Court Records
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 1 of 19
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
JANE DOE No. 101,
Plaintiff,
VS.
JEFFREY EPSTEIN,
Defendant.
09-80591
Civil Action No.
CH-MARRA
MAGISuper
COMPLAINT AND
DEMAND FOR JURY TRIAL
FILED by i th - S - D C
INTAKE
APR 1 7 2009
STEVEN M LARIMORE CLERK U.S DIST. CT. $.0 OF FLA. MIAMI
COMPLAINT AND DEMAND FOR JURY TRIAL
Plaintiff, Jane Doe No. 101 ("Jane Doe"), brings this Complaint against Defendant,
Jeffrey Epstein, and states as follows:
PARTIES. JURISDICTION, AND VENUE
I. At all times material to this cause of action, Plaintiff, Jane Doe, was a resident of
Palm Beach County, Florida.
2. This Complaint is brought under a fictitious name to protect the identity of
Plaintiff, Jane Doe, because this Complaint makes sensitive allegations of sexual assault and
abuse of a then minor.
3. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a
residence located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida.
4. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is
currently incarcerated in the Palm Beach County Stockade.
5. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an
adult male born in 1953.
Podlnust Orseck, P.A.
25 West Flagler Street. Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] 1 www.pocUntrstcoM
EFTA02738115
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6. This Court has jurisdiction of this action and the claims set forth herein pursuant
to 18 U.S.C. § 2255.
7. This Court has venue of this action pursuant to 28 U.S.C. § 1391(a), as a
substantial part of the events giving rise to the claim occurred in this District.
STATEMENT OF FACTS
8. At all relevant times, Defendant, Jeffrey Epstein, was an adult male,
approximately 50 years old. Epstein is known as a billionaire financier and money manager with
a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth, power,
and influence. He owns a fleet of aircraft that includes a Gulfstream IV, a helicopter, and a
Boeing 727. Until his incarceration, he maintained his principal place of residence in the largest
home in Manhattan. a 51,000-square-foot eight-story mansion on the Upper East Side. Upon
information and belief, he also owns a $6.8 million mansion in Palm Beach, Florida, a $30
million 7,500-acre ranch in New Mexico he named "Zorro," and a 70-acre private island known
as Little St. James in St. , U.S. Virgin Islands. The allegations herein concern
Defendant's conduct while at his lavish estate in Palm Beach.
9. Upon information and belief, Defendant has a sexual preference for underage
minor girls. He engaged in a plan, scheme, or enterprise in which he gained access in his home
to countless relatively economically disadvantaged minor girls, sexually assaulted or molested
these girls, and then gave them money.
10. Beginning in or around 2001 through in or around September 2007, Defendant
used his resources and his influence over vulnerable minor children to engage in a systematic
pattern of sexually exploitative behavior.
11. Defendant's plan and scheme reflected a particular pattern and method.
Defendant coerced and enticed impressionable, vulnerable, and relatively economically less
Podhurst Orseck, P.A. 2
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdak [Phone Redacted] www.podhast.com
EFTA02738116
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 3 of 19
fortunate minors to participate in various acts of sexual misconduct that he committed upon
them. Defendant's scheme involved the use of underage girls as well as other individuals to
recruit other underage girls. Upon information and belief, Defendant or an authorized agent
would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach
residence. His assistants would seek out economically disadvantaged and underage girls from
West Palm Beach and surrounding areas who would be enticed by the money being offered—
generally $200 to $300 per "massage" session—and who Defendant and/or his assistants
perceived as less likely to complain to authorities or have credibility issues if allegations of
improper conduct were made. The then minor Plaintiff and other minor girls, some as young as
14 years old, were transported to Defendant's Palm Beach county mansion by Defendant's
employees, agents, and/or assistants in order to provide Defendant with "massages."
