Court Records
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 1 of 27
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
JANE DOE No. 102,
Plaintiff,
VS.
JEFFREY EPSTEIN,
09-80656
Civil Action No.
CIV-RYSKA MP
MAGISTRATE JUDGE
VITUNAC
IFILED by 11:/3 D C
INTAKE
MAY - 12009
STEVEN a 4ARIMORE
Ca%U.S. OUST. CT
COMPLAINT AND
Defendant. DEMAND FOR JURY TRIAL
COMPLAINT AND DEMAND FOR JURY TRIAL
Plaintiff, Jane Doe No. 102, brings this Complaint against Defendant, Jeffrey Epstein,
and states as follows:
PARTIES. JUFtISDICIION, AND VENUE
1. At all times material to this cause of action, Plaintiff, Jane Doe No. 102, was a
resident of Palm Beach County, Florida.
2. This Complaint is brought under a fi ctitious name to protect the identity of
Plaintiff, Jane Doe No. 102, 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, 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.
Podhurst Orseck, P.A.
25 Wert Flagler Street, Suite 803, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.podhurstcom
EFTA02738734
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6. This Court has jurisdiction over 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(b), 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, spanning the
ages of 45 and 55 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, as well as a fleet of motor vehicles. 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," a 70-acre private island known as Little St. James in St. , U.S. Virgin Islands, a
mansion in London's Westminster neighborhood, and a home in the Avenue Foch area of Paris.
The allegations herein concern Defendant's conduct while at his lavish homes and/or numerous
other locations both nationally and internationally.
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 to countless
vulnerable and relatively economically disadvantaged minor girls, and sexually assaulted,
molested, and/or exploited these girls, and then gave them money.
10. Beginning in or around 1998 through in or around September 2007, Defendant
used his resources and his influence over vulnerable minor girls to engage in a systematic pattern
of sexually exploitative behavior.
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800, Miami, F133130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale 954.4(6.4346 www.podhursteorn
EFTA02738735
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II. Defendant's plan and scheme reflected a particular pattern and method.
Defendant coerced and enticed impressionable, vulnerable, and relatively economically less
fortunate minor girls 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 and/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 call economically disadvantaged and underage girls from West
Palm Beach and surrounding areas who would be enticed by the money being offered 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 12 years old, were transported to Defendant's Palm Beach
mansion by Defendant's employees, agents, and/or assistants in order to provide Defendant with
"massages."
12. 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 with and/or without their
knowledge. Defendant would pay the procurer of each girl's "appointment" hundreds of dollars.
3
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted]
EFTA02738736
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 4 of 27
13. Epstein designed this scheme to secure a private place in Defendant's Palm Beach
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
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 Palm Beach 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 six homes and/or on his computers.
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 and/or the other female would direct the girl to massage him, giving the minor girl
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 vulva,
vagina, and/or anus with a vibrator and/or back massager and/or his finger(s) and/or his penis,
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 and/or
4
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Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 5 of 27
enticing the then minor girl to engage in sexual acts with another female in Defendant's
presence. The exact degree of molestation and frequency with which the sexual exploitations
took place varied and is not yet completely known; however, Defendant committed such acts
regularly on a daily basis and, in most instances, several times a day. In order to facilitate the
daily exchanges of money for sexual assault and abuse, Defendant kept U.S. currency readily
available.
16. Defendant, Epstein, traveled to his mansion in Palm Beach for the purpose of
luring minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to
contact these minor girls for the purpose of coercing them into acts of prostitution and to enable
himself to commit sexual battery against them and/or acts of lewdness in their presence, and he
conspired with others, including assistants and/or his driver(s) and/or pilot(s), and his socialite
friend/partner, Ghislaine Maxwell, to further these acts and to avoid police detection.
Defendant's systematic pattern of sexually exploitative behavior referred to in paragraph 10 and
described in paragraphs I 1 through the present paragraph occurred in all of Defendant's
domestic and international residences and/or places of lodging and/or modes of transportation.
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.
A vulnerable young girl, Plaintiff was working as a changing room assistant at The Mar-A-Lago
Club in Palm Beach making approximately S9 an hour when she was first lured into Defendant's
sexually exploitative world. In or about the summer of 1998, when Plaintiff was merely fifteen
years old while attending to her duties at Mar-A-Lago, Plaintiff was recruited by Ghislaine
Maxwell, who lived, traveled, socialized, and worked with Defendant. Ms. Maxwell asked
Plaintiff if she was interested in learning massage therapy and earning a great deal of money
while learning the profession. Plaintiff's father, who was a maintenance manager at The Mar-A-
5
Podhurst Orseck, P.A.
