Draft: efta02773015

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 106¶

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

October 2004 — Incident 2¶

441. Plaintiff, L.M. adopts and realieges paragraphs 1 through

442. On or about October 2004, the exact date being unknown t2,

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 trafficidnfi4iildren, 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 1 9 2422(b), § 2423(a), § 2423(b), and § 2423(e). .._&.. L.M. is therefore a victim of one pfmore 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.¶

eta....as a direct and proximate result of the offenses enumerated in Title 18, tin' 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 loascif 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.¶

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

COUNT 107¶

Cause of Action Pursuant tote U,S,C, 6 2256¶

October 20(14 — Incident 3¶

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

448. On or about October 2004, the exact date being unknown to L.M., Defendant, ffrirEpstein, 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.¶

•¶

('S 447. 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 injur aln nd 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 inccvrcn the future, and a loss of the capacity to enjoy life These injuries are • rmanent in nature and the plaintiff, L.M., will continue to suffer these losses iR~dla.fut .¶

Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrby 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. 4 2255¶

October 2004 - Incident 4¶

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

450. On or about October 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, !exploitation of minor children, transport of visual depictions of a minorengaging in sexually explicit conduct, child exploitation enterprises, and other uirt pecifically 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 against the defendant, Jeffrey Epstein, pursuant to this Section of the United StatesiCode and the agreement between the Defendant, Jeffrey Epstein, and the United States Government

451. As ` a direct and proximate result of the offenses enumerated in Title 18, United ' Unlit Ctfe, Section 2255, being committed against her, L.M. has in the past suffers 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.¶

452. 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 109¶

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

November 2004 - Incident 1¶

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

454. On or about November 2004, the exact date being unknown to L.M., Defendant, Jeffrey Eprittn, committed a federal sexual offense against her. Including a violation of nufierous federal criminal statutes condemning the coercion and enticement o4p 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.¶

455. As a direct and proximate result of the offenses enumerated litiiaA 18, United States Code, Section 2255, being committed against her, L.M. i ll the past suffered, and will in the future suffer, physical injury pain and.8l ring, 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, manipulatinglrid 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, .14., has suffered a loss of income, a loss of the capacity to earn income in the futunt, nd 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.

456. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by laWlorney'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 110¶

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

November 2004 — Incident 2¶

457. Plaintiff, L.M. adopts and reafleges paragraphs 1 through 20 above.

458, On or about November 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), 24V), § 2423(b), and § 2423(e). he L.M. is therefore a victim of one or more offenses en rated In 18 U.S.C. § 2255 and, \ r .. 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. A¶

459. As a direct end primate 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.¶

460. Wherefore, the plaintiff, L.M., demands judgments against the deltlant, Jeffrey Epstein, for compensatory damages of at least the minimum a t provided by law, attorneys fees, costs, and such other and further relief as deems just and proper, and hereby demands trial by jury on all issues triable t oot right by a jury.

COUNT 111¶

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

November 2004 — Incident 3¶

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

482. On or about November 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 childrenvtfarispon 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.¶

463. As a direc 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 distress, psychological trauma, mental anguish, humiliation, embarrastia, toss of .be 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 ofIlife for a minor The then-minor plaintiff L.M. incurred medical and psychological expen ses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. ' The plaintiff, L.M., d a loss of income, a loss of the capacity to earn income in the future, alto a of the capacity to enjoy life. These Injuries are permanent in nature and the MON, L.M., will continue to suffer these losses in the future. 2'/' ) 7

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

COUNT 112¶

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

November 2004 — Incident 4¶

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

466. On or about November 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 children, transport of visual depictions of a minor engaging in sexually expl conduct. child exploitation enterprises, and other crimes, specifically Including, but n 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 enumerated '...)i 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 t he*reement between the Defendant, ..." . Jeffrey Epstein, and the United States Government

467. As a direct and pro 1' e result of the offenses enumerated In Title 18, United States Code, Section 2255, , ng committed against her, L.M. has in the past suffered, and will in that, suffer, physical Injury pain and suffering, emotional distress, psychologicM trauma, mental anguIsh, humiliation, embarrassment, loss of self-esteem, I s of dignity, invasion of her privacy and other damages associated with defends ffrey Epstein, controlling, manipulating and coercing her into a perverse and ntional way of life for a minor. The then-minor plaintiff L.M. incurred medical nd otiological 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.¶

488. 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 Courtiec just and proper, and hereby demands trial by jury on all Issues triable as of 'ity A jury.