12. Defendant would pay the procurer of each girl's "appointment" approximately
$200. Many of the instances of illegal sexual conduct committed by Defendant were perpetrated
with the assistance, support, and facilitation of at least three assistants who helped him
orchestrate this child exploitation enterprise. These assistants would often arrange times for
underage girls to come to Defendant's residence, transport or cause the transportation of
underage girls to Defendant's residence, escort the underage girls to the massage room where
Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove
their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the
conclusion of each "massage appointment," and, upon information and belief, take nude
photographs and/or videos of the underage girls' for Defendant without their knowledge.
13. Epstein designed the scheme to secure a private place in Defendant's mansion
where only persons employed and invited by Epstein would be present, so as to reduce the
chance of detection of Defendant's sexual abuse and prostitution as well as to make it more
Podhurst Orseck, P.A. 3
25 West Hagler Street. Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale 954.463.430 www.podlnumsom
EFTA02738117
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difficult for the minor girls to flee the premises and/or to credibly report his actions to law
enforcement or other authorities. The girls were usually transported by his employees, agents,
and/or assistants or by a taxicab paid for by Defendant in order to make it difficult for the girls to
flee his mansion.
14. Upon arrival at Defendant's mansion, each underage victim would generally be
introduced to one of Defendant's assistants, who would gather the girl's personal contact
information. The minor girl would then be led up a flight of stairs to a room that contained a
massage table and a large shower. The staircase leading to the room was plastered with nude
photographs of young girls, including some photographs depicting two or more young girls
engaged in lewd acts. Upon information and belief, Defendant, Jeffrey Epstein, had such
photographs in each of his four homes and on his computer.
15. At times, if it was the girl's first "massage" appointment, another female would
be in the room to "lead the way" until Defendant would have her leave. Generally, Defendant
would start his massage wearing only a small towel, which eventually would be removed.
Defendant would direct the girl to massage him, giving her specific instructions as to where and
how he wanted to be touched, and then direct her to remove her clothing. He would then
perform one or more lewd, lascivious, and sexual acts, including masturbation, fondling the
minor's breasts and/or sexual organs, touching the minor's vagina with a vibrator and/or back
massager, digitally penetrating her vagina, performing intercourse, oral sex, and/or anal sex,
and/or coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution. The
exact degree of molestation and frequency with which the sexual crimes took place varied and is
not yet completely known; however, at least when Defendant was in Palm Beach, Florida, such
acts occurred usually on a daily basis and, in most instances, several times a day.
Podhurst Orseck, P.A. 4
25 West Hagler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] ww‘v.podliurstcoin
EFTA02738118
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16. As previously stated in paragraph 14, Defendant displayed nude photographs of
underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S.
Virgin Islands. Upon information and belief, some of the photographs in the possession of
Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the
day of his arrest, police found two hidden cameras and photographs of underage girls on a
computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may
have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and may have
transported lewd photographs of Plaintiff (among many other victims) to his other residences and
elsewhere using a facility or means of interstate commerce.
17. Consistent with the foregoing plan and scheme, Defendant used his money,
wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff.
Plaintiff, Jane Doe, was recruited by one of Defendant's agents to give Defendant a massage for
compensation. Plaintiff was apprehensive, but needed the money and finally agreed to go.
Plaintiff was first brought to Defendant's mansion in or about the spring of 2003, when she was
merely 17 years old and in high school. Epstein's procurer drove her to Jeffrey Epstein's
mansion. Plaintiff was led up a flight of stairs by a blonde woman to a spa room with a shower
and a massage table, where she was left alone. A woman with dark hair, an accent, and naked
from the waist up entered and tried to coax Plaintiff to remove her shirt, but Plaintiff refused.
Atter the woman showed Plaintiff how to use the lotions that were there, the woman left.
