Case 9:08-cv-80811-KAMDocument 39Entered 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), vs. JEFFREY EPSTEIN and Defendant(s). ## FIRST AMENDED COMPLAINT Parties, Jurisdiction and Venue COMES NOW the Plaintiff, and brings this First Amended Complaint against the Defendants, JEFFREY EPSTEIN and SARAH KELLEN, 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, 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, was a resident of SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003349 EFTA00157731 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 2 of 91 | | | | :--- | :--- | | 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, 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, 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 3505-025 Page 2 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003350 EFTA00157732 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 3 of 91 | | | | :--- | :--- | | 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, was the first brought to the Defendant, JEFFREY EPSTEIN'S, mansion in late May or early June of 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 , and continuing until approximately August of , 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 until August of . At a bare minimum, 3 Page 3 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00003351 | | :--- | :--- | This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text. EFTA00157733 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 4 of 91 | vs. Epstein, et al. | | :--- | | Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | | First Amended Complaint | these acts occurred twice a month from June until August of . 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, 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, were committed in violation of numerous criminal State and Federal statutes condemning the sexual 4 3505-025 Page 4 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003352 EFTA00157734 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 5 of 91 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, its 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 Page 5 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003353 EFTA00157735
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 6 of 91 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 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". 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. Cause of Action Pursuant to 18 USC §2255 May/June 20. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 6 3505-025 Page 6 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003354 EFTA00157736
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 7 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 21. In late May or early June of was first introduced to Defendant, JEFFREY EPSTEIN. was brought to JEFFREY EPSTEIN'S residence by a female friend of hers. 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 In exchange for her participation as an observer of JEFFREY EPSTEIN'S lewd and lascivious conduct, 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 3505-025 Page 7 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003355 EFTA00157737 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 8 of 91 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, 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, and as such he must effectively admit liability unto the Plaintiff. 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, 8 Page 8 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003356 EFTA00157738
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 9 of 91 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, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 - Incident 2 26. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 27. Approximately one week after the first incident, received a telephone call from JEFFREY EPSTEIN requesting that she return to his residence. On this occasion, JEFFREY EPSTEIN directed 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 presence. JEFFREY EPSTEIN paid C.M.A. $300 for this encounter. 9 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003357 EFTA00157739 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 10 of 91 | 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, 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 3505-025 Page 10 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003358 EFTA00157740
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 11 of 91 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, and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 3505-025 Page 11 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003359 EFTA00157741 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 12 of 91 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. 32. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 33. In July again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to undress to her underwear and to provide him with a massage. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 3505-025 Page 12 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003360 EFTA00157742
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 13 of 91 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, 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, and as such he must effectively admit liability unto the Plaintiff, 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, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, 13 Page 13 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003361 EFTA00157743
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 14 of 91 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 – Incident 2 14 3505-025 Page 14 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003362 EFTA00157744 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 15 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 38. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 39. For the second time in July of again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 3505-025 Page 15 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003363 EFTA00157745
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 16 of 91 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, 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, , and as such he must effectively admit liability unto the Plaintiff,. 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, 16 3505-025 Page 16 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003364 EFTA00157746
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 17 of 91 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, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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. 17 3505-025 Page 17 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00003365 | | :--- | :--- | This is a simple Markdown document with no headings or paragraphs. It contains a single line of text. EFTA00157747
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 18 of 91 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, 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 3505-025 Page 18 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003366 EFTA00157748
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 19 of 91 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, , and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 3505-025 Page 19 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003367 EFTA00157749 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 20 of 91 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 – Incident 2 50. The Plaintiff, adopts and realleges paragraphs 1 through 19 above. 51. For the second time in August of again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 3505-025 Page 20 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003368 EFTA00157750
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 21 of 91 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, 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, , and as such he must effectively admit liability unto the Plaintiff, 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, has in the past suffered, and will in the future suffer, physical injury, pain and 21 3505-025 Page 21 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003369 EFTA00157751 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 22 of 91 | 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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. 56. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 22 3505-025 Page 22 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003370 EFTA00157752 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 23 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 57. In September again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 3505-025 Page 23 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003371 EFTA00157753 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 24 of 91 | vs. Epstein, et al. | | :--- | | Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | | First Amended Complaint | 59. The Plaintiff, 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, , and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a 24 3505-025 Page 24 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003372 EFTA00157754 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Par 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, , will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 – Incident 2 62. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 63. For the second time in September again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 25 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003373 EFTA00157755 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 26 of 91 | 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, 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 3505-025 Page 26 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003374 EFTA00157756
