EFTA00724117.pdf

IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028058XXXXMB AB E.W., Plaintiff, v. JEFFREY EPSTEIN, Defendant. EPSTEIN'S MOTION TO COMPEL S ANSWERS TO FOURTH SET OF INTERROGATORIE Fla. R. Civ. P. 1.380, Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to th Set of Interrogatories and moves to compel Plaintiff, E.W. to answer Epstein's Four states: th Set of 1. On February 25, 2010, Epstein propounded his Four Interrogatories on EW (attached as Exhibit A). ndant's Fourth 2. On April 1, 2010, EW served Answers to Defe Interrogatories (attached as Exhibit B). to Interrogatory 3. Epstein moves to compel EW to provide a better answer No. 1: e numbers, dates of List the names, business addresses, telephone and cell phon rates of pay employment, immediate supervisor (name and address) and you have worked regarding all employers, including self-employment, for whom unde d by Defendant on since you answered the First Set of Interrogatories propo all sources of income or about December 10, 2008; this includes listing any and you have received. ANSWER T's Lounge West Palm Beach, FL 2009 EFTA00724117  Diamond Dolls Coconut Creek, FL 2009 Roxy's Bar & Grill Coconut Creek, FL 2009 ACG West Palm Beach, FL 2010 — present 4. EW failed to provide an adequate answer to Interrogatory No. 1 as she did not include any business addresses, telephone and cell phone numbers, immediate supervisors (name and address) and rates of pay nor did she object to the interrogatory. 5. Moreover, it is unclear what business or entity EW is referring to by her answer “ACG, West Palm Beach, FL." 6. Rule 1.380(a)(3), Florida Rules of Civil Procedure, provides that "...an evasive or incomplete answer shall be treated as a failure to answer." 7. Accordingly, Epstein moves, pursuant Fla. R. Civ. P. 1.380(a)(2), for an order compelling EW to answer Interrogatory No. 1. WHEREFORE, Defendant, JEFFREY EPSTEIN, requests the Court enter an order compelling Plaintiff, E.W., to fully answer Interrogatory No. 1 and grant any additional relief the Court deems just and proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. Mail to the following addressees on this 27th day of April, 2010: Brad Edwards, Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Atterbury Goldberger & Weiss, P.A. & Lehrman, PL 250 Australian Avenue South 424 N. Andrews Avenue, Suite 2 Suite 1400 2 EFTA00724118  Wes L 33401-5012 Fort Lauderdale, FL 33301 Fax: x Co-Counsel for De endant Jeffrey Epstein Counsel for Plaintiff Jay Howell, Esq. Jay Howell & Associates, P.A. 644 Cesery Boulevard Suite 250 le 32211 hone ax Co-counsel for Plain tiff BURMAN CRITTON LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 Beac L 33401 By: Robert D. n, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 David A. Yarema Florida Bar #12492 3 EFTA00724119  IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA E.W., CASE NO. 502008CA028058XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT'S NOTICE OF SERVING FOURTH SET OF INTERROGATORIES TO PLAINTIFF Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), files this Notice of Serving Fourth Set of Interrogatories to Plaintiff E.W., pursuant to Rule 1.340, Florida Rules of Civil Procedure, and request the Plaintiff to answer said interrogatories in writing within thirty (30) days from date of service hereof. Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by U.S. Mail to s of the following addressees on thise :lay February 2010: Brad Edwards, Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Atterbury Goldberger & Weiss, Ill. & Lehrman, PL 250 Australian Avenue South 425 N. Andrews Avenue, Suite 2 Suite 1400 Fort Lauderdale, FL 33301 West Palm Beach, FL 33401-5012 954-524-2820 Fax: 561-835-8691 954-524-2822 —fax Co-Counsel for Defendant Jeffrey Epstein [email protected] Counsel for Plaintiff Jay Howell, Esq. Jay Howell & Associates, M. 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 EXHIBIT A- EFTA00724120 904-680-1234 Phone 904-680-1238 Fax Co-counsel for Plaintiff BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 West Pa B:: •ch, FL 33401 (561) 8 (561) Fax By: \ 0-4 t2- D. Griffon, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) EFTA00724121  DEFINITIONS AND INSTRUCTIONS agents, employees, 1. The term "Plaintiff" refers to E.W., and all her acting on their behalf. representatives, attorneys, accountants or anyone else and all his agents, 2. The term "Defendant" refers to Jeffrey Epstein persons acting or purporting to representatives, employees, assigns, or other person or act on its behalf. conjunctively and 3. The words "and" and "or" shall be construed both r than exclusive. The singular disjunctively so as to make the request inclusive rathe include the singular. shall be construed to include the plural and the plural to n statement or 4. The word "communication(s)" shall mean any oral or writte more persons, including but not exchange of information of any type between two or conversations, meetings or limited to documents, telephone or face-to-face conferences. kind, including, but 5. The word "document" shall mean any writing of every r, envelope, file cabinet drawer not limited to, any letter, book, record, report, file folde ing, chart, draft, schedule, label, memorandum, correspondence, communication, draw uter printout and any other photograph, tape, disc, card, wire, computer program comp instrument or device from electronic or mechanical recording or transcript of any other memorialize human thought, which information can be perceived or which is used to tiff. The term "document" speech or action in the possession, custody, or control of Plain to that contained on the original also includes copies containing Information in addition to in any document. The and all the attachments, enclosures, or documents referred ing and equal in scope to term "document" is also defined to be synonymous in mean