of trial as additional facts are ascertained a a ly ses a mad esea i co mpl eted and contentions are made DATED June ANISH SHEA BOYLE LLP By Robert Gl ass man Attorneys fo aintiff PLAINTI FF RESPONSE TO FIRST
