EFTA01734603.pdf

03:04:45p.m. 02-04-2010 7/15 305-9312200 Herman &Mermelsteln, P Doe No. 3 v. Epstein Page 6 11. Please identify your five closest friends for the years 2006 — 2010, including their full name, current address, home telephone number and cellular telephone number. ANSWER: Plaintiff objects to this interrogatory as vague, overly broad, unduly burdensome, an unwarranted invasion of privacy and not reasonably calculated to lead to admissible evidence. Subject to and without waiving said objections, Plaintiff states: 1. 2. 3. 4. Plaintiff does not have a fifth person that she would consider "a close friend" during that time period. 12. Do you intend to call at trial other females who went to Mr. Epstein's residence? If so, please identify each individual, including their name, current address, home telephone number and cellular telephone number, and identify her counsel. Also, please state the substance of each witness's testimony. Answer: Plaintiff objects to this interrogatory as vague, overly broad, unduly burdensome, cumulative, and calling for speculation. Subject to and without waiving said objections, Plaintiff states: EFTA_R1_00012990 EFTA01734603 305-9312200 Herman &Mermelsteln, P 03:04:58 p.m. 02-04-2010 8/15 Doe No. 3 v. Epstein Page 7 Plaintiff has not yet identified all of the witnesses she intends to call at trial. The witnesses who went to Epstein's residence include: Jane Doe No. 2 Address previously provided by Mermelstein & Horowitz, P.A., While still a minor, Jane Doe No. 2 was brought to Defendant Epstein's home by Jane Doe No. 3 wherein she was sexually assaulted by Defendant Epstein in a manner during a massage wherein she was paid $200.00. See transcript of Jane Doe No. 2's deposition. Jane Doe No. 4 Address previously provided by Mermelstein & Horowitz, P.A. r, Jane Doe No. 4 was brought to Defendant Epstein's home by an agent and employee of Defendant Epstein, wherein she was repeatedly sexually assaulted during the course of a massage wherein she was paid $200.00 for each sexual assault. Additionally, • at s n rail called by Defendant Epstein's employees, •• nd when Defendant Epstein wanted Jane Doe No. 4 to come to his ome for sexual activity. See transcript of Jane Doe No. 4's deposition. Jane Doe No. 5 Address previously provided by Mermelstein & Horowitz, P.A., As a minor, Jane Doe No. 5 went to Defendant Epstein's home as the result of a conversation with an agent of Defendant Epstein who attended school with Jane Doe No. 5. While at Defendant Epstein's home, she was sexually assaulted by Defendant Epstein during the course of a massage wherein she was paid $200.00. See transcript of Jane Doe No. 5's deposition. Jane Doe No. 6 Address previously provided by Mermelstein & Horowitz, P.A. As a minor, Jane Doe No. 6 was brought to Defendant Epstein's home by- to provide him with a massage. During the course of the massage, she was sexually assaulted by Defendant Epstein and was paid $200.00. See transcript of Jane Doe No. 6's deposition. Jane Doe No. 7 Address previously provided by Mermelstein & Horowitz, P.A. As a mino oe No. 7 was brought to Defendant Epstein by his employee and agent to give Defendant Epstein a massage. She was also on the telephone y Defendant Epstein's agent and employee, when Defendant Epstein wanted her to come to his home for a ma unng the course of the massages, Jane Doe No. 7 was sexually assaulted by Defendant Epstein. She was paid $200.00 each time. See transcript of Jane Doe No. 7's deposition. EFTA_R1_00012991 EFTA01734604  03:05:19 p.m. 02-04-2010 9115 305-9312200 Herman &IVIermelstoin, P Doe No. 3 v. Epstein Page 8 Jane Doe No. 8 Address previously provided by Mermelstein & Horowitz, P.A. As a minor, Jane Doe No. 8 was brought to Defendant Epstein's home byM to give Defendant Epstein a massage. During the course of the massage, Defendant Epstein sexually assaulted Jane Doe No. 8. She was paid $200.00 for the massage/sexual assault. Home do Ma address unknown Esq. Upon informatio n and belief, was brought to Defendant Epstein's home by his employee and/li mo t to give Defendant Epstein a massage wherein he sexually assaulted n at least one occasion. She ' testify that she knew Jane oe No. 6 and introduced her to who brought Jane Doe No. 6 to Defendant Epstein's home for a massage. Jane Doe Home address unknown doMa Esq. Upon information and belief, Jane Doe was invited or bought to Defendant Epstein's home by his agent/employee to give him a massage wherein he sexually assaulted Jane Doe on at least one occasion. See transcript of Jane Doe's deposition. Ho ess unknown do Esq. Upon Informatio n and belief, was brought or invited to Defendant Epstein's home by his employee and/66Nant to give Defendant Epstein a massage wherein he sexually assaulted on at least on occasion. She will also likely testify that she knew Jane Doe No. 6 and brought Jane Doe No. 6 to Epstein's home at his re uest and that Defendant Epstein paid her to bring other girls. See transcript o deposition. nown c/ Esq. Upon i nd belief, was bought or Invited to Defendant Epstein's home by agent/employell give him a massage wherein he sexually assaulted on at least one occasion. She will also likely testify that she was paid by Defendant Epstein to recruit and bring other underage girls to his home for "massages" wherein he sexually assaulted the underage girls. See transcript of deposition. mo e Address Unknown EFTA_R1_00012992 EFTA01734605 305-9312200 Herman &Mermelsteln, P 03:05:37 p.m. 02-04-2010 10/15 Doe No. 3 v. Epstein Page 9 c/o Esq. Upon in ormation and belief was bought or invited to