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 27 of 91 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, , and as such he must effectively admit liability unto the Plaintiff. 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 Page 27 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003375 EFTA00157757 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 28 of 91 | 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- Incident 1
68. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. ___ 69. In October of 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 At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 3505-025 Page 28 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003376 EFTA00157758 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 29 of 91 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, 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, and as such he must effectively admit liability unto the Plaintiff, 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, has in the past suffered, and will in the future suffer, physical injury, pain and 29 3505-025 Page 29 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003377 EFTA00157759
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 30 of 91 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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. - Incident 2 30 3505-025 Page 30 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003378 EFTA00157760
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 31 of 91 | vs. Epstein, et al. | | :--- | | Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | | First Amended Complaint | 74. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 75. For the second time in October 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 At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 3505-025 Page 31 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003379 EFTA00157761
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 32 of 91 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, 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, , and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, 32 3505-025 Page 32 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003380 EFTA00157762 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 33 of 91 | 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, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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. 80. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 81. In November again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 33 Page 33 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003381 EFTA00157763
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 34 of 91 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, 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 3505-025 Page 34 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003382 EFTA00157764
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 35 of 91 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, , and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 3505-025 Page 35 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003383 EFTA00157765 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 36 of 91 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 - Incident 2 86. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 87. For the second time in November again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 3505-025 Page 36 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003384 EFTA00157766
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 37 of 91 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, 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, and as such he must effectively admit liability unto the Plaintiff, 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, has in the past suffered, and will in the future suffer, physical injury, pain and 37 3505-025 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003385 EFTA00157767 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 38 of 91 ## 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, , will in the future suffer additional medical and psychological expenses. The Plaintiff, , has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, , will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 92. The Plaintiff, adopts and realleges paragraphs 1 through 19 above. 38 3505-025 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00003386 | | :--- | :--- | This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text. EFTA00157768
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 39 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 93. In December again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself. in presence. JEFFREY EPSTEIN paid 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 Page 39 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003387 EFTA00157769 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 40 of 91 | vs. Epstein, et al. | | :--- | | Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | | First Amended Complaint | 95. The Plaintiff, 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, , and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a 40 3505-025 Page 40 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00003388 | | :--- | :--- | This is a simple Markdown representation of the text from the image. No formatting or special characters are used, preserving the original layout. EFTA00157770
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 41 of 91 | | | | :--- | :--- | | 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, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 — Incident 2 98. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 99. For the second time in December again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 41 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00003389 | | :--- | :--- | This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text. EFTA00157771 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 42 of 91 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, 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 3505-025 Page 42 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003390 EFTA00157772
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 43 of 91 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, , and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 3505-025 Page 43 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00003391 | | :--- | :--- | This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text: "EFTA_00003391". EFTA00157773 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 44 of 91 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. Cause of Action Pursuant to 18 USC §2255 January of - Incident 1 104. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 105. In January again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 Page 44 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003392 EFTA00157774 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 45 of 91 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, 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, , and as such he must effectively admit liability unto the Plaintiff, 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, has in the past suffered, and will in the future suffer, physical injury, pain and 45 3505-025 Page 45 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003393 EFTA00157775 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 46 of 91 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 110. The Plaintiff, adopts and realleges paragraphs 1 through 19 above. 46 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 Page 46 of 91 | EFTA_00003394 | | :--- | :--- | This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text: "EFTA_00003394". EFTA00157776 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 47 of 91 | | | | :--- | :--- | | vs. Epstein, et al. | | | Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | | | First Amended Complaint | | 111. For the second time in January again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 3505-025 Page 47 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003395 EFTA00157777 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 48 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 113. The Plaintiff, 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, and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a 48 3505-025 Page 48 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003396 EFTA00157778