Defendant walked in wearing only a small towel. He lay down on the massage table still
wearing the small towel, and Plaintiff began to massage his shoulders and neck. Nervously, she
asked him what he did for a living. Defendant responded that he was a scientist. Defendant
asked Plaintiff what year she would graduate high school, to which Plaintiff honestly replied that
she would graduate in 2004. Plaintiff massaged Defendant's lower back and calves. Defendant
Podhurst Orseck, P.A. 5
25 West Flatter Street, Suite PM, Miami, FL 33130, Miami [Phone Redacted] Fax 30535112382 • Fort Lauderdale [Phone Redacted] www.podhurstaxn
EFTA02738119
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 6 of 19
told her to remove his towel. Defendant told her that he had just worked out and wanted his
buttocks massaged. Although disgusted, she was afraid to refuse and did it. At some point,
Defendant ordered Plaintiff to remove her clothes. In shock, fear, and trepidation, Plaintiff partly
complied, removing only her shirt and bra. When Defendant turned over, Plaintiff was afraid
and embarrassed and she wanted to leave. Defendant repeatedly told her to relax and
complimented her, saying that she had a nice body. Defendant then pulled Plaintiff closer to
him. He began masturbating and then began fondling her breasts. He asked her to do more and
mentioned more money, which she adamantly declined. Defendant continued masturbating until
he ejaculated. Plaintiff next recalls that she received $200 and was transported by the procurer,
whom she later learned received $200 for having brought her to Epstein's mansion.
IR. Defendant thereafter lured the then minor Plaintiff to the Epstein mansion on at
least one and perhaps two other occasions in the spring and/or summer of 2003. The procurer
made another appointment for her to return, but Plaintiff didn't want to sec Defendant. By
having his assistants continue to contact Plaintiff and attempt to lure her to the mansion for other
sexual acts, Defendant engaged in a continuous course of conduct that injured Plaintiff upon
each instance of contact and/or abuse.
19. In addition to the direct sexual abuse and molestation of the then minor Plaintiff,
Defendant used his money, wealth, and power to unduly and improperly manipulate and
influence the then minor Plaintiff to bring him another minor girl in a promised exchange for
money. Rather than go herself, Plaintiff and the procurer took another girl there one time.
20. As a result of these encounters with Defendant, Plaintiff, Jane Doe, has in the past
suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
Podhurst Orseck, P. A. 6
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale 954,63.4346 I www.podhamitcom
EFTA02738120
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 7 of 19
other damages associated with Defendant's controlling and manipulating her into a perverse and
unhealthy way of life.
21. Any assertions by Defendant that he was unaware of the age of the then minor
Plaintiff are belied by her telling him her high school graduation year, as well as his own actions,
and are rendered irrelevant by the provision of applicable federal statutes concerning the sexual
exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this
cause of action, knew and should have known of Plaintiff's age of minority. In fact, his
preference for underage girls was well-known to those who regularly procured them for him.
22. Defendant, Jeffrey Epstein, committed the above-referenced acts upon the then
minor Plaintiff in violation of federal statutes condemning the coercion and enticement of a
minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual
conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual
depictions of a minor engaging in sexually explicit conduct, transport of child pornography, child
exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes
designated in 18 U.S.C. § 2422(b), § 2423(b), § 2423(c), § 2251, § 2252, § 2252A(a)(1), §
2252A(g)(1), and § 1591.
23. After investigations by the Palm Beach Police Department, the Palm Beach State
Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's Office
for the Southern District of Florida, Defendant, Jeffrey Epstein, entered pleas of "guilty" to
various Florida state crimes involving the solicitation of minors for prostitution and the
procurement of minors for the purposes of prostitution in June 2008 in the Fifteenth Judicial
Circuit in Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if
he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such,
Podhurst Orseck, P.A. 7
25 West Master Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale 954A63.4346 www.podhurst.com
EFTA02738121
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 8 of 19
must admit liability unto Plaintiff, Jane Doe. Plaintiff hereby exclusively seeks civil remedies
pursuant to 18 U.S.C. § 2255.
COUNT ONE
(Cause of Action for Coercion and Enticement of Minor to 1 I-maze in Prostitution or
Sexual Activity pursuant to 18 U.S.C. 4 2255 in Violation of 18 U.S.C. S 2422(b)1
24. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 23 above.
25. Defendant, Jeffrey Epstein, used a facility or means of interstate commerce to
knowingly persuade, induce, or entice Jane Doe, when she was under the age of 18 years, to
engage in prostitution and/or sexual activity for which any person can be charged with a criminal
offense pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(b).
26. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code.
27. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
and will in the future suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
other damages associated with Defendant's manipulating and leading her into a perverse and
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
suffer these losses in the future.
Podhurst Orseck, P.A. 8
25 West Hagler Street. Suite WO, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.podhurst com
EFTA02738122
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 9 of 19
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
a jury.
COUNT TWO
(Cause of Action for Travel with Intent to Engage in Illicit Sexual Conduct pursuant to 18
U.S.C. 5 2255 in Violation of 18 U.S.C. 5 2423(b))
28. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 23 above.
29. Upon information and belief, Defendant, Jeffrey Epstein, traveled in interstate
commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. §
2423(0, with minor females, in violation of 18 U.S.C. § 2423(b).
30. Plaintiff. Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code.
31. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
and will in the future suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
other damages associated with Defendant's manipulating and leading her into a perverse and
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has
suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
Podhurst Orseck, P.A. 9
25 West Hagler Street, Suite 800, Nan* FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.podhurst.com
EFTA02738123
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 10 of 19
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
suffer these losses in the future.
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
a jury.
COUNT THREE
(Cause of Action for Sex Trafficking of Children pursuant to 18 U.S.C. & 2255 in Violation
of 18 U.S.C. & 1591(a))
32. Plaintiff, Jane Doe, hereby adopts, repeats. realleges, and incorporates by
reference the allegations contained in paragraphs I through 23 above.
33. Defendant, Jeffrey Epstein, knowingly, in or affecting interstate or foreign
commerce, recruited. enticed, and obtained Plaintiff, Jane Doe, knowing that she had not attained
the age of 18 years and would be caused to engage in a commercial sex act as defined in 18
U.S.C. § 1591(cX1), in violation of 18 U.S.C. § 1591(a)(1).
34. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code.
35. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
and will in the future suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
other damages associated with Defendant's manipulating and leading her into a perverse and
Podhurst Orseck, P.A. 10
25 West Flagkr Street Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] I www.podluirst.corn
EFTA02738124
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 11 of 19
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
suffer these losses in the future.
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
a jury.
COUNT FOUR
(Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. & 2255 in
Violation of 18 U.S.C. & 22511
36. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 23 above.
37. Defendant, Jeffrey Epstein, knowingly induced, enticed, or coerced then minor
Plaintiff Jane Doe to engage in sexually explicit conduct for the purpose of producing a visual
depiction of such conduct in violation of 18 U.S.C. § 2251. As previously stated in paragraphs
14 and 16, Defendant displayed a myriad of photographs of underage girls throughout his homes
in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. Upon information and
belief, many of the photographs in the possession of Defendant were taken with hidden cameras
set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden
cameras and photographs of underage girls on a computer in Defendant's home. Upon
information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of
Plaintiff, Jane Doe, with his hidden cameras and may have transported lewd photographs of
Podhurst Orseck, P.A. 11
25 West Flagler Steer, Suite 800, Miami, Fl. 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.podhtust.rom
EFTA02738125
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 12 of 19
Plaintiff (among many other victims) to his other residences and elsewhere using a facility or
means of interstate commerce.
38. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code.
39. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
and will in the future suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
other damages associated with Defendant's manipulating and leading her into a perverse and
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
suffer these losses in the future.
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
a jury.
Podhurst Orseck, 12
25 West Flagler Street, Suite 800, Miami, 1-1, 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.podhurst.com
EFTA02738126
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COUNT FIVE
(Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit
Conduct pursuant to 18 U.S.C. 2255 in Violation of 18 U.S.C. $ 2252(a)(1)1
40. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 23 above.
41. Defendant, Jeffrey Epstein. knowingly mailed, transported, or shipped in
interstate or foreign commerce child pornography in violation of 18 U.S.C. § 2252(1). As
previously stated in paragraphs 14, 16, and 37, upon information and belief, Defendant displayed
a myriad of photographs of underage girls throughout his homes in New York, Palm Beach, New
Mexico, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in
the possession of Defendant were taken with hidden cameras set up throughout his home in Palm
Beach. On the day of his arrest, police found two hidden cameras and photographs of underage
girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey
Epstein, may have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and
may have transported lewd photographs of Plaintiff (among many other victims) to his other
residences and elsewhere using a facility or means of interstate commerce.
