Draft: efta02774962

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG¶

vs.¶

SCOTT ROTIISTEIN, individually,¶

J. individually, -¶

Defendant/Counter-Plaintiff. CO¶

NOTICE OF E-FILING EXH¶

Plaintiff/Counter-Defendant Jeffrey Epstein, \ by arid through his undersigned counsel and pursuant to Rule 2.516 of the Florida Rules of Judicial Administration, hereby files his exhibits to Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Summary Judgment on Defendant/Counter-Plaintiff Fourth Amended Counterclaim and Supporting Memorandum of Law ("Motion"), previously filed and accepted by the Palm Beach County, Florida Civil Division Filing N 5846906. The files accompanying this Notice of Filing Exhibits were previously filed on September 26, 2013 and again on October 2, 2013, but moved to Pending Queue due to procedural issues. This filing is an attempt to correct those procedural issues. The attachment hereto contains the exhibits to the above referenced Motion, which is not being re-filed contemporaneously herewith. However, the exhibits are being divided based upon the filing requirements of the rules of e-filing; each new exhibit begins when so marked on the is so marked on the bottom of the first page of said exhibit.¶

WE HEREBY CERTIFY that a true and correct copy of the foregoing was served, via electronic service (through the e-file portal), to all parties on the attached service list, this October 3, 2013.¶

/s/ Tonja Haddad Coleman Tonja Haddad Coleman, . Florida Bar No.: 17673 Tonja Haddad, PA 5315 SE 7th S Suite 301 Fort Lauderdal da 33301 954.467.1223 954.337.3716 (facsimile) Attorneys for Epstein

¶

SERVICE LIST¶

CASE NO. 502009CA040800XXXXMBAG¶

Jack Scarola, Esq. jsx@searcylaw.com; mep@searcylaw.com Searcy 2139 Palm Beach Lakes Blvd. 4O4sk Denney Scarola et al. West Palm Beach, FL 33409¶

Jack Goldberger, Esq. jgoldberger@agwpa.com; smahoney@agwpa.com Atterbury, Goldberger, & Weiss, PA West Palm Beach, FL 33401 250 Australian Ave. South Suite 1400¶

4)9¶

iS¶

Marc Nurik, Esq. I East Broward Blvd. Sui Fort Lauderdale, Fl. 33301 ? S' te 700¶

J. , Esq. lfiliathtojustice.com Jaffe Weissing Edw Lehrman 425 N Andrews Avenue Suite 2 Fort Lauderdale, Flori¶

Fred Haddad, Dee@FredHaddadLaw.com 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301¶

W. Chester =, Jr., Esq. wctlawiniol.conv wcbcg@aol.com W. Chester Jr., P.A. One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, FL 33401¶

(con't)¶

Tonja Haddad Coleman, Esquire Tonja@tonjahaddad.com; efiling@tonjahaddad.com Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein¶

Cos¶

From: To: Subject Date: SIM Re: epsteln Tuesday, int 23,20095:28:53 PM¶

Thanks so much. I am going to continue to pursue the Bear Steams angle tomorrow. But, as for now, I will run two graphs citing Radar as the source. It should be up on the web within the hour at www.palmbeachdallyn¶

On 6/23/09 5:22 PM, <bedwardslgarra-law.com> wrote:¶

Unfortunately sht h send the does. I hope she gets them out today. but it may not happen. There is nothing to really comment on. It doesn't surprise me at all that he, despite being a registered sex offender, is being released early, and it also won't be a surprise when he is released without the victims being notified. Par for the course with this case. I will try to get you the dots you want. Set Thursday.¶

J. Partner Rothstein Rosenfeldt Adlert Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale. FL 33301 (954) 522-3458 ?SY (954) 522.6863 - facsimile bedwards@rra-lew.00m¶

From: Michele Carom (plan rganaphriadvrorws coal Seri y 2009 4:37 PM To: 1 Sub ect: Re: epstein¶

Brad, I haven't received those documents yet. Will she be able to forward them to me today?¶

am Ming a story to the web about his release date. Found out It's July 22 and ng Radaronline about his Involvment in the Bear Stearns case.¶

u want to comment on the fact that he's getting released on July 22?¶

On 6/23/09 1:16 PM, J. Mr <bedwardsgrra-law.com> wrote: I sent the request to my secretary and she will send you those does today.¶

J. Partner Rothstein Roserafeldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard. Suite 1650 Fort Lauderdale, FL 33301 (954) 522.3456¶

(954) 522.8663 - facsimile bedwarliserra-law.COm smailicahetiriads.artaziarn¶

From: Michele Dargan imailurrnclarganophdallynews roml, <rnailtoundargan(Bobdailvnews.com5,05d> Seat liguda r, 2009 1:11 PM To J. Subject: Re: epstein¶

Brad, Thanks for the link. 1 appreciate RI Also, would you e-mall those documents that we talked about ur to unseal - and the Posts' atty if she has a separate one an les attorney document that was filed on Friday. Thanks so mucht Michele¶

On 6/23/09 12:52 PM, Mt Abb ym Orra -Iaw.com> wrote: ilito/Movny radarnnline mrrilerrlisiyes/7004/06/nertitve-leffrey-epstein-be•reieacedprison-earty¶

Partner Rothstein Rosonteldt Adler) Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale. F 3330,1,V (954) 522.3456 (954) 522.8663 • fa e bed Wdfd stPrra- la w. co m sinailto;bedwarrilarra -ia w.rom >¶

Michele Dargan, staff writer Palm Beach Daily News (561) ti20-3863 phone (561) 655.4594 fax¶

Front =LBW& To: licbraratamen Subject Epstein applicable gatutes Date: Fridirf, *Umber is, 2039 2:55:00 PM Attachments: Itasalit 133110407.0¶

did not pull the conspiracy version, and convictions of conspiracy would add some amount of time, how much I don't know. I hope this helps.¶

I cut the statutes straight from Westlaw:¶

18 U.S.C.A. § 2422¶

United States Code Annotated Currentness¶

Title 18. Crimes and Criminal Procedure (Refs & Armes),¶

Part 1. Crimes (Refs & Anneal¶

Chanter 117. Transportation for Illegal Sexual Activity and R Anno.al MeS¶

§ 2422. Coercion and enticement¶

(a) Whoever knowingly persuades, Induces, entices, or cberces any Individual to travel in Interstate or foreign commerce, or in any Territory or Possession of the United States,'"to engage in prostitution, or in any sexual activity for which any person can be charged with a criminal offense, or attempts to do so, shall be fined under this title or imprisoned not more than 20 years, or both.¶

(b) Whoever, using the mall or any facility or means of Interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices, or coerces any individual who has not attained the age of :18 years, to engage In prostitution or any sexual activity for which any person can be charged with a criminaloffense, or attempts to do so, shall be fined under this title and imprisoned not less than 10 years or for life¶

18 U.S.C.A. §¶

United States Co e Annotated Currentness¶

Title 18. Crimes and Criminal Procedure (fiefs & Almost¶

Part I. Crimes (Refs & Annos)¶

Chanter 117. Transportation for Illegal Sexual Activity and Related Crimes iRefs_& a¶

23. Transportation of minors

(a) Transportation with intent to engage in criminal sexual activity.--A person who knowingly transports an individual who has not attained the age of 18 years In interstate or foreign commerce, or in any commonwealth, territory or possession of the United States, with Intent that the individual engage in prostitution, or in any sexual activity for which any person can be charged with a criminal offense, shall be fined under this title and imprisoned not less than 10 years nr for lift¶

(b) Travel with intent to engage in illicit sexual conduct.--A person who travels In Interstate commerce or travels into the United States, or a United States Citizen or an¶

alien admitted for permanent residence in the United States who travels In foreign commerce, for the purpose of engaging in any Illicit sexual conduct with another person shall be fined under this title or imorisonori not more than 30 ve/u-s, or both.¶

(c) Engaging in illicit sexual conduct In foreign places.--Any United States Citizen or alien admitted for permanent residence who travels in foreign commerce, and engages in any Illicit sexual conduct with another person shall be fined under this title or imprisoned not more than 30 years, or both.¶

(d) Ancillary offenses.--Whoever, for the purpose of commercial advantage or private financial gain, arranges, Induces, procures, or facilitates the travel of a person knowing that such a person is traveling in interstate commerce or foreign commerce for the purpose of engaging in Illicit sexual conduct shall be fined under this title, Imprisoned not more than 30 years, or both.¶

(e) Attempt and conspiracy.--Whoever attempts or ennsoires to violate subsection (a), fbl. (r). or (dl shall he nimishahle in the same manner as a completed violation of that subsecUnn¶

(f) Definition.--As used in this section, the term "illicit sexual conduct° means (1) a sexual act (as defined in section 2246) with a person under 18 years of age that would be in violation of chapter 109A if the sexual act occurred in the special maritime and territorial Jurisdiction of the United States; or (2) any commercial sex act (as defined in section 1591) with a person under 18 years of age.¶

(g) Defense.--In a prosecution under this Section based on illicit sexual conduct as defined In subsection (0(2), it Is a defense, which the defendant must establish by a preponderance of the evidence, that ;defendant reasonably believed that the person with whom the defendant engaged jtl ge commercial sex act had attained the age of 18 years.¶

18 U.S.C.A. § 1591 ( ..a,¶

United States Code Annotated Currentness.¶

Title 18. Crimes and Criminal Procedure (Rgfs & Annas)¶

Part Crimes /Refs & Annosi¶

chapter 77. Peonage, Slavery, and Trafficking in Persons (Refs & Annos)¶

§ 1591. Sex trafficking of children or by force, fraud, or coercion¶

(a) Whoever knowingly--¶

, (1) In or affecting interstate or foreign commerce, or within the special maritime and obtains, jurisdiction of the United States, recruits, entices, harbors, transports, provides, Obtains, or maintains by any means a person; or¶

(2) benefits, financially or by receiving anything of value, from participation in a venture which has engaged in an act described In violation of paragraph (1),¶

knowing, or in reckless disregard of the fact, that means of force, threats of force, fraud, coercion described in subsection (e)(2), or any combination of such means will be used to cause the person to engage In a commercial sex act, or that the person has not attained the age of 18 years and will be caused to engage in a commercial sex act, shall be punished as provided In subsection (b).¶

(b) The punishment for an offense under subsection (a) is--¶

(1) if the offense was effected by means of force, threats of force, fraud, or coercion described in subsection (e)(2), or by any combination of such means, or if the person recruited, enticed, harbored, transported, provided, or obtained had not attained the age of 14 years at the time of such offense, by a fine under this title and iffloristillMent far Arty term of years not less than IS nr for life• or¶

(2) If the offense was not so effected, and the person recruited, enticed, harbored, transported, provided, or obtained had attained the ane of 14 years hut had nat attained the age of 18 years at the time of siirh offense hv a fine under this title imprisonment for_not less than 10 years or fnr life.¶

(c) In a prosecution under subsection (a)(1) in which the defendant had a reasonable opportunity to observe the person so recruited, enticed, harbored, transported, provided, obtained or maintained the Government nerd not prove that the_defendant knew that the person had not attained the age of 18 years.¶

(d) Whoever obstructs, attempts to obstruct, or in any way interferes with or prevents the enforcement of this section, shall be fined under t1s titt imprisoned for a term not to exceed 20 years, or both.¶

(e) In this section:¶

(1) The term "abuse or threatened abuse Of law legal process" means the use or threatened use of a law or legal process, whether administrative, civil, or criminal, in any manner or for any purpose for which the law was not designed, In order to exert pressure on another person to cause that person to take some action or refrain from taking some action.¶

(2) The term "coercion" m¶

(A) threats of serious physical restraint against any person;¶

(B) any scheme, pla or pattern intended to cause a person to believe that failure to perform an act would t in serious harm to or physical restraint against any person; or¶

(C) the abuse o !threatened abuse of law or the legal process.¶

term "commercial sex act" means any sex act, on account of which anything of given to or received by any person.¶

term "serious harm" means any harm, whether physical or nonphysical, including logical, financial, or reputational harm, that is sufficiently serious, under all the surrounding circumstances, to compel a reasonable person of the same background and In the same circumstances to perform or to continue performing commercial sexual activity In order to avoid incurring that harm.¶

(5) The term "venture' means any group of two or more individuals associated in fact, whether or not a legal entity.¶

Twelfth, Section 206 of the Adam Walsh Act added 18 nal to the list of offenses for which a defendant is to be sentenced to life under 18 U S.C. 3459felf21fAt The amendment adds 18 USA- +4,41to the list of instant offenses of convictions that are¶

covered sex crimes under § 4B1.5.¶

USSG, Ch. TWO, Pt. A, Refs & Annos, 18 U.S.C.A.¶

United States Code Annotated Currentness
Federal Sentencing Guidelines
Chapter Two. Offense Conduct¶

Part A. Offenses Against the Person¶

3. Criminal Sexual Abuse and Offenses Related to Registration as a Sex Offender

HISTORICAL NOTES¶

2007 Amendments¶

Chapter Two, Part A, Subpart Three, is amended in the heading by adding at the end "AND OFFENSES RELATED TO REGISTRATION AS A SEX OFFENDER".¶

