UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-8081 1-c!V- Plaintiff, vs. an EPSTEIN and Defendants. / PLAINTIFF'S NOTICE OF SERVING SECOND AMENDED ANSWERS TO INTERROGATORIES COMES NOW the Plaintiff, ma. 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. | HEREBY CERTIFY that a true copy of the foregoing has been furnished by e- mail this ay of October, 2009, fo: list of counsel. JACK SCAROLA Florida Bar No.: 169440 JACK P. HILL Florida Bar No.: 0547808 Shipley, P.A. Attorney for Plaintiff(s) EFTA00023624

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. vs, Epstein, et al. ase No.: 06-Cv-60811-clv ae Plaintiffs Second Amended Answers to De’ nt'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 father’s name and address. List the names and address of your parents and any brother or sister. ANSWER Nickname- Dates: July, 2007-Present West Palm Beach, FL. 33417 Po Dates: February, 2004- July, 2007 West Palm Beach, FL. Rome, Georgia Dates: August, 2003-February, 2004 Po Dates: About 2 % years ago West Palm Beach, FL. 33409 a Dates: Approximately 1 year West Palm Beach, FL. 33409 a Dates: Unknown Lake Park, FL SSN bo: | have never been married. Children Father: Address: West Palm Beach, FL. 33407 EFTA00023625

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i. vs. Epstein, et al. Case No.; 08-CV-80811-CIV. Plaintiffs Second Amended Answers to Defendant's First Interrogatories Father: Address: West Palm Beach, FL. Parents: Address Unknown West Palm Beach, FL. 33417 Siblings: 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 c/o her attorneys: 1, Jack Scarola, Esq. and Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. West Palm Beach, FL 33409 To: Richard Willits, Esq. Richard H. Willits, P.A. Lake 1 Tel: Subject matter: _—_ Plaintiff. EFTA00023626

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. vs. Epstein, et al. ase No.: 08-cv-60011-c\v a Plaintiffs Second Amended Answers to ndant's First Interrogatories 2. Jeffrey Epstein c/o his attorneys: | Robert Critton, Esquire n Luttier & Coleman LLP Jack A. Goldberger, Esquire West Palm Beac! 3 | Te: Bruce E. Reser’, Eectulre Subject matter: Defendant ma: — ma. and her brother, ia clo ” s attorneys: | Jack Searola, Esq. and Jack P. Hill, Esq. | hart & Shipley, P.A. Subject matter: | involvement with Epstein. 4 EFTA00023627

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C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CI Plaintiff's Second Amended Answers to Defendant's First interrogatories (Address unknown) Subject matter: Defendant. 5. Jane Doe (Case No.: 1:93-cv-01109-KAM) | clo her attorney: Theodore Leopold, Esquire Pa ns, FL 33410 | Te Subject matter: Victim of Epstein. 6. Jane Doe (Case No.: 502008CA020614) c/o her attorney: | lsidro M. Garcia, Esquire s & Associates, LLC | Subject matter: Victim of Epstein. 7. Jane Doe #2 (Case No.: 9:08-cv-80119-KAM) clo her attorney: Jeffrey M. Herman, Esquire Subject matter: Victim of Epstein. 8. Jane Doe #3 (Case No.,: 9:08-cv-80232-KAM) c/o her attorney: EFTA00023628

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HEE. vs. Epstein, et al. Case No.: 08-CV-80811-CIV. Plaintiff's Second Amended Answers to Defendant's First Interrogatories Jeffrey M. Herman, Esquire ! Subject matter: Victim of Epstein. 9. Jane Doe #5 (Case No.: 9:08-cv-80381-KAM) clo her attorney: Jeffrey M. Herman, Esquire Subject matter: Victim of Epstein. 10. Jane Doe #4 (Case No.: 9:08-cv-80380-KAM) c/o her attorney: Jeffrey M. Herman, Esquire ! Subject matter: Victim of Epstein. 11. Jane Doe (Case No.; 9:08-cv-80804-KAM) c/o her attorney: Theodore Leopold, Esquire Subject matter: Victim of Epstein. EFTA00023629

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iz. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiffs Second Amended Answers to Defendant's First Interrogatories 42. Jane Doe #7 (Case No.: 9:08-cv-80993-KAM) clo her attorney: Jeffrey M. Herman, Esquire Subject matter: Victim of Epstein. 13. [RBI (case No.: 502008CA025129XXXXMB Al c/o her attorneys: Jack Scarola, Esquire Jack P. Hill, Esquire rcy De r hart & Shipley, P.A. Tel: Subject matter: Victim of Epstein. (Address unknown at this time) Subject matter: Jeffrey i. 15. Pal artment Subject matter: —_ Investigator. EFTA00023630