25 West Flagler Street Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] I www.podhurst.com
EFTA02738738
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Lago Club, was not apprehensive because he felt comforted that an older woman had approached
Plaintiff with this opportunity. As a result, Plaintiffs father dropped off Plaintiff at Defendant's
mansion that same day. Ms. Maxwell met Plaintiff and her father outside of Defendant's Palm
Beach mansion, where Ms. Maxwell assured the minor girl's father that Ms. Maxwell would
provide transportation home for his teenaged daughter. Ghislaine Maxwell led Plaintiff up a
flight of stairs to a spa room with a shower and a massage table. Defendant was lying naked on
the massage table. Plaintiff was shocked, but, with no experience with massages, thought this
could be massage therapy protocol. Ms. Maxwell then took off her own shirt and left on her
underwear and started rubbing her breasts across Defendant's body, impliedly showing Plaintiff
what she was expected to do. Ms. Maxwell then told Plaintiff to take off her clothes. The minor
girl was apprehensive about doing this, but, in fear, proceeded to follow Ms. Maxwell by
removing everything but her underwear. She was then ordered to remove her underwear and to
straddle Defendant. The encounter escalated, with Defendant and Ms. Maxwell sexually
assaulting, battering, exploiting, and abusing Plaintiff in various ways and in various locations,
including the steam room and shower. At the end of this sexually exploitive abuse, Defendant
and Ms. Maxwell giddily told Plaintiff to return the following day and told her she had "lots of
potential." Defendant paid Plaintiff hundreds of dollars, told her it was for two hours of work,
and directed one of his employees to drive her home.
18. Defendant and/or his procurers thereafter lured the then minor Plaintiff to his
Palm Beach mansion every day for the next two weeks in order to engage in a similar pattern of
sexual exploitation. Defendant and/or his procurers arranged at the end of each incident the
transportation and scheduling for the following day's appointment. Additionally, Defendant
telephoned the minor Plaintiff himself and/or had Ms. Maxwell telephone Plaintiff to make
arrangements. Plaintiff was often times driven to and from Epstein's mansion by Epstein
6
Podhurst Orseck, P.A.
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EFTA02738739
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 7 of 27
himself or his driver. Alternatively, Defendant or Ms. Maxwell would arrange and pay for
Plaintiff's transportation home by taxicab.
19. During Plaintiff's second incident of being sexually exploited and assaulted by
Defendant at Defendant's Palm Beach mansion, Defendant asked Plaintiff to quit her job at The
Mar-A-Lago Club and travel with him to earn much more money while ►earning the massage
profession. Thus, Plaintiff, an impressionable and vulnerable young girl of modest means, quit
her job as a changing room assistant, was lured by Defendant, and continued to be victimized by
Defendant, who immersed the minor Plaintiff into Defendant's lewd and abusive lifestyle.
Under Defendant's dominion and control, Defendant continuously "groomed" the minor
adolescent. Defendant's daily routine required the minor Plaintiff to perform sexually on
Defendant multiple times per day and to provide Defendant massages multiple times per day.
Plaintiff had absolutely no say as to when, how many times, or what was done during each
sexual encounter. Often, Plaintiff was joined by Ms. Maxwell, Ms. Maxwell's assistant, and/or a
countless array of young women who would be brought to one of Defendant's homes for the
sexual trysts and then be sexually exploited by Defendant.
20. The first time that Defendant transported Plaintiff to another state in order to
engage in sexual acts with her occurred when she was merely fifteen years old and after only two
weeks of daily sexually abusive encounters with Defendant. Defendant used his private jet to
transport the minor Plaintiff to Manhattan, where he provided her with spending money and
accommodations with him at his mansion. From the time that Plaintiff was 15 years old,
Defendant abused her to serve his every sexual whim, obtaining and purchasing passports and
whatever was needed for her to travel with him and/or for him. Defendant transported Plaintiff
in his private jet to locations that included Palm Beach, New York City, Santa Fe, Los Angeles,
San Francisco, St. Louis, and numerous other domestic destinations, as well as international
7
Podhurst Orseck, P.A.
