Court Records
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 1 of 19
ave„ (al 03/e4/0
Sealed IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Civil Action No.
1 0 - 8 0 3 0 9 JANE DOE No. 103,
Plaintiff,
v.
JEFFREY EPSTEIN,
Defendant.
FILED by ?PM D.C.
FEB 2 3 2010
STEVEN M. LARIMORE CLERK LI 01ST CT
S. D. at FLA. • MIAMI
COMPLAINT AND DEMAND FOR JUR\ TRIAL
Plaintiff, Jane Doe No. 103 ("Plaintifff'), brings this Complaint against Defendant, Jeffrey
Epstein ("Defendant"), and states as follows:
PARTIES. JURISDICTION, AND VENUE
1. At all times material to this cause of action, Plaintiff was a resident of Palm Beach
County, Florida.
2. This Complaint is brought under a fictitious name to protect the identity of
Plaintiff 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 owned a residence located
at 358 El Brillo Way, Palm Beach, Palm Beach County, Florida.
4. Defendant is presently a citizen of the United States Virgin Islands. Pursuant to
the plea agreement entered by the Defendant in state court and the sentencing which occurred on
June 30, 2008, Defendant is currently under community control in Palm Beach County, Florida.
Podhurst Orseck, P.A.
25 West Hagler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted]
EFTA02739126
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 2 of 19
5. Defendant is an adult male born on January 20, 1953.
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 was an adult male spanning the ages of 45 and 55
years old. Defendant 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 pursuant to the plea entered and
sentencing, which occurred on June 30, 2008, he maintained his principal place of residence in
the largest dwelling in Manhattan, a 51,000-square-foot eight-story mansion on the Upper East
Side. 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
the U.S. Virgin Islands, a mansion in London's Westminster neighborhood, and another
residence in the Avenue Foch area of Paris. The allegations herein concern Defendant's conduct
while at his lavish residence in Palm Beach and numerous other locations both nationally and
internationally.
9. 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.
Podhurst Orseck, P.A. 2
25 West Hagler Stritet. Suite 800. Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] t www.podtunt.com
EFTA02739127
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 3 of 19
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.
11. 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 underage girls. 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
14 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 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 assist Defendant in taking nude photographs
Podhurst Orseck, P.A. 3
25 West Flagler Street, Suite 800, Miami, FL 33130, Miunt [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] 1 www.podlwrattorn
EFTA02739128
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 4 of 19
and/or videos of the underage girls with and/or without their knowledge. Defendant would pay
the procurer of each girl's "appointment" hundreds of dollars.
13. Defendant designed this scheme to secure a private place in Defendant's Palm
Beach mansion where only persons employed and invited by Defendant would be present, so as
to reduce the chance of detection of Defendant's sexual abuse and/or exploitation, 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 employee(s),
agent(s), and/or assistant(s) and/or by taxicab(s) and/or motor vehicle(s) paid for by Defendant,
which also made it difficult for the girls to flee his mansion.
14. Upon her initial 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 be led up a remote flight of stairs to a
room that contained a massage table and a large shower.
15. At times, if it was the girl's first "massage" appointment, another female would
be in the room to "lead the way." Generally the other female would leave, or Defendant would
dismiss her. Often, 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. Defendant 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, back massager,
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
Podhurst Orseck, P.A. 4
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] I www.podhurst.com
EFTA02739129
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 5 of 19
w.
prostitution and/or 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 traveled out of Florida to 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 his employee(s), assistant(s), driver(s), pilot(s), and/or agent(s), to
facilitate these acts and to avoid police detection. Defendant's systematic pattern of sexually
exploitative behavior described above also occurred in Defendant's other domestic and/or
international residences, 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 merely a seventeen year old high school student when she
was first lured into Defendant's sexually exploitative world in or about January 2004. Plaintiff
was recruited while at work by a co-worker, one of the minor victims Defendant paid to procure
underage females. Plaintiff went to Defendant's Palm Beach mansion accompanied by this co-
worker. Upon arriving, Plaintiff was led by one of Defendant's assistants up a flight of stairs to a
spa room with a shower and a massage table. Defendant entered this room wearing only a towel.
Defendant suddenly removed his towel, exposing his naked body, and then lay on the massage
Podhurst Orseck, P.A. 5
25 West Flagler Street Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.podhurst.com
EFTA02739130
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 6 of 19
table. Defendant told Plaintiff to massage his back and take off her clothing, which she refused
to do. Defendant then began to try to touch the minor Plaintiff and/or take off her clothing.