Reason for Amendment: This amendment responds to the Adam Walsh Child Protection and Safety Act of 2006 (the "Adam Walsh Act"), Pub.L. 109-248, which contained a directive to the Commission, created new sexual offenses, and enhanced penalties for existing sexual offenses. The amendment implements the directive by creating two new guidelines, §§ 2A3.5 (Criminal Sexual Abuse and Offenses Related to Registration as a Sex Offender) and 2A3.6 (Aggravated Offenses Relating to Registration as a Sex Offender). It further addresses relevant provisions in the Adam Walsh Act by making changes to Chapter Two, Part A, Subpart 3 (Criminal Sexual Abuse) and Part G (Offenses Involving Commercial Sex Acts, Sexual Exploitation of Minors, and Obscenity), § 2J1.2 (Obstruction of Justice), § 3D1.2 (Groups of Closely Related Counts), § 4B1.5 (Repeat and Dangerous Sex Offender Against Minors), § 5B1.3 (Conditions of Probation), § 5D1.2 (Term of Supervised Release), § 5D1.3 (Conditions of Supervised Release) and Appendix A (Statutory Index).¶

First, section 206 of the Adam Walsh Act amended 18 U.S.C. 2241(c) to add a new mandatory minimum term of imprisonment of 30 years for offenses related to the aggravated sexual abuse of a child under 12 years old, or of a child between 12 and 16 years old if force, threat, or other means was used. In response to the new mandatory minimum for these offenses, the amendment increases the base offense level at § 2A3.1 (Criminal Sexual Abuse; Attempt to Commit Criminal Sexual Abuse) from level 30 to level 38. The base offense level of 30 has been retained for all other offenses. At least one specific offense characteristic applied to every conviction under 18 U.S.C. 2241(c) sentenced under § 2A3.1 in fiscal year 2006. Accordingly, the mandatory minimum 360 months' imprisonment is expected to be reached or exceeded in every case with a base offense level of 38.¶

The amendment provides a new application note that precludes application of the specific offense characteristic at § 2A3.1(b)(1) regarding conduct described in 18 U.S.C. 2241(a) or (b) if the conduct that forms the basis for a conviction under 18 U.S.C. 2241(c) is that the defendant engaged in conduct described in 18 U.S.C. 2241(a) or (b) (force, threat, or other means). The amendment also precludes application of the specific offense characteristic for the age of a victim at § 2A3.1(b)(2) if the defendant was convicted under section 2241(c). The heightened base offense level of 38 takes into account the age of the victim. These instructions, therefore, avoid unwarranted double counting.¶

Second, section 207 of the Adam Walsh Act increased the statutory maximum term of imprisonment under 18 U.S.C. 2243(b) from 5 years to 15 years for the sexual abuse of a person in official detention or under custodial authority. In response to increased penalty,¶

the amendment increases the base offense level from 12 to 14 in § 2A3.3 (Criminal Sexual Abuse of a [REDACTED] or Attempt to Commit Such Acts). The amendment also adds a new definition of "minor" consistent with how this term is defined elsewhere in the guidelines manual. In addition, the amendment includes an application note precluding application of § 3B1.3 (Abuse of Position of Trust or Use of Special Skill) for these offenses because an abuse of position of trust is assumed in all such cases and, therefore, is built into the base offense level.¶

Third, section 206 of the Adam Walsh Act created a new subsection at 18 U.S.C. 2244. Section 2244(a)(5) provides a penalty of any term of years if the sexual conduct would have violated 18 U.S.C. 2241(c) had the contact been a sexual act. Section 2241(c) conduct involves the aggravated sexual abuse of a child under 12 years old or of a child between 12 and 16 years old if force, threat, or other means was used, as defined in 18 U.S.C. 2241(a) and (b). Prior to the Adam Walsh Act, the penalty for offenses involving children under 12 years old was "twice that otherwise provided," and the penalty for sexual contact involving behavior described in 18 U.S.C. 2241 was a statutory maximum term of imprisonment of 10 years.¶

The amendment addresses this new offense by increasing the minimum offense level in the age enhancement in subsection (b)(1) of § 2A3.4 (Abusive Sexual Contact or Attempt to Commit Abusive Sexual Contact) from level 20 to level 22.¶

Fourth, section 141 of the Adam Walsh Act created a new offense under 18 U.S.C. 2250(a) for the failure to register as a sex offender. The basic offense carries a statutory maximum term of imprisonment of 10 years. Section 141 also included a directive to the Commission that when promulgating guidelines for the offense, to consider, among other factors, the seriousness of the sex offender's conviction that gave rise to the requirement to register; relevant further offense conduct during the period for which the defendant failed to register; and the offender's criminal history.¶

The amendment creates a new guideline, § 2A3.5 (Failure to Register as a Sex Offender), to address the directive. The new guideline provides three alternative base offense levels based on the tiered category of the sex offender: level 16 if the defendant was required to register as a Tier III offender; level 14 if the defendant was required to register as a Tier II offender; and level 12 if the defendant was required to register as a Tier I offender.¶

The amendment also provides two specific offense characteristics. First, subsection (b)(1) provides a tiered enhancement to address criminal conduct committed while the defendant is in a failure to register status. Specifically, § 2A3.5(b)(1) provides a six-level increase if, while in a failure to register status, the defendant committed a sex offense against an adult, a six-level increase if the defendant committed a felony offense against a minor, and an eight-level increase if the defendant committed a sex offense against a minor. Second, § 2A3.5(b)(2) provides a three-level decrease if the defendant voluntarily corrected the failure to register or voluntarily attempted to register but was prevented from registering by uncontrollable circumstances, and the defendant did not contribute to the creation of those circumstances. The reduction covers cases in which (1) the defendant either does not attempt to register until after the relevant registration period has expired but subsequently successfully registers, thereby correcting the failure to register status, or (2) the defendant, either before or after the registration period has expired, attempted to register but circumstances beyond the defendant's control prevented the defendant from successfully registering. An application note specifies that the voluntary attempt to register or to correct the failure to register must have occurred prior to the time the defendant knew or reasonably should have known a jurisdiction had detected the failure to register. The application note also provides that the reduction does not apply if the enhancement for committing one of the enumerated offenses in § 2A3.5(b)(1) applies.¶

Additionally, the amendment adds § 2A3.5 to the list of offenses that are considered groupable under § 3D1.2(d) because the failure to register offense is an ongoing and continuous offense.¶

Fifth, section 141 of the Adam Walsh Act created two new aggravated offenses relating to the registration as a sex offender. Section 141 of the Act created 18 U.S.C. 2250(c), which carries a mandatory minimum term of imprisonment of 5 years and a statutory maximum term of imprisonment of 30 years if a defendant commits a crime of violence while in a failure to register status, with the sentence to be consecutive to the punishment provided for the failure to register. Section 702 of the Adam Walsh Act created a new offense at 18 U.S.C. 2260A that prohibits the commission of various enumerated offenses while in a failure to register status. The penalty for this offense is a mandatory term of imprisonment of 10 years to be imposed consecutively to the underlying offense.¶

The amendment creates a new guideline at § 2A3.6 (Aggravated Offenses Relating to Registration as a Sex Offender) to address these new offenses. The new guideline provides that for offenses under section 2250(c), the guideline sentence is the minimum term of imprisonment required by statute, and for offenses under section 2260A, the guideline sentence is the term of imprisonment required by statute. Chapters Three and Four are not to apply. This is consistent with how the guidelines treat other offenses that carry both a specified term of imprisonment and a requirement that such term be imposed consecutively. See §§ 3D1.1 (Procedure for Determining Offense Level on Multiple Counts) and 5G1.2 (Sentencing on Multiple Counts of Conviction).¶

The guideline includes an application note that provides an upward departure stating that a sentence above the minimum term required by section 2250(c) is an upward departure from the guideline sentence. An upward departure may be warranted, for example, in a case involving a sex offense committed against a minor or if the offense resulted in serious bodily injury to a minor.¶

Sixth, section 208 of the Adam Walsh Act added a new mandatory minimum term of imprisonment of 15 years under 18 U.S.C. 1591(b)(1) for sex trafficking of an adult by force, fraud, or coercion. In response, the amendment provides a new base offense level of 34 in § 2G1.1 (Promoting a Commercial Sex Act or Prohibited Sexual Conduct with an Individual Other than a Minor) if the offense of conviction is 18 U.S.C. 1591(b)(1), but retains a base offense level of 14 for all other offenses. In addition, the amendment limits application of the specific offense characteristic at § 2G1.1(b)(1) that applies if the offense involved fraud or coercion only to those offenses receiving a base offense level of 14. Offenses under 18 U.S.C. 1591(b)(1) necessarily involve fraud and coercion and, therefore, such conduct is built into the heightened base offense level of 34. This limitation thus avoids unwarranted double counting.¶

Seventh, section 208 of the Adam Walsh Act added a new mandatory minimum term of imprisonment of 15 years under 18 U.S.C. 1591(b)(1) for sex trafficking of children under 14 years of age and added a new mandatory minimum term of imprisonment of 10 years and increased the statutory maximum term of imprisonment from 40 years to life under 18 U.S.C. 1591(b)(2) for sex trafficking of children who had attained the age of 14 years but had not attained the age of 18 years. Further, the Adam Walsh Act increased the mandatory minimum term of imprisonment from 5 years to 10 years and increased the statutory maximum term of imprisonment from 30 years to life under both 18 U.S.C. 2422(b), for persuading or enticing any person who has not attained the age of 18 years to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense, and 18 U.S.C. 2423(a), for transporting a person who has not attained the age of 18 years in interstate or foreign commerce, with the intent that the person engage in prostitution, or in any sexual activity for which any person can be charged with¶

a criminal offense.¶

In response, the amendment provides alternative base offense levels in § 2G1.3 (Promoting a Commercial Sex Act or Prohibited Sexual Conduct with a Minor; Transportation of Minors to Engage in a Commercial Sex Act or Prohibited Sexual Conduct; Travel to Engage in Commercial Sex Act or Prohibited Sexual Conduct with a Minor; Sex Trafficking of Children; Use of Interstate Facilities to Transport Information about a Minor) based on the statute of conviction and the conduct described in that conviction. For convictions under 18 U.S.C. 1591(b)(1), the base offense level is 34. For convictions under 18 U.S.C. 1591(b)(2), the base offense level is 30.¶

The amendment further provides a base offense level of 28 for convictions under 18 U.S.C. 2422(b) and 2423(a). The two-level enhancement for the use of a computer at § 2G1.3(b)(3) applied to 95 percent of offenders convicted under 18 U.S.C. 2422(b) and sentenced under § 2G1.3 in fiscal year 2006. In addition, the two-level enhancement for the offense involving a sexual act or sexual contact at § 2G1.3(b)(4) applied to 95 percent of offenders convicted under 18 U.S.C. 2423(a) and sentenced under this guideline in fiscal year 2006. With application of either enhancement, the mandatory minimum term of imprisonment of 120 months will be reached in the majority of convictions under 18 U.S.C. 2422(b) and 2423(a), before application of other guidelines adjustments.¶

Further, the amendment addresses the interaction of two specific offense characteristics with the alternative base offense levels. First, every conviction under 18 U.S.C. 1591 necessarily involves a commercial sex act. With the base offense levels being determined based on the statute of conviction, the amendment clarifies that § 2G1.3(b)(4)(B), which provides a two-level enhancement if the offense involved a commercial sex act, does not apply if the defendant is convicted under 18 U.S.C. 1591. Second, the amendment precludes application of the age enhancement in § 2G1.3(b)(5) if the base offense level is determined under subsection (a)(1) of § 2G1.3 for a conviction under 18 U.S.C. 1591(b)(1). The base offense level provided by subsection (a)(1) of § 2G1.3 takes into account the age of the victim and, therefore, limitations on application of subsections (b)(4)(B) and (b)(5) of § 2G1.3 avoid unwarranted double counting.¶

Eighth, section 503 of the Adam Walsh Act created a new section, 18 U.S.C. 2257A, adopting new recordkeeping obligations for the production of any book, magazine, periodical, film, videotape, or digital image that contains a visual depiction of simulated sexually explicit conduct. Section 2257A has a statutory maximum of one year imprisonment for the failure to comply with the recordkeeping requirements and a statutory maximum term of imprisonment of five years if the violation was to conceal a substantive offense that involves either causing a minor to engage in sexually explicit conduct for the purpose of producing a visual depiction or trafficking in material involving the sexual exploitation of a minor. The new offense is similar to 18 U.S.C. 2257, which is referenced to § 2G2.5 (Recordkeeping Offenses Involving the Production of Sexually Explicit Materials; Failure to Provide Required Marks in Commercial Electronic Mail). Accordingly, the amendment refers the new offense to § 2G2.5.¶

Ninth, section 701 of the Adam Walsh Act created a new offense in 18 U.S.C. 2252A(g) that prohibits engaging in child exploitation enterprises, defined as violating 18 U.S.C. 1591, 1201 (if the victim is a minor), chapter 109A (involving a minor victim), chapter 110 (except for 18 U.S.C. 2257 and 2257A), or chapter 117 (involving a minor victim), as part of a series of felony violations constituting three or more separate incidents and involving more than one victim, and committing those offenses in concert with three or more other people. The statute provides a mandatory minimum term of imprisonment of 20 years.¶

The amendment creates a new guideline at § 2G2.6 (Child Exploitation Enterprises) to cover this new offense. The guideline provides a base offense level of 35 and four specific¶

offense characteristics. The Commission anticipates these offenses typically will involve conduct encompassing at least one of the specific offense characteristics, resulting in an offense level of at least level 37. Thus, the mandatory minimum term of imprisonment of 240 months typically is expected to be reached or exceeded, before application of other guideline adjustments.¶

