EFTA00727684.pdf

IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO.: 50 2008 CA 028051 XXXXIVIB AD • , Plaintiff; vs. JEFFREY EPSTEIN, Defendant. NOTICE OF SERVICE OF PLAINTIFF'S UNVERIFIED BETTER ANSWERS TO DEFENDANT'S INTERROGATORIES PLEASE TAKE NOTICE that the Plaintiff, M., by and through her undersigned counsel, has served her Unverified Better Answers to Defendant's Interrogatories, numbered 1 to 26, inclusive, propounded to said Plaintiff on or about December 10, 2008. I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by all counsel on the attached Service List via email transmission and U.S. Mail, this 64 day of August, 2009. ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Tel: (954) 522-3456 Fax: (954) 527-8663 Email: By: EDWARDS, ESQ. Florida Bar No.: 542075 EFTA00727684  DEFENDANT'S UNVERIFIED BETTER ANSWERS TO FIRST INTERROGATORIES TO PLAINTIFF 1. What is the name and address of all persons answering or assisting in answering these interrogatories, and, if applicable, the person's official position or relationship with the party to whom the interrogatories are directed? ■., with the assistance of my attorney, Edwards, Esquire. Plaintiff objects to Defendant, Jeffre Epstein, having her address, as Mr. Epstein is a registered sex offender and . was a victim of his, and disclosure of her address could compromise her safety and privacy. 2. 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 in the past 10 years; this includes listing all sources of income you have received. Answer this question by year, i.e. 1998 - 2008. EFTA00727685 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. Plaintiff objects to Defendant, Jeffrey Epstein, having her current address, as Mr. Epstein is a registered sex offender and was a victim of his, and disclosure of her address could compromise her safety and pnvacy. Past addresses and approximate year living at each: EFTA00727686 4. Have you ever been convicted of a crime, other than any juvenile adjudication, which under the law under which you were convicted was punishable by death or imprisonment in excess of 1 year, or that involved dishonesty or a false statement regardless of the punishment? If so, state as to each conviction, the specific crime and the date and the place of conviction. No. 5. List the names and addresses of all persons who are believed or known by you, your agents or attorneys to have any knowledge concerning any of the issues in this lawsuit; and specify the subject matter about which the witness has knowledge. Knowledge of finances and defendant's sexual desire for minor girls Jean Luc Brunel Knowledge of finances and defendant's sexual desire for minor girls Wexner Knowledge of finances and defendant's sexual desire for minor girls Mark Epstein Knowledge of finances and defendant's sexual desire for minor girls Donald Trump Knowledge of finances and defendant's sexual desire for minor girls Jennie Saunders Arranges for underage girls to go to and from Jeff's island David Copperfield Knowledge of finances and defendant's sexual desire for minor girls Ghislaine Maxwell Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls 4 EFTA00727687  Cunningham Knowledge of finances and defendant's sexual desire for minor girls Harry Beller Knowledge of finances and defendant's sexual desire for minor girls Tony Malotta Knowledge of finances and defendant's sexual desire for minor girls Egor Zanovie Knowledge of finances and defendant's sexual desire for minor girls Tagliana Knowledge of finances and defendant's sexual desire for minor girls Natalie in NY Knowledge of finances and defendant's sexual desire for minor girls Lawrence Krauss Knowledge of finances and defendant's sexual desire for minor girls Mortimer Zuckerman Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Vadwon Cotrin Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Jeffrey Epstein's mother Knowledge of finances and defendant's and father sexual desire for minor girls Lebet Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Janvz Banasialc Epstein's house manager during time our client's went to him Michael Reiter Knowledge of defendant's sexual desire for minor girls Det. Recarey Knowledge of defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Bob and Todd Meister Knowledge of finances and defendant's 5 EFTA00727688  sexual desire for minor girls Cecelia Stein Knowledge of finances and defendant's sexual desire for minor girls Larry Visoski Knowledge of finances and defendant's sexual desire for minor girls Ronald Baron Knowledge of finances and defendant's sexual desire for minor girls Glenn Knowledge of finances and defendant's sexual desire for minor girls Amy Fortimer Knowledge of finances and defendant's sexual desire for minor girls Abigail Wexner Knowledge of finances and defendant's sexual desire for minor girls Jeffrey Goldsmith Knowledge of finances and defendant's sexual desire for minor girls Sandy Berger Knowledge of finances and defendant's sexual desire for minor girls Ofc. Munyan Knowledge of defendant's sexual desire for minor girls Ofc. Minot Knowledge of defendant's sexual desire for minor girls Sgt. Sorge Knowledge of defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Pilot David Rogers Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Alfredo Rodriquez Knowledge of finances and defendant's sexual desire for minor girls Leon Black Knowledge of finances and defendant's sexual desire for minor girls Jeff Fuller