25 Weal Flagler Street. Suite 800, Miami, FL 33130. Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.podhurst com
EFTA02738740
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 8 of 27
destinations, including Europe, the Caribbean, and Africa. He provided accommodations with
him in order to have her available to him at all times wherever he went, including while
transporting the minor Plaintiff on his private jet. Each time they would travel to one of these
destinations, the same pattern of sexual abuse would occur, often with a vast array of aspiring
models, actresses, celebrities, and/or other females, including minors, from all over the world.
Upon information and belief, Defendant transported minor girls from Turkey, the Czech
Republic, Asia, and numerous other countries, many of whom spoke no English. To Plaintiff's
knowledge, the only females specifically excluded from Defendant's sexual escapades were
African-Americans.
21. In addition to being continually exploited to satisfy Defendant's every sexual
whim, Plaintiff was also required to be sexually exploited by Defendant's adult male peers,
including royalty, politicians, academicians, businessmen, and/or other professional and personal
acquaintances. Whenever Defendant transported Plaintiff with him in
destination, Defendant would pay Plaintiff a flat rate per day while
mentioned associates would sexually exploit and abuse minor Plaintiff.
22. Most of these acts of abuse occurred during a time when Defendant knew that
Plaintiff was approximately 15, 16, and 17 years old, and, after years of daily sexual exploitation,
continued into her adulthood. Despite Defendant's stating shortly before Plaintiff's sixteenth
birthday that he soon would have to trade her in because she was getting too old, Defendant
continued to sexually exploit Plaintiff until she fed at age 19. Defendant's predilection for
young girls was well known to those who regularly procured them for him and to his circle of
friends. On one of Defendant's birthdays, a friend of Defendant sent him three 12-year-old girls
from France who spoke no English for Defendant to sexually exploit and abuse. After doing so,
they were sent back to France the next day.
8
his private jet to any
he and/or his above-
Podhurst Orseck, P.A.
25 West Flagler Street Suite 800. Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] orww.podhurstcom
EFTA02738741
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 9 of 27
23. Any assertions by Defendant that he was unaware of the age of the then minor
Plaintiff are belied by 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. Defendant and Ms. Maxwell acknowledged and celebrated Plaintiff's
I6th birthday. Defendant's preference for underage girls was well-known to those who regularly
procured them for him.
24. As previously stated in paragraph 14, Defendant displayed nude photographs of
underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S.
Virgin Islands. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each of
Defendant's homes, including a photograph of herself naked at Defendant's home in Palm
Beach. When she asked Defendant about it, he stated dismissively that he had naked photographs
of her in all of his homes.
25. Upon information and belief, some of the photographs in Defendant's possession
were taken with hidden cameras set up in 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 may have taken lewd photographs
of Plaintiff, Jane Doe No. 102, 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 and/or foreign commerce. In addition, while Plaintiff was a
minor teenager and upon Ms. Maxwell's insistence after Ms. Maxwell rejected as inappropriate
photographs that Plaintiff presented of herself fully clothed, Ms. Maxwell photographed Plaintiff
naked in different sexually explicit positions. Ms. Maxwell then presented these nude
photographs of Plaintiff to Defendant as a birthday present for Defendant from Ms. Maxwell.
9
Podhurst Orseck, P.A.
25 West Hagler Street. Suite 800, Miami. FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] I
EFTA02738742
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 10 of 27
Upon information and belief, one or more nude photographs of Plaintiff that were taken when
she was a minor were confiscated by the Palm Beach Sheriff's Office during its execution of a
search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information
and belief, those photographs are still in the custody of law enforcement.
26. It is virtually impossible to calculate the exact number of times that Defendant
sexually exploited and abused Plaintiff. From the age of IS, Plaintiff was sexually exploited and
abused by Defendant on a daily basis and, most often, multiple times each day. While some of
the precise dates these acts occurred are unknown to Plaintiff, these dates are known to
Defendant, as he is reported to have kept a written log of each instance in which he engaged in
these lewd acts with then minor Plaintiff and others. Upon information and belief, these logs are
also in the custody of law enforcement.
27. In or around September 2002, Defendant purchased a commercial round-trip
airline ticket, and provided a passport, U.S. currency, and accommodations for Plaintiff to fly to
Thailand. While thousands of miles away from Defendant on this extended trip alone for the
first time in more than four years, Plaintiff met, fell in love, and married a young man. She
escaped from Defendant's abuse with the help and insistence of her new husband and, instead of
returning to Defendant, boarded a plane to Australia with one suitcase.