Tenth, section 206 of the Adam Walsh Act increased the statutory maximum term of imprisonment from 4 years to 10 years under 18 U.S.C. 2252B(b) for knowingly using a misleading domain name with the intent to deceive a minor into viewing material harmful to minors on the Internet. In addition, section 703 of the Act created a new section, 18 U.S.C. 2252C, that carries a statutory maximum term of imprisonment of 10 years for knowingly embedding words or digital images into the source code of a Web site with the intent to deceive a person into viewing material constituting obscenity. Section 2252C(b) carries a statutory maximum term of imprisonment of 20 years for knowingly embedding words or digital images into the source code of a Web site with the intent to deceive a minor into viewing material harmful to minors on the Internet.¶

In response to the new offense, the amendment expands the scope of subsection (b)(2) of § 2G3.1 (Importing, Mailing, or Transporting Obscene Matter; Transferring Obscene Matter to a Minor; Misleading Domain Names) by adding to this enhancement "embedded words or digital images into the source code on a Web site."¶

Eleventh, section 141 of the Adam Walsh Act added a new provision in 18 U.S.C. 1001 that carries a statutory maximum term of imprisonment of 8 years for falsifying or covering up by any scheme or making materially false or fraudulent statements or making or using any false writings or documents that relate to offenses under chapters 109A, 109B, 110, and 117, and under section 1591 of chapter 77. The amendment adds a new specific offense characteristic at subsection (b)(1)(A) of § 2J1.2 (Obstruction of Justice) enhancing the offense level by four levels if the defendant was convicted under 18 U.S.C. 1001 and the statutory maximum term of 8 years' imprisonment applies because the matter relates to sex offenses. The amendment also added language to Application Note 4 stating an upward departure [REDACTED] by warranted under the guideline in a case involving a particularly serious sex offense.¶

Twelfth, section 206 of the Adam Walsh Act added 18 U.S.C. 1591 to the list of offenses for which a defendant is to be sentenced to life under 18 U.S.C. 3559(e)(2)(A). The amendment adds 18 U.S.C. 1591 to the list of instant offenses of convictions that are covered sex crimes under § 4B1.5.¶

Thirteenth, section 141 of the Adam Walsh Act amended 18 U.S.C. 3563 and 3583. The amendment adds a new subdivision to (a)(9) of § 5B1.3 and to (a)(7) of § 5D1.3 to require a defendant to comply with the new registration requirements provided by the Adam Walsh Act. The amendment also modifies the language in §§ 5B1.3(a)(9) and 5D1.3(a)(7) relating to defendants convicted of a sexual offense described in 18 U.S.C. 4042(c)(4). Not all states have implemented the new requirements, continuing to register sex offenders pursuant to the sex offender registry in place prior to July 27, 2006, the date of enactment of the Adam Walsh Act. Thus, it is necessary to maintain the language in the guidelines providing for conditions of probation and supervised release for those offenders.¶

Fourteenth, section 141 of the Act amended 18 U.S.C. 3583(k), which provides that the authorized term of supervised release for any offense under enumerated sex offenses is any term of years or life. In response, the amendment adds offenses under chapter 109B and sections 1201 and 1591 of title 18 United States Code or 18 U.S.C. 1201 and 1591 to the definition of sex offense under § 5D1.2(b)(2) for which the length of the term of supervised release shall be not less than the minimum term of years specified for the offense and may be up to life.¶

( Finally, the amendment provides a definition of "minor In relevant guidelines that is consistent with how this term Is defined elsewhere in the guidelines. Outdated background commentary also is deleted by this amendment. The e date of this amendment is November 1, 2007.¶

AO¶

J. Partner Rothstein Rossnfeldt /WW) Las Olas City Centre 401 East Las Olas Boulev Fort Lauderdale. FL 333 (954) 522.3456 (954) 522-8663 - facsimile besimardagrottlawaitar¶

+6\¶

From: csarnoff1@verizon.net¶

Sent: Sep 24, 2009 20:45:34¶

To: [REDACTED] J. [REDACTED]¶

Cc:¶

Bec:¶

Subject: T Visas¶

Please read this important. I think you can offer a trafficked victim protection, asylum and an incentive for coming forward on the case. Ask your clients if they know of any victims who were foreign so they can tell them about this and assuage their fears! This is a break through for some of the girls, because they'll be able to bring their families into the US on these visas.¶

According to Acosta some 7000 visas are issued annually and the last time he checked only 1500 -2000 apply annually. That means that the word is NOT out about the visas (on purpose may I add and furthermore, that there is ZERO effort on the part of law enforcement to get it out, fear of having visa abused!!!!)¶

More importantly, How are you feeling? Hope you're healing quickly!!!¶

Conchita¶

Congress passes Violence Against Women Act of 2000
Immigrants' Rights Update, Vol. 14, No. 6, October 19, 2000¶

Passed by Congress on Oct. 11, 2000, the Victims of Trafficking and Violence Protection Act of 2000 (H.R. 3244) includes the Violence Against Women Act of 2000 (VAWA 2000), which expands and improves on the protections for battered spouses and children that were originally enacted in the Violence Against Women Act of 1994 (VAWA 1994).¶

Most notably, VAWA 2000 eliminates the ""extreme hardship"" requirement for self-petitioners and allows all self-petitioners to adjust their status in the United States. The act also creates two new nonimmigrant visas for victims of trafficking and for victims of certain serious crimes, including victims of crimes against women (see ""Congress Creates New ""T"" and ""U"" Visas for Victims of Exploitation ""). Individuals granted these visas may subsequently adjust to permanent resident status. The bill passed both houses by enormous margins (371-1 in the House and 95-0 in the Senate), and President Bill Clinton has promised to swiftly sign it.¶

VAWA 1994. The original VAWA included provisions to address the particular problems faced by battered immigrant women and children. Under pre-VAWA immigration law, immigrant spouses and children of U.S. citizens or lawful permanent residents (LPRs) were dependent on the citizen or LPR to petition to immigrate them, and this dependency left them particularly subject to abuse on the part of that relative. The VAWA created a procedure whereby abused spouses and their children or abused children and their parents can ""self-petition"" to obtain LPR status without the cooperation of the abusing relative. The VAWA also enabled battered spouses and children to obtain suspension of deportation or cancellation of removal if they were present in the U.S. for at least three years rather than¶

the seven years normally required for suspension or ten years for cancellation.¶

Obstacles based on family/marital status removed. VAWA 2000 removes a number of obstacles that battered spouses and children have encountered in attempting to use provisions of the VAWA intended to help them. For example, a battered spouse whose marriage is defective because her husband failed to tell her that he was already married is not eligible to immigrate under VAWA 1994. VAWA 2000 corrects this problem by allowing individuals who believed that they were married to a U.S. citizen or LPR to self-petition. VAWA 2000 also allows individuals to self-petition even though they have been divorced from the citizen or LPR, provided that the marriage terminated within the past two years and a connection between the termination of the marriage and the abuse of the immigrant can be shown. These changes also apply to VAWA suspension of deportation and cancellation of removal. Moreover, individuals may self-petition even if the citizen relative has died, provided they petition within two years of the death.¶

No need to leave U.S. to apply for VAWA visa. The new law allows all VAWA self-petitioners to apply for adjustment of status in the United States, regardless of whether they were inspected when they entered the country or whether they subsequently maintained lawful status.¶

""Extreme Hardship"" and other requirements for VAWA self-petitioners. The act also eliminates the disparate treatment of self-petitioners who, under prior law, had to meet certain requirements not applied to regular family immigrant visa applicants. Most significantly, self-petitioners no longer need to show that their deportation would cause ""extreme hardship."" This eliminates an enormous evidentiary hurdle from the self-petition procedure. The law also allows abused spouses and children of U.S. employees and military personnel living abroad to self-petition.¶

Under the new law, if the U.S. citizen or LPR parent or spouse subsequently loses that status for reasons related to their abusive conduct, the loss does not affect the abused immigrant's eligibility to immigrate if they petition within two years. Moreover, abused immigrants with approved self-petitions may remarry without causing the petition to be revoked.¶

Good moral character. Self-petitioners under the new law still must show that they have ""good moral character."" However, the new law partially exempts them from the bar on establishing good moral character outlined in INA section 101(f). Under that provision, immigrants cannot establish good moral character if they have committed or been convicted of certain criminal acts. The new law removes the bar if the act constitutes a ground of admissibility or deportability that is waivable, and the act was connected to the abuse the applicant suffered. This rule also applies to applicants for VAWA suspension or cancellation.¶

Children who ""age out."" Under the act, children who have filed a self-petition or are derivative beneficiaries of a parent's petition no longer ""age out,"" or become subject to normal family visa rules, when they become 21 years old. Instead, they are treated as self-petitioners under the appropriate category (as unmarried sons or daughters of U.S. citizens or LPRs, or married sons or daughters of citizens), with the parent's priority date.¶

Relaxed continuous physical presence requirement. The act allows applicants for VAWA cancellation of removal to show that they have three years' continuous physical presence in the U.S., despite a single absence longer than 90 days or cumulative absences exceeding 180 days, if there is a connection between the absence and the abuse perpetrated against the applicant. The act also eliminates application of the "'stop-time rule'" (under which service of a Notice to Appear stops the accrual of continuous physical presence) in VAWA cancellation and suspension cases. And it requires the attorney general to parole the children or parents of individuals who are granted VAWA suspension or cancellation.¶

Motions to reopen. The act allows individuals who become eligible for VAWA suspension or cancellation because of the changes made by the new law to move to reopen their proceedings. It also amends the INA's time limitations on motions to reopen, allowing individuals to file a motion to reopen to apply for VAWA cancellation within one year of the entry of a final order. The attorney general may also waive the one-year limitation in cases of extraordinary circumstances or extreme hardship to a child.¶

New waivers of grounds of inadmissibility and deportability. The act establishes waivers of certain grounds of inadmissibility for abused immigrants. There is a waiver of the ground of inadmissibility for reentering the U.S. without inspection following a one-year period of unlawful presence or after having been ordered removed. This waiver is available to individuals who can establish a connection between the abuse they suffered and their departure or reentry.¶

There is also a waiver of the ground of deportability for having a conviction for a crime of domestic violence or for violation of a protective order, if the abused immigrant can show that she was not the primary perpetrator of violence in the relationship. She must also show that she was acting in self-defense or that the crime did not result in serious bodily injury and was connected to the abuse that the immigrant suffered.¶

The act makes available to abused immigrants the INA's waivers for certain criminal grounds (§ 212(h)), fraud or misrepresentation (§ 212(i)), and health grounds (§ 212(g)). Expanding the availability of these waivers was considered necessary because they had been limited to spouses of U.S. citizens or LPRs. Abused immigrants may no longer have such a relationship.¶

Public charge. The act amends the public charge ground of exclusion to provide that cash or other benefits received pursuant to 8 U.S.C. section 1641(c) (which permits VAWA beneficiaries to obtain cash and other government assistance in connection with their escape from domestic violence) may not be considered in public charge determinations.¶

Changes to Cuban Adjustment Act, NACARA, and HRIFA. The act also amends the Cuban Adjustment Act, the adjustment of status provisions of the Nicaraguan Adjustment and Central American Relief Act (NACARA), and the Haitian Refugee Immigration Fairness Act (HRIFA). These amendments allow abused spouses or children who are dependents of individuals eligible for relief under these laws to adjust their status, without having to reside with the principal or maintain the relationship. Under the act, persons who become LPRs through VAWA may also apply for naturalization after they have resided in the U.S. in LPR status for three years.¶

Sep 24, 2009 08:34:02 PM, bedwards©rra-law.com wrote:¶

Long day. I will call you tomorrow. Client went through hell today.¶

Message-----¶

From: csamoffl@verizon.net (mailto:csarnoffl©verizon.net]¶

Sent: Thursday Se 24, 2009 10:39 AM¶

To: J.¶

Subject: Not a mention of the name after a 2 112 hour interview¶

Sent via Blacicilerry from "1'-Mobile S )¶

' C¶

From: Michele Dargan Sent: Jul 29 2009 13:47:51 To: Cc: Bcc: Subject: Re: Epstein¶

Brad,¶

We have no way of getting the members or the banned members lists.¶

However, I spoke to Donald 'Frump today — nothing like getting it from the horse's mouth!¶

Anyway, he said Epstein is not a member and would not confirm or dtny that he ever was a member. He would not comment at all (which is very rare for him) on wheth at Epstein got booted from the club or if he had recruited girls front Mar-A-Lago.¶

Sorry I couldn't be more help. I really thought that he mething. He usually does comment for all of our stories. That's why this was quite emus¶

If you get any info, please pass it on....like if ones out during depos of anything related to Epstein getting booted from the club or abot im sting girls from there. You know I will run with it!¶

Michele¶

On 7/28/09 9:28 AM, ""Bradley J. $dWards"" wrote:¶

Hi Michele,¶

I was wondering if you were able to get a members list at the Maralago, and even more importantly if you were able to get a list of banned members from the Maralago? Rumor has it that he was banned for having sex with and attempting to have sex with minors at the club, and we already know of certain minors that he took from the club to his house. I will take a deposition of someone there if we need to do that to get the true information on this, but there are so many depositions to take in this case (and we are setting them right now around the country) that I would like to avoid this one if we could get the info another way.¶

Thanks¶

J. Partner¶

Risaky,E4wards017032^0.42,1Contem Inm¶

Rothstein Rosenfeldt Adler' Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 (954) 522-3456 (954) 522-8663 - facsimile bedwards@rra-law.com¶