EFTA00724122  edure 34(a), including, without the usage of this term in Federal Rule of Civil Proc s. A draft or non-identical copy is limitation, electronic or computerized data compilation a separate document within the meaning of this term. n, individual, 6. The word "person" shall mean any natural perso organization, joint venture, proprietorship, partnership, corporation, association, rnmental body or agency, or business trust or other business enterprise, gove of natural persons or other governmental, public, legal, or business entity, or group entities whether sui juris or otherwise. e to, respond to, 7. The phrase "relate to" shall mean refer to, contain, allud mention, analyze, constitute, comment upon, discuss, show, disclose, explain, characterize, either directly comprise, evidence, set forth, summarize, support, refute or or indirectly, in whole or in part. state the 8. "Identify," when used to refer to a natural person, means to following: ss is not know, (a) his or her full name and address (or, if the present addre his or her last known address); oyers, each (b) the full name and address of each of his or her empl each business corporation of which he or she is an officer or director, and in which he or she is a principal; known, his or (c) his or her present position (or if the present position is not the Interrogatory her last known position(s) at the time of the act to which response relates). identify the (d) Such other information sufficient to enable Defendant to person. al person 9. "Identify" when used to refer to any entity other than a natur means to state the following: EFTA00724123  entity (e.g., corporation, (a) The full name of the entity, the type of the of business, its partnership, etc.), the address of its principle place the jurisdiction under principle business activity, and if it is a corporation, ion. which it has been organized and the date of incorporat or Communication 10. "Identify," when used with reference to a Document means to state the following: um, etc), date of (a) the nature of the document (e.g., letter, memorand address of each creation, author, place of preparation, the name and addressee; (b) The identity of each signatory; (c) The title or heading of the document; (d) the general substance and subject matter; known); (e) Its present location and custodian (or, If not know, the last was sent and (t) the identity of each person to whom a copy of the document disposition; each date of its receipt and date of its transmittal or other mittal or other (g) The circumstance of each such receipt and each trans receiving it. disposition, including identity of the person transmitting and a true and correct 11. In lieu of identifying any document, Plaintiff may attach Interrogatories, along with copy of such document as an exhibit to its response to these ment is responsive. an explicit reference to the Interrogatory to which each docu n at the time 12. If the response to all or part of any Interrogatory is not know to that effect, furnish the the initial response is made, please include a statement ogatory by amended or information that is known or available, and respond to the Interr days of the date on which supplemental response in writing under oath within ten (10) the complete response becomes known or available. EFTA00724124  FOURTH SET INTERROGATORIES TO PLAINTIFF cell phone numbers, dates of 1. List the names, business addresses, telephone and ss) and rates of pay employment, immediate supervisor (name and addre for whom you have worked regarding all employers, including self-employment, unded by Defendant on since you answered the First Set of Interrogatories propo and all sources of income or about December 10, 2008; this includes listing any you have received. ding mental health 2. Identify' each physician or medical provider (inclu with whom you have professionals, drug or alcohol counselors and therapists) identify each facility consulted or who has treated or examined you, and ient or outpatient) (including drug or alcohol treatment facilities, whether inpat treatment that is in where you have received any consultation, examination or date of consultation, any way related to this case; and state as to each the reason for which you examination or treatment and the injury, condition or other Set of Interrogatories were examined or treated since you answered the First . propounded by Defendant on or about December 10, 2008 for the information sought by use of the ' Please refer to the 'Definitions' section of these interrogatories term 'identify." EFTA00724125  ers of all males, excluding 3. List separately the names, addresses and phone numb activity since you answered the Mr. Epstein, with whom you have had sexual t on or about December 10, First Set of Interrogatories propounded by Defendan e of sexual activity, the 2008 up through the current date. Describe the natur ideration from the person. date(s) and whether you received money or other cons 4. Are you o member of a social networking website or any similar such as websites? you are currently a a. If so, please list all social networking websites of which were previously a member, list all social networking websites of which you the date you member and state the date you joined each site and cancelled your membership with each site. you used for b. Also, please list all usemames, screen names or "handles" ber. Also, each social networking site of which you were ever a mem each social please provide all uniform resource locators ("URL") for (i.e. on i we i e f which you are, or were previously a member EFTA00724126 5. A ember of an online dating website such at, or any similar website? you are currently a a. If so, please list all online dating websites of which were previously a member, list all online dating websites of which you and the date you member and state the date you joined each site cancelled your membership