Defendant Epstein's home by his agent/employee to give him a massage wherein he sexually assaulted C.M.A. on at least one occasion. She will also likely testify that she was paid by Defendant Epstein to recruit and bring other underage girls to his home for " " wherein he sexually assaulted the underage girls. See transcript adeposition. Home address unknown Upon information and belief, was bought or invited to Defendant Epstein's home to ' a massage by his agent/employee wherein he sexually assaulted n at least one occasion. She will also likely testify that she was paid by Defendant Epstein to recruit and bring other underage girls to his home for "massages" wherein he sexually assaulted the underage iris, in I in but not limited to, Jane Doe Nos., 3, 4, and 7. See transcript of deposition. Jane Doe No. 101 Hos...known do Esq. Upon information and belief, Jane Doe No. 101 was invited or bought to Defendant Epstein's home by his agent/employee to give him a massage wherein he sexually assaulted Jane Doe No. 101 on at least one occasion. Jane Doe No. 102 Ho dress unknown do Esq. Upon information and belief, Jane Doe No. 102 was invited or bought to Defendant Epstein's home by his agenVemployee to give him a massage wherein he sexually assaulted Jane Doe 102 on at least one occasion. Ja do Esq. Upon Information and belief, Jane Doe No. 103 was invited or bought to Defendant Epstein's by his agent/employee home to give him a massage wherein he sexually assaulted Jane Doe 103 on at least one occasion. do sq. D.D. went with Jane Doe No. 5 to Defendant Epstein's home to give him a massage wherein she was sexually assaulted. Upon information and belief, she was also brought/invited to Defendant Epstein's home on su ent occasions to give him a massage wherein she was sexually assaulted. will also likely testify that she was still a minor when the sexual assaults occurred. EFTA_R1_00012993 EFTA01734606 305-9312200 Herman diMermelpteln, P 03:05:56p.m. 02-04-2010 11 PIS Doe No. 3 v. Epstein Page 10 MEI Home address unknown Esq. is likely to testify that she was brought or invited to Defendant Epstein's home by his agent/employee to give him a massage wherein he sexually assaulted her on at least one occasion. She will likely testify that she was still a minor when the sexual assault(s) occurred. Home address unknown is likely to testify that she was friends with Jane Doe No. 5 and , and knew them to have gone to Defendant Eptein's home on at least one occasion to give him a masszas and that they stated Defendant Epstein touched them in a sexual manner. EN is likely to testify that she too went to Defendant Epstein's home to give him a massage and during the course of that massage, Defendant Epstein touched her in sexual manner while she was still a minor. Home address unknown is likely to testify that she was repeatedly sexually assaulted by Defendant Epstein at his home during the course of massages. She is also likely to testify that Defendant Epstein forced her to engage in sexual intercourse with him against her will, and that she was forced to engage in sexual activity with Epstein's employee/agent, , against her will. She is likely to testify that she was a minor w en ese evens occurred. Home Address Unknown is likely to testify that she was brought or invited to Defendant Epstein's home by his employee/agent to give Defendant Efil a massage wherein she was sexually assaulted on at least one occasion. is likely to testify that she was a minor when these events occurred. Home address unknown is likely to testify that she was friends with Jane Doe Nos. 3, 4, and 7, and knew them to go to Defendant Epstein's home to give him massages. She is also likely to testify that she was brought or invited to Defendant Epstein's home by an agent of Defendant Epstein to give him a massage wherein she was sexually assaulted. She is likely to testify that these events occurred when she was a minor. Il e address unknown is likely to testify that she was friends with Jane Doe No. 3 and knew Jane Doe No. 3 to have gone to Defendant Epstein's home to give him a massage. EFTA_R1_00012994 EFTA01734607 305-9312200 Herman drhAermelsteln, P 03:06:15 p.m. 02-04-2010 12/15 Doe No. 3 v. Epstein Page 11 is also likely to testify that she was brought or invited to Defendant Epstein's home by his agent to give him a massage wherein he sexually assaulted her. She is also likely to testify that these events occurred when she was a minor. is likely to testify that she was friends with Jane Doe No. 3 during the riod, and that she was brought to Defendant Epstein's home by to give him a massage wherein he touched her in a sexual manner. She is also likely to testify that she was a minor when these events occurred. is likely to testify that she was friends with Jane Doe No. 7 and was brought to Defendant Epstein's house to provide him with a massage, wherein she was sexually assaulted by Defendant Epstein. She is also likely to testify that she was a minor when these events occurred. Esq. is likely to testify that she was brought or invited to Defendant Epstein's home by his agent or employee to give him a massage wherein she was sexually assaulted on at least one occasion. She is likely to testify that she was a minor when these events occurred. Jane Doe II Ad wn AEI Esq. Jane Doe I is likely to testify that she was brought to or invited to Defendant Epstein's home by his agent or employee to give him a massage wherein she was sexually assaulted by Defendant Epstein. She is also likely to testify that she was a minor when these events occurred. EFTA_R1_00012995 EFTA01734608