28. Since November 2002, Plaintiff has lived a modest life in Australia, while
maintaining lines of communication with her family and without contact with Defendant or any
of the people in his entourage. However, suddenly, in 2008, Plaintiff received numerous phone
calls from one of Defendant's agents. During these phone calls to Plaintiff, he repeatedly asked
whether she knew anything about the civil cases against Defendant, whether she knew any of the
females who were proceeding with the civil suits, whether she was planning on filing suit,
whether she was communicating and/or cooperating with anyone against Defendant, and whether
10
Podhurst Orseck, P.A.
9% Weal Flavin Perm. GS* ➢M Miami PI MI VI Miami ins MA MITI Pay Mg 150. '12' • Pawl ..Aswiela OSA Siti ALA
EFTA02738743
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 11 of 27
she would return to the United States to testify. Terrified by Defendant's demonstrated ability to
track her down on her changed cell phone number halfway across the world, Plaintiff attempted
to reassure Defendant's agent that she would remain quiet. During the course of one of these
phone calls from Defendant's agents, Defendant himself spoke on the phone, continued to
question her intentions, and, upon being reassured by Plaintiff, thanked her for not getting
involved.
29. Around January 2009, Plaintiff received a letter from the United States Attorney's
Office for the Southern District of Florida, informing her of her potential civil claims against
Defendant under 18 U.S.C. § 2255. Plaintiff contacted undersigned counsel within days and
diligently and repeatedly pursued a good faith viable settlement of her claims against Defendant.
Unable to reach a settlement, this lawsuit followed.
30. As a result of these encounters with Defendant, Plaintiff, Jane Doe No. 102, has in
the past suffered, and will in the future continue to 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, separation from her family, and other damages associated with
Defendant's controlling and manipulating her on a daily basis Sr years into a perverse and
unhealthy way of life.
31. Defendant, Jeffrey Epstein, committed the above-referenced acts upon 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
I
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] I podburst com
EFTA02738744
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in 18 U.S.C. § 2421, § 2422(a), § 2422(b), § 2423(a), § 2423(b), § 2423(e), § 2251, § 2252, §
2252A(a)(1), and § 2252A(gX1).
32. In June 2008, 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 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, must
admit liability unto Plaintiff, Jane Doe No. 102. 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 Enzaze in Prostitution or
Sexual Activity pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. & 2422(13))
33. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, reallcges, and incorporates by
reference the allegations contained in paragraphs I through 32 above.
34. Defendant, Jeffrey Epstein, used a facility or means of interstate and/or foreign
commerce to knowingly persuade, induce, entice, or coerce Jane Doe No. 102, 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, or attempted to do so, pursuant to 18 U.S.C. § 2255 in
violation of 18 U.S.C. § 2422(b).
35. Plaintiff, Jane Doe No. 102, 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.
12
Podhurst Orseck, P.A.
25 Wet Flagler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax 305.358Z182 • Fort Lauderdale [Phone Redacted] WWW.p0C8011XLCOITI
EFTA02738745
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36. 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 continue to 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,
separation from her family, 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 No. 102, 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 Transportation of Minor with Intent to Engage in Criminal Sexual
Activity pursuant to 18 1:.S.C.$ 2255 in Violation of 18 U.S.C. & 2423(a)1
37. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 32 above.
38. Defendant, Jeffrey Epstein, knowingly transported then minor Plaintiff, Jane Doe
No. 102, in interstate and/or foreign commerce, with the intent that Plaintiff engage in
prostitution, or in any sexual activity for which any person can be charged with a criminal
offense, in violation 18 U.S.C. § 2423(a). As previously stated in paragraphs 20, 21, and 27,
13
Podhurst Orseck, P.A.
25 West Elegies Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] I www.podhwattom
EFTA02738746
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 14 of 27
Defendant transported Plaintiff, Jane Doe No. 102, across state lines and across international
borders numerous times from the time that Plaintiff was merely 15 years old through adulthood
with the primary intent of sexually exploiting her.
39. Plaintiff, Jane Doe No. 102, 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.
40. 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 continue to 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,
separation from her family, and other damages associated with Defendant's manipulating and
leading her into a perverse and unhealthy way of life for a minor. 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 No. 102, 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.
14
Podhurst Orsecic, P.A.