with each site. you used for b. Also, please list all usernames, screen names or "handles° ber. Also, each online dating website of which you were ever a mem which you ite of please provide all URLs for each soc are, or were previously a member (i.e. ). so, please state 6. Do you, or have you ever kept, a diary or journal since 2002? If it was/is kept on whether the diary or journal was/is kept in hard copy or whether a computer or other electronic device. ical attributes a. If the diary or journal was kept in hard copy, describe its phys state its current (i.e. book, collection of loose paper, day planner) and location. EFTA00724127  ronic device, b. If the diary or journal was/is kept on a computer or other elect ding the make and please identify the computer or electronic device, inclu e; and state model; identify the owner of the computer or electronic devic If the current the current location of the computer or electronic device. computer location is unknown, please state the last known location of the or electronic device. ss, home c. Identify all individuals, including their full name, current addre have read any telephone number and cellular telephone number, that portion of the diary or journal. or journal. If so, d. Please state whether any copies were made of the diary ding their state the number of copies made and identify all individuals, inclu and cellular full name, current address, home telephone number diary or telephone number, who have, or at any time had, a copy of the journal. ify the owner of 10. Please identify all computers you have used since 2002 and ident each computer; if each computer; state the make, model and current location of state each location in the current location of a particular computer is unknown, which you used last used each computer. EFTA00724128  , including their 11. Please identify your five closest friends for the years 2006 - 2010 and cellul ar telephone full name, current address, home telephone number number. residence? 12. Do you intend to call at trial other females who went to Mr. Epstein's address, home If so, please identify each individual, including their name, current counsel. Also, telephone number and cellular telephone number, and identify her please state the substance of each witness's testimony. EFTA00724129  VERIFICATION By: STATE OF FLORIDA ) ss COUNTY OF PALM BEACH SWORN TO AND SUBSCRIBED before me this day of 2010 by , who is personally known to me or has produced the following identification which is current or has been issued within the past five years and bears a serial or other identifying number. Print Name Signature NOTARY PUBLIC - STATE OF FLORIDA Commission Number: My commission expires: (Notarial Seal) EFTA00724130  IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502008CA028058XXXXMB AB E.W. Plaintiff, v. JEFFREY EPSTEIN, Defendant. NOTICE OF SERVICE OF PLAINTIFF'S VERIFIED ANSWERS TO DEFENDANT'S FOURTH INTERROGATORIES Plaintiff, E.W., hereby files her Notice of Service of Plaintiff's Answers to Fourth Interrogatories propounded by Defendant on February 25,2010. CERTICATE OF SERVICE I HEREBY CERTIFY that the original of the above and a copy of the foregoing has been provided this ix day of April 2010 via U.S. Mail and email transmittal to all those on the attached service list Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, M. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954) 524-2820 (9541524-2822 fax By: BRADLEY J. EDWARDS Florida Bar No.: 542075 EXHIBIT 1' EFTA00724131  SERVICE LIST Robert D. Critton, Jr. BURMAN, CRITTON, et al. 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 Jay Howell, Esq. Jay Howell & Assoc. 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 Jack Alan Goldberger, Esq. Atterbury Goldberger et al. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401 EFTA00724132  PLAINTIFF'S ANSWERS TO FOURTH INTERROGATORIES 1. 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 self-employment, for whom you have worked since you answered the First Set of Interrogatories propounded by Defendant on or about December 10, 2008; this includes listing any and all sources of income you have received. ANSWER: T's Lounge West Palm Beach, FL 2009 Diamond Dolls Coconut Creek, FL 2009 Roxy's Bar & Grill Coconut Creek, FL 2009 ACG West Palm Beach, FL 2010 - present 2. Identify' each physician or medical provider (including mental health professionals, drug or alcohol counselors and therapists) with whom you have consulted or who has treated or examined you, and identify each facility (including drug or alcohol treatment facilities, whether inpatient or outpatient) where you have received any consultation, examination or treatment that is in any way related to this case; and state as to each the date of consultation, examination or treatment and the injury, condition or other reason for which you were examined or treated since you answered the First Set of Interrogatories propounded by Defendant on or about December 10, 2008. ANSWER: Randee Speciale Victim's Services West Palm Beach, FL Dates reflected in records previously produced. EFTA00724133 Dr. Amy C. Swan,. 918 N. E. 26th Avenue Fort Lauderdale, FL 33304 Dates reflected in records. Interrogatories 3-12 ANSWERS: Objection, beyond the limit of Interrogatories allowed pursuant to FRCP 1.340. EFTA00724134  VERIFICATION B STATE OF FLORIDA ) ss COUNTY OFPAirrett uaajed ) , SWORN TO AND SUBSCRIBED before me this day of Hage.k) 2010 by Cour-iieve\j. NEI who is personaltgnown to me or has produced the following identi ication Ir -WSEAD-f05-$7-%131Vhich is current or has been issued within the past five years and bears a serial or other identifying number. Norg_a Si1 0 ve4 ignature tto? NOTARY PUBLIC - STATE OF FLORIDA Commission Number: My commission expires: (Notarial Seal) NORM A &WAD WOOMMISSIN #00082062 DCFIRES: SEP 142012 001AftN E Vthka Bo* tiro* 'WV*run. EFTA00724135