EFTA01076870.pdf

IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028058XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendant. EPSTEIN'S MOTION TO COMPEL ANSWERS TO FOURTH SET OF INTERROGATORIES Fla. R. Civ. P. 1.380, Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Set of Interrogatories and moves to compel Plaintiff,li. to answer Epstein's Fourth states: th Set of 1. On February 25, 2010, Epstein propounded his Four Interrogatories on. (attached as Exhibit A). 2. On April 1, 2010, IS served Answers to Defendant's Fourth Interrogatories (attached as Exhibit B). to Interrogatory 3. Epstein moves to compel. 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 d by Defendant on since you answered the First Set of Interrogatories propounde all sources of income or about December 10, 2008; this includes listing any and you have received. West Palm Beach, FL 2009 EFTA01076870  Coconut Creek, FL 2009 Coconut Creek, FL 2009 West Palm Beach, FL 2010 - present 4. • 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 ■ is referring to by her answer ' , 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 ■ to answer Interrogatory No. 1. WHEREFORE, Defendant, JEFFREY EPSTEIN, requests the Court enter an order compelling Plaintiff, ■., 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, ■. & Lehrman, PL 250 Australian Avenue South 424 N. Andrews Avenue, Suite 2 Suite 1400 2 EFTA01076871  le, FL 33301 Wes FL 33401-5012 Fax: Co-Counsel for Defendant Jeffrey Epstein Counsel for Plaintiff Jay Howell, Esq. Jay Howell & Associates, . 644 Cesery Boulevard Suite 250 INEFL 32211 Phone Fax Co-counsel for Plaintiff BURMAN CRITTON LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 West L 33401 By: Robert n, Jr. Florida Bar #224 162 Michael J. Pike Florida Bar #617296 David A. Yarema Florida Bar #12492 3 EFTA01076872  IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA 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 S Tpursuant 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 the following addressees on this Ciay of February , 2010: Brad Edwards, Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Atterbury Goldberger & Weiss, ■ & Lehrman, PL 250 Australian Avenue South 425 N. Andrews Avenue, Suite 2 Suite 1400 Fort Lauderdale, FL 33301 West Palm Beach, FL 33401-5012 Fax: - fax a Co- ounse or Defendan t Jeffrey Epstein ounsel for Plaints Jay Howell, Esq. Jay Howell & Associates, ■. 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 EXHIBIT it EFTA01076873  Phone Fax Co-counsel for Plaintiff BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 West Pa i B ch, FL 33401 Fax By: !!7 0-41)- o +e D. Critton, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) EFTA01076874  DEFINITIONS AND INSTRUCTIONS 1. The term "Plaintiff" refers to III., and all her agents, employees, acting on their behalf. representatives, attorneys, accountants or anyone else ein and all his agents, 2. The term "Defendant" refers to Jeffrey Epst 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 persons, including but not exchange of Information of any type between two or more ersations, meetings or limited to documents, telephone or face-to-face conv conferences. including, but 5. The word "document' shall mean any writing of every kind, r, envelope, file cabinet drawer not limited to, any letter, book, record, report, file folde ing, chart, draft, schedule, label, memorandum, correspondence, communication, draw computer printout and any other photograph, tape, disc, card, wire, computer program instrument or device from electronic or mechanical recording or transcript of any other to memorialize human thought, which information can be perceived or which is used 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 meaning and equal in scope to term "document" is also defined to be synonymous in EFTA01076875  dure 34(a) , including, without the usage of this term in Federal Rule of Civil Proce 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 ization, joint venture, proprietorship, partnership, corporation, association, organ 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. to, respond to, 7. The phrase "relate to° shall mean refer to, contain, allude ion, analyze, constitute, comment upon, discuss, show, disclose, explain, ment characterize, either directly comprise, evidence, set forth, summarize, support, refute or or indirectly, in whole or in part. s to state the 8. "Identify," when used to refer to a natural person, mean 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). to identify the (d) Such other information sufficient to enable Defendant person. al person 9. "Identify" when used to refer to any entity other than a natur means to state the following: EFTA01076876  (e.g., corporation, (a) The full name of the entity, the type of the entity of business, its partnership, etc.), the address of its principle place , the jurisd iction under principle business activity, and if it is a corporation which it has been organized and the date of incorporation. 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 (f) the identity of each person to whom a copy of the document dispo sition; each date of its receipt and date of its transmittal or other l or other (g) The circumstance of each such receipt and each transmitta receiving it. disposition, including identity of the person transmitting and and correct 11. In lieu of identifying any document, Plaintiff may attach a true ogatories, along with copy of such document as an exhibit to its response to these Interr is responsive. an explicit reference to the Interrogatory to which each document at the time 12. If the response to all or part of any Interrogatory is not known that effect, furnish the the initial response is made, please include a statement to ry by amended or information that is known or available, and respond to the Interrogato days of the date on which supplemental response in writing under oath within ten (10) the complete response becomes known or available. EFTA01076877  FOURTH SET INTERROGATORIES TO PLAINTIFF cell phone numbers, dates of 1. List the names, business addresses, telephone