After Defendant's relentless pawing, she reluctantly removed some of her clothing. During this
encounter, Defendant turned over on his back and fondled Plaintiff's breasts, despite her
repeatedly telling him not to do so. As Plaintiff massaged Defendant, Defendant proceeded to
masturbate until ejaculation. Defendant then paid Plaintiff two hundred dollars, and Plaintiff
was escorted out of Defendant's mansion and left Defendant's property.
18. A similar pattern of grooming continued, and the sexual exploitation
progressively escalated, over the course of approximately seventeen months during which
Defendant would often travel to Palm Beach. Prior to arriving and w!..iie in Palm Beach,
Defendant and/or his agent(s) would frequently call Plaintiff at her home telephone number
and/or other telephone numbers, arranging for encounters with her for Defendant, sometimes
twice daily. While usually such contacts were made by his assistants, Defendant personally
called Plaintiff repeatedly, despite being told to leave Plaintiff alone. After the first few
encounters, Defendant coerced Plaintiff to remove all her clothing, and Defendant penetrated the
minor Plaintiffs vagina digitally. Defendant sexually abused and/or battered and/or exploited
Plaintiff at least a hundred times between approximately January 2004 and May 2005. Such
exploitation included, but was not limited to, Defendant's sexual abuse and battery of Plaintiff
with vibrator(s), back massager(s), his finger(s), and his penis. At times, Defendant manipulated
Plaintiff to interact sexually with another female. During one encounter, Defendant penetrated
the minor Plaintiff's vagina with his penis, all the while narrating and demonstrating his sexual
battery of Plaintiff to another female present in the room. While some of the precise dates that
Defendant's acts of sexual exploitation occurred are unknown to Plaintiff, these dates are known
Podhurst Orseck, P.A. 6
25 West Flagler Street, Suite WO, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] 1 winv.podhurstcom
EFTA02739131
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 7 of 19
to Defendant, as he and/or his assistants kept written records, some of which are in the custody
of law enforcement, of each instance in which he committed lewd acts upon minor girls,
including the then minor Plaintiff.
19. Defendant's preference for underage girls was well-known to those who regularly
procured them for him. The above-described acts of abuse began to occur during a time when
Defendant knew that Plaintiff was a minor. Defendant, at all times material to this cause of
action, knew and/or should have known of Plaintiff's age of minority. In fact, Defendant
repeatedly urged the minor Plaintiff to become legally emancipated in order to accompany him
as he traveled, both nationally and internationally. Additionally, Defendant, knowing that
Plaintiff was merely seventeen years old, lured her by inviting her to stay with him at his
mansion in Manhattan and arranging and/or paying for airplane tickets, theater tickets, and a
personal chauffeur as gifts for her upcoming birthday.
20. As part of Defendant's persistent process of grooming Plaintiff and immersing her
in his lewd and abusive lifestyle, Defendant regularly showered the ado/ recent Plaintiff with
gifts, including, but not limited to lingerie, flowers, bikini bathing suit(s), art book(s), purse(s),
envelopes of U.S. currency, use of a car, and/or other accoutrements.
21. Defendant possessed photographs of nude underage girls, some of which may
have been taken with hidden cameras set up in his residence in Palm Beach. On the day of
Defendant's arrest, police found two hidden cameras and photographs of underage girls in
Defendant's mansion. Defendant took lewd photographs of Plaintiff with his hidden cameras
and transported lewd photographs of Plaintiff and other victims elsewhere using a facility or
means of interstate and/or foreign commerce. On one occasion, Defendant manipulated the
minor Plaintiff to pose nude for him and photographed her using several rolls of film. One or
Podhurst Orseck, P.A. 7
25 West Hagler Street. Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] t vin.podhorst.com
EFTA02739132
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 8 of 19
more of those nude photographs of Plaintiff that were taken by the Defendant when she was a
minor were confiscated by the Palm Beach Police Department during its execution of a search
warrant of Defendant's Palm Beach mansion on October 20,2005.
22. Defendant was particularly skillful at discerning his minor victims' respective
hopes, dreams, and ambitions. As he did with many of his victims, Defendant lured Plaintiff
early-on with modeling opportunities, impressing her with his modeling business and contacts
with supermodels, indicating that he could help her with a modeling career.