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F | vs. Epstein, et al. Case No.: 08-CV-80811-CiV-/i iain Plaintiffs Second Amended Answers to Defendant's First Interrogatories Palm Beach a Prosecutors Office est Paim Beach, Tel: (561) 355-7100. 16. Subject matter: Prosecutor. 17. Detective (EEE iead investigator rtment Subject matter: Investigator. . oo Subject matter: | Former boyfriend of a victim of Epstein. 19. Sgt. rtment Subject matter: Investigator. : Ae oo Subject matter: _ Plaintiff's former boyfriend. 21. Tony Higgins, supervisor e Town of Palm Beach EFTA00023631

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a. Epstein, et al. ase No.: 08-CV-80811-CI \ Plaintiff's Second Amended Answers fo Defendant's First Interrogatories To: Subject matter: The incident which is the subject matter of this lawsuit. Discovery is ongoing. 22. Palm Beach County Sheriff's Office Subject matter: Investigator. 23. , friend of Subject matter: (Address will be provided upon receipt) Victim and friend of J 24. Ghislane Maxwoll c/o Ghislane Corp. Subject matter: Associate of Epstein. aren 1 enter Subject matter: 26. Subject matter: 27. Chief Counselor at Parent Child Center. Investigator. Palm Beach Police — 9 EFTA00023632

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ra Epstein, et al. ase No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff's Second Amended Answers to Defendant's First Interrogatories 28. 29. 30. 31. 32. : Subject matter: Investigator. (Address unknown at this time) Subject matter: Associate of Epstein who facilitated introductions with various victims. (Address unknown at this time) Subject matter: Employee of Epstein. Detective Hi rtment Subject matter: Investigator First Assistant U.S. Attorney Tel: Subject matter: Federal prosecutor. Subject matter: Investigator. EFTA00023633

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me Epstein, et al. ase No.: 08-CV-80811-CIV- Plaintiff's Second Amended Answers . ool First Interrogatories 33. 34. 35. 36. 37. 38. 39. Address will be provided upon receipt West Palm Beach ma: physician. Subject matter: Assistant U.S. Attorney U.S. Dept. of Justice Subject matter: Federal prosecutor. friend of mother {Address will be provided upon receipt) Subject matter: Friend of ma mother. friend of *s mother Address will be provided upon receipt) Subject matter: Friend of ma: mother , friend of ress will be provided upon receipt) Subject matter: Potential victim and friend of i. — — at this time) Subject matter: Associate of Epstein who may have been involved in encounters between Epstein and a friend of ress unknown at this time) 11 EFTA00023634

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ail vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff's Second Amended Answers to Defendant's First Interrogatories 11. 40. EE (iast name unknown), friend of Gi (Address unknown at this time) 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 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 s0, state the type and amount of alcoholic beverages, drugs, or medication which were consumed, and when (dates) and where you consumed them. ANSWER 4. On one occasion | had taken “Morning Glory” and “Angel Trumpets”. | do not recall the date. 2. On more than one occasion | used cocaine powder. | do not recall the dates. 3. On more than one occassion | used marijuana. | do not recall the dates. 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: | do not recall the date. | would defer to the Doctor's records, 12 EFTA00023635

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. | vs. Epstein, et al. Case No.: 08-CV-80811-CIV: Plaintiffs Second Amended Answers to Defendant's First interrogatories es Date: Since high school. Ongoing. | enn 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 | went to Mr, Epstein’s home on average 2 times a week. There were weeks when | 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 | was introduced to Jeffrey Epstein by my friend[MMMMMMin 2002. | was to give Jeffrey Epstein a massage. | continued to provide massages up until August of 2003. | was transported to Jeffrey Epstein’s h Cab, provide’ i cee ex- b j my mother and my brother 1 was also transported via private car provided by Jeffrey Epstein. (Address will be provided upon receipt) 13 EFTA00023636

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| | vs. Epstein, et al. } Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | Plaintiffs Second Amended Answers to Defendant's First interrogatories 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 23. State the names, addresses, ages, phone numbers and dates of all females | you claim you were paid to bring each female. | ANSWER was pa 5 as: name unknown) ress unknown) | was paid $100.00 ooo | was paid $100.00 EFTA00023637

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vs. Epstein, et al. se No.: 08-CV-2061 1-01 Plaintiff's Second Amended Answers jant’s First Interrogatories Signature of Answering Party STATE OF Florida ) COUNTY OF Palm Beach ) The foregoing instrument was acknowledged before me this day of February, 2009 by FY 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 EFTA00023638

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vs. Epstein, et al. ase No: 08-CV-80811-CIV: Plaintiff's Second Amended Answers to Defendant's First Interrogatories COUNSEL LIST Jack A. Goldberger Bruce E. Reinhart, Esquire Bruce E. Robert Critton Burman Critton L r& Coleman LLP Richard H. Willits _ Richard H. Willits, P.A Attorneys for Party EFTA00023639

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VERIFICATION :: 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 Vw COUNTY OF PALM BEACH ) SWORN TO AND SUBSCRIBED before me this 26 day of Oc 4a 40 2 _, 2009 by who is eeesonally known’ td) me or has produced the following identification x rotary sie ine State of Florida ; eh & My Commissen DDe10408 La O04 ~ CH ie apes HORS Notary - Print Name Notary - Signature EFTA00023640