First amended complaint against Jeffrey Epstein, February 2009

EFTA00175369¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 1 of 91¶

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA¶

CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON¶

Plaintiff(s),¶

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 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 Palm Beach County, Florida.

EFTA00175370¶

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 2002, when she was fifteen-years old and in middle school.

12. The Defendant, JEFFREY EPSTEIN, a wealthy financier with a lavish home, significant wealth, a network of assistants and employees, used his resources and his influence over a vulnerable minor child to engage in a systematic pattern of sexually exploitive behavior.

13. Beginning in approximately late May or early June of 2002, and continuing until approximately August of 2003, the Defendant coerced and enticed the impressionable, vulnerable, and economically deprived then minor Plaintiff to commit various acts of sexual misconduct. These acts occurred, on average, one to three times per week from late May or early June of 2002 until August of 2003. At a bare minimum,

3¶

EFTA00175371¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 5 of 91¶

A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint¶

exploitation of minor children, prostitution, sexual performance by a child, lewd and lascivious assaults, sexual battery, contributing the delinquency of a minor and other crimes, specifically including, but not limited to, those crimes designated in 18 USC §2241, §2242, §2243, §2421, and §2423, criminal offenses outlined in Chapter 800 of the Federal Codes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §39.01; and §827.04.¶

16. The above-described acts took place in Palm Beach County, Florida, at the residence of the Defendant, JEFFREY EPSTEIN. Any assertions by the Defendant, JEFFREY EPSTEIN, that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual exploitation and abuse of a minor child. The Defendant, JEFFREY EPSTEIN, at all times material to this cause of action, knew and should have known of the Plaintiff, .‘s minority.

17. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, the Defendant, JEFFREY EPSTEIN, entered pleas of “guilty” to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purpose of prostitution.

18. As a condition of that plea, and in exchange for the Federal Government not prosecuting the Defendant, JEFFREY EPSTEIN, for numerous federal offenses, Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the

5¶

EFTA00175372¶

Case 9:08-cv-80811-KAM Document 39 Entered 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 2002, 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¶

EFTA00175373¶

Case 9:08-cv-80811-KAM Document 39 Entered 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 2002- 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 ‘s presence. JEFFREY EPSTEIN paid $300 for this encounter.

9¶

EFTA00175374¶

Case 9:08-cv-80811-KAM Document 39 Entered 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¶

EFTA00175375¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 13 of 91¶

A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

First Amended Complaint¶

purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.”¶

35. The Plaintiff, 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, C.M.A.

37. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation,

13¶

EFTA00175376¶

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 2002, 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 ‘s 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¶

EFTA00175377¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 17 of 91¶

C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint¶

has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff,. 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 V¶

Cause of Action Pursuant to 18 USC §2255¶

August of 2002 – Incident 1¶

44. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above.

45. In August of 2002, 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 ‘s presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter.

17¶

EFTA00175378¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 19 of 91¶

A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

First Amended Complaint¶

48. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, , 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¶

EFTA00175379¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 21 of 91¶

vs. Epstein, et al.¶

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¶

EFTA00175380¶

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 of 2002, 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 ‘s 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¶

EFTA00175381¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 25 of 91¶

A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

First Amended Complaint¶

loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, , 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 of 2002 – Incident 2¶

62. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above.

63. For the second time in September of 2002, 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 ‘s presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter.

25¶

EFTA00175382¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 27 of 91¶

vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

First Amended Complaint¶

66. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, , 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¶

EFTA00175383¶

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¶

EFTA00175384¶

Case 9:08-cv-80811-KAM Document 39 Entered 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 of 2002, 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 ‘s 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¶

EFTA00175385¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 33 of 91¶

A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint¶

has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff,, 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 XI¶

Cause of Action Pursuant to 18 USC §2255¶

November of 2002 – Incident 1¶

80. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above.

81. In November of 2002, 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 ‘s presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter.

33¶

EFTA00175386¶

Case 9:08-cv-80811-KAM Document 39 Entered 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, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, 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¶

EFTA00175387¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 37 of 91¶

A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

First Amended Complaint¶

if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.”¶

89. The Plaintiff, 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, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and

37¶

EFTA00175388¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 39 of 91¶

A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

First Amended Complaint¶

93. In December of 2002, 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 ‘s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.

94. As a condition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.”

39¶

EFTA00175389¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 41 of 91¶

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 of 2002 – Incident 2¶

98. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above.

