Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 1 of 91 # UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff(s), ## FIRST AMENDED COMPLAINT Parties, Jurisdiction and Venue COMES NOW the Plaintiff, C.M.A., and brings this First Amended Complaint against the Defendants, JEFFREY EPSTEIN and states as follows: 1. This is an action for damages in excess of $75,000.00, exclusive of interest and costs. 2. This Complaint is brought under a fictitious name in order to protect the identity of the Plaintiff, C.M.A., because this Complaint makes allegation of sexual assault and child abuse of a then minor. 3. At all times material to this cause of action, the Plaintiff, C.M.A., was EFTA00087853 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 2 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 4. At all times material to this cause of action, the Defendant, JEFFREY EPSTEIN, had a residence located in Palm Beach County, Florida. 5. At all times material to this cause of action, the Defendant, JEFFREY EPSTEIN, was an adult male, born in 1953. 6. This Court has jurisdiction of this action and the claim set forth herein pursuant to 18 U.S.C. §2255. 7. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial part of the events or omissions giving rise to the claim occurred in this district. 8. At all times material, the Defendant, JEFFREY EPSTEIN, owed a duty unto Plaintiff, C.M.A., to treat her in a non-negligent manner and to not commit intentional or tortious illegal acts against her. ## Factual Allegations 9. Upon information and belief, the Defendant, JEFFREY EPSTEIN, has demonstrated a sexual preference and obsession for minor girls. He engaged in a plan, scheme, and enterprise in which he gained access to economically disadvantaged minor girls, such as Plaintiff, C.M.A., sexually assaulted these girls, and/or coerced them to engage in prostitution, and in return gave these girls money. 10. The Defendant's plan, scheme and enterprise included an elaborate system wherein the then minor Plaintiff and other minor girls were brought to the 2 EFTA00087854 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 3 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint Defendant, JEFFREY EPSTEIN'S, residence by the Defendant's employees and assistants. When the employees and assistants left the then minor Plaintiff and other minor girls alone in a room at the Defendant's mansion, the Defendant, JEFFREY EPSTEIN, himself would appear, remove his clothing, and direct the then minor Plaintiff to remove her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including, but not limited to, masturbation, touching of the then minor Plaintiff's breasts and buttock, and solicitation and enticement of the then minor Plaintiff to engage in sexual acts with another female in JEFFREY EPSTEIN'S presence. 11. The Plaintiff, C.M.A., was the first brought to the Defendant, JEFFREY EPSTEIN'S, mansion in late May or early June of 2002, when she was fifteen-years old and in middle school. 12. The Defendant, JEFFREY EPSTEIN, a wealthy financier with a lavish home, significant wealth, a network of assistants and employees, used his resources and his influence over a vulnerable minor child to engage in a systematic pattern of sexually exploitive behavior. 13. Beginning in approximately late May or early June of 2002, and continuing until approximately August of 2003, the Defendant coerced and enticed the impressionable, vulnerable, and economically deprived then minor Plaintiff to commit various acts of sexual misconduct. These acts occurred, on average, one to three times per week from late May or early June of 2002 until August of 2003. At a bare minimum, 3 EFTA00087855 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 4 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint these acts occurred twice a month from June 2002 until August of 2003. While the precise dates these acts occurred are unknown to Plaintiff, including those weeks in which no acts occurred, these dates are known by Defendant, JEFFREY EPSTEIN, as he is reported to have kept a written log of each and every instance in which he engaged in these illegal acts with the then minor Plaintiff, C.M.A. and others. These acts included, but were not limited to, fondling and inappropriate and illegal sexual touching of the then minor Plaintiff, sexual misconduct and masturbation of the Defendant, JEFFREY EPSTEIN, in the presence of the then minor Plaintiff, soliciting and enticing the then minor Plaintiff to engage in sexual acts with another female in JEFFREY EPSTEIN'S presence, and encouraging the then minor Plaintiff to become involved in prostitution; Defendant, JEFFREY EPSTEIN, committed numerous criminal sexual offenses against the then minor Plaintiff including, but not limited to, sexual battery, solicitation of prostitution, procurement of a minor for the purpose of prostitution, and lewd and lascivious assaults upon the person of the then minor Plaintiff. 14. Defendant, JEFFREY EPSTEIN, used his money, wealth and power to unduly and improperly manipulate and influence the then minor Plaintiff. 15. The acts referenced in paragraphs 9 through 14, committed by Defendant, JEFFREY EPSTEIN, against the then minor Plaintiff, C.M.A., were committed in violation of numerous criminal State and Federal statutes condemning the sexual 4 EFTA00087856 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 5 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint exploitation of minor children, prostitution, sexual performance by a child, lewd and lascivious assaults, sexual battery, contributing the delinquency of a minor and other crimes, specifically including, but not limited to, those crimes designated in 18 USC §2241, §2242, §2243, §2421, and §2423, criminal offenses outlined in Chapter 800 of the Federal Codes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §39.01; and §827.04. 16. The above-described acts took place in Palm Beach County, Florida, at the residence of the Defendant, JEFFREY EPSTEIN. Any assertions by the Defendant, JEFFREY EPSTEIN, that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual exploitation and abuse of a minor child. The Defendant, JEFFREY EPSTEIN, at all times material to this cause of action, knew and should have known of the Plaintiff, C.M.A.’s minority. 17. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, the 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 purpose of prostitution. 18. As a condition of that plea, and in exchange for the Federal Government not prosecuting the Defendant, JEFFREY EPSTEIN, for numerous federal offenses, Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the 5 EFTA00087857
Case 9:08-cv-80811-KAMDocument 40Entered on FLSD Docket 02/09/2009P