42. As previously stated in paragraph 21, any assertions by Defendant that he was
unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by
the provision of applicable federal and state statutes concerning the sexual exploitation and abuse
of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew
and should have known of Plaintiff's age of minority. In fact, his preference for underage girls
was well-known to those who regularly procured them for him.
43. Plaintiff, Janc Doc, was a victim of one or more offenses enumerated in 18 U.S.C.
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code.
Podhurst Orseck, P.A. 13
25 West Raster Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] I www.podhiust.com
EFTA02738127
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44. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
and will in the future suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
other damages associated with Defendant's manipulating and leading her into a perverse and
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
suffer these losses in the future.
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
a jury.
COUNT SIX
(Cause of Action for Transport of Child Pornography pursuant to 18 U.S.C. 4 2255 in
Violation of 18 U.S.C. 4 2252A(a)(1))
45. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 23 above.
46. Defendant, Jeffrey Epstein, knowingly mailed, transported, or shipped in
interstate or foreign commerce child pornography in violation of 18 U.S.C. § 2252A(a)(1).
Podhurst Orsecic, P.A. 14
25 West Flagler Street Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted]
EFTA02738128
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47. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
§ 2255, and, as such asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code.
48. Defendant, Jeffrey Epstein, is in the same position as if he had been tried and
convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability
unto Plaintiff, Jane Doe.
49. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
and will in the future suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
other damages associated with Defendant's manipulating and leading her into a perverse and
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
suffer these losses in the future.
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
a jury.
Podhurst Orseck, P.A. 15
25 West Flagler Street, Suite 800. Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] 1 www.podhurstcom
EFTA02738129
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 16 of 19
COUNT SEVEN
(Cause of Action for Emitting in a Child Exploitation Enterprise pursuant to 18 U.S.C.
2255 in Violation of 18 U.S.C. 4 2252A(211
50. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 23 above.
51. Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise,
as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 USC § 2252A(g)(1). As more fully set
forth above in paragraphs 9 through 19, Defendant's actions involved countless victims and
countless incidents of abuse, and he committed those offenses against minors in concert with at
least three other persons.
52. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code.
53. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
and will in the future suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of ha privacy, and
other damages associated with Defendant's manipulating and leading her into a perverse and
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
suffer these losses in the future.
Podhurst Orseck, P.A. 16
25 West Hagler Street, Suite 600, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] I urrnv.podhuntcarn
EFTA02738130
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 17 of 19
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
a jury.
Date: April 17, 2009
Rob..4 6 WE Robert C. Joset 473: 4111o. 0408 56
Katherine W. Ezell, Bar No. 114771
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800
Miami, Florida 33130
([Phone Redacted]
([Phone Redacted] (fax)
riosefsbenfectodhurst.com
[Email Redacted]
Attorneys for Plaintiff
DEMAND FOR JURY TRIAL
Plaintiff demands to have her case tried before a jury.
Robert C. Josefs Bar No. 04\326
Katherine W. Ezell, Bar No. 114771
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800
Miami, Florida 33130
([Phone Redacted]
([Phone Redacted] (fax)
riosefsbergOnodhurst.com
[Email Redacted]
Attorneys for Plaintiff
C • kon
Podhurst Orseck, P.A. 17
25 West Flagler Street Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.podhurst com
EFTA02738131
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 18 of 19
%1844 (Rev. I V05) CIVIL COVER SHEET
The.IS 44 civil oowx sheet and the informationcontainedherein neither replace nor supplement the filing and senrice ofpleadings. or other paper...isrequited b) law, c,cepl a. pro% 'tied
• by kieal rules of court. This form, approved by theJudicial Conference of the United Sialcs in September 1974. is required for thc usc of the Clerk of Court liar the nurpownt
the civil docket aka. (SEE NSTRU(TIONS ON THE REVERSE OF THE FORM.) NOTICE: Attorneys MUST Indicate All Re -filed Cases Below.