23. Knowing that the minor Plaintiff was an excellent student and desired to attend
New York University or Columbia University, Defendant pretended to show great interest in her
college admission, and offered to help her with her applications and to assist her with her
tuition. Defendant had told Plaintiff of his substantial connections within the academic
community, a matter about which he often bragged. Defendant took it upon himself to take
control of Plaintiff's college application process and led Plaintiff to believe that he was sincere
about helping her. Even though she had earned a Bright Futures Scholarship to the Florida
college of her choice, Defendant insisted that she would not need it, and that, with his
involvement, she would be admitted into one or both of the universities in New York. As a
result of Defendant's manipulation, Plaintiff did not apply timely for the Bright Futures
Scholarship or to any college, and therefore missed the fall semester of her freshman year. When
the Palm Beach Police Department executed the search warrant on Defendant's mansion, among
the artifacts found and confiscated were Plaintiff's high school transcript.
24. In June 2008, after an investigation by the Palm Beach Police Department, the
State Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's
Office, Defendant entered pleas of "guilty" to one count of solicitation of prostitution, in
Podhurst Orseck, P.A. 8
25 West Hagler Street, Suite 800, Miami, Fl 33130, Miami [Phone Redacted] Fax 305.35&2382 • Fat Lauderdale [Phone Redacted] www.podhuretcom
EFTA02739133
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 9 of 19
violation of Fla. Stat. § 796.07, and one count of solicitation of a minor to engage in prostitution,
in violation of Fla. Stat. § 796.03 in the Fifteenth Judicial Circuit in Palm Beach County, Florida.
25. As a condition of that plea, Defendant entered into a Non-Prosecution Agreement,
Addendum, and Affirmation (collectively, the "NPA") with the United States Attorney's Office
for the Southern District of Florida on September 24, 2007, October 29, 2007, and December 7,
2007, respectively. In so doing, Defendant acknowledged that Plaintiff was one of his victims
and agreed to the following provisions of the NPA :
8. If any of the [acknowledged victims] elects to file suit pursuant to 18 U.S.C.
§2255, Epstein will not contest the jurisdiction of the United States District Court
for the Southern District of Florida over his person and/or the subject matter, and
Epstein waives his right to contest liability and also waives his right to contest
damages up to an amount agreed to between the identified individual and Epstein,
so long as the identified individual elects to proceed exclusively under 18 U.S.C.
§2255, and agrees to waive any other claim for damages, whether pursuant to
state, federal or common law.
10. Except as to those individuals who elect to proceed exclusively under 18
U.S.C. §2255, as set forth in paragraph (8), supra, neither Epstein's signature on
this agreement, nor its terms, nor any resulting waivers or settlements by Epstein
are to be construed as admissions of evidence or evidence of civil or criminal
liability or a waive of any jurisdictional or other defense as to any person, whether
or not her name appears on the list provided by the United States (emphasis
added).
26. Plaintiff was among the individuals identified by the United States Attorney's
Office as victims of Defendant upon whose testimony it intended to base its federal prosecution
of Defendant for his illegal conduct. Consequently, Defendant is estopped by his state court plea
and the Non-Prosecution Agreement from denying the acts alleged in this Complaint and must
effectively admit liability to Plaintiff, Jane Doe No. 103.
COUNT ONE
Podhurst Orseck, P.A. 9
25 West Bugler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.podhurstoorn
EFTA02739134
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 10 of 19
iCause of Action for Coercion and Enticement of Minor to Enaays in Prostitution or
Sexual Activity pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. & 2422(1)))
27. Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
allegations contained in paragraphs 1 through 26 above.
28. Defendant used a facility or means of interstate and/or foreign commerce to
knowingly persuade, induce, entice, or coerce Plaintiff, 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).
29. Plaintiff 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 pursuant to this Section of the United
States Code.
30. 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
luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
and psychological expenses, and Plaintiff will in the future incur 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. 10
25 West Hagler Street., Suite 800. Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.pxlhurstcorn
EFTA02739135
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 11 of 19
WHEREFORE, Plaintiff demands judgment against Defendant 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 Emote in Illicit Sexual Conduct pursuant
to 18 U.S.C. 2255 in Violation of 18 U.S.C. 6 2423(t)1
31. Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
allegations contained in paragraphs I through 26 above.