04 (561) 655-4594 fax¶

Michele Dargan, staff writer Palm Beach Daily News (561) 820-3863 phone¶

From: Michele Dargan Sent: Jul 31, 2009 11:20:03 To: J. Cc: Bcc: Subject: Re: Epstein¶

Brad,¶

I didn't get your e-mail until 1 got in this morning (Friday) so it was too late....cl this morning, right? Anything interesting? it took place¶

On 7/30/09 6:06 PM, "a J. M ."' wrote:¶

Michele, I forgot to tell you that I have a hearing in Hafel motion to add punitive damages. Should be some irate been said before. n (HB I think) at 8:30 on our said for you. Things that have not¶

J. Partner Rothstein Rosenfeldt Adlerf Attorn Las Ohs City Centre 401 East Las Olas Boulevard, S Fort Lauderdale, FL 33301 (954) 522-3456 (954) 522-8663 - ins' tile bedwards@rra-law.co¶

Froint7G1781Rte Dargan [mailto:mdargan®pbdailynews.com] Sent: Wednesditia29, 2009 1:48 PM To: J. Subject: Re. Epstein¶

Brad,¶

( 14/ o¶

We have no way of getting the members or the banned members lists.¶

liowever, I spoke to Donald Trump today — nothing like getting it from the horse's mouth!¶

Anyway, he said Epstein is not a member and would not confirm or deny that he ever was a member. He would not comment at all (which is very rare for him) on whether or not Epstein got booted from the club or if he had recruited girls from Mar-A-Lago.¶

Sorry I couldn't be more help. I really thought that he would say something. He usually does comment for all of our stories. That's why this was quite unusual.¶

If you get any info, please pass it on....like if any info comes out during depos of anything related to Epstein getting booted from the club or about him recruiting girls from there. Yost know I will run with it! co¶

Michele¶

On 7/28/09 9:28 AM, "")_3. " wrote: Hi Michele, / 6'¶

I was wondering if you were able to get a members list at the Maialago, and even more importantly if you were able to get a list of banned members from the Maralago? Rumor has it that he was banned for having sex with and attempting to have sex with minors at the club, and we already know of certain minors that he took from the club to his house. I will take a deposition of someone there if we need to do that to get the true information on this, but therkare so many depositions to take in this case (and we are setting them right now around the counpflhat fl ould like to avoid this one if we could get the info another way.¶

Thanks¶

J. Partner Rothstein Rosenfeld( Adler! Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, FL 33301 (954) 522-3456 (954) 522-8663 - facsimile bedwards@irra-law.com¶

--
Michele Dargan, staff writer
Palm Beach Daily News
(561) 820-3863 phone
(561) 655-4594 fax¶

From: =J. Sent: Jul 30, 2009 14:36:23 To: Michele Dargan Cc: lice: Subject: RE: Epstein¶

Thank you. We have our answer then. All the pieces are public record - Complaint f by Josephsberg regarding Epstein being at the club with Ghislaine Maxwell and taking a 15 year of with him, a newspaper article that indicated he was banned for similar conduct (don't remember who published it but I read it a few months back), and a no comment from Trump. He's banned. Don't worry, we will get the official word. We are setting many depositions soon and certain people ttlpttl set will know that inthrmation. I will keep you informed. Good work. I'll be in touch.¶

J.¶

"S 4)9¶

Partner¶

Rothstein Rosenfeldt Adler' Attorneys at Law¶

Las Olas City Centre¶

401 East Las Olas Boulevard, Suite¶

Fort Lauderdale, FL 33301¶

(954) 522-3456¶

(954) 522-8663 - faesirn!*¶

bedwards®rra-law.com¶

From: Michele Dargan [mailto:mdargan®pbdailynews.com)¶

Sent: Wednesdi.29, 2009 1:48 PM¶

To: J.¶

Subject: Re: Epstein¶

Brad,¶

We have no way of getting the members or the banned members lists.¶

However, I spoke to Donald Trump today - nothing like getting it from the horse's mouth!¶

Anyway, he said Epstein is not a member and would not confirm or deny that he ever was a member. He would not comment at all (which is very rare for him) on whether or not Epstein got booted from the club or if he had recruited girls from Mar-A-Lago.¶

Sorry I couldn't be more help. I really thought that he would say something. He usually, does comment for all of our stories. That's why this was quite unusual.¶

If you get any info, please pass it on....like if any info comes out during depos of anything related to Epstein getting booted from the club or about him recruiting girls from there. You know I will run with it!¶

Michele¶

On 7/28/09 9:28 AM, "a J. 1" wrote: "Sc )¶

Hi Michele,¶

I was wondering if you were able to get a in lt~at the Maralago, and even more importantly if you were able to get a list of banned mem m e Maralago? Rumor has it that he was banned for having sex with and attempting to have sex wr inors at the club, and we already know of certain minors that he took from the club to his house, I will take a deposition of someone there if we need to do that to get the true information on this, but there are so many depositions to take in this case (and we are setting them right now around the country) that I would like to avoid this one if we could get the info another way.¶

Thanks¶

Partner¶

Rothstein ftosenfel Adler' Attorneys at Law¶

Las Olas City antre¶

401 East Las Mrs Boulevard, Suite 1650¶

Fort Lauderdale, FL 33301¶

(954) 522-3456¶

(954) 522-8663 - facsimile¶

bedwards®rra-law.com¶

--
Michele Dargan, staff writer
Palm Beach Daily News
(561) 820-3863 phone
(561) 655-4594 fax¶

From: El Sent: Jul 30, 2009 18:06:49 To: Michele Dargan Cc: Bcc: Subject: RE: Epstein¶

Michele, I forgot to tell you that I have a hearing in Hafele's courtroom (118 1 think) 48:30 on our motion to add punitive damages. Should be some interesting things said for you,_11;thiga,Lhat have not been said before.¶

J.¶

Partner¶

Rothstein Roscnfeldt Adlerl Attorneys at Law¶

Las Olas City Centre¶

401 East Las Olas Boulevard, Suite 1650¶

Fort Lauderdale, FL 33301¶

(954) 522-3456¶

(954) 522-8663 - facsimile¶

bedwards®rra-law.com¶

From: Michele `D n [mailtoandargan@pbdailynews.com]¶

Sent: Wednesd.129, 2009 1:48 PM¶

To: J.¶

Subject: Re: Epstein¶

C GC¶

Brad,¶

We have no way of getting the members or the banned members lists.¶

However, I spoke to Donald Trump today - nothing like getting it from the horse's mouth!¶

Anyway, he said Epstein is not a member and would not confirm or deny that he ever was a member. would not comment at all (which is very rare for him) on whether or not Epstein got booted from the club or if he had recruited girls from Mar-A-Lago.¶

lo¶

Sorry I couldn't be more help. I really thought that he would say something. He usually does comment for all of our stories. That's why this was quite unusual.¶

If you get any info, please pass it on....like if any info comes out during depos of anything related to Epstein getting booted from the club or about him recruiting girls fromibecou know I will run witl it!¶

Michele¶

On 7/28/09 9:28 AM, "" J. " wrote:¶

Hi Michele,¶

I was wondering if you were able to get a IDA Jist at the Maralago, and even more importantly if you were able to get a list of banned members from the Maralago? Rumor has it that he was banned for having sex with and attempting to have sex with minors at the club, and we already know of certain minors that he took from the club to his house. I will take a deposition of someone there if we need to c that to get the true information on this, but there are so many depositions to take in this case (and we ar setting them right now aror the '8inintry) that I would like to avoid this one if we could get the info another way.¶

CO S¶

Thanks¶

J. Edwark)¶

lar art¶

Rothstein Rosenfeldt Adled Attorneys at Law Las Olas City Centre 401 East Las Olas Boulevard, Suite 1650 t Lauderdale, FL 33301 (954) 522-3456 ) 522-8663 - facsimile dwards@rra-law.com¶

Michele Dargan, staff writer¶

bradley\_Edwards020732@eMailContent.htm¶

Palm Beach Daily News
(561) 820-3863 phone
(561) 655-4594 fax¶

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA¶

CASE NO.: 08-CIV-80119-MARRa¶

JANE DOE NO. 2,¶

Plaintiff,¶

vs.¶

JEFFREY EPSTEIN,¶

Defendant.¶

Related cases:¶

08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591,09-80656, 09-80802, 09-81092¶

This cause is before the Court u i Jane Doe's Motion for Injunction Restraining Fraudulent Transfer is ppointnent of a Receiver to Take Charge of Property of Epstein, and to Post Million Bond to Secure Potential Judgment (DE 165). Defendant Jeffrey Epstein I response in opposition to the motion (DE 198), and Plaintiff filed a reply (DE Ell The motion is now fully briefed and ripe for review.¶

P1 t t,lion argues that Defendant is fraudulently transferring his assets with the specific in t to defeat any judgment that might be entered against him in this and other similar cases. Plaintiff therefore seeks an order enjoining Defendant from fraudulent transfers of his assets, appointing a receiver to take charge of Defendant's property, and requiring Defendant to post a SI 5 million dollar bond against any potential judgment in this case.¶

The relief sought by Plaintiff is injunctive and, essentially, amounts to a prejudgment writ of attachment. v. Cascade Intern Inc., 21 F.3d 1520, 1530 (1 Cir. 1994) (vacating district court's preliminary injunction freezing defendant's assets). "No relief of this character has been thought justified in the long history of equity jurisprudence."De Beers Canso!. Mines, Ltd. v. United States, 325 U.S. 212, 222-23 (1945).¶

"Preliminary injunctive relief freezing a defendant's assets in order to es with which to satisfy a potential judgment for money damages is simply no riate exercise of a federal district court's authority." M, 21 F.3d at 1530 (i]t is entirely settled by a long and unbroken line of Florida cases that in an t law for money damages. there is simply no judicial authority for an order requirin e t of the amount in controversy into the registry of the court ... or indee at r traint upon the use of a defendant's unrestricted assets prior to the ent ofj ent." Id. at 1531, gtLagi Konover Realty Assoc., Ltd. v. Mladen, 511 So. 7 (Fla. 3d DCA 1987).¶

In Florida, an injunction c tered to prevent a party from using or disposing of his assets prior to the conclusio egal action. Briceno v. Brvdcn Investments, Ltd., 973 So.2d 614, 616 (Fla. 3d D 8). See also SME Racks, Inc. v. Sistemas Mecanicos Para, Electronica, S.A. Fed.Appx. 502 (1 l'" Cir. 2007) (affirming district's court's denial of prelimina to freeze defendant's assets); Proctor v. Eason,651 So.2d 1301, 1301-02 (Fla. 2d A 1995) (Defendant not required to deposit funds in court registry prior to final judgment where Plaintiff failed to show unavailability of an adequate remedy at law and the likelihood of irreparable harm, two elements essential to entry of an injunction); Lawhon v. Mason, 611 So.2d 1367 (Fla. 2d DCA 1993) (quashing trial court order requiring defendant to¶

give plaintiffs ten days notice prior to the transfer of any assets in excess of $500).¶

Additionally, as the Eleventh Circuit explained in¶

In actions at law, plaintiffs in Florida possess an adequate, exclusive prejudgment remedy for the sequestration of assets under the attachment statute, Fla.Stat.Ann. § 76.04-.05 (West 1987), provided that they can satisfy the enumerated statutory grounds for relief. Accordingly, the use of injunctive relief as a substitute for the remedy of prejudgment attachment, with its attendant safeguards, is improper.¶

21 F.3d at 1531 (emphasis added). Hem, Plaintiff did not move to amend her amt to allege a claim under the Florida Uniform Fraudulent Transfers Act ("FUFTA" § 726.101, et seq.' Rather, she filed the present motion for injunctive relief. Event d moved to amend her complaint, it is certainly not clear that she could meet statutory elements. Plaintiff's motion is premised on the contention that s fraudulently transferring his assets. However, Plaintiff's motion is entirely idence of Defendant's alleged fraudulent transfers. The Court declines t c that Defendant is fraudulently transferring assets based upon the adverse inf re upon by Plaintiff. Plaintiff's supplemental filing regarding the titles of approxi ely f v of Defendant's vehicles is clearly de minimis, particularly in light of Plal repeated characterization of Defendant as a "billionaire."¶

Based upo fors ing, it is hereby¶

ORD A 'D ADJUDGED that¶

^&#x27;Fraudulent transfer claims under Florida law arise under the Florida Uniform Fraudulent Transfers Act ("FUFTA"), Fla. Stat. § 726.101 et sea.. FUFTA, as set forth in Florida Statute § 726.105, provides the substantive requirements that must be pled to state a valid fraudulent transfer claim. Nationsbank, N.A. v. Coastal Utilities, Inc.,814 So.2d 1227, 1229 (Fla. Dist Ct. App. 2002). The plaintiff must show that "(I) there was a creditor to be defrauded; (2) a debtor intending fraud; and (3) a conveyance of property which could have been applicable to the payment of the debt due." Id.¶

(1) Plaintiff Jane Doe's Motion for leave to Provide Recently-obtained Deposition¶

Testimony and Affidavit (DE 386 in 08-80119) is GRANTED.¶

(2) Plaintiff Jane Doe's Motion for Injunction Restraining Fraudulent Transfer of Assets,¶

Appointment of a Receiver to Take Charge of Property of Epstein, and to Post a SI5 Mil lion¶