I. (a) PLAINTIFFS
Jane Doe No. 101
(b) COunty Of Residence of First Listed Plaintiff West Palm Beach
(EXCEPT N VS. PIANTIEF CASES)
(C) Anomey's (Firm Name. Address. and Telephone Number)
Robert C. Josefsberg, Esq./Katherine W. Ezell, Esq.
Podhurst Orseck, P.A.
25 W. Flagler St., Suite 800
Minn RI
7'11t0
09_ cv so o s IT Mturra
(4) Check County Where Action Arose: O MIAMI- DADE 0 MONROE 0 BROWARD j1 PADA BEACH CI
DEFENDANTS
Jeffrey Epstein
County of Residence of Fall Listed Defendant RI**
(IN U.S. PLAINTIFF CA
2231 ..
D.G.
NOTE: IN LAND CONDEMNATION CASE USE THE LOCATION OF THE IRA
LANDINVOLVED
APR 1 Attorneys (Irks:mil
Jack A. Goldberger, Esq., Atterbury
Australian Ave., #1400, West Palm
STEVEN M. Lraimaii•E gal view of
rt •
C/ ST. LUCIE 0 INDIAN RIVER OKEECHOBEE
HIGHLANDS
II. BASIS OF JURISDICTION (rwe to-x- in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES(Pus ion"X" inOne Box for Plaintiff
For Diversity Can Only) and One Box for Defendant)
Cl I U.B. rtinerumcnt .07 I Petrel ()action PTV DEF PTV DEE
Plarmitt BLS. Government Noc a Petry) Citizen of Ibis State - I I Incorporated or Pntrapal Place 0 4 04
of Business In Thit Susie
O 2 U.S. Uovenimen
fktendant
0 4 Denny
(Indicate Citizenship of Parties in hem III)
citizen of Another State 1 2 O 2 Inaarnated and Pnrcinal Place 0 S 0 5
of Dulness In Another Slate
(manor Subject of a 1 3
Enna County
1 Foreign Nation O 6 0 6
- - - - - - - - - CONTRA(?- VORIS VORFEIRRUPENALTY BAMBRUPTCY OTHER STATUTES
0 'Inhume/ewe PERSONAL INJURY PERSONAL INJURY Cl 610 Apiculture 0 422 Appeal 28 USC 158 400 State Reapportionment
0 120 Mann.: El 310 Airplane 0 362 Pewits/ Injury- Cl 620 Other I ood & Drug 0 423 Withdrawal 410 Anling
II 130 Act 0 315 Airplane Ptodua Med. Matinntice 0 625 Drug Related Senn 28 USC 157 430 Banks and Bang:
0 140 Negotiable IllgrIllIK111 Liability Cl 365 Pawn Injury • or Property 21 USC *1 450 Commerce
0 150 Recovery of Overpayment 0120 Assauti. Libel & Pionct Liability 0 630 Liquor laws IM.:/t.it:iiit::ei ita 460 Depottation
& Enforcement of lodgment Slander 0 368 Asbestos Person 0 640R.R. A truck 0 820 Copynglry 470 Racketea Influenced and
0 151 Medicare Au 0 330 Federal Employers' Injury Product 0 650 Aidur Rego- Cl 830 Patna Camp Oryantrains
Liability Cl 152 Recovery of Dandled Liability 0 660 OccuPthowl Cl 840 I naksnadt *Genuine Creda
&Wen Lon 0 340 Marine PERSONAL PROPERTY Safely 1 Icon 490 Catkin TV
(Excl. Veterans) 0 345 Marine Proiluct 0 370 Other Fraud 0 690 Other 810 Selective Smite
0 153 Recncry of th elPran•ni Liability 0 371 Truk in Lending LABOR SOCIAL SECERIEY 850 SeastitiesCommalitin
of Vneran's Benerny 1 350 Mon kekkle 0 380 Other Pcnon 0 710 Fait labor Sunder& 0 861 HIA 113950 Etchange