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 49 of 91 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, , will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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. 116. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 117. In February again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 49 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003397 EFTA00157779 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 50 of 91 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, 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 3505-025 Page 50 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003398 EFTA00157780
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 51 of 91 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, , and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 3505-025 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003399 EFTA00157781 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 52 of 91 | 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 – Incident 2 122. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 123. For the second time in February again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 3505-025 Page 52 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003400 EFTA00157782
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 53 of 91 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, 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, , and as such he must effectively admit liability unto the Plaintiff, 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, has in the past suffered, and will in the future suffer, physical injury, pain and 53 3505-025 Page 53 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003401 EFTA00157783 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 54 of 91 | 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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. 128. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 54 3505-025 Page 54 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003402 EFTA00157784 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 55 of 91 | vs. Epstein, et al. | | :--- | | Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | | First Amended Complaint | 129. In March again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 3505-025 Page 55 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003403 EFTA00157785 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 56 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 131. The Plaintiff, 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, and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a 56 3505-025 Page 56 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003404 EFTA00157786
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 57 of 91 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, , will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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. March - Incident 2 134. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 135. For the second time in March of again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 57 Page 57 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003405 EFTA00157787
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 58 of 91 | 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, 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 3505-025 Page 58 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003406 EFTA00157788 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 59 of 91 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, , and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 3505-025 Page 59 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003407 EFTA00157789 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 60 of 91 | 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 - Incident 1 140. The Plaintiff, adopts and realleges paragraphs 1 through 19 above. 141. In April again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 3505-025 Page 60 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003408 EFTA00157790 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 61 of 91 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, 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, , and as such he must effectively admit liability unto the Plaintiff, 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, has in the past suffered, and will in the future suffer, physical injury, pain and 61 3505-025 Page 61 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003409 EFTA00157791 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 62 of 91 | 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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. 146. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 62 3505-025 Page 62 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003410 EFTA00157792 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 63 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 147. For the second time in April again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 3505-025 Page 63 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003411 EFTA00157793 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 64 of 91 | vs. Epstein, et al. | | :--- | | Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | | First Amended Complaint | 149. The Plaintiff, 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, and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a 64 3505-025 Page 64 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003412 EFTA00157794
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 65 of 91 | 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, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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. 152. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 153. In May again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 65 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003413 EFTA00157795 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 66 of 91 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, 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 3505-025 Page 66 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003414 EFTA00157796 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 67 of 91 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, , and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 3505-025 Page 67 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003415 EFTA00157797 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 68 of 91 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 - Incident 2 158. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 159. For the second time in May again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 3505-025 Page 68 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003416 EFTA00157798 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Pa 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, 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, , and as such he must effectively admit liability unto the Plaintiff, 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, has in the past suffered, and will in the future suffer, physical injury, pain and 69 Page 69 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003417 EFTA00157799 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 70 of 91 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, , will in the future suffer additional medical and psychological expenses. The Plaintiff, , has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, , will continue to suffer these losses in the future. WHEREFORE, the Plaintiff., 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. 164. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 70 3505-025 Page 70 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003418 EFTA00157800 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 71 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 165. In June again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 3505-025 Page 71 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003419 EFTA00157801 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 72 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 167. The Plaintiff, 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, and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a 72 3505-025 Page 72 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003420 EFTA00157802 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 73 of 91 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, , will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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. 170. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 171. For the second time in June again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 73 Page 73 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00003421 | | :--- | :--- | This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text. EFTA00157803
