Court Records
Case 9:08-cv-80119- KAM Document 228-2 Entered on FLSD Docket 07/29/2009 Page 1 of 4 • #281849/clw UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE N : - V-80811-CIV- C.M.A., Plaintiff(s), vs. JEFFREY EPSTEIN and Defendant(s). NOTICE OF SERVING ANSWERS TO INTERROGATORIES COMES NOW the Plaintiff, C.M.A., by and through undersigned counsel, and hereby files this Notice with the Court that Answers to Interrogatories propounded by the Defendant, JEFFREY EPSTEIN, on January 16, 2009, have been furnished to the attorney for the Defendant. I HEREBY CERTIFY that a true copy of the foregoing has been furnished by mail this R CL day of February, 2009, to: See attacked list of counsel. 9N JACK SCR OLA Florida Bar No.: 169440 JACK P. Florida Bar No.: 0547808 Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: ([Phone Redacted] Fax: ([Phone Redacted] Attorney for Plaintiff(s) EFTA02745508 Case 9:08-cv-80119-KAM Document 228-2 Entered on FLSD Docket 07/29/2009 Page 2 of 4 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRJUJOHNSON Plaintiff's Answers to Defendant's First Interrogatories School behavioral problems, received counseling prior to the incident 8. 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 so, state the type and amount of alcoholic beverages, drugs, or medication which were consumed, and when (dates) and where you consumed them. ANSWER 1. On one occasion I had taken "Morning Glory" and "Angel Trumpets". I do not recall the date. 2. On another occasion I used cocaine powder. I do not recall the date. 9. 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. ANSWER I have bi-polar disorder and manic depression. I lost my self-esteem. I began cutting myself on my arms and legs and developed drug problems. Permanent injuries are psychological. 10. 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. ANSWER I am claiming compensation for mental anguish, mental pain, psychic trauma, and loss of enjoyment of life. These damages will be evaluated by a jury who will provide their own methods of computation in an amount of at least the statutory minimum established by 18 U.S.C.A. § 2255. Discovery is ongoing. 11. List the names and business addresses of each physician (including psychiatrist, psychologist, chiropractor or medical provider) who has treated or examined you, 13 EFTA02745509 Case 9:08-cv-80119-KAM Document 228-2 Entered on FLSD Docket 07/29/2009 Page 3 of 4 C.M.A. vs. Epstein, et al. Case No.: 08-CV-808 I I-CIV-MARRAMIIII Plaintiff's Answers to Defendant's First Interrogatories STATE OF Florida COUNTY OF Palm Beach ) by ••• Signature of Answering P The foregoing instrument was acknowledged before me this /7 day of February, 2009 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: 19 EFTA02745510 Case 9:08-cv-80119-KAM Document 228-2 Entered on FLSD Docket 07/29/2009 Page 4 of 4 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRABOHNSON Plaintiff's Answers to Defendant's First Interrogatories COUNSEL LIST Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S. West Palm Beach, FL 33401 Phone: ([Phone Redacted] Attorneys for Jeffrey Epstein Bruce E. Reinhart, Esquire Bruce E. Reinhart, P.A. 250 South Australian Avenue Suite 1400 West Palm Beach, FL 33401 Phone: ([Phone Redacted] Fax: (561)-82 -0 Attorneys for c et , Robert Critton Burman Critton Luttier & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33414 Phone: ([Phone Redacted] Fax: ([Phone Redacted] Attorneys for Jeffrey Epstein Richard H. Willits, Esquire [Email Redacted] Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 Phone: ([Phone Redacted] Fax: ([Phone Redacted] Attorneys for Party 20 EFTA02745511