Page 6 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint Federal Government to the following: "Any person, who while a minor, was a victim or an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less". 19. The Defendant, JEFFREY EPSTEIN, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged in this Complaint, and must effectively admit liability to the Plaintiff, C.M.A. COUNT | ## Cause of Action Pursuant to 18 USC §2255 ## May/June 2002 20. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 6 EFTA00087858 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 21. In late May or early June of 2002, C.M.A. was first introduced to Defendant, JEFFREY EPSTEIN. C.M.A. was brought to JEFFREY EPSTEIN'S residence by a female friend of hers. C.M.A. sat on the couch while the female friend took off her own clothes, mounted JEFFREY EPSTEIN who was wearing only a towel and lying on a table, and performed a sexual act upon JEFFREY EPSTEIN in the presence of C.M.A. In exchange for her participation as an observer of JEFFREY EPSTEIN'S lewd and lascivious conduct, C.M.A. was paid $300 by JEFFREY EPSTEIN. 22. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in 7 EFTA00087859 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 23. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 24. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 25. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 8 EFTA00087860 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 I Page 9 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 II ## Cause of Action Pursuant to 18 USC §2255 ## June 2002- Incident 2 26. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 27. Approximately one week after the first incident, C.M.A. received a telephone call from JEFFREY EPSTEIN requesting that she return to his residence. On this occasion, JEFFREY EPSTEIN directed C.M.A to undress to her brassiere and underwear and to provide him with a massage. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. $300 for this encounter. 9 EFTA00087861 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 10 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 28. As a condition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 29. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 10 EFTA00087862 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 11 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 30. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 31. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 11 EFTA00087863 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 12 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 III Cause of Action Pursuant to 18 USC §2255 July, 2002 – Incident 1 32. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 33. In July of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to undress to her underwear and to provide him with a massage. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 34. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For 12 EFTA00087864 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 13 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 35. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 36. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 37. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, 13 EFTA00087865 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 14 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 IV Cause of Action Pursuant to 18 USC §2255 July 2002 – Incident 2 14 EFTA00087866 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 15 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 38. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 39. For the second time in July of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 40. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in 15 EFTA00087867 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 16 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 41. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 42. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 43. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 16 EFTA00087868 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 17 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 V ## Cause of Action Pursuant to 18 USC §2255 ## August of 2002 – Incident 1 44. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 45. In August of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 17 EFTA00087869 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 18 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 46. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 47. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 18 EFTA00087870 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 19 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 48. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 49. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 19 EFTA00087871 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Par C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 VI Cause of Action Pursuant to 18 USC §2255 August of 2002 – Incident 2 50. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 51. For the second time in August of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 52. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 20 EFTA00087872 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 21 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 53. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 54. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 55. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and 21 EFTA00087873 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 22 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 VII ## Cause of Action Pursuant to 18 USC §2255 ## September of 2002 – Incident 1 56. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 22 EFTA00087874 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 23 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 57. In September of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 58. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 23 EFTA00087875 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 24 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 59. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 60. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 61. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., has suffered a loss of income, a loss of the capacity to earn income in the future, and a 24 EFTA00087876 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 25 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 VIII ## Cause of Action Pursuant to 18 USC §2255 ## September of 2002 – Incident 2 62. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 63. For the second time in September of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 25 EFTA00087877 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 26 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 64. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 65. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 26 EFTA00087878 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 27 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 66. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 67. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 27 EFTA00087879 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 28 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 IX Cause of Action Pursuant to 18 USC §2255 October of 2002 – Incident 1 68. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 69. In October of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 70. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 28 EFTA00087880 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 29 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 71. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 72. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 73. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and 29 EFTA00087881 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 30 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 X Cause of Action Pursuant to 18 USC §2255 October of 2002 – Incident 2 30 EFTA00087882 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 31 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 74. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 75. For the second time in October of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 76. As a condition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in 31 EFTA00087883 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 32 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 77. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 78. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 79. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 32 EFTA00087884 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 33 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 XI ## Cause of Action Pursuant to 18 USC §2255 ## November of 2002 – Incident 1 80. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 81. In November of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 33 EFTA00087885 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 34 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 82. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 83. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 34 EFTA00087886 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 35 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 84. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 85. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 35 EFTA00087887 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 F C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 XII Cause of Action Pursuant to 18 USC §2255 November of 2002 – Incident 2 86. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 87. For the second time in November of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 88. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 36 EFTA00087888 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 37 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 89. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 90. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 91. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and 37 EFTA00087889 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 38 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 XIII ## Cause of Action Pursuant to 18 USC §2255 ## December of 2002 – Incident 1 92. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 38 EFTA00087890 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 39 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 93. In December of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 94. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 39 EFTA00087891 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 40 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 95. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 96. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 97. As a direct and proximate result of the offenses enumerated in Title 18, United States Code; Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., has suffered a loss of income, a loss of the capacity to earn income in the future, and a 40 EFTA00087892 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 41 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 XIV ## Cause of Action Pursuant to 18 USC §2255 December of 2002 – Incident 2 98. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 99. For the second time in December of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 41 EFTA00087893 Case 9:08-cv-80811-KAM | Document 40 | Entered on FLSD Docket 02/09/2009 | | :--- | :--- | Page 42 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 100. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 101. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 42 EFTA00087894 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 43 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 102. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 103. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 43 EFTA00087895 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 44 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 XV Cause of Action Pursuant to 18 USC §2255 January of 2003 – Incident 1 104. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 105. In January of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 106. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 44 EFTA00087896 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 45 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 107. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 108. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 109. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and 45 EFTA00087897 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 46 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 XVI ## Cause of Action Pursuant to 18 USC §2255 ## January of 2003 – Incident 2 110. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 46 EFTA00087898 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 47 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 111. For the second time in January of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 112. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 47 EFTA00087899 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 48 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 113. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 114. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 115. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., has suffered a loss of income, a loss of the capacity to earn income in the future, and a 48 EFTA00087900 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 49 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 XVII ## Cause of Action Pursuant to 18 USC §2255 February of 2003 – Incident 1 116. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 117. In February of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 49 EFTA00087901 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 50 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 118. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 119. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 50 EFTA00087902 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 51 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 120. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 121. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 51 EFTA00087903 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 52 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 XVIII Cause of Action Pursuant to 18 USC §2255 February of 2003 – Incident 2 122. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 123. For the second time in February of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 124. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 52 EFTA00087904 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 53 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 125. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 126. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 127. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and 53 EFTA00087905 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 54 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 XIX ## Cause of Action Pursuant to 18 USC §2255 ## March of 2003 – Incident 1 128. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 54 EFTA00087906 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 55 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 129. In March of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 130. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 55 EFTA00087907 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 56 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 131. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 132. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 133. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., has suffered a loss of income, a loss of the capacity to earn income in the future, and a 56 EFTA00087908 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 57 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 XX ## Cause of Action Pursuant to 18 USC §2255 ## March of 2003 – Incident 2 134. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 135. For the second time in March of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 57 EFTA00087909 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 58 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 136. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 137. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 58 EFTA00087910 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 59 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 138. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 139. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 59 EFTA00087911 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 60 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 XXI Cause of Action Pursuant to 18 USC §2255 April of 2003 – Incident 1 140. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 141. In April of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 142. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 60 EFTA00087912 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 61 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 143. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 144. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 145. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and 61 EFTA00087913 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 62 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 XXII ## Cause of Action Pursuant to 18 USC §2255 ## April of 2003 – Incident 2 146. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 62 EFTA00087914 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 63 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 147. For the second time in April of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 148. As a condition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 63 EFTA00087915 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 64 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 149. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 150. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 151. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., has suffered a loss of income, a loss of the capacity to earn income in the future, and a 64 EFTA00087916 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 | Page 65 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 XXIII ## Cause of Action Pursuant to 18 USC §2255 ## May of 2003 – Incident 1 152. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 153. In May of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 65 EFTA00087917 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 66 of 91 C. M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 154. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 155. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 66 EFTA00087918 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 67 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 156. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 157. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 67 EFTA00087919 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 68 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 XXIV Cause of Action Pursuant to 18 USC §2255 May of 2003 – Incident 2 158. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 159. For the second time in May of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 160. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 68 EFTA00087920 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 69 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 161. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 162. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 163. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and 69 EFTA00087921 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 70 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 XXV ## Cause of Action Pursuant to 18 USC §2255 ## June of 2003 – Incident 1 164. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 70 EFTA00087922 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 71 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 165. In June of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 166. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 71 EFTA00087923 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 72 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 167. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 168. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 169. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., has suffered a loss of income, a loss of the capacity to earn income in the future, and a 72 EFTA00087924 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 73 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 XXVI ## Cause of Action Pursuant to 18 USC §2255 ## June of 2003 – Incident 2 170. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 171. For the second time in June of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 73 EFTA00087925 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 74 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 172. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 173. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 74 EFTA00087926 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 75 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 174. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 175. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 75 EFTA00087927 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 P C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 XXVII Cause of Action Pursuant to 18 USC §2255 July of 2003 – Incident 1 176. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 177. In July of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 178. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 76 EFTA00087928 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 77 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 179. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 180. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 181. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and 77 EFTA00087929 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 78 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 XXVIII ## Cause of Action Pursuant to 18 USC §2255 ## July of 2003 – Incident 2 182. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 78 EFTA00087930 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 79 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 183. For the second time in July of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 184. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 79 EFTA00087931
Case 9:08-cv-80811-KAMDocument 40Entered on FLSD Docket 02/09/2009
Page 80 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 185. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 186. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 187. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., has suffered a loss of income, a loss of the capacity to earn income in the future, and a 80 EFTA00087932 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 81 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 XXIX ## Cause of Action Pursuant to 18 USC §2255 ## August of 2003 – Incident 1 188. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 189. In August of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 81 EFTA00087933 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 82 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 190. As a condition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 191. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 82 EFTA00087934
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Page 83 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 192. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 193. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 83 EFTA00087935 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 XXX Cause of Action Pursuant to 18 USC §2255 August of 2003 – Incident 2 194. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 195. For the second time in August of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 196. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 84 EFTA00087936
Case 9:08-cv-80811-KAMDocument40Entered on FLSD Docket 02/09/2009
Page 85 of 91 C. M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 197. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 198. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 199. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and 85 EFTA00087937 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 86 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 XXXI ## Sexual Battery 200. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 199 above. 86 EFTA00087938 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 87 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 201. Between late May or early June of 2002 and August of 2003, Defendant, JEFFERY EPSTEIN, engaged in dozens of illegal and depraved sexual acts against Plaintiff, C.M.A. 202. As described more fully in the above paragraphs, Defendant, JEFFERY EPSTEIN, intentionally inflicted harmful and/or offensive sexual contact on the person of C.M.A. 203. Defendant, JEFFREY EPSTEIN'S, tortuous commission of sexual battery upon C.M.A. were done willfully and maliciously. 204. As a direct and proximate result of JEFFREY EPSTEIN'S battery on C.M.A., she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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 XXXII ## Conspiracy to Commit Tortious Assault Against Defendant. 205. Plaintiff incorporates into this count the allegations of paragraphs 1 through 19. 87 EFTA00087939 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Pag C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 206. Defendant is one of Defendant, JEFFREY EPSTEIN'S, referenced in paragraph 12 above. Defendant, JEFFREY EPSTEIN, Defendant, and others reached an agreement between themselves for the purpose of allowing Defendant, JEFFREY EPSTEIN, to commit the illegal acts described above upon Plaintiff, C.M.A. 207. Many of the instances of illegal sexual conduct committed by Defendant, JEFFREY EPSTEIN, described above were perpetrated with the assistance, support, and facilitation by Defendant. In fact, Defendant, aided, assisted, and/or abetted Defendant, JEFFREY EPSTEIN, in his organized scheme and plan to sexually assault, and/or coerce Plaintiff, C.M.A., to engage in prostitution. 208. Defendant, would often arrange times for C.M.A. to come to Defendant, JEFFREY EPSTEIN'S, residence, would escort C.M.A. to the room where Defendant, JEFFREY EPSTEIN, was waiting, would deliver cash from Defendant, JEFFREY EPSTEIN, at the conclusion of a session, and took nude photographs of Plaintiffs, C.M.A., for Defendant, JEFFREY EPSTEIN. 209. As a direct and proximate result of Defendant, participation in the aforementioned conspiracy, Plaintiff, C.M.A, has suffered and will continue to suffer damages, including, but not limited to, pain, suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of 88 EFTA00087940 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 89 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint self-esteem, loss of dignity, invasion of personal privacy and other damages associated with JEFFREY EPSTEIN'S controlling, manipulating, and coercing C.M.A. into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 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 the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and 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. ## CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 9th day of February, 2009, I electronically filed the foregoing with the Clerk of the Court by using CM/ECF system, which will send a notice of electronic filing to all counsel of record on the attached service list. 89 EFTA00087941 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 90 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint Page 90 of 91 /s/Jack P. Hill Jack Scarola Florida Bar No.: 169440 Jack P. Hill Florida Bar No.: 0547808 Searcy Denney Scarola Barnhart & Shipley, P.A. Attorneys for Plaintiff(s) 90 EFTA00087942 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 91 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint Page 91 of 91 ## COUNSEL LIST Richard H. Willits, Esquire Richard H. Willits, P.A. Robert Critton, Esquire Burman Critton Luttier & Coleman LLP Jack A. Goldberger, Esquire Afterbury, Goldberger & Weiss, P.A. Bruce E. Reinhart, Esquire Bruce E. Reinhart, P.A. 91 EFTA00087943