99. For the second time in December of 2002, 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 M.A.’s presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter.

41¶

EFTA00175390¶

Case 9:08-cv-80811-KAM Document 39 Entered 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¶

EFTA00175391¶

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¶

EFTA00175392¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 47 of 91¶

A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

First Amended Complaint¶

111. For the second time in January of 2003, 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 ‘s 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¶

EFTA00175393¶

Case 9:08-cv-80811-KAM Document 39 Entered 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.¶

COUNT XVII¶

Cause of Action Pursuant to 18 USC §2255¶

February of 2003 – Incident 1¶

116. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above.

117. In February 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 ‘s presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter.

49¶

EFTA00175394¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 51 of 91¶

A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

First Amended Complaint¶

120. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, , 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¶

EFTA00175395¶

Case 9:08-cv-80811-KAM Document 39 Entered 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, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and

53¶

EFTA00175396¶

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 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 ‘s 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¶

EFTA00175397¶

Case 9:08-cv-80811-KAM Document 39 Entered 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.¶

COUNT XX¶

Cause of Action Pursuant to 18 USC §2255¶

March of 2003 – Incident 2¶

134. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above.

135. For the second time in March 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 ‘s presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter.

57¶

EFTA00175398¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 59 of 91¶

A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

First Amended Complaint¶

138. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, , 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¶

EFTA00175399¶

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¶

EFTA00175400¶

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 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 ‘s 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¶

EFTA00175401¶

Case 9:08-cv-80811-KAM Document 39 Entered 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.¶

COUNT XXIII¶

Cause of Action Pursuant to 18 USC §2255¶

May of 2003 – Incident 1¶

152. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above.

153. In May of 2003, 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 ‘s presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter.

65¶

EFTA00175402¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 67 of 91¶

A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

First Amended Complaint¶

156. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, , 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¶

EFTA00175403¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 69 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.”¶

161. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government.

162. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, , 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¶

EFTA00175404¶

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 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 ‘s 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¶

EFTA00175405¶

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.¶

COUNT XXVI¶

Cause of Action Pursuant to 18 USC §2255¶

June of 2003 – Incident 2¶

170. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above.

171. For the second time in June 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 ‘s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.

73¶

EFTA00175406¶

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¶

EFTA00175407¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 77 of 91¶

A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

First Amended Complaint¶

if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.”¶

179. The Plaintiff, 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¶

EFTA00175408¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009¶

Page 79 of 91¶

A. vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

First Amended Complaint¶

183. For the second time in July of 2003, 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 ‘s 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¶

EFTA00175409¶

Case 9:08-cv-80811-KAM Document 39 Entered 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.¶

COUNT XXIX¶

Cause of Action Pursuant to 18 USC §2255¶

August of 2003 – Incident 1¶

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 ‘s presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter.

81¶

EFTA00175410¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 8°¶

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¶

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EFTA00175411¶

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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, C.M.A.

199. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, has in the past suffered, and will in the future suffer, physical injury, pain and

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EFTA00175412¶

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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 2002 and August of 2003, 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 Detendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney’s fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.¶

COUNT XXXII¶

Conspiracy to Commit Tortious Assault Against Defendant,¶

205. Plaintiff incorporates into this count the allegations of paragraphs 1 through 19.

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EFTA00175413¶

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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, 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.¶

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EFTA00175414¶

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Pac¶

vs. Epstein, et al.¶

Case No.: 08-CV-80811-CIV-MARRA/JOHNSON¶

First Amended Complaint¶

Page 91 of 91¶

COUNSEL LIST¶

Richard H. Willits, Esquire¶

Richard H. Willits, P.A.¶

2290 10th Avenue North, Suite 404¶

Lake Worth, FL 33461¶

Phone:¶

Fax:¶

Robert Critton, Esquire

Burman Critton Luttier & Coleman LLP

515 North Flagler Drive, Suite 400

West Palm Beach, FL 33414

Phone:

Fax:

Jack A. Goldberger, Esquire¶

Atterbury, Goldberger & Weiss, P.A.¶

250 Australian Avenue South¶

West Palm Beach, FL 33401¶

Phone:¶

Bruce E. Reinhart, Esquire¶

Bruce E. Reinhart, P.A.¶

250 South Australian Avenue¶

Suite 1400¶

West Palm Beach, FL 33401¶

Phone:¶

Fax:¶

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