25 West Hagler Street, Suite SO O, Mami e FL 33130, Nand 305.35BM00 Fax 305.35442382 • Fort Lauderdale [Phone Redacted] www.podhurstcom
EFTA02738747
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 15 of 27
COUNT THREE
(Cause of Action for Travel with Intent to Eneaee in Illicit Sexual Conduct pursuant to 18
U.S.C. 8 2255 in Violation of 18 U.S.C. 6 2423(b11
41. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 32 above.
42. Upon information and belief, Defendant, Jeffrey Epstein, traveled in interstate
and/or foreign commerce with the intent to engage in illicit sexual conduct, as defined in 18
U.S.C. § 2423(f), with minor females, including the then minor Plaintiff, in violation of 18
U.S.C. § 2423(b).
43. Plaintiff, Jane Doe No. 102, 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.
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 continue to 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,
separation from her family, 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 No. 102, demands judgment against Defendant,
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation,
15
Podhurst Orseck, P.A.
25 West Flagler Street Suite 800, Muni, FL 33130, Muni [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.px1hursteom
EFTA02738748
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 16 of 27
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 Coercion and Enticement to Emu in Prostitution or Sexual Activity
pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. & 2422(a)1
45. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs I through 32 above.
46. Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, and/or
coerced Jane Doe No. 102 to travel in interstate and/or foreign commerce to engage in
prostitution and/or sexual activity for which any person can be charged with a criminal offense,
or attempted to do so, pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(a).
47. Plaintiff, Jane Doe No. 102, 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. 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 continue to 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,
separation from her family, 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
16
Podhurst Orseck, P.A.
25 West Ragler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] envw.podhurst.com
EFTA02738749
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 17 of 27
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 No. 102, 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 FIVE
(Cause of Action for "Transportation with Intent to Enzaze in Criminal Sexual Activity
pursuant to 18 U.S.C. Ft 2255 in Violation of 18 U.S.C. 24211
49. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 32 above.
50. Defendant, Jeffrey Epstein, knowingly transported, or attempted to transport,
Plaintiff, Jane Doe No. 102, in interstate and/or foreign commerce, with the intent that Plaintiff
engage in prostitution and/or in any sexual activity for which any person can be charged with a
criminal offense, in violation of 18 U.S.C. § 2421. As previously stated in paragraphs 20, 21,
and 27, Defendant transported Plaintiff, Jane Doe No. 102, across state lines and across
international borders numerous times from the time that Plaintiff was merely 15 years old
through adulthood with the primary intent of sexually exploiting her.
51. Plaintiff, Jane Doe No. 102, 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.
52. 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 continue to suffer, physical injury, pain and suffering, emotional distress,
17
Podhurst Orseck, P.A.
25 West Flagler Street. Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax 3(5358.2382 • Fort Lauderdale [Phone Redacted] I www.podhuxstcom
EFTA02738750
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 18 of 27
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,
separation from her family, and other damages associated with Defendant's manipulating and
leading her into a perverse and unhealthy way of life for a minor. 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 No. 102, 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 Sexual Exploitation of Children pursuant to 18 U.S.C. ti 2255 in
Violation of 18 U.S.C. $ 22511
53. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, rcalleges, and incorporates by
reference the allegations contained in paragraphs 1 through 32 above.
54. Defendant. Jeffrey Epstein, knowingly persuaded, induced, enticed, or coerced the
then minor Plaintiff 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, 24, and 25, Defendant kept and displayed a myriad of nude photographs of underage girls
throughout his homes, including his homes in New York City, Palm Beach, Santa Fe, and the
U.S. Virgin Islands. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each
of Defendant's homes, including a photograph of herself naked at Defendant's home in Palm
18
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale 954A63.4346 www.podhurstcom
EFTA02738751
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 19 of 27
Beach. Upon information and belief, many of the photographs in the possession of Defendant
were taken with hidden cameras set up in 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 No. 102, 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 and/or foreign commerce. Upon information
and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were
confiscated by the Palm Beach Sheriff's Office during its execution of a search warrant of
Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those
photographs are still in the custody of law enforcement.
55. Plaintiff, Jane Doe No. 102, 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.
56. 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 continue to 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,
separation from her family, 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
19
Podhurst Orseck, P.A.
75 Weci Flaalrr Strpnt Snit. Rill. Miami. FI .11110 Miami inc 158 Mil Fay 105 MA 71R? • Fnrt l andeniale 954 4fil 414A www reflefhlITOrlIT
EFTA02738752
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 20 of 27
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 No. 102, 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 SEVEN
(Cause of Action for Transport of Visual Depiction of Minor Enenine in Sexually Explicit
Conduct pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. & 2252(a)f1D
57. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 32 above.
58. Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via
computer and/or facsimile in or affecting interstate and/or foreign commerce at least one visual
depiction of the minor Plaintiff engaging in sexually explicit conduct, in violation of 18 U.S.C. §
2252(O1). As previously stated in paragraphs 14, 24, and 25, Defendant displayed a myriad of
nude photographs of underage girls throughout his homes, including his homes in New York
City, Palm Beach. Santa Fe, and the U.S. Virgin Islands. Plaintiff, Jane Doe No. 102, saw
photographs of naked young girls in each of Defendant's homes, including a photograph of
herself naked as a minor at Defendant's home in Palm Beach. As previously stated in paragraph
24, Defendant told Plaintiff that he had photographs of her naked in all of his homes. 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 nude photographs of underage girls on a computer in Defendant's
home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd
20
Podhurst Orseck, P.A.
' Wm. Plantar Groat Gnat. grin Miami Ll Min Miami Inc Ara 7Rnil Per 7111, • Part I ertelawiela Orul. AAA 1144 la/WYE ralitliPS4 "Omen
EFTA02738753
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 21 of 27
photographs of Plaintiff, Jane Doe No. 102, 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 and/or foreign commerce. Upon information and belief,
one or more nude photographs of Plaintiff that were taken when she was a minor were
confiscated by the Palm Beach Sheriff's Office during its execution of a search warrant of
Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those
photographs are still in the custody of law enforcement.
59. As previously stated in paragraph 23, any assertions by Defendant that he was
unawarc 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. Defendant's preference for underage girls
was well-known to those who regularly procured them for him.
60. Plaintiff, Jane Doe No. 102, 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.
61. 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 continue to 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,
separation from her family, 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
21
Podhurst Orseck, PA.
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.podhurstcom
EFTA02738754
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 22 of 27
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 No. 102, 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 EIGHT
(Cause of Action for Transport of Child Pornoeraphv pursuant to 18 U.S.C. & 2255 in
Violation of 18 U.S.C. 4 2252A(a)(1)1
62. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 32 above.
63. Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via
computer and/or facsimile in or affecting interstate and/or foreign commerce child pornography
in violation of 18 U.S.C. § 2252A(a)(1).
64. Plaintiff, Jane Doe No. 102, 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.
65. 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 continue to 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,
separation from her family, and other damages associated with Defendant's manipulating and
22
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.poclhurst.com
EFTA02738755
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 23 of 27
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 No. 102, 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 NINE
(Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to 18 U.S.C.
2255 in Violation of 18 U.S.C. 4 2252A(2)1
66. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 32 above and Counts One through
Eight above.
67. Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise,
as defined in 18 U.S.C. § 2252A(gX2), in violation of 18 U.S.C. § 2252A(gX1). As more fully
set forth above, Defendant engaged in actions that constitute countless violations of 18 U.S.C. §
1591 (sex trafficking of children), Chapter 110 (sexual exploitation of children in violation of 18
U.S.C. §§ 2251, 2252(a)(1), and 2252(AXaX1)), and Chapter 117 (transportation for illegal
sexual activity in violation of 18 U.S.C. §§ 2421, 2422, and 2423). As more fully set forth above
in paragraphs 9 through 32, Defendant's actions involved countless victims and countless
separate incidents of sexual abuse, which he committed against minors, including Plaintiff, in
concert with at least three other persons.
23
Podhurst Orseck, P.A.
25 West Hagler Street Suite 800, Miami, F1.33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.podhunt.com
EFTA02738756
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 24 of 27
68. Plaintiff, Jane Doe No. 102, 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.
69. 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 continue to 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,
separation from her family, 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 No. 102, 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: May 1, 2009
Cu-x ! Pirs44—s-lre.•6. _12 E Robert C. JosefsWerg, Bar No. 0408563
Katherine W. Ezell, Bar No. 114771
Podhurst Orseck, P,A.
25 West Flagler Street, Suite 800
Miami, Florida 33130
([Phone Redacted]
([Phone Redacted] (fax)
riosefsberiapodhurst.com
24
Podhurst Orseck, P.A.
25 West Hagler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.podhuracorn
EFTA02738757
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 25 of 27
kezelltilpodhurst.corn
Attorneys for Plaintiff
DEMAND FOR JURY TRIAL
Plaintiff demands to have her case tried before a jury.