Bond to Secure Potential Judgment (DE 165 in 08-80119) is DENIED.¶

DONE AND ORDERED in at West Palm Beach, Palm BeacM°.,IN,¶

Florida, this 5ih day of November, 2009.¶

Copies to: all counsel of record¶

i et....!-. -2 0 KENNETH A. MARRAC.,) United States Dis ge¶

From: Cara L. Holmes
To: Bradley J. Edwards
Subject: Strategy
Date: Wednesday, July 29, 2009 1:13:13 PM¶

---

I think our best bet is to go after those close to Epstein.¶

NOT A CERTIFIED COPY¶

IN THE CIRCUIT COURT OF THE 17TR JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: 09-062943 07¶

RAZORBACK FUNDING, LLC, et al,¶

Plaintiffs,¶

I¶

CO S¶

Defendants.¶

vs.¶

SCOTT W. ROTHSTEIN, et 01,¶

0¶

.CAA: 1.47)¶

DAY 1 - AFTERNOON: G SIGN \ I DEPOSITION Og,SCOTT ROTHSTEIN¶

DATE TAKEN: TIME: PLACE: y, December 12, 2011 0 p.m. - 5:00 p.m. 9 N.E. Fourth Street, Miami, FL¶

( L )¶

Taken on Behalf of Razorback¶

Examination of the witness taken before:¶

Terri United Reporting, Inc. 1218 Southeast Third Avenue Fort Lauderdale, Florida 33316 (954)525-2221¶

no. 4.4.6••••••• ••••••••••••••S..1.4....1¶

1 funds that were supposed to be held in trust?¶

2 3 4 5 6 7 A It was simply what and I had -- the whole reason it stayed in, Mr. Preve and I discussed from time to time the fact that anything we could do to add additional levels of security for the investors was 464,4, good. So, it stayed in the package unless someo s4o As they didn't want it.¶

8 9 Q Now, the Epstein settlements were used by you based on actual cases with Jeffrey EpateitAkard¶

10 A Yes, on that.¶

11 Q -- Palm Beach person?¶

12 A Yes.¶

13 Q Do you recall, t¶

14 A Yes.¶

15 16 Q And do to all that my clients were D-3 investors w t invested in that?¶

17 A I do.¶

18 19 Q t would be Discala and Von Allmen and other people of the Razorback group?¶

20 I do.¶

2 . ^Q Do you recall when they came to your office and you brought down boxes for Michael Legamaro to review? 22¶

A The boxes were actually already in my office. 23¶

Q Nell, there's some testimony that you called and asked Ken Jenne and Fistaa to bring them down and they 24 25¶

1 2 brought down boxes for you at a show, as to show these are the real cases?¶

3 4 S 6 A I believe that a substantial number of the boxes were already in my office. And there were additional boxes and I did have people bring them to me. I dong. Atillky remember who brought them to me, but yes.¶

7 8 Q And do you recall Mr. Legamaro, wha 0 with respect to his review of those boxes of e c ?¶

9 10 11 12 13 A I recall bringing the boxes in, nly real recollection I have of that meeti fter meeting with them and bringing the bo walked out for a period of time, let them g u the boxes, came back in, answered questions at ey had and we went forward.¶

14 15 0 You pull t some kind of a flight manifest; do you recall that?,¶

16 17 18 19 20 21\ 22 23 24 25 A Yeah. At some point in time I believe it was either Brad one of the pieces of evidence they were using in the aetual case was the flight manifest. And I actually used or Russ Adler pointed out to me that ,..that to make a fairly big show. I found that those most of the time in these cases the more significant our underlying investigation was and the more tantalizing it was, the more interested the investors got. We had that real piece of evidence and we used it to our advantage to attempt to secure the investor.¶

4¶

1 2 Q Did Russ help you make it more tantalizing, that manifest --¶

3 A Did he help me?¶

4 Q Did he help you make it more tantalizing?¶

5 6 7 B A The only way Russ would have helped me make t more tantalizing was by just discussing the size case. But other than that, no, he didn't do that I recall during that meeting with re the actual manifest. I did.¶

10 11 Q Didn't you add some sensat na names to the manifest that weren't there to s t i ?¶

12 A 1 did. I did. A);¶

13 Q Tell us about ,eha .¶

14 15 16 17 18 A There wer I Said that there were additional manifests -- if a ber correctly, I said there were additional nit that we had discovered containing Bill Cl.nton • ame, Prince Andrew, all being shown flyi g h young girls on the plane.¶

19 And do you know whether -- let me back up.¶

20 The original manifests that were in evidence in theee real case, didn't have those names on it?¶

22 23 24 25 A No, but it's interesting you bring that up because the way I came up with Bill Clinton and Prince Andrew was Mr. Adler and Mr. both told me on different occasions that the reason the case - when we¶

1 2 3 4 5 were discussing the actual real case, the reason it was becoming so, quote, unquote, tasty because they had information that he had been flying Bill Clinton around and Prince Andrews around, the piece that was missing from the real case was the connection to the young g'rls.¶

6 7 Q The young girls - connection to the you Ae4^s was fiction, it was a lie?¶

8 9 A Not as far as Mr. Epstein is con ut as far as the other people are concerned, y¶

10 11 12 Q Do you know whether Adler Adler or Mr. injected any of to the depositions in the real case in order with the Ponzi?¶

13 14 A I don't know - N, I don't know whether they did that or no I uldn't think they would.¶

15 16 17 18 Q When you we asked - this morning about Brad you really hesitated. I don't know if you know you did that. You were answering yes, no, maybe so. On really paused. his you¶

19 20 On the question as whether or not he would have ed us in, you mean?¶

22 involved and you didn't quite answer. Q Whether he was a player or whether he was¶

23 A Just because of the way I knew Brad and 24 socialized with him, I did not know that he was at that 25 level. There are certain people, Barry, second ho 1 2 3 4 5 6 found out about it would have absolutely done what was appropriately - supposed to do from an ethical standpoint. And then there were people who I would say would never do that. And then there are people in the middle. I believe Brad is probably in the middle.¶

7 8 9 Q Did you have your investigators, that be Jenne and Wayne Black and Fistas investigate Epstein himself and try to gat evidence from Epstein --¶

10 A I didn't know --¶

11 Q -- do you have of any knowledge of that?¶

12 A No, sir.¶

13 14 15 Q Did you instruct them to file any kind of pleadings in federal-Court or anything like that in order to help you promote the Ponzi?¶

16 17 18 19 20 A No. As fitii as the Epstein case is concerned, Mr. Scherer, ever asked Mr. Adler or Mr. or anyo e el e associated with that case to do anything for h°se of furthering the Ponzi other than bring me boxes. That was all my creation.¶

22 23 24 I'm going to talk to you about Ted Morse a little bit. You said he was one of your best friends, he was one of your intercirole?¶

25 A Correct.¶

Q Thank you.¶

--alwaXISZIFIZISCpc •¶

1¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA¶

JEFFREY EPSTEIN,¶

PlaintifflCotmter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG¶

vs.¶

J. individually,¶

Defendant/Counter-Plaintiff.¶

AFFIDAVIT OF JEFFREY Era¶

The undersigned, Jeffrey E. Epstein, having first been duly sworn, hereby deposes and says:¶

• 1. I am over eighteen (18) years old and have personal knowledge of the facts stated herein.
• 2. I am the Co pdu c tex-Dgendant in the above captioned action (the "Action") and submit this Affidavit pport of my Motion for Summary Judgment (the "Summary Judgment Motion") with respect to the Fourth Amended Counterclaim (the "Counterclaim") of Counter-Plaintiff re. the Counterclaim has asserted unsupported claims against me for Abuse of Process and Malicious Prosecution.
• 4. As more fully described below, at the time that I commenced the Action against and Scott Rothstein ("Rothstein") in December 2009, I had a good faith basis for filing the same, based on the facts that existed at the time I filed suit, as set forth below and more fully in my Summary Judgment Motion.

5. I filed the Action against Rothstein and because, based on the facts described below and in the Summary Judgment Motion, I believed at the time of filing my original Complaint that these two individuals, and other unknown partners of theirs at Rothstein, Rosenfeldt, Adler ("RRA"), engaged in serious misconduct involving a widely publicized illegal Ponzi scheme operated through their law firm (the "Ponzi Scheme") that featured the very civil cases litigated against me by IMA 4hich, were being used to defraud potential investors in the Ponzi Scheme.

6. In early November 2009, stories in the press, on the news, and on the internet were legion about the implosion of RRA, the P • INfe perpetrated at that firm, and the misuse in the Ponzi Scheme of • evil cases then being litigated against me by RRA partner, The cases'Ed s was litigating against me, which are described in the Summary Judgment ,Motion (the "Epstein Cases"), were being used to defraud investors out of milliontfe ars and to fund the RRA Ponzi Scheme.

7. In November 2009, I also became aware of news stories that as a result of the Ponzi scheme at RRA, €FilyvrIda Bar had commenced investigations into over onehalf of the attorneys employed by RRA.

8. At or about the same time in November 2009, I also became aware that the law firm of Co>ad Scherer filed a Complaint against Scott Rothstein and others, k Funding, LLC, et al. v. Scott W. Rothstein, et al., Case No. 09-062943(19) (hereinafter referenced as the "Razorback Complaint"), on behalf of some of the Ponzi Scheme investors.

9. Upon reviewing the Razorback Complaint, I learned that the Razorback Complaint detailed the use of the Epstein Cases (i.e., the cases being litigated against me

to defraud investors in the Pored Scheme; including, but not limited to, improper discovery practices and other methods to bolster the cases.¶

10. Prior to my filing the initial Complaint in the Action, I also became aware that the Federal government filed an Information against Scott Rothstein, which included allegations of RRA as an "Enterprise" in which Rothstein and his yet unidentified coconspirators engaged in a racketeering conspiracy, money laundering cosiiracy, mail and wire fraud conspiracy, and wire fraud, and specifically alleged that (a) potential investors were told by Rothstein and other co-conspirators that confidential settlement agreements were available for purchase; (b) settlem allegedly available in amounts ranging from hundreds of thousands of dollars to millions of dollars and could be purchased at a discount and repaid to the ain%thrs at face value over time; (c) Rothstein and other co-conspirators utilized the offices of RRA and the offices of other co-conspirators to convince potential investors of the legitimacy and success of the law firm, which enhanced the credibility of the purported investment opportunity; (4) Rothstein and other co-conspirators utilized funds obtained through the Potth Scheme to supplement and support/ he operation and activities of RRA, to expand RRA by the hiring of additional attorneys and support staff, to fund salaries and bonuses, and to acquire larger m elaborate office space and equipment in order to enrich the personal wealth >persons employed by and associated with the RRA Enterprise.

II. Prior to filing the initial Complaint in the Action, consistent with the allegations made by the press, in the Razorback Complaint, and in the Rothstein Information, it was clear that the activity in the Epstein Cases being litigated by intensified substantially during the short six (6) months during which was a¶

partner at RRA from April 2009 through the end of October 2009. Furthermore, during that six (6)-month period, questionable discovery like that detailed in the Razorback Complaint had taken place in the Epstein Cases being litigated against me by M, including noticing the depositions of famous dignitaries and celebrities such as Bill Clinton, Donald Trump and David Copperfield, who appeared to have no connection whatsoever to any claims of misconduct made ba clients.¶

12. Equally consistent with the allegations in the press and in the Razorback Complaint that the Epstein Cases were being deliberately misused forlserposes unrelated to the litigation in order to lure investors into the Ponzi Scheme is tg fact that on July 24, 2009, 1.1 filed a two hundred thirty-four (234) one fifty-six (156) count federal complaint against me on behalf of a plain for whom was already prosecuting a case against me in state court invo g the very same facts alleged in the federal complaint. The complaint ,filed in federal court, but was never served on me or prosecuted, leading me to conclude that the only reason it was filed was to enhance the case files shown at the offiev of RRA to potential investors in the Portz; Scheme.

13. Also while a partner at RRA, filed a motion in Federal court in which he requested that the court order me to post a fifteen million dollar bond in the Jone Doe case/' case, according to the Razorback Complaint, was being touted at that same time to inve4ixs in the Ponzi Scheme. In connection with that motion, filed papers discussing my net worth and filed supplemental papers purporting to list in great detail my vehicles, planes and other items of substantial value, all at a time when, according to the accounts in the press, the Information and the Razorback Complaint, the Ponzi Scheme was unraveling and the need for new investors in the Ponzi Scheme was becoming urgent. The court rejected the Motion, calling it "devoid of evidence."

14. The facts set forth above and in the Summary Judgment Motion were the facts upon which I relied in (a) determining that I had incurred damages, such as attorneys fees and disbursements paid to defend against these actions which appeared to be unrelated to the underlying litigation against me, and (b) asserting my causes of action against [REDACTED] and Rothstein in the Action.

