IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT\ IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG\ CASE NO. 502009CA040800XXXXMB\ Judge David F. [REDACTED] JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and\ [REDACTED] J. [REDACTED], individually, Defendants/Counter-Plaintiffs. SHARON R. BOCK-CLERK\ PALM BEACH COUNTY, FL\ CIRCUIT CIVIL 2012 JAN 30 PM 12:42 FILED **PLAINTIFF JEFFREY EPSTEIN'S NOTICE OF FILING SUMMARY EXHIBIT OF\ OBJECTIONABLE QUESTIONS AND DEPOSITION TRANSCRIPT IN SUPPORT\ OF PLAINTIFF'S MOTION FOR PROTECTIVE ORDER RELATING TO HIS\ DEPOSITION AND MOTION TO TERMINATE DEPOSITION** Plaintiff, Jeffrey Epstein, by and through his undersigned counsel and pursuant to the Florida Rules of Civil Procedure, hereby gives notice of filing his Summary Exhibit (attached hereto as Exhibit 1) and the transcript of the Videotaped Deposition of Jeffrey Epstein taken