8660 • fr it-kk-Zr
Robert C. Josetnerg, Bar No. 040856
Katherine W. Ezell, Bar No. 114771
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800
Miami, Florida 33130
([Phone Redacted]
([Phone Redacted] (fax)
rjosefsberg (podhurst.com
kezellApodhurst.com
Attorneys for Plaintiff
25
Podhurst Orseck, P.A.
25 West Flagkr Street, Suite 800. Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] I www.podhurst.com
EFTA02738758
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 26 of 27
*LIS 44 (Ren. II L05) CIVIL COVER SHEET
ThelS44civil cover sheet and the information contained herein neither repbee nor supplement the filing ard service of pleadings or other papas as required by law, except as provided
by local rules of coon. This form, approved by the Judicial Conference of the United States in September 1974. is matured for the use of the Clerk of Court for the purpose of initiating
the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) NOTICE: Attorneys MUST Indicate AD Re4lIed Cases Below.
I. (a) PLAINTIFFS
Jane Doe No. 102
(b) County of Residetwe of First Listed Plaintiff West Palm Beach
(EXCEPT IN US. PLAINTIFF CASES/
(C) Attorney's (Finn Name. Address. and Telephone Number)
Robert C. Josefsberg, Esq./Katherine W. Ezell, Esq.
Podhurst Orseek, P.A.
25 W. Flagler St., Suite 800
/Jinni FI OR — — 80(0 S
(d)Check County Where Action Arose. 1 MIAMI DWI- 1 MO NROE 1 nup
s 41.
DEFENDANTS
Jeffrey Epstein
County of Residence of PS Listed Defendant West Palm Beach
NOTE: IN LAND CONUNDEMUS NPLAATIIONNTICE/WaSOCZ:tifi Lul 41 1tACT
LAND INVOLVED. 1
AttorrieyS (If Known)
y 1 2009 Jack A. Goldberger, Esq., AtterburS Gold ger, et al., 250 S.
L AY • I JJ
Australian Ave., 111400. West Palm'BeattlIkFLN3.840.1MIWRobett
D 45 PALM BEACH O 0 ST. LUCIE 1 INDISIERLIREIFLIO LOISICHGlitg
CLEM" E. Geer r I
HIGHLANDS nate.
(him an "X - in One Box Only)
Federal Question
Ill. ClT0! Zornity
0.
SHIP 004')PRINCIPAL PARTIESinue an-X- or in One Box f Plaintiff
iF and One Box for Defeedere)
L/ PTV DE PIT DEF
(U.S Cowman Not a Party) Citizen of This State I I hmorporated or Principal Place
of Business In This State
1 4 34
Divenity Citizen ofAnother State 0 2 0 2 Inompormed and Pommel Place
of Burin In Another Stew
0 5 0 5
(Indicate Csizeaship of Panics w Item III)
Citizen or Subject of a 1 3 1 3 Foreign Nation O 6 0 6
Foreign Country
II. BASIS OF JURISDICTION
fl I US. Cos (Trento< /13
Plaintiff
0 2 US Covernment 0 4
Defendant
1
_
CON tet Inas FORFEITURE/PENALTY BANKRUPTCY OTHER SIAITTEN I
110 Innuence
120 Marine
130 IIIIINct
140 Negotiable Instrument
150 ROOM ely of Oveirayerent
& F.nforeement of hdpitent
151 Mecham Act
132 Recovery of Defaulted
Studere Lam
(Excl. Veterans)
0 133 Recovery of Ovapiamm
of Veteran's Benefits
0 160 Sackholders' Suits
0 1900T/ter Contract
0 195 Comma Product Liability
0 196 Franchise
PERSONAL INJURY PERSONAL INJURY
0 310 Milan 0 362 Personal Injury •
0 315 Aiffiline holm Med. Molar/Mitt
Liability 0 365 Personal Injury-
0 320 Assault-Lk/el A Product Liability
Slander 0 364 Asbenos Perini
1 330 Federal Employai 'May Proekrt
Liability liabdity
0 MOMmine PERSONAL PROPERTY
0 345 Menne Product 0 370 Other Fnigl
Liability 0 371 Truth in Leading
0 350 Motor Vehicle I 380 Odin Penonal
0 155 Motor Vehicle Property Dansage
Predua Liability 0 385 Promo). Damage
Ell 360 Other Personal Product Liability
10107
0 off/Agriculture
0 620 Other Food di Drug
3 625 Drug Related Seizure
of hoped): 21 USC Mil
0 630 Liquor Laws
0 640 R.R. & Tack
0 650 Airline Rep.