32. Defendant traveled in interstate and/or foreign commerce for the purpose of
engaging 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 § 2423(b).
33. Plaintiff 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 pursuant to this Section of the United
States Code.
34. 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
luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
and psychological expenses, and Plaintiff will in the future incur additional medical and
psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
Podhurst Orseck, P.A. 11
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale 954.40.4316 www.podhurstaxen
EFTA02739136
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 12 of 19
income in the future, and a loss of the capacity to enjoy life. These injures are permanent in
nature, and Plaintiff will continue to suffer these losses in the future.
WHEREFORE, Plaintiff demands judgment against Defendant 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 Sexual Exploitation of Children pursuant to 18 U.S.C. 4 2255 in
Violation of 18 U.S.C. 6 2251)
35. Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
allegations contained in paragraphs 1 through 26 above.
36. Defendant 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.
37. Plaintiff 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 pursuant to this Section of the United
States Code.
38. 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
luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
Podhurst Orseck, P.A. 12
25 West Flagler Street, Suite SOO, Miami. FL 33130, MiamI [Phone Redacted] Fax 305.35&2382 • Fort Lauderdale [Phone Redacted] www.pixtbausteom
EFTA02739137
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 13 of 19
and psychological expenses, and Plaintiff will in the future incur 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 demands judgment against Defendant 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 Transport of Visual Depiction of Minor Engaging in Sexually Explicit
Conduct pursuant to 18 U.S.C. 4 2255 in Violation of 18 U.S.C. & 2252(a)(11)
39. Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
allegations contained in paragraphs 1 through 26 above.
40. Defendant 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(aX1).
41. Defendant transported lewd photographs of Plaintiff and otbar victims elsewhere
using a facility or means of interstate and/or foreign commerce.
42. Plaintiff 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 pursuant to this Section of the United
States Code.
43. 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,
Podhurst Orsedc, P.A. 13
25 West Hagler Street, Suite 800, Wand, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.podhurst.COD1
EFTA02739138
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 14 of 19
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
luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
and psychological expenses. and Plaintiff will in the future incur 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 demands judgment against Defendant 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 Transport of Child Pornography pursuant to 18 § 2255
in Violation of 18 U.S.C. & 2252A(a)(1))
44. Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
allegations contained in paragraphs 1 through 26 above.
45. Defendant 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(aX1).
46. Defendant transported lewd photographs of Plaintiff and other victims elsewhere
using a facility or means of interstate and/or foreign commerce.
47. Plaintiff 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 pursuant to this Section of the United
States Code.
Podhurst Orseck, P.A. 14
2$ West Flagier Street, Suite SOO, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] I www.podhurstcorn
EFTA02739139
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 15 of 19
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
luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
and psychological expenses, and Plaintiff will in the future incur 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 demands judgment against Defendant 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 Entwine in a Child Exploitation Enterprise pursuant to 18
U.S.C. 2255 in Violation of 18 U.S.C. 4 2252A(2)1
49. Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
allegations contained in paragraphs 1 through 26 above and Counts One through Five above.
50. Defendant knowingly engaged in a child exploitation enterprise, as defined in 18
U.S.C. § 2252A(g)(2), in violation of 18 U.S.C. § 2252A(gXI). 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. §§
Podhurst Orseck, PA. 15
25 West Fla gler Street Suite 800, Mandl, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] I vonv.podhurstuart
EFTA02739140
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 16 of 19
2251, 2252(a)( I ), and 2252(A)(aX I)), and Chapter 117 (transportation for illegal sexual activity
in violation of 18 U.S.C. §§ 2421. 2422(b), and 2423(b)). As more fully set forth above in
paragraphs I through 26, 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.
51. Plaintiff 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 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,
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
luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
and psychological expenses, and Plaintiff will in the future incur 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 demands judgment against Defendant for all damages available
under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages,
Podhurst Orseck, P.A. 16
25 West Flagkr Street, Suite 800, Miami, FL 33130, Miami 305.358.28W Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.podhurstcom
EFTA02739141
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 17 of 19
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: , 2010.
Respectfully Submitted,
By: Rrai- C • f24dieot LLD lea
Robert C. Josef
Bar No. 040856
Katherine W. Ezell
Bar No. 114771
Podhurst Orseck, P.A.