and address) and rates of pay employment, immediate supervisor (name and for whom you have worked regarding all employers, including self-employment, unded by Defendant on since you answered the First Set of Interrogatories propo any and all sources of income or about December 10, 2008; this includes listing you have received. (including mental health 2. Identify each physician or medical provider with whom you have professionals, drug or alcohol counselors and therapists) identify each facility consulted or who has treated or examined you, and inpatient or outpatient) (including drug or alcohol treatment facilities, whether n or treatment that is in where you have received any consultation, examinatio the date of consultation, any way related to this case; and state as to each 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 2008 . propounded by Defendant on or about December 10, the information sought by use of the ' Please refer to the 'Definitions' section of these Interrogatories for term "Identify." EFTA01076878  ers of all males, excluding 3. List separately the names, addresses and phone numb ty since you answered the Mr. Epstein, with whom you have had sexual activi 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 tion from the person. date(s) and whether you received money or other considera 4. Are you o ever been a member of a social networking website or any similar such as II websites? are currently a a. If so, please list all social networking websites of which you 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. used for b. Also, please list all usemames, screen names or "handles" you ber. Also, each social networking site of which you were ever a mem each social please provide all uniform resource locators ("URL") for a mem ber (i.e. e rkin website of which you are, or were previously EFTA01076879 5. A r ember of an online dating website such as , 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, mem each online dating website of which you were ever a e of which you please provide all URLs for each so "websit ). are, or were previously a member (i.e. If so, please state 6. Do you, or have you ever kept, a diary or journal since 2002? her it was/is kept on whether the diary or journal was/is kept in hard copy or whet a computer or other electronic device. ical attributes a. If the diary or journal was kept in hard copy, describe its phys its current (i.e. book, collection of loose paper, day planner) and state location. EFTA01076880  ronic device, b. If the diary or journal wasfis kept on a computer or other elect ding the make and please identify the computer or electronic device, inclu device; and state model; identify the owner of the computer or electronic e. If the current the current location of the computer or electronic devic of the computer location is unknown, please state the last known location or electronic device. nt address, home c. Identify all individuals, including their full name, curre have read any telephone number and cellular telephone number, that portion of the diary or journal. journal. If so, d. Please state whether any copies were made of the diary or , Including their state the number of copies made and identify all individuals er and cellular full name, current address, home telephone numb of the diary or telephone number, who have, or at any time had, a copy joumal. and identify the owner of 10. Please identify all computers you have used since 2002 of each computer; if each computer; state the make, model and current location state each location in the current location of a particular computer is unknown, which you used last used each computer. EFTA01076881  , including their 11. Please identify your five closest friends for the years 2006 — 2010 cellular telephone full name, current address, home telephone number and number. in's residence? 12. Do you intend to call at trial other females who went to Mr. Epste nt address, home If so, please identify each individual, including their name, curre counsel. Also, ify her telephone number and cellular telephone number, and Ident please state the substance of each witness's testimony. EFTA01076882  VERIFICATION By: STATE OF FLORIDA ) ss COUNTY OF PALM BEACH ) day of 2010 by SWORN TO AND SUBSCRIBED before me this who is personally known to me or has produced the following identification which is current or has been issued number. within the past five years and bears a serial or other identifying Print Name Signature NOTARY PUBLIC - STATE OF FLORIDA Commission Number: My commission expires: (Notarial Seal) EFTA01076883  IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502008CA028058XXXXMB AB Plaintiff, V. JEFFREY EPSTEIN, Defendant. NOTICE OF SERVICE OF PLAINTIFF'S VERIFIED ANSWERS TO DEFENDANT'S FOURTH INTERROGATORIES Plaintiff, ., hereby files her Notice of Service of Plaintiffs 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 w 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, P.L. 425 N. Andrews Ave., Suite 2 , FL 33301 Th By: BRADLEY J. EDWARDS Florida Bar No.: 542075 EXHIBIT 1 , EFTA01076884  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 EFTA01076885  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: West Palm Beach, FL 2009 cont Creek, FL 2009 ocontt Creek, FL 2009 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; Victim's Services West Palm Beach, FL Dates reflected in records previously produced. EFTA01076886 Fort Lauderdale, FL 33304 Dates reflected in records. Interrogatories 3-12 ANSWERS: Objection, beyond the limit of Interrogatories allowed pursuant to FRCP 1.340. EFTA01076887  VERIFICATION By:e STATE OF FLORIDA ) ss COUNTY O EFIAM EAet taVIA ILL SWORN TO AND SUBSCRIBED before me this day of HatCh 2010 by ho Is e nown to me or has produced the following identi 'cation mflich is current or has been issued within thtpast five years and bears a serial or other identifying number. Norg_o i by<to tizAr/ 9 ignature NOTARY PUBLIC - STATE OF FLORIDA Commission Number: My commission expires: (Notarial Seal) NOW A. BILYall0 MY COMMISSIN00822662 IMRE& SEP 14, 2012 Beadedirough m Sit Pants EFTA01076888