Knowledge of finances and defendant's sexual desire for minor girls Ron Burkle Knowledge of finances and defendant's sexual desire for minor girls Al] people that visited Knowledge of finances and defendant's Defendant in jail sexual desire for minor girls, and statements made by defendant All minor females with Knowledge of finances and defendant's whom Defendant has sexual desire for minor girls engaged in sexual activities (including, but 6 EFTA00727689 not limited to, those provided in addendum to NPA, all Plaintiff's with sex abuse claims against Defendant, those listed in police reports and documents by Palm Beach Police) Juan Alessi Knowledge of finances and defendant's sexual desire for minor girls Maria Alessi Knowledge of finances and defendant's sexual desire for minor girls Jim Baca Knowledge of finances and defendant's sexual desire for minor girls Janusz Banasiak Knowledge of finances and defendant's sexual desire for minor girls Keith Blumberg Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Campos Knowledge of finances and defendant's sexual desire for minor girls Jimmy Cayne Knowledge of finances and defendant's sexual desire for minor girls Cecelia (last name Knowledge of finances and defendant's unknown at this time) sexual desire for minor girls Maximilia Cordero Knowledge of finances and defendant's sexual desire for minor girls Ellen Cunningham Knowledge of finances and defendant's sexual desire for minor girls Dave (last name unknown Knowledge of finances and defendant's at this time) sexual desire for minor girls Ryan Dionne Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Michael Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Eric Gany Knowledge of finances and defendant's sexual desire for minor girls Hessey Knowledge of finances and defendant's sexual desire for minor girls EFTA00727690  (last name Knowledge of finances and defendant's unknown at this time) sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Gary King Knowledge of finances and defendant's sexual desire for minor girls Bella Klein Knowledge of finances and defendant's sexual desire for minor girls Adam Perry Lang Knowledge of finances and defendant's sexual desire for minor girls Michael Liffman Knowledge of finances and defendant's sexual desire for minor girls Mark Lumberg Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Lynn (last name unknown Knowledge of finances and defendant's at this time) sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls David Mullen Knowledge of finances and defendant's sexual desire for minor girls Gary Nikolitis Knowledge of finances and defendant's sexual desire for minor girls David Non- Knowledge of finances and defendant's sexual desire for minor girls Bill Peadon Knowledge of finances and defendant's sexual desire for minor girls Francis Peadon Knowledge of fmances and defendant's sexual desire for minor girls Jerome Pierre Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Governor Bill Richardson Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls EFTA00727691 Alfredo Rodriguez Knowledge of finances and defendant's sexual desire for minor girls David Rogers Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Howard Rubenstein Knowledge of finances and defendant's sexual desire for minor girls Florena Rueda Knowledge of finances and defendant's sexual desire for minor girls Joseph Rueda Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Santa Fe County Sheriff Knowledge of finances and defendant's Solano sexual desire for minor girls Alan Stopeck Knowledge of finances and defendant's sexual desire for minor girls Mark Tafoya Knowledge of finances and defendant's sexual desire for minor girls Brent Tindall Knowledge of finances and defendant's sexual desire for minor girls Jojo (last name unknown Knowledge of finances and defendant's at this time) sexual desire for minor girls All girls identified in the Knowledge of finances and defendant's attachment to the non- sexual desire for minor girls prosecution agreement that Defendant, Jeffrey Epstein, has entered with the United States and all other similarly-situated girls, whose identities Plaintiff will attempt to determine (and with regard to whom Defendant, Jeffrey Epstein, has invoked the Fifth Amendment rather than disclose their identities). All other then-minor girls Knowledge of finances and defendant's (those not listed in the sexual desire for minor girls attachment to the non- prosecution agreement), whose identities Plaintiff EFTA00727692 will attempt to determine, with whom Defendant, Jeffrey Epstein, has engaged in sex FBI agents, whose names, Knowledge of finances and defendant's addresses and telephone sexual desire for minor girls numbers are unknown at this time, that investigated the criminal case(s) and the allegations made against Defendant, Jeffrey Epstein. State Prosecutors, whose Knowledge of finances and defendant's names, addresses and sexual desire for minor girls telephone numbers are unknown at this time, including but not limited to: ASA Lanna Belohlavek State Attorney's Office 15th Judicial Circuit ASA Weiss State Attorneys Office 15th Judicial Circuit United States' Prosecutors, Knowledge of finances and defendant's whose names, addresses sexual desire for minor girls and telephone numbers are unknown at this time, including but not limited to: United States Attorney's Office 500 South Australian Avenue West Palm Beach, Florida 10 EFTA00727693 33401 