1 1605yd:holders' Sun 0 355 Moor Vehicle Property Damage Act 0 862 Black Low (923) 875 Customer Clulkine
O 190 Other Comma Product Liability O 385 Property Damage 0 720 Lab:Odra. Malin 0 863 DIWUDIWW (405(01 12 USC 3410
1 195 Combo PrOdilel Liability 81 360 Other Peron Product Liability 0 730 LatenIgnis.Repatiryi 0 864 &SID Tide XVI 890 Other Suntory AMNIA
1 196 Franchise BNB & Disclosure Act 0 865 RSI (405(1/1 891 Agricultuial Ans
I REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS n 740 Railway 1-aboi An FEDERAL TAX SUDS 892 Economic Stabilisation Act
1 210 Land Condemnation 0 441 Violin 0 SIO Mot win to Vacate 1 790 Other Tan Litigation 0 870 Taws (U.S. Plaintiff 893 Environmental Maury
Cl 220 Foredoom 0 442 Finpinyrnenl Sentence 1 791 EmpI Ret. or Defendant) 894 Energy Allocation Act
0 230 Rent Lase & thscrinent 0 443 Housing Habeas Corpus: Sanity Act 1 871 IRS Ind Patty 895 Freedom of Intonation
0 240 Tons to Lan
CI 245 Tort Product Liabilky
Accoiranntstions
fl 444 Welfare
1 530 General
1 535 Death Penalty
26 USC 7609 Act
900 Appeal of Fee I/denim:um
0 290 All Other Real Property O 445 As.. vaDistibilins -
Eassonneo
1 540 Alandamus & Other
0 550 Chil Rights
Under Equal Access
toJustice
0 446 Amer wiDisatilines • 0 555 Poson Condition 0 950 Conntitionallry of
Caber Slaw Stains
Cl NOON Civil Rights
V. ORIGIN (Place an lr in One Box Only) Trans erred from
I °im& nd 2 Removed from 3 Rolled- n 4 Reinstated or O 5 anotha district • Proceeding State Cows (see VI birMul Reopened (Ifni Yl
Appeal 10 District
6 Muhidistrict O 7 Judge from
Magistrate
Judi:malt Litigation
VI. RELATED/RE-FILED
CASE(S). (See insauctions
second page):
a) Re-filed Case n YES 0 NO
JUDGE Kenneth A. Marra
b) Related Cases OYES O NO
DOCKET Scc Attached NUMBER
VII. CAUSE OF
ACTION
( i e the U.S. Civil Statute under which you are filing and Write a Brief Staletilent of Cause (IM not cite jurisdictional statutes unless
divinity):
IS U.S.C. 2255 (Predicate Statutes IS U.S.C. 2422(b), 2423(b), 2423(e). 2251, 2252, 2252A(aK I ). 2252A(g)( I)
and 159I)
LENGTH OF TRIAL via 4 days estimated (for both sides to try entire case)
O CHECK IF THIS IS A CLASS ACTION DEMANDS CHECK YES only if demanded in complaint:
JURY DEMAND: [ Yes P - No
VIII. REQUESTED IN
COMPLAINT: UNDER F.R.C.P. 23
ABOVE INFORMATION IS TRUE & CORRECT TO SIGNATl RE OF ArroaNtiv or RECORD
•
THE: BEST OF MY KNOWLEDGE (--3
DATE
01 Fon OFEICESsk Om
A MOI AT 4 2S Q. O RECEIPT
DV/7/0
EFTA02738132
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 19 of 19
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
WEST PALM BEACH DIVISION
ATTACHMENT TO CIVIL COVER SHEET
FOR: Jane Doe No. 101 v. Jeffrey Epstein
VI. RELATED/RE-FILED CASE(S):
08-80069
08-80119
08-80232
08-80380
08-80381
08-08804
08-80811
08-80893
08-80993
08-80994
08-80469
EFTA02738133