25 West Flagler St., Suite 800
Miami, Florida 33130
Telephone: ([Phone Redacted]
Fax: ([Phone Redacted]
riosefsberei400dhurst.com
kezell(Thoodhurst.com
Attorneys for Plaintiff
Podhurst Orseck, P.A. 17
25 West Flagler Street, Suite 900, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale [Phone Redacted] www.podburstrom
EFTA02739142
Case 9:10-cv-80309-KAM Document 1
ralS etts -2/0k CIVIL COVER SHEET
Entered on FLSD Docket 03/09/2010 Pag 18 of 19
b._): - ID i
bb(-4-• ThelS 44 eivilcover sket endek infismationcontained hemin ncither Roba nor suppkment the Eling and service ofpladin orother pas as roquired by law. except as provided bybal ruka of mun. This fornt aron:d by theItu:hela( Confaince of theUnited Stats in Scptanber 1974, is required fort o lask of Coun for the purpose of inietating the civil docka sket. (SEE 1NSTRUCTIONS ON INC RLVERSE OF THE FORM.) NOTICE: Attorneys MUST Isdi Can Bdm..
I. (a) PLAINTIFFS
Jane Doc No. 103 10-80 (I)) County of 1h:sidolce of Funt Listed Plano« West Palm Beach
1EXCEPT IN U.S. PLAINTIFE CASES)
(c) Attomey's (Firm Name. Aden.. bod idfiske« Romki)
Robert C. losefsberg, Esq./ICatherinc W. Ezell, Esq.
Podhurst Orscck, P.A.
25 W. Magier St., Suite 800
Miami PI 1111(1
n ts
FILED County of Raidenee of Firn Liswd Defa-lent Uni tates Vitvin 1 (IN U.S. PLANO CASES ORLY)
NOT!: 114 LAND CONDEMNAT1ON thASES. {Te r2m, THE
LAND INVOLVED.
STEPEM IB 1.O 17II CIRE
ant'.
ACT
All0111cy5 (If Knotom CLERK U. S. DIST. CT.
Robert D. Critton, Esq., Burman, CesitiaaaaaP,
• 303 Banyan Blvd., Suite 400, West Palm Beach. Fl.. 33401
I) Check County Where Action Anse 0 MIAMI. DADE 3 MONROE O BROWAR° tio PALM IWACH 3 Mł 0 ST. LUCIE 3 INDIAN RIVER 3 ORIECHOSEE
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CONTRACT TORTS FORTEITURE7PENALTY DANKRUITCY OTHER iTATUTPS I
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PERSONAL PRO PERTY
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Appeal l0 District
-I Hage from
' Magistrale
Judemat
VI. RELATED/RE-FILED
CASE(S). See ilikruelonnt
.road pam)
a) Re-likd Case CI YES 4TI NO b) Related Cases OVES ONO
JUDGE Kenneth A. Mam DOCKET NUMBF.R See Attached.
Ci c the U.S. Civil Statute onda which you arc Sling and Moc a anet Statement of Coast (Do not elle J tartsdletional statut.% u nias diveralty):
VII. CA USE OF ACTION 18 U.S.C. 2255 (Predicate Statutes 18 U.S.C. 2422(b), 2423(b), 2423(e), 2251, 2252, 2252A(aX1). 2252A(g)(1)
LENGTH OF TRIAL via days a:timma:I (for bab sida to wy mim asa)
VIII. REQUESTED IN o CHECK IF THIS IS A CLASS ACTION DEMAND S CHECK YES only if &monda) in coroPlainl: COM IPLAINT: UNDER F.R.C.P. 23 neo e. cceF I 15 000.0- JURY DEMAND: gaj No
A BOVE INFORMATION IS TRUE & CORRECT TO mmmii RE pp A no or g y OF RECORD D TE THE BEST OF MY K,NOWLEDGE
23 FOR OFFICE USt ONLY
AMOUNT 35 1 '0 0 RECE1PT • fo
EFTA02739143
Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 19 of 19
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
WEST PALM BEACH DIVISION
ATTACHMENT TO CIVIL COVER SHEET
FOR: Jane Doe 103 v. Jeffrey Epstein
VI. RELATED PENDING CASES
08-80119 - KAM
08-80232 - KAM
08-80380 - KAM
08-80381 - KAM
08-80811 - KAM
08-80893 - KAM
08-80993 - KAM
08-80994 - KAM
09-80469 - KAM
09-80802 - KAM
09-81092 - KAM
EFTA02739144