All accountants, bookkeepers, - ." bankers, financial institutions, representatives, real estate advisors, financial planners, employees, governmental persons or entities, and unknown others that may have discoverable information related to Defendant, Jeffrey Epstein's net worth and finances. Any and all persons and/or entities identified through discovery having any knowledge of Defendant, Jeffrey Epstein's charitable, political or other donations made in the past. Any and all persons and/or entities identified through discovery that were sued in the past by the Defendant, Jeffrey Epstein, and/or by any company or entity that the Defendant, Jeffrey Epstein, owned and/or managed Reporters and other media persons, whose names, addresses and telephone numbers are unknown at this time. All other witnesses learned through discovery process Knowledge of finances and defendant's sexual desire for minor girls 11 EFTA00727694  Jean Luc Brunel Knowledge of finances and defendant's sexual desire for minor girls Wexner Knowledge of finances and defendant's sexual desire for minor girls Mark Epstein Knowledge of finances and defendant's sexual desire for minor girls Donald Trump Knowledge of finances and defendant's sexual desire for minor girls Jennie Saunders Arranges for underage girls to go to and from Jeff's island David Copperfield Knowledge of finances and defendant's sexual desire for minor girls Ghislaine Maxwell Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Harry Beller Knowledge of finances and defendant's sexual desire for minor girls Natalie in NY Knowledge of finances and defendant's sexual desire for minor girls Lawrence Krauss Knowledge of finances and defendant's sexual desire for minor girls Mortimer Knowledge of finances and defendant's sexual Zuckerman desire for minor girls Marie and Juan Knowledge of finances and defendant's sexual ism desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Vadwon Collin Knowledge of finances and defendant's sexual desire for minor girls & Evelyn Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Jeffrey Epstein's Knowledge of finances and defendant's sexual mother and father desire for minor girls Lebet Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor gir]s 12 EFTA00727695  Knowledge of finances and defendant's sexual desire for minor girls Janvz Banasiak Epstein's house manager during time our client's went to him Michael Reiter Knowledge of defendant's sexual desire for minor girls Det. Recarey Knowledge of defendant's sexual desire for minor girls Bums Knowledge of finances and defendant's sexual desire for minor girls Bob and Todd Knowledge of finances and defendant's sexual Meister desire for minor girls Cecelia Stein Knowledge of finances and defendant's sexual desire for minor girls Larry Visoski Knowledge of finances and defendant's sexual desire for minor girls Ronald Baron Knowledge of finances and defendant's sexual desire for minor girls Glenn Knowledge of finances and defendant's sexual desire for minor girls Amy Fortimer Knowledge of finances and defendant's sexual desire for minor girls Abigail Wexner Knowledge of finances and defendant's sexual desire for minor girls Jeffrey Goldsmith Knowledge of finances and defendant's sexual desire for minor girls Sandy Berger Knowledge of finances and defendant's sexual desire for minor girls Ofc. Munyan Knowledge of defendant's sexual desire for minor girls Ofc. Minot Knowledge of defendant's sexual desire for minor girls Sgt. Sorge Knowledge of defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Pilot David Rogers Knowledge of finances and defendant's sexual desire for minor girls Knowledge of finances and defendant's sexual desire for minor girls Alfredo Rodriquez Knowledge of finances and defendant's sexual desire for minor girls Leon Black Knowledge of finances and defendant's sexual desire for minor girls Jeff Fuller Knowledge of finances and defendant's sexual 13 EFTA00727696  Desire for minor girls Ron Burkle Knowledge of finances and defendant's sexual desire for minor girls All people that visited defendant Knowledge of finances and defendant's in jail sexual desire for minor girls, and statements made by Defendant. 6. 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? No. 14 EFTA00727697 7. Did you consume any alcoholic beverages or take any drugs or medication within 12 hours before the time of each incident(s) described in the complaint? If so, state the type and amount of alcoholic beverages, drugs or medication which were consumed and when and where you consumed them. The first time I went I was completely sober and was extremely nervous. Subsequent times I always took various pain killer type medications before going to Defendant, Jeffrey Epstein's house. 8. Describe each injury (physical, emotional, mental) for which you are claiming damages in this case, specifying the part of your body that was injured, the nature of the injury, and as to any injuries you contend are permanent, the effects on you that you claim are permanent. My injuries are primarily emotional/psychological and are the direct result of Defendant, Jeffrey Epstein's actions. I was touched, battered, and fondled by Defendant, Jeffrey Epstein, during the incidents described in the complaint. I observed the Defendant touch and fondle himself. I observed the Defendant ejaculate numerous times. I was made to touch the Defendant. I also observed sexual acts and had sexual acts perpetrated on me by Defendant, Jeffrey Epstein. At various times I was unclothed, as was the Defendant and others. At all times material, I was a child, under the age of 18 years. The Defendant also used me to bring him other minor girls and he controlled and brainwashed me into believing this lifestyle was healthy and normal for a girl my age. I was a victim of various criminal acts and sexual exploitation. I was induced and coerced by the Defendant into acts of prostitution. These injuries are further described in more detail in the factual allegations of the complaint. 