FURTHER AFFIANT SAYITH NAUGHT.¶

STATE OF NEW YORK )
) ss.:
COUNTY OF NEW YORK )¶

Sworn and subscribed to before me, the undersigned authority, by Jeffrey Epstein, this 25^th day of September, 2013.¶

LESLEY K GROFF
Notary Public - State of New York
NO. 01GR6285700
Classified in New York County
My Commission Expires Jul 8, 2017¶

• Beach County, Florida.
• 1. At all times material to this cause of a, was a resident of Palm
• 2. This Complaint is brought under Sti<c name to protect the identity of \ ct ous L.M., because this Complaint makes sensitive allegations of sexual assault and abuse of a then-minor. ( A' 3. At all times material to th s cause of action, Defendant, Jeffrey Epstein, had a mansion located at 358 El Brillo Way, Palm Beach, Palm Beach County, Florida.
• 4. At all times materials to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953.
• 5. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida. This is substantiated by the residence that he maintains at 358 El Brillo Way, West Palm Beach, Florida where he spends the majority of his time, and intentions to remain at that address permanently are further evidenced by his statements to the Court during

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA¶

L.M., CASE NO: 09-CV-81092-Cohn-Seltzer¶

Plaintiff¶

vs.¶

JEFFREY EPSTEIN,¶

Defendant¶

/¶

FILED by	<u>VT</u>	D.C.
ELECTRONIC
July 24, 2009
STEVEN M. LARIMORE CLERK U.S. DEST. CT. S.D. OF FLA. - MIAMI

COMPLAINT AND DEMAND FOR JURY TRIAL¶

Plaintiff, L.M., hereby sues the Defendant, Jeffrey pst, and states as follows:¶

his State Plea colloquy on June 30, 2008, case number 06CF009454AMB, taken before the Honorable Judge Dale Pucillo, wherein he indicated that after his release from the Palm Beach County Jail he intends to reside permanently at his home at 358 El Brillo Way, West Palm Beach, Florida, and he plans to work in West Palm Beach, Florida as well¶

6. This Court has jurisdiction of this action and the claims selforth Aterein pursuant to 18 U.S.C. § 2255. L.M. seeks damages in excess of 1 illion dollars.

7. This Court has venue of this action pursuant to 28 U.S.C. § 1391(b), as a substantial part of the events giving rise to the claims occurred in this District.

STATEMENT OFF \I¶

8. Upon information and belief, t ua endant, Jeffrey Epstein, has demonstrated a sexual preference and obsession for minor girls. IF

9. The Defendant, Jeffrey Epstein, developed a plan, scheme, and criminal enterprise that included an elaborate system wherein the then-minor L.M. was brought to the Defendant, Jeffrey t in's residence by the Defendant's employees, recruiters, and assistants Wh the assistants and employees left the then-minor L.M. (and, on some occasio othe minor girls) alone in a room at the Defendant's mansion, the Defendan e Epstein, himself would appear, remove his clothing, and direct the then-minor L.M. to remove her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including, out not limited to, masturbation, touching of the then minor Plaintiffs sexual organs, coercing or forcing the then-minor L.M. to perform oral sex on him, using vibrators or sexual toys on the then-minor L.M., coercing the

then-minor L.M. into sexual acts with himself or others, and digitally penetrating the then-minor L.M.. He would then pay L.M. for engaging in this sexual activity.¶

10. L.M. was first brought to the Defendant, Jeffrey Epstein's mansion in 2002 when she was a fourteen-year old in middle school.

11. The then-minor L.M. was a vulnerable child without adequate parental support at all times material to this Complaint. The Defendant, Jeffrey Epstein, a wealthy financier with a lavish home, significant wealth, and 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.

12. Beginning in approximately August 2002 and continuing until approximately the end of October 2005, the Defendant, Jeffrey Epstein, repeatedly coerced, induced and/or enticed the impressionable, vulnerable, and economically deprived then-minor L.M. to commit various acts of sexual misconduct and sexually abused L.M. These acts included, but were not limited to, fondling and inappropriate and illegal sexual touching of the then-minor L.M., forcing the then-minor L.M. into oral sex, sexual misconduct and masturbation of the Defendant. Jeffrey Epstein, in the presence of the then-minor L.M., handling and fondling of the then-minor L.M.'s sexual organs for the purpose of masturbation. and encouraging the then-minor L.M. to become involved in prostitution; Defendant, Jeffrey Epstein, committed, and conspired with others to commit, numerous criminal sexual offenses against the then minor Plaintiff including, but not limited to, sexual battery, solicitation of prostitution, coercing a minor into a life of prostitution, and lewd and lascivious assaults upon the person of the then-minor L.M. Defendant Jeffrey

transported L.M. and other minors in interstate commerce with the . engage in prostitution and in other sexual activity for which he and charged with criminal offenses. Defendant Jeffrey Epstein also 'ens of interstate commerce to knowing persuade and induce minors, engage in prostitution and other sexual activity for which arged with criminal offenses. he and¶

ldition to the direct sexual abuse and molestation of the then-minor leffrey Epstein, instructed, coerced and otherwise induced the thenhim numerous other minor girls (some as young at 12 years old) for further satisfying his deviant sexual attraction to minors and ution. On information and belief, Epstein sexually abused hu )ugh his recruiting system. Defendant, Jeffrey Epstein, used his I power to unduly and improperly manipulate and influence the thenig him these other minor girls for purposes of prostitution and in ey. This influence led the then-minor L.M. away from the life of a d child and into a delinquent lifestyle. This conduct also involved and other minors in interstate commerce and using means of e, to persuade and induce L.M. and others to engage in prostitution ill activity for which he and others could be charged with criminal¶

endant, Jeffrey Epstein, at all times material to this Complaint, knew own of L.M.'s minority. The Defendant, Jeffrey Epstein, at all times¶

Cos¶

Epstein knowingl intent that the L.? others could be knowingly used m including L.M., tc others could be of¶

13. In at L.M., Defendant, minor L.M. to brine the purposes of purposes of prostil of minor girls thrc money, wealth anc minor L.M. to brir exchange for mon middle school age transporting L.M.. interstate commerc and in other sexu offenses.

14. The De. and should have ki material to this Complaint, knew and should have know of the minority of the other girls he was sexually abusing

15. The acts referenced above in paragraphs 10 through 14, committed by Defendant, Jeffrey Epstein, against the then-minor Plaintiff L.M. were committed in violation of numerous State criminal statutes condemning the sexual exploitation of minor children, prostitution and prostitution-related offenses, sexual performances by a child, lewd and lascivious assaults, sexual battery, contributing to the delinquency of a minor and other crimes, specifically including, but not limited to, those criminal offenses outlined in Chapters 794, 800, 827 and 847 of the Florida Statutes, as well as those designated in Florida Statutes §796.03, §796.07, §Z, 5, §796.04, §796.09, §39.01, and §827.04. 4 kN

16. The acts reference above in paragraphs 10 through 15, committed by Defendant, Jeffrey Epstein, against the then-Minor Plaintiff L.M. were committed in violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct sex trafficking of children, sexual exploitation of minor children, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(b), and § 2423(e).

17. The crimes committed against L.M. by Epstein were committed, on average, four times per month from the beginning of August 2002 through the end of October 2005, the exact dates being unknown to L.M..

18. In June 2008, after investigations by the Palm Beach Police Department, the Palm Beach State Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's Office for the Southern District of Florida, Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution in the Fifteenth Judicial Circuit in the Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability unto Plaintiff, Jane Doe No. 101. In this action, Plaintiff hereby exclusively seeks civil remedies pursuant to 18 U.S.C. § 2255.

19. As a condition of his 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 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." Plaintiff L.M. is covered by this paragraph and entitled to rights under this paragraph.¶

20. 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, L.M., including admitting liability for all counts enumerated in this Complaint. Plaintiff L.M. is entitled to damages, as further alleged below, including damages as provided in 18 U.S.C. § 2255, as led by Pub. L. 109-248, Title VII, § 707(b) and (c), 120 Stat. 650.

COUNT 1¶

Cause of Action Pursuant to 18 U.S.C. 9 2265¶

August 2902 — Incident 1¶

21. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

22. On or about August 2002 the exact date being unknown to L.M.,

Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

23. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

24. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 2¶

Cause of Action Pursuant to 18 U.S.C. 4 2255¶

August 2002 — Incident 2¶

25. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

26. On or about August 2002, the exact date being unknown to L.M.,

Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and¶

enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically Including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).¶

L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

27. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will In the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.¶

28. Wherefore, the plaintiff. L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 3¶

Cause of Action Pursgant to 18 U.S.C. 4 2256¶

August 2002 - Incident 3¶

29. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

30. On or about August 2002, the exact date being unknown to L.M.,

Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b). and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

31. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 associ ted with defendant, Jeffrey Epstein. controlling, manipulating and coercing her ' to a 9pVerse and conventional way of life for a minor. The then-minor plaintiff L.MAu4ed medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., has suffered a t of income, a loss of the capacity to earn income in the future, and a loss city to enjoy life. These injuries are permanent in nature and the plaint ., will continue to suffer these losses in the future.

32. Wherefore, the plaintiffr iwM., mends judgments against the defendant, . Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereb4gLamands trial by jury on all issues triable as of right by a jury.

COUNT 4¶

Cause of Action Pursuant to 18 U.S.C. § 2255¶

August 2002 — Incident 4¶

33. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

34. On or about August 2002, the exact date being unknown to L.M.,

Defendant. Jeffrey Epstein, committed a federal sexual offense against her, including a¶

violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children. sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not hniited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 . I . R. 2255 and, a as such, asserts a cause of action against the defendant, Jeffrey EpsEi, pursuant to tow this Section of the United States Code and the agreement between the Defendant, ' ) Jeffrey Epstein, and the United States Government.¶

35. As a direct and proximate resuitA0 offenses enumerated in Title 18, United States Code, Section 2255, being:committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

36. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 5¶

Cause of Action Pursuant to 18 U.S.C. ti 2255¶

September 2002 — Incident 1¶

37. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

38. On or about September 2002, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U S C. § 2422(b), § 2423(a). § 2423(b), and § 2423(e), L.M. is therefore -a victim of one or more offenses enumerated in 18 U.S.C. § 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 Ep, and the United States Government.

39. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incuitel medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., has suffered a loss of loss of the a 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, L.M., will continue to suffer these losses in the future.¶

40. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory dama 6 h,r, s of at least the minimum amount provided by law, attorney's fees, costs, and such o 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 6¶

use of Action Pursuant to 18 U.S.C. § 2255¶

September 2002 — Incident 2¶

41. ala intiff, L.M. adopts and realleges paragraphs 1 through 20 above.

or about September 2002, the exact date being unknown to L.M.,¶

Defeo 1, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to¶

engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically Including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

43. As a direct and proximate result of the offenses enumerated In Title 18. United States Code, Section 2255, being committed against her, L.M. 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 conventional way of kfe for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses In the future.

44. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 7¶

Cause of Action Pursuant to 18 U.S.C. 6 2255¶

September 2002 — Incident 3¶

45. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

46. On or about September 2002, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.

47. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., has suffered a loss of income, a loss of the A. capacity to earn income in the future, and a loss of the capacity to enjoy ' e. These injuries are permanent in nature and the plaintiff, L.M., will continue3 ffer these losses in the future.¶

48. Wherefore, the plaintiff, L.M., demands juts against the defendant, Jeffrey Epstein, for compensatory damages of at 1411w /i nimum amount provided H. by law, attorney's fees, costs, and such other and further rehef as this Court deems just and proper, and hereby demands trial by on all issues triable as of right by a jury.

Ifit AcfOUNT 8¶

Cause of Action Pursuant to 18 U.S.C. 4 2255¶

September 2002 — Incident 4¶

49. Plaintiff,44Ladopts and realleges paragraphs 1 through 20 above.

50. Orvor about September 2002, the exact date being unknown to L.M., Defendant, Jetke%p, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and entiOapt of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct,

child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

51. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her. L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

52. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 9¶

Cause of Action Pursuant to 18 U.S.C. 4 2255¶

October 2002 — Incident 1¶

53. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

54. On or about October 2002, the exact date being unknown to L.M.,

Defendant, Jeffrey Epstein, committed a federal sexual offense against her, Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(0). § 2423(a). § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

55. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.¶

56. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 10¶

Cause of Action Pursuant to 18 U.S.C. Q 2255¶

October 2002 — Incident 2¶

57. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

58. On or about October 2002, the exact date being unknown to L.M.,

Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).¶

L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

59. As a direct and proximate result of the offenses enumerated iniTttle 18, Ait-United States Code, Section 2255, being committed against her, L.M. erin1 in the past suffered, and will in the future suffer, physical injury pain and suff emotional distress, psychological trauma, mental anguish, humiliation, L mbarrlisment, 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plain will in the future suffer medical and psychological expenses. The plaintiff L.Nhas suffered a loss of income, a loss of the capacity to earn income in the r and a loss of the capacity to enjoy life. These ) injuries are permanent in na, nd the plaintiff, L.M., will continue to suffer these losses in the future

60. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, omey's fees. costs, and such other and further relief as this Court deems just and 'Apr lr, and hereby demands trial by jury on all issues triable as of right by a jury.