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 74 of 91 | 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, 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 3505-025 Page 74 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003422 EFTA00157804 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 75 of 91 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, , and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 3505-025 Page 75 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003423 EFTA00157805 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 76 of 91 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 176. The Plaintiff, adopts and realleges paragraphs 1 through 19 above. 177. In July again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 3505-025 Page 76 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003424 EFTA00157806 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 77 of 91 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 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, , and as such he must effectively admit liability unto the Plaintiff, 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, has in the past suffered, and will in the future suffer, physical injury, pain and 77 Page 77 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003425 EFTA00157807
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 78 of 91 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, , will in the future suffer additional medical and psychological expenses. The Plaintiff, , has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, , will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 – Incident 2 182. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 78 3505-025 Page 78 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003426 EFTA00157808
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 79 of 91 | vs. Epstein, et al. | | :--- | | Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | | First Amended Complaint | 183. For the second time in July again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 3505-025 Page 79 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003427 EFTA00157809
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 80 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 185. The Plaintiff, 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, and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a 80 3505-025 Page 80 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003428 EFTA00157810
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 81 of 91 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, , will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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. 188. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 189. In August of 2003, again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 81 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003429 EFTA00157811 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 82 of 91 | 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, 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 Page 82 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003430 EFTA00157812 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 83 of 91 | | | | :--- | :--- | | 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, and as such he must effectively admit liability unto the Plaintiff, 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, 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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 3505-025 Page 83 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 | EFTA_00003431 | | :--- | :--- | This is a simple Markdown document with no headings, paragraphs, or tables. It contains just one line of text: "EFTA_00003431". EFTA00157813
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 84 of 91 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 – Incident 2 194. The Plaintiff, adopts and realleges paragraphs 1 through 19 above. 195. For the second time in August again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid 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 Page 84 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003432 EFTA00157814 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 85 of 91 vs. Epstein, et al. | 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, 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, , and as such he must effectively admit liability unto the Plaintiff, 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, has in the past suffered, and will in the future suffer, physical injury, pain and 85 Page 85 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003433 EFTA00157815 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 86 of 91 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, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 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, □, adopts and realleges paragraphs 1 through 199 above. 86 3505-025 Page 86 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003434 EFTA00157816 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 87 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 201. Between late May or early June of and August of , Defendant, JEFFERY EPSTEIN, engaged in dozens of illegal and depraved sexual acts against Plaintiff, 202. As described more fully in the above paragraphs, Defendant, JEFFERY EPSTEIN, intentionally inflicted harmful and/or offensive sexual contact on the person of 203. Defendant, JEFFREY EPSTEIN'S, tortuous commission of sexual battery upon were done willfully and maliciously. 204. As a direct and proximate result of JEFFREY EPSTEIN'S battery on , she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. WHEREFORE, the Plaintiff, 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, SARAH KELLEN 205. Plaintiff incorporates into this count the allegations of paragraphs 1 through 19. 87 Page 87 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003435 EFTA00157817
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 88 of 91 | vs. Epstein, et al. | | :--- | | Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | | First Amended Complaint | 206. Defendant, SARAH KELLEN, is one of Defendant, JEFFREY EPSTEIN'S, employees/assistants referenced in paragraph 12 above. Defendant, JEFFREY EPSTEIN, Defendant, SARAH KELLEN, and others reached an agreement between themselves for the purpose of allowing Defendant, JEFFREY EPSTEIN, to commit the illegal acts described above upon Plaintiff. 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, SARAH KELLAN. In fact, Defendant, SARAH KELLEN, aided, assisted, and/or abetted Defendant, JEFFREY EPSTEIN, in his organized scheme and plan to sexually assault, and/or coerce Plaintiff, to engage in prostitution. 208. Defendant, SARAH KELLEN, would often arrange times for to come to Defendant, JEFFREY EPSTEIN'S, residence, would escort 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, for Defendant, JEFFREY EPSTEIN. 209. As a direct and proximate result of Defendant, SARAH KELLEN's, participation in the aforementioned conspiracy, Plaintiff, 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 3505-025 Page 88 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003436 EFTA00157818
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
Page 89 of 91 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 into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, demands judgment against the Defendant, SARAH KELLEN, 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 3505-025 Page 89 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003437 EFTA00157819
Case 9:08-cv-80811-KAMDocument 39Entered on FLSD Docket 02/09/2009
| | | | :--- | :--- | | vs. Epstein, et al. | | | Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | | | First Amended Complaint | | | Page 90 of 91 | | Attorneys for Plaintiff(s) 90 3505-025 Page 90 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003438 EFTA00157820 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 91 of 91 | | | | :--- | :--- | | vs. Epstein, et al. | | | Case No.: 08-CV-80811-CIV-MARRA/JOHNSON | | | First Amended Complaint | | | Page 91 of 91 | | COUNSEL LIST Robert Critton, Esquire Burman Critton Luttier & Coleman LLP Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. Bruce E. Reinhart, Esquire Bruce E. Reinhart, P.A. 3505-025 Page 91 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17 EFTA_00003439 EFTA00157821