9. Please state each item of damage that you claim, and include in your answer: the count to which the item of damages relates; the factual basis for each item of damages; and an explanation of how you computed each item of damages, including any mathematical formula used. I incurred medical and psychological expenses in the past and will incur such expenses in the future. I have suffered a loss of earning capacity due to Jeffrey 15 EFTA00727698  Epstein's influence because I was encouraged by him as a minor child to enter a life of prostitution for him I suffered a loss of the capacity to enjoy life as a result of being coerced and induced into committing acts of prostitution and as a result of being sexually exploited. I lost self-worth, confidence and self esteem due to his control and influence. I have suffered mental anguish, emotional distress, fear, humiliation and psychological trauma as a result of the acts described in the complaint. The effect of these injuries is permanent in nature. These damages are further described in the complaint. The factual basis for these damages is described in the answer to #8 above, and in the factual allegations in the complaint. 10. Do you contend that you have lost any income, benefits, or earning capacity in the past or future as a result of the incident described in the complaint? If so, state the nature of the income, benefits, or earning capacity, and the amount and the method that you used in computing the amount. Lost earning capacity, in that Defendant, Jeffrey Epstein, influenced me to dedicate my life to making money pleasing men sexually and away from the traditional life of a middle school and high school adolescent. Thus, I did not get the education I would have received had I never met Defendant, Jeffrey Epstein, or fell under his spell, and as such I am now unable to get jobs in a traditional profession.. 11. List the names and business addresses of each physician (including psychiatrist, psychologist, etc.) or medical provider (including chiropractors) 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. Office Palm Beach Doctors n West Palm Beach treated me for anxiety and depression, which are related to the abuse inflicted by Defendant, Jeffrey Epstein. 16 EFTA00727699  M.S. LMHC (Licensed Therapist) I FFI ac lcumty Public Safety Department Victim Services Division 205 North Dixie Highway Suite 5.1100 West Palm Beach, FL 33401 12. List the names and business addresses of all other physicians, medical facilities, rehab facilities (drug, alcohol or psychiatric) or other health care providers including psychiatrist, psychologist, mental health counselor and chiropractors by whom or at which you have been examined or treated in the past 10 years; and state as to each the dates of examination or treatment and the condition or injury for which you were examined or treated. Good Samaritan Hospital 1309 North Flagler West Palm Beach, Florida 33401 Me II ach IIIIM Doctors West Palm Beach, Florida Palm Beach Lakes Village Common Planned Parenthood, West Palm Beach Okeechobee walk-in clinic S. LMHC (Licensed Therapist) Palm Beach County Public Safety Department Victim Services Division 205 North Dixie Highway Suite 5.1100 West Palm Beach, FL 33401 I am unsure as to the dates. 17 EFTA00727700 13. State the name and address of every person known to you, your agents, or attorneys, who has knowledge about, or possession, custody or control of any model, plat, map, drawing, motion picture, video tape, or photograph pertaining to any fact or issue involved in this controversy; and described as to each, what item such person has, the name and address of the person who took or prepared it, and the date it was taken or prepared. At this time I am unable to say who has or might have these types of photographs; however, Plaintiff reserves the right to supplement this response should that information become available. 14. Please state if you (or parents or guardians on your behalf) have ever been a party, either plaintiff or defendant, in a lawsuit other than the present matter and if so, state whether you were plaintiff or defendant, the nature of the action, and the date and court in which such suit was filed. I was involved in a custody proceeding with Sprague. 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. I was a minor child at all times that I went to Defendant, Jeffrey Epstein's house and have not been since approximately September 2005; to the best of my knowledge and recollection. I went for the first time in July 2002, and I went there with . Aside from Defendant, Jeffrey Epstein, .. and were present in the home while I was with Defendant, Jeffrey Epstein, in his bedroom, and other persons employed by Defendant, Jeffrey Epstein, were there as well. After the first time in July 2002 through the last time in September 2005, I went to Defendant, Jeffrey Epstein's house more than 100 times and Defendant, Jeffrey Epstein, would have a much more accurate count ofaiyLvi its and more documentation of the times I was there because he and kept a schedule. Because Defendant, Jeffrey Epstein, paid me to bring him other underage minor girls, I brought him more than 50 minor girls and I went to his house with them. I do not know all of their names, although Defendant, Jeffrey 18 EFTA00727701  Epstein does. The names I recall can be found on Answer to Interrogatory Number 24. 