COUNT 11¶

Cause of Action Pursuant to 18 U.S.C. § 2255¶

October 2Q02 — Incident 3¶

61. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

62. On or about October 2002, the exact date being unknown to L.M.,

Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent Co engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor — *6....- children. transport of visual depictions of a minor engaging in set/ explicit conduct, child exploitation enterpnses, and other crimes, specifical ing, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2 423(b), and § 2423(e). L.M. is therefore a victim of one or more often u erraated in 18 U.S.C. § 2255 and, 4' as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States C oitce..._, the agreement between the Defendant, Jeffrey Epstein, and the United States vernment¶

63. As a direct antrolimate result of the offenses enumerated in Title 18, United States Code. Section 2255. being committed against her, L.M has in the past suffered, and wilt in the future suffer, physical injury pain and suffering, emotional distress. psychological trauma, mental anguish, humiliation, embarrassment, loss of self-estee?tl: loss of dignity, invasion of her privacy and other damages associated with defendant; Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and

enses. The plaintiff, L.M., has suffered a loss of income, a loss of the income in the future, and a loss of the capacity to enjoy life. These ament in nature and the plaintiff, L.M., will continue to suffer these a.¶

refore, the plaintiff, L.M., demands judgments against the defendant, or compensatory damages of at least the minimum amount provided fees, costs, and such other and further relief as this Court deems just ereby demands trial by jury on all issues triable as of right by a jury.¶

COUNT 12¶

Cause of Action Pursuant to 18 U.S.C. § 2255¶

October 2002 – Incident 4¶

tiff, L.M. adopts and realleges paragraphs 1 through 20 above. about October 2002, the exact date being unknown to L.M., Epstein, committed a federal sexual offense against her, including a bus federal criminal statutes condemning the coercion and nor to engage in prostitution or sexual activity, travel with intent to sexual conduct, sex trafficking of children, sexual exploitation of minor of visual depictions of a minor engaging in sexually explicit conduct, enterprises, and other crimes, specifically including, but not limited to, nated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, cause of action against the defendant, Jeffrey Epstein, pursuant to¶

psychological exp capacity to earn injuries are perm losses in the futur¶

64. Whe Jeffrey Epstein, f by law, attorney's and proper, and h

65. Plain

66. On o

Defendant, Jeffrey violation of numero enticement of a mi engage in illicit sex children, transport child exploitation e those crimes desig L.M. is therefore a as such, asserts a¶

this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government.¶

67. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., has suffered a loss of income, a loss of the capacity to earn income in the future, a -a loss of the capacity to enjoy life. These injuries are permanent in nature an Ici mei e 'ntiff, L.M., will continue to suffer these losses in the future.

68. Wherefore, th plaint' , L.M., demands judgments against the defendant, Jeffrey Epstein. for compensa ory damages of at least the minimum amount provided by law, 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 13,¶

Cause of Action Pursuant to 18 U.S.G. 6 2255¶

November 2002 — Incident 1¶

69. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

70. On or about November 2002, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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,

71. As a direct and proximate result of the offenses enumerated in Title 18. United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.¶

72. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 14¶

Cause of Action Pursuant to 18 U.S.C. 4 2266¶

November 2002 — Incident 2¶

73. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

74. On or about November 2002. the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. §2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.

75. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 t perverse and conventional way of life for a minor. The then-minor plaintiff L.M. incurr medical "-b... and psychological expenses and the plaintiff, L.M, will in the tutee suffer medical and psychological expenses. The plaintiff, L.M., has suffered a las of income, a loss of the N capacity to earn income in the future, and a loss of Tcapacity to enjoy life. These injuries are permanent in nature and the plaintiff, b1., will continue to suffer these losses in the future. V

A N" 76. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensa a ages of at least the minimum amount provided by law, attorney's fees, cos ch other and further relief as this Court deems just and proper. and hereby demands trial by jury on all issues triable es of right by a jury¶

COUNT 15¶

Cause of Action Pursuant to 18 U.S.C. 6 2255¶

:\ I November 2002 — Incident 3¶

77. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

78. On or about November 2002, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a

violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a). § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

79. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

80. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 16¶

Cause of Action Pursuant to 18 U.S.C. 6 2265¶

November 2002 — Incident 4¶

81. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

82. On or about November 2002, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S C. § 2422(b). § 2423(a). § 2423(b), and § 2423(c). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.

83. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.¶

84. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 17¶

Cau§e of Action Pursuant to 18 U.S.C. 4 2255¶

pecember 2002 — Incident 1¶

85 Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.¶

86. On or about December 2002, the exact date being unknown to L.M., Defendant. Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage In prostitution or sexual activity, travel with intent to

engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b). § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2256 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.¶

( 14/ 87. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. Incurred medical and psychological expenses and the plaintiff, L M will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.¶

88. Wherefore, the plaintiff. L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 18¶

Cause of Action Pursuant to 18 U.S.C. 4 2255¶

December 2002 — Incident 2¶

89. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

90. On or about December 2002, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging In sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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 Epstelakand the United States Government.

La;a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will contir eL suffer these losses in the future.¶

(7' ) 92. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 19¶

Cause of Agtion Pursuant to 18 U.S.C, 4 2255¶

December 2002 — Incident 3¶

93. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

94. On or about December 2002, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct,

child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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 Defend t, Jeffrey Epstein, and the United States Government. JEN¶

95. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. has in the past suffered, and will in the future suffer, physical injury paltfiend suffering, emotional distress, psychological trauma, mental anguish, h tion, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacyll14;:ki3Ther damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in theitriN,

96.<, Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Ep, for compensatory damages of at least the minimum amount provided by law, 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 20¶

Cause of Action Pursuant to 18 U.S.C. 4 2255¶

December 2002 - Incident 4¶

97. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

98. On or about December 2002, the exact date being unknown to L.M.,

Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated In 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

99. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

100. Wherefore, the plaintiff. L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 21¶

Cause of Action Pu'uant to 18 U.S.C. & 2255¶

January 2003 — Incident 1¶

101. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

102. On or about January 2003, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct. child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).

L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

103. As a direct and proximate result of the offenses enumerated In Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future

104. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorneys 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 22¶

Cause of Action Pursuant to 18 U.S.C. 4 2266¶

January 2003 — Incident 2¶

105. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

106. On or about January 2003, the exact date being unknown to L.M.,

Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with' Z ..)tenbto engage in illicit sexual conduct, sex trafficking of children, sexual exploitation f minor children, transport of visual depictions of a minor engaging in sexually plicit conduct, lbw child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 242308/423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against thelc, t1 dant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States overnment.¶

107 As a direct a proximate result of the offenses enumerated in Title 18, United States Code Section 55. being committed against her, L M has in the past suffered, and IU. in t e 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 defendaol, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and¶

psychological expenses. The plaintiff, L.M., 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 • are permanent in nature and the plaintiff, L.M., will continue to suffer these v.ses in the future.¶

108. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 23¶

Cause of Action Pursuant to 18 c.s.c, 4 2265¶

January 2003 - Incident 3¶

109. Plaintiff, L.M. adopts and. lieges paragraphs 1 through 20 above.

110. On or about January 2003, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

111. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her. L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff. L.M., has suffered a loss of income, a loss of the capacity to earn income in the future, an loss of the capacity to enjoy life. These injuries are permanent in nature ar e intiff, L.M., will continue to suffer these losses in the future.

112. Wherefore, thClainti L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 24¶

Cause of Action Pursuant to 18 U.S.C. § 225§¶

January 2003 — Incident 4¶

113. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

114. On or about January 2003, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes. specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b). § 2423(a). § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.

115. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trait. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., has suffered a loss of income, a loss of the capacity to eam income in the future, and a loss of the capacity to enjoy life. These

injuries are permanent In nature and the plaintiff, L.M., will continue to suffer these losses in the future.¶

116. Wherefore, the plaintiff. L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 25¶

Cause of Action Pursuant to 10 U.S.C. 6 2255¶

February 2003 — Incident 1¶

117. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

118. On or about February 2003, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage In prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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 Govemment.

119 As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. Wed medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of capacity to enjoy life. These injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future¶

120. Wherefore, the plaintiffrkM., demands judgments against the defendant, Jeffrey Epstein, for compensatory ges of at least the minimum amount provided by law, 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 26¶

Cause of Action Pursuant to 18 U.S.C. 6 2255¶

_\ February 2003 — Incident 2¶

121. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

122. On or about February 2003. the exact date being unknown to L.M., Defendant. Jeffrey Epstein, committed a federal sexual offense against her, including a

violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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 agreemenjbe n the Defendant, Jeffrey Epstein, and the United States Government¶

123. As a direct and proximate result Ath offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

124. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 27¶

Cause of Action Pursuant to 18 U.S.C. 4 2255¶

February 2003 - Incident 3¶

125. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

126. On or about February 2003, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U S.C. § 2422(b). § 2423(a), § 2423(b), and § 2423(e) L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.

127. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.¶

128. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 28¶

Cause of Action Pursuant to 18 U.S.C. 4 2255¶

February 2003 — Incident 4¶

129. O int, L.M. adopts and realleges paragraphs 1 through 20 above.

1 or about February 2003, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to¶

engage in Illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to. those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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 th ) c Defendant, i Jeffrey Epstein, and the United States Government.¶

C 131. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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, lass of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M . will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.¶

132. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 29¶

Cause of Action Pursuant to 18 U.S.C. 4 2255¶

March 2003 — Incident 1¶

133. Plaintiff. L.M. adopts and realleges paragraphs 1 through 20 above.

134. On or about March 2003. the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explidt conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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, i s Jeffrey EpsteltviocNthe United States Government.

135. M a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.¶

C ) 136. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 30¶

Cause of Action Pursuant to 18 U.S.C. 4 2265¶

March 2003 — Incident 2¶

137. Plaintiff. L.M. adopts and reaileges paragraphs 1 through 20 above.

138. On or about March 2003. the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct,

child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).¶

LM, is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

139. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

140. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 31.¶

Cause of Action Pursuant to 18 U.S.C. 4 2255¶

March 2003 — Incident 3¶

141. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

142. On or about March 2003, the exact date being unknown to L.M.,

Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. Is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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¶

143. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L,M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.¶

144. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 32¶

Cause of Action Pursuant to 18 U.S.C. 6 2255¶

March 2003 - Incident 4¶

145. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

146. On or about March 2003, the exact date being unknown to L.M., Defendant. Jeffrey Epstein. committed a federal sexual offense against her. including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).

L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

147. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

148. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attomey'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 33¶

Cause of Action Pursuant to is U.S.C. 4 2255¶

April 2003 — Incident 1¶

149. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

150. On or about April 2003, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with Intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.

151. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and

psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.¶

152. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 34¶

cause of Action Pursuant to 18 U.S.C. 6 2255¶

April 2003 - Incident 2¶

153. Plaintiff, L.M. adopts and realieges paragraphs 1 through 20 above.

154. On or about April 2003, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent•to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

155. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future. \vS"

( -14/ 156. Wherefore, the plaint, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 35¶

Cause of Action Pursuant to 18 U.S.C. 4 2255¶

April 2003 — Incident 3¶

157. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

158. On or about April 2003, the exact date being unknown to L.M., Defendant Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitutior or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited) O thos;t8crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2e3). L.M. is therefore a victim of one or more offenses enumerated i C. § 2255 and, as such, asserts a cause of action against the defend Epstein, pursuant to this Section of the United States Code and the agr tween the Defendant, Jeffrey Epstein, and the United States Government.

159. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 5 being committed against her, L.M. has in the past suffered, and will in the fe uffer, physical injury pain and suffering, emotional distress, psychologicakira, mental anguish, humiliation, embarrassment, loss of self-esteem, loss df dignity, invasion of her privacy and other damages associated with defendanttJeffrey pstein, controlling, manipulating and coercing her into a perverse and cony banal way of life for a minor. The then-minor plaintiff L.M. incurred medical and irological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.¶

160. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's Fees, costs, and such other and further relief as this Court just and proper, and hereby demands trial by jury on all issues triable as of rig a jury.

( 14/ O¶

Cause of Action Pursuant to 18 U.S.C. 4 2265¶

COUNT 38¶

April 2003 — Incident 4¶

161. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

162. On or about April 2003, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a 01,4pangaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.

163. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 associatc _... iwith defendant, Jeffrey Epstein, controlling, manipulating and coercing her into perverse and conventional way of life for a minor. The then-minor plaintiff LM. incurred medical and psychological expenses and the plaintiff, L.M., will in the futtsuffer medical and psychological expenses. The plaintiff, L.M., has suffered a lositof 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, L.M., will continue to suffer these losses in the future.

164. Wherefore, the plaintiff, L.M., demands judgments against the defendant. Jeffrey Epstein, for compensato\layages of at least the minimum amount provided by law, attorney's fees, cos and such other and further relief as this Court deems just and proper and herebySzands trial by jury on all issues triable as of right by a jury

COUNT 37¶

Cause of Action Pursuant to 18 U.S.C. § 2255¶

May 2003 — Incident 1¶

165. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

166. On or about May 2003, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of

numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated In 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

167. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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, ition of her privacy and other damages associated with defendant Jeffrey Epitri,4ontrolling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

by law, 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 73¶

Cause of Action Pursmint to 18 U.S.C. 4 2254¶

February 2004 — Incident 1¶

309. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

310. On or about February 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in Illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.

311. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will contire suffer these losses in the future.¶

C) 312. Wherefore, the plaintiff, L.M., demands judgme against the defendant, Jeffrey Epstein, for compensatory damages of at least the inimum amount provided by law, 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 74¶

Cause of Action Pursuant to 18 U.S.C. 6 2255¶

February 2004 - Incident 2¶

313. Plaintiff. L M. adopts and realleges paragraphs 1 through 20 above.

314. On or about February 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct,

child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

315. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of Ilfe for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

316. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 75¶

Cause of Action Pursuant to 18 U.S.C. 6 2255¶

February 2004 — Incident 3¶

317. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

318. On or about February 2004, the exact date being unknown to L.M.,

Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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 th'United States Government.¶

319. Ae/a direct and proximate result of the offenses enumerated in Title 18, United States Code. Section 2255, being committed against her. L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

320. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorneys fees, costs, and such other and further ra as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury.