0 660 Occupational
Salayffiealth
3 690 War
0 422 Appeal 28 USC 158
n 423 Withdrawal
28 USC 07
400 State ReaMonooment
410 Anomm
430 Banks and Banking
430 Commerce
460 Detonation
470 Ractewer Influenced and
Comp Organizations
480 Consumer Credit
490 CabloSte TV
810 Sekaive Service
850 SearliesCommoditiew
Exchange
875 Ctatoma Challenge
12 USC 3410
890 Other Statutory Actions
891 Agricultural Acts
892 Economic Smbiliration Act
893 Emironrnental Niemen
894 Energy Allocation Act
895 Frtedom of Inkontswo
Act
900Atpeal of Fee Uncut: ration
Under Equal ACCess
to Justice
0 950 Caentiheionality of
Stale Statutes
PROP* ll IL RIGHTS
3 420 Copyrigkes
3 830 Piece
El 840 Tack:matt
LABOR SOCIAL SECURITY
1861111A 1139518
0 862 Black Lung (923)
0 863 DIWC/DIWW (40500)
0 864 SSW Title XVI
0 865 R51(405(0)
0 710 Fair tabor Standards
Ad
0 720 LabooMgmt. Religions
0 730 LaboriMgmt.Repotting
a Disclosure Act
0 740 Railway Labor Act
O 790 Other Lake Litignioa
0 791 Empl. Mint.
Sonny Act
FEDERAL TAX SUITS ) REAL PROPERTY Civil. RIGHTS PRISONER PETITIONS
0 870 fates (U.S. Plaintiff
or Defining)
0 871 IRS— Wed Patty
26 DSC 7609
0 2101*nd Condemnation
0 220 Foreekson
0 230 Rent Lease & Erectment
O 240 Tons to l aM
O 245 Ton Product Liabiliry
O 290 All Other Real Prom"
0 441 Voting
0 442 Employment
0 443 Homing:
Accommodations
0 444 Welfare
0 445 Amer. wiDisabilities •
Fritts:new
0 446 Ames wThweilities •
Other
3 440OtherCivil Rights
1 510 /Imam to Vacate
Sereenx
Habeas t orpui:
1 510 General
1 535 Death Penalty
1 540 Slant:onus & Other
fl 550 Covut It 'glom
1 555 Cram tondo ion
V. ORIGIN (Place 'X" istOise Box (My)
2 1 1 Off &Sl ing 2 Rammed from 3
to Court
Heated- O 4 'MINUS of 0 5 mTransferreauler
pisigjad from O Multidistrict
(see VI beim) Reopened Opeci Litigation
Appeal to District
CI tAgn fmm
' Magtsttalc
lodgment
VI. RELATED/RE-FILED
CASE(S). (See iamuctions
leCald Pate):
a) Re-Pled Case O YES 0 NO
JUDGE Kenneth A. Marra
b) Related Cases OYES 0 NO
DOCKr I See Attached NUMBER
VII. CAUSE OF
ACTION
Cie the U.S. ('Iva Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless
diversity):
18 U.S.C. 2255 (Predicate Statutes 18 U.S.C. 2422(b). 2423(8), 2423(e), 2251, 2252, 2252A(a)(1), 2252A(g)( I)
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 'n complaint:
JURY DEMAND: [$ Yes 11 No
VIII. REQUESTED IN
COMPLAINT: UNDER F.R.C.P. 23
ABOVE INFORMATION IS TRUE & CORRECT TO
TILE BEST OF MY KNOWLEDGE
SIG. TURE OIATTORNLY try 0
P2 1 Et0143:: USE Olt."
A.AIOUN4 SY ). RECEIPTS
DC1O I /C;(7
DATE
5 ) el 9
EFTA02738759
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 27 of 27
UNITED STATES DISTRICT COURT
SOUTIIERN DISTRICT OF FLORIDA
WEST PALM BEACH DIVISION
ATTACHMENT TO CIVIL COVER SHEET
FOR: Jane Doe 10tv. Jeffrey Epstein
VI: RELATED/RE-FIELD CASE(S):
08-80069
08-80119
08-80232
08-80380
08-80381
08-08804
08-80811
08-80893
08-80993
08-80994
08-80469
09-80591
EFTA02738760