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. I went the first time with and most of the other times I took a cab. Defendant, Epstein personally took me home on at least one occasion. or Defendant Epstein would call for me to go to his house and bring him other girls. 17. State the date you began engaging in prostitution, where (City and State), and whether you are still engaged in prostitution. Defendant, Jeffrey Epstein, introduced me to prostitution and encouraged me to be a prostitute, and I was never engaged in prostitution prior to meeting Defendant, Jeffrey Epstein. 18. State the amount of monies (or anything else of value, including gifts) you claim were given or paid to you by Mr. Epstein (or someone paid/gave you on his behalf and that person's name, address and phone number) by year from 2000 - 2006. Each time I went to Defendant, Jeffrey Epstein, he paid me $200 for him to sexually touch and fondle me; he also paid me $200 for each minor girl that I brought him for the purposes of him engaging in sex acts with them. 19. List separately the names, address and phone number of all males, excluding Mr. Epstein, with whom you have had sexual activity since age 10 (by year) up through your current age. Describe the nature of sexual activity, the date(s) and whether you received money or other consideration from the person. Objection, harassing; irrelevant, not reasonably calculated to lead to admissible evidence, violation of privacy interests and rights of Plaintiff and other innocent persons. 19 EFTA00727702 20. List separately the names, addresses and phone numbers of all males, excluding your claims against Mr. Epstein, whom you have claimed (formally or informally) committed sexual assault or battery on you since age 10 (by year) up through your current age. Describe the nature of sexual assault or battery, the date(s) and whether you received money or other consideration from the person. Jeffrey Epstein was the only known person. 21. State the names, addresses and phone numbers of all males, excluding your claims against Mr. Epstein, whom you have claimed (formally or informally) committed lewd or lascivious conduct to you since age 10 (by year) up through your current age. Describe the lewd or lascivious conduct, the date and whether you received money or other consideration from the person. Jeffrey Epstein was the only known person. 22. State the names, addresses and phone numbers of all males, excluding your claims against Mr. Epstein, whom you have claimed (formally or informally) committed lewd or lascivious exhibition to you since age 10 (by year) up through your current age. Describe the lewd or lascivious exhibition„ the date and whether you received money or other consideration from the person. Jeffrey Epstein was the only known person. 23. List in detail all discussions/interviews which you had with any representative from FBI, U.S. Attorneys' Office, State Attorneys' Office (Palm Beach County), Palm Beach Sheriffs Office and Palm Beach Police Department regarding your meeting with Mr. Epstein. Include dates, who was present, the details of what was discussed, whether a court reporter was present and whether a taped statement was taken or whether you provided a written statement. After Defendant, Jeffrey Epstein, hired and paid for an attorney to represent me while he was being criminally investigated, I provided a taped statement to the F.B.I. 20 EFTA00727703 24. State the names, addresses, ages and phone numbers of all females whom you claim were brought by you to Mr. Epstein's home to give him a massage. As to each female, state the amount of money you claim you were paid to bring each female. There were a roximatel 50 *iris. The names I remember:. 25. Please list each time you were interviewed by any state or federal law enforcement agent or prosecutor, who was present, whether notes were taken, and what you recall saying to them. To the best of my knowledge, the only time I was interviewed was the taped statement to the F.B.I. 26. Please describe any statements made to you by any federal or state law enforcement agent or prosecutor regarding the availability of civil remedies against Mr. Epstein and regarding whether there would be any benefit from your voluntary cooperation with law enforcement. There was never anything told to me about any civil remedies. 21 EFTA00727704  M, Plaintiff I, counsel fora, the Plaintiff herein, personally witnessed the Plaintiff execute this Jurat page and do swear that M. is personally known to me, is the individual identified in the foregoing answers and is the same individual whose identify has been previously disclosed, under seal to the Defendant's counsel. Edwards STATE OF FLORIDA :ss COUNTY OF BROWARD SWORN TO AND SUBSCRIBED before me this day of , 2009 by =EDWARDS, who is personally known to me. Print Name Signature NOTARY PUBLIC - STATE OF FLORIDA Commission Number: My commission expires: (Notarial Seal) 22 EFTA00727705