COUNT 76¶

Cause of Action Pursuant tq 18 U.S.C. 4 2255¶

February 2904 — incident 4¶

321. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

322. On or about February 2004, the exact date being unknown to L.M.,

Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numatous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in Illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).¶

L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

323. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

324. Vyherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey EpsfeNorNompensatory damages of at least the minimum amount provided by law, attomey'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 77¶

Cause of Action Pursuant to 18 U.S.C. a 2255¶

March 2004 — Incident 1¶

325. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

326. On or about March 2004, the exact date being unknown to L.M.,

Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b). and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

327. As a direct and proximate result of the offenses enumerated in Title 18, United States Code. $on 2255 being committed against her. L M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and

psychological expenses. The plaintiff, L.M., 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, LM., will continue to suffer these losses in the future.¶

328. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 78¶

Cause of Action Pursuant to 18 U .C. 5 2255¶

March 2004 —fficident 2¶

329. Plaintiff, L.M. adopts and reaMeges paragraphs 1 through 20 above.

330. On or about March 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor ngage in prostitution or sexual activity, travel with intent to engage In illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

331. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

332. Wherefore, tC intiff, pla L.M., demands judgments against the defendant, Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law, 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 79¶

Cause of Action Pursuant to 18 U.S.C. 4 2266¶

March 2004 — Incident 3¶

333. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

334. On or about March 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.

335. As a direct and proximate result of the offenses enumerated in Title 18. United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff. L.M., 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, L.M., will continue to suffer these losses in the future.

336. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 80¶

Cause of Action Pursuant to 18 U.S.C. 4 2266¶

March 2004 — Incident 4¶

337. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

338. On or about March 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of yiskual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.

339. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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 p irj Iti r.M., will continue to suffer these losses in the future.

340. Wherefore, the plain Lia..., .M., \ l emends judgments against the defendant, Jeffrey Epstein, for compensatory d ages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and herebydemands trial by jury on all issues triable as of right by a jury

-7¶

COUNT 81¶

O Cause of Action Pursuant to 18 U.S.C. Q 2255¶

Arm"\¶

April 2004 - Incident 1¶

341. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

342. On or about April 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of

numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, thoseAcrimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e is therefore a victim of one or more offenses enumerated in 18 U.S.0 5 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 e¶

343. As a direct and proximate result of me ff enses enumerated in Title 18, United States Code, Section 2255, being committed against her. L.M. 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, nvaslon of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., has suffered a loss of income, a loss of the capady to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, L.M., will continue to suffer these losses in the future.

344. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 88¶

Cause of Action Pursuant to 18 U.S.C, e 2255¶

April 2004— Incident 2¶

345. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

346. On or about April 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against tier, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity. travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to. those crimes designated in 18 U S C § 2422(b), § 2423(a), § 2423(b), and § 2423(e) L M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.

347. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. has in the past losses in the future 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurre medical and psychological expenses and the plaintiff, L.M., will in the future sufferned al and psychological expenses. The plaintiff, L.M., has suffered a loss of O co ), loss of the _A.., capacity to earn income in the future, and a loss of the capaciLy, enjoy life. These injuries are permanent in nature and the plaintiff, L.M\., will continue to suffer these .)

348. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein. for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby dem ,by jury on all issues triable as of right by a jury.

) C NT 83¶

Cause of Action Pursuant to 18 U.S.C. § 2255¶

April 2004 - Incident 3¶

349. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

On or about April 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual¶

conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

351. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff. L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

352. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 84¶

Cause of Action Pursuant to 18 U.S.C. 4 2255¶

April 2004 — incident 4¶

353. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

354. On or about April 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. Is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.

355. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will contIcey suffer these C ) losses in the future.¶

356. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at Nast the minimum amount provided by law, 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 85¶

Cause of Aptton Pursuant to 18 U.S.C. 4 2268¶

Pay 2004— Incident 1¶

357. PlaintiftS.,M. adopts and realleges paragraphs 1 through 20 above

358. On or about May 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation

enterprises, and other crimes, specifically including, but not limited to, those crimes designated In 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. Is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

359. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., has suffered a loss of income, a loss of the capacity to earn inc me in the future and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, L.M., will continue to suffer these losses in the future.

360. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 86¶

Cause of Action Pursuant to 18 U.S,C. I 2255¶

May 2004 — Incident 2¶

361. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

362. On or about May 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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 Ungad__States Government

363. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.¶

384. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 "ivs triable as of right by a jury.

gg aru T'\¶

Cause of Action Piesuent tarn U.S.C. 4 2255¶

May 2004 — Incident 3¶

385. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

386. On or about May 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage-in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is

therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

367. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.Man in t e past ..46.\ suffered, and will in the future suffer, physical injury pain and suffering, emotional / Nth- distress, psychological trauma, mental anguish, humiliation, !embarrassment, toss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and 4rcing her into a perverse and conventional way of life for a minor. Th t A\i -irrtinor plaintiff L.M. incurred medical and psychological expenses and the plaintiN, will in the future suffer medical and QM psychological expenses. The plaintiff, LI\M.,.has suffered a loss of income, a loss of the capacity to earn income in th repand a loss of the capacity to enjoy life. These injuries are permanent in nay nd the plaintiff, L.M., will continue to suffer these losses in the future t oi,t_

388 Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein. for compensatory damages of at least the minimum amount provided by law, 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 88¶

Cause of Action Pursuant to 18 U.S.C. § 2255¶

Mav 2004— Incident 4¶

369. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

370. On or about May 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor chi transport of visual depictions of a minor engaging in sexually explicit condu exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against K defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Ay Epstein, and the United Sta r '4rnment.

371. As a direct ar pr9kimate result of the offenses enumerated in Title 18, ....... United States Code Section 2255, being committed against her. L.M has in the past suffered, and will in t4 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and

psychological expenses. The plaintiff, L.M., has suffered a loss of income, a loss of the capacity to earn income in the Mute, and a loss of the capacity to enjoy life. These Injuries are permanent in nature and the plaintiff, L.M., will continue to suffer these losses in the future.¶

372. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 89¶

Cause of Action Pursuant to 18 U.S.C. 4 2255¶

June 2004 - Incident 1¶

373. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

374. On or about June 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor,to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. Is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

375. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embar t, loss of self-esteem, loss of dignity, invasion of her privacy and other damages ociated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will In the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

( 14/ 376. Wherefore, the plaint, L.M., demands judgments against the defendant, Jeffrey Epstein. for compensatory damages of at least the minimum amount provided by law, 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 90¶

Cause of Action Pursuant to 18 U.S.C. 4 2255¶

June 2004 — Incident 2¶

377. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

378. On or about June 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with Intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.

379. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.¶

380. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 r y a jury.

COUNT 91¶

Cause of Action Pursuant to 18 U.S.C. 4 2265¶

June 2004 — Incident 3¶

381. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

382. On or about June 2004, the exact date being unknown to L.M.,

Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct. child exploitatiori enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

383. As a direct and proximate result of the offenses enumerated In Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

384. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 92¶

O¶

rCause of Action Pursuant to 18 U.S.C. 5 2255¶

June 2004 — Incident 4¶

385. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above. 366. On or about June 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, Including a

violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with Intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

387. As a direct and proximate result of the offenses enumerated In Title 18, United States Code, Section 2255, being committed against her, L.M, 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

388. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 93¶

Cause of Action Pursuant to 18 U.S.C. 5 2255 July 2004— Incident 1 O¶

A.,¶

389. Plaintiff, L.M. adopts and realleges paragraphs 1 th gt)20 above. —4%

390. On or about July 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein. committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U S 6,1422(b). § 2423(a). § 2423(b). and § 2423(e) L M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.

391. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L. will ontinue to suffer these losses in the future.¶

392. Wherefore, the plaintiff, L.M., de'nds dgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 94¶

Cause of Action Pursuant to 18 U.S.C. 4 2255¶

July 2004 — Incident 2¶

393, Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.¶

394. On or about July 2004, the exact date being unknown to L.M., Defendant, Jeffrey EpM, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual

conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging In sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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 fondant, Jeffrey Epstein, and the United States Government.¶

C.) 395. As a direct and proximate result of the offense ' enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.¶

398. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorneys 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 95¶

Cause of Action Pursuant to 18 U.S.C. § 2255¶

July 2004 — Incident 3¶

397 Plaintiff, L.M. adopts and realleges paragraphs 1 through2Sove.¶

398. On or about July 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel s t to engage in illicit sexual conduct, sex trafficking of children, sexual to i on of minor children, transport of visual depictions of a minor engaging in#41 xplicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422 23(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or ellorLeffenses enumerated in 18 U S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the jded Stites Code and the agreement between the Defendant, Jeffrey Epstein, and th United States Government

399. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. Incurred medical and psychological expenses and the plaintiff, L.M, will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will contl 0 e t SSuffer these in the future. ( is, .!

400. Wherefore, the plaintiff, L.M., demands j me s against the defendant, Jeffrey Epstein, for compensatory damages of a 14t the minimum amount provided by law, attorney's fees, costs, and such other further relief as this Court deems just and proper, and hereby demands trial by jury I Issues triable as of right by a jury.

COUNT 96¶

Cause of Action Pursuant to 18 U.S.C. § 2255¶

July 2004 — Incident 4¶

401 Plaintiff, ljet. adopts and realleges paragraphs 1 through 20 above¶

402. rNor Ia t July 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epsteiht co mated a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to eng e in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation

enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

re 403. As a direct and proximate result of the offenses env, rated in Title 18, United States Code, Section 2255, being committed against heihleat. has in the past suffered, and will in the future suffer, physical injury pain X )n d 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. TIr plaintiff, L.M., 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, L.M., will continue to suffer these losses in the futurNi¶

404. Wherefore, the plaintiff, L.M, demands judgments against the defendant, Jeffrey'tein, for compensatory damages of at least the minimum amount provided by law, 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 97¶

Cause of Action Pursuant to 18 U.S.C. § 2256¶

August 2004 — Incident 1¶

405. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

406. On or about August 2004, the exact date being unknown to L.M ., ., _..c., Defendant, Jeffrey Epstein, committed a federal sexual offense against her r • chiding r a violation of numerous federal criminal statutes condemning the coerciO4? enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of childre) children, transport of visual depictions of a minor engagi4,jn sexually explicit conduct, child exploitation enterprises, and other crim \ ,---skecifically including, but not limited to, (b), 2423(a), § 2423(b), and § 2423(e). ses enumerated in 18 U.S.C. § 2255 and, OM the defendant, Jeffrey Epstein, pursuant to those crimes designated in 18 U.S.C. § L.M. is therefore a victim of one or as such, asserts a cause of act exploitation of minor this Section of the United States Mode and the agreement between the Defendant, Jeffrey Epstein, and the United States Government

407. direchnd proximate result of the offenses enumerated in Title 18, United State de, Section 2255. being committed against her, L.M has in the past suffered, ancrCivill l 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

408. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 98¶

Cause of Action Pursuant 1p 18 U.S.C. I 2265¶

Auaust 2004 — Incident 2¶

409. Plaints f, L.M. adopts and realleges paragraphs 1 through 20 above.

410. On or about August 2004, the exact date being unknown to L.M., Defendant. Jeffrey Epstein. committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).

L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

411. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. has the past suffered, and will in the future suffer, physical injury pain and tittering, 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical A and psychological expenses and the pla ft, 144:, will in the future suffer medical and psychological expenses. The plaintiff, L.M., S 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, L.M., will continue to suffer these losses in the future

412. refore, he plaintiff, L.M., demands judgments against the defendant, Jeffrey EpsteilScor • ompensatory damages of at least the minimum amount provided by la SPI 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 99¶

Cause of Action Pursuant to 18 U.S.C. § 2255¶

August 2004 — Incident 3¶

413. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

414. On or about August 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.

415. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

416. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorneys fees, costs, and such other and further relief "alit& Court deems just and proper, and hereby demands trial by jury on all issues triabli s, right by a jury.

COUNT 100¶

Cause of Action Pursuant to 1A.C. 4 2255¶

August 2004— Incident 4¶

417. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

418. On or about August 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a mino age in prostitution or sexual activity, travel with intent to engage in illicit tlexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 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.¶

419. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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 a the plaintiff, L.M., will continue to suffer these losses in the future.

420. Wherefore, the plaintiff, L.M., demands judgments against the defendant, ( 14/ ' Jeffrey Epstein. for compensatory damages of at feast the minimum amount provided by law, 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 101¶

Gauss of Action Pursuant to 18 U.S.C. 4 2255¶

September 2004 — Incident 1¶

421. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

422. On or about September 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explic/conIct, c child exploitation enterprises, and other crimes, specifically includi C ,but ., not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 24 b),..and § 2423(e). L.M. is therefore a victim of one or more offenses enumer476 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and theAreement between the Defendant, At Jeffrey Epstein, and the United States Government.

423. As a direct and proximate result of the offenses enumerated in Title 18. United States Code, Section 32v ng committed against her, L.M. has in the past suffered, and will in the f re Suffer, physical injury pain and suffering, emotional ..., distress. psychoiogica! trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, lo of dignity, invasion of her privacy and other damages associated with defendant, ay stein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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

424. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff. L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.

425. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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 103¶

O Cause of Action Pursuant to 18 U.S.C. 4 2255¶

September 2004— incident 3¶

42 . Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.¶

430. On or about September 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 § 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.

431. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 Epatein. controlling manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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, L.M., will continue to suffer these losses in the future.