COUNT 113¶

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

December 2004 Incldep¶

469. Plaintiff, L.M. adopts and realleges paragtajr 1 through 20 above.

470. On or about December 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, ex 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.0 § 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.

471. 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 assomiat 1.ed 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 suffere lo, of income, a loss of the capacity to earn income in the future, and a loss of4he4 capacity to enjoy life. These injuries are permanent in nature and the plaintiff, DM., will continue to suffer these losses in the future. . ' e.

472. Wherefore, the plallittlit, (\ mands 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 here_ ldemands trial by jury on all Issues triable as of right by a jury

COUNT 114¶

Cause of Action Pursuant to 18 U.S.C. 6 2256¶

pecernber 2004 — Incident 2¶

473. Plaintiff, L.M. adopts end realleges paragraphs 1 through 20 above. 474. On or about December 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 1 § 2255 and, as such, asserts a cause of action against the defendant, Jefirs tein, pursuant to this Section of the United States Code and the agreemetaeen the Defendant, Jeffrey Epstein, and the United States Governmek 0¶

475. As a direct and proximate resuiC4 the offenses enumerated in Title 18, United States Code, Section 2255, being -coinrnitted against her, L.M. has In the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological traun rJlental anguish, humiliation, embarrassment, loss of .,7"' self-esteem, loss of digni 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.

476. 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 116¶

"NA¶

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

December 2004 — Incident 3¶

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

-AMP,¶

478. On or about December 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal nse 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, an, other crimes, specifically including, but not limited to. those crimes designated in 18 U S.C. § 2422(5), § 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, Jeff Epstein, and the United States Government.

479. 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. incuffetcedical and psychological expenses and the plaintiff, L.M., will in the future au dice' and psychological expenses. The plaintiff, L.M., has suffered a loss of 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. losses in the future. I continue to suffer these¶

480. 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, acts, such other and further relief as this Court deems just and proper, and hereby d by Jury on all issues triable as of right by a jury.

) COUNT 118¶

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

December 2004 — Incident 4¶

⁴(aPlaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.¶

n or about December 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. § as such, asserts a cause of action against the defendant, Jeffrey Epstelni, uant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government.¶

483. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed al t her, L.M. hes in the past suffered, and will In the future suffer, phy Mju pain and suffering, emotional distress, psychological trauma, mental anguisk 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 t t- earn income in the future, and a loss of the capacity to enjoy life. These injuries L permanent in nature and the plaintiff, L.M., will continue to suffer these i losses in the future.

484. 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 117¶

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

January 2005 — Incident 1¶

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

486. On or about January 2005, 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 conde7 "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 minor engaging in sexually explicit conduct, child exploitation enterprises, smother crimes, specifically including, but not limited to, those crimes designated Intl, § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of ire or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a met of action against the defendant. Jeffrey Epstein. pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey ' , and the United States Government.

As a direct and proximate result of the offenses enumerated in Title 18, Unit -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.¶

488. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided fr by law, attorney's fees, costs, and such other ;we, 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.

°PUNT 118¶

Cause of Actlin>ursuant to 18 U.S.C. § 2255¶

January 2005— Incident 2¶

489. Plaintiff, L M. adopts and roalleges paragraphs 1 through 20 above.

490. On or about January 2005, the exact date being unknown to L.M., Defend e7i . . ffap Epstein, committed a federal sexual offense against her, including a violationof merous 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.

1_,¶

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 Dele Jeffrey Epstein, and the United States Government.¶

491. 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 injury14/ in 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 killItitte then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. Tbplaintiff, 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 t ure.

erefore, the plaintiff, L.M., demands judgments against the defendant, Jeffre 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 119¶

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

January 2005 — Incident 3¶

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

494. On or about January 2005, the exact date being unknown to L.M.,ac Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including 0 violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity,I travel with intent to engage in illicit sexual conduct, sex trafficking of childrro01 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 (*Amore offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of acit'egainst the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and t Z_ United ap_ States Government.

495. As a di 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.¶

496. 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 furth s this Court deems just and proper, and hereby demands trial by jury on all ble as of right by a jury.

COUNT 120¶

Cause of Action P_yrsuant to is U.S.C. 4 2265¶

January 2005 — Incident 4¶

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

498. On or about January 2005, 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 engagat illicit sexual conduct, sex trafficking of children, sexual exploitation of minor ehllAre, 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.¶

499. As a direct and proximate result of the offenses enumerated 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 Isrn ages associated with defendant, Jeffrey Epstein, controlling, manipul,4 ,poercing her into a perverse and conventional way of life for a minor. Th -minor plaintiff L.M. incurred medical and psychological expenses and the plakaiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, t......, Mhas suffered a loss of income, a loss of the capacity to earn income In the future. nd a loss of the capacity to enjoy life. These injuries are permanent in &and the plaintiff, L.M., will continue to suffer these losses in the future - •— .*, - _.

500. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by ItieSterney'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 121¶

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

February 2006 — Incident 1¶

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

502. On or about February 2005, 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 C e nd the agreement between the Defendant, Jeffrey Epstein, and the Unit overnment.

503. As a direct and mate 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-et In, loss of dignity, invasion of her privacy and other damages associated with defen nt, 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.¶

504. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum a provided by law, attorney's fees, costs, and such other and further relief as Co deems just and proper, and hereby demands trial by jury on all issues triablacs eof right by a Jury.

COUNT 12R¶

Cause of Action Pursuant tit Cit2255¶

February 200$ trident¶

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

506. On or about Februa 21105, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, ed a federal sexual offense against her, Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor lo engage in prostitution or sexual activity. travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor childrenvtrouiport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, a mino, 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.¶

507. 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, distress, psychological trauma, mental anguish, humiliation, embarra 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 pc Sbi /114s, psychological expenses. The plaintiff, L.M., tiered a loss of income, a loss of the capacity to earn income in the future, II of the capacity to enjoy life. These injuries are permanent in nature and the alntiff, L.M., will continue to suffer these losses in the future. Nt 1 7

508. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for et• ensatory, damages of at least the minimum amount provided by law, attorr fees ts, and such other and further relief as this Court deems just and proper,-egd hereby demands trial by jury on all issues triable as of right by a jury.

COUNT 123¶

Cause of Acton Pursuant to 18 U.S.C. i 2255¶

February 2006— Incident 3¶

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

510. On or about February 2005, 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 mivr children, transport of visual depictions of a minor engaging in sexually expliciteonduct, 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 enu 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defen rey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government.

511. 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 fere) 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 defenderrilsaEpstein, 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.¶

512. 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 124¶

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

February 2005 — Incident 4¶

513. Plaintiff, L.M. adopts and realleges • raphs 1 through 20 above.

514. On or about February 2005, tip Ct d to 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 enga titution or sexual activity, travel with intent to engage in illicit sexual conduct, lex 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.

515. 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 Incurred medical and psychological expenses and the plaintiff, L.M., will in the ffer medical and psychological expenses, The plaintiff, L.M., has suffered of income, a loss of the capacity to earn income .in the future, and a loss of the,tpadty to enjoy life. These Injuries are permanent In nature and the plaintiff, L.M.,WIII.eontinue to suffer these losses in the future.

516. Wherefore, the plaintiff, tAz demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, co ,and such other and further relief as this Court deems just and proper. and hereb t demands ip, trial by jury on all issues triable as of right by a jury.

COUNT 126¶

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

March 2005 — Incident 1¶

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

518. On or about March 2005, 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 notitinited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), 423(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 agreerttgtArpetween the Defendant, Jeffrey Epstein, and the United States Government.¶

519. As a direct and proximate result of the offenses enumerated in Title 18, A United States Code, Section 2255, be' committed against her, L.M. has in the past suffered, and will in the future slit physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of ,e-A self-esteem, loss of dignfbAkInvasion of her privacy and other damages associated with defendant, Jeffrey E p ein. controlling, manipulating and coercing her into a perverse, and conventional way 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 toss 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.

520. 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 126¶

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

March 2005 – Incident 2¶

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

522. On or about March 2005, 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.

523. 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.¶

524. 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 127¶

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

X y 525. laintiff, L.M. adopts and realleges paragraphs 1 through 20 above.¶

On or about March 2005, 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¶

March 2005 — Incident 3¶

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.CAMArd, 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.¶

527. 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, ph injury pain and suffering, emotional distress, psychological trauma, mental uish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion ,.....L 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 p'aintiff. 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 earn income in the future, and a loss of the capacity to enjoy life These injuries permanent in nature and the plaintiff, L.M., will continue to suffer these lossein the future.

528. 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 128¶

Cause of Action Pursuant to 18 U.S.C. 42265¶

March 2005 — Incident 4¶

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

530. On or about March 2005, 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 condemnir'e,coercion and enticement of a minor to engage in prostitution otextial activity, travel with intent to engage in illicit sexual conduct, sex traffickintcOildren, sexual exploitation of minor children, transport of visual depictions of ticinor engaging in sexually explicit conduct. child exploitation enterprises, and other crimes, specifically Including, but not limited to, those crimes designated 'net, t 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim o14/ Ot 21te 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.

531. As a direct and proximate result of the offenses enumerated in Title 18, UniteStates 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 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 \at¶

532. Wherefore, the plaintiff, L.M., demands)C ents against the defendant, a14/_, Jeffrey Epstein, for compensatory damages of at least 96 minimum amount provided by law, attorney's fees, costs, and such other triikil further relief as this Court deems just and proper, and hereby demands trIaliNerybrell issues triable as of right by a jury.

I OUNT 129¶

Cause of Actlo ursuant to 19 U.S.C. fi 2265¶

Awn 2005 — Incident 1¶

533 Plaintiff. L NI adopts and realleges paragraphs 1 through 20 above¶

534. On of at)Out April 2005, the exact date being unknown to L.M., Defendant, Jeffrey Epstein. acmmitted a federal sexual offense against her, including a violation of nurne 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.¶

535. 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 Injup( pt )nd 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

erefore. the plaintiff, L.M., demands judgments against the defendant, afire pstein, 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 130¶

Causo of Action Ppreuant to 18 U.S.C, 6 2255¶

Ann 2006 - Incident 2¶

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

538. On or about April 2005, 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 intenjjp engage in illicit sexual conduct, sex trafficking of children, sexual exploitation children, transport of visual depictions of a minor engaging in sexually explicit cdnduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2424V,t2423(b), and § 2423(e). L.M. is therefore a victim of one or more offensesinumerated 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.

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

540. 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 a this Court deems just and proper, and hereby demands trial by jury on al'• * , table as of right by a .

fr COUNT tit¶

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

April 2005 — Incident 3¶

541. Plaintiff, L.M.0 a *ti taerealleges paragraphs 1 through 20 above.

542 On or about ril ;b05. 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 co uct, sex trafficking of children, sexual exploitation of minor children, transport of visual pictions 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. edirriiv¶

543. As a direct and proximate result of the offenses enumerat 18, United States Code, Section 2255, being committed against her, L 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 90 amages associated with defendant, Jeffrey Epstein, controlling, manipulating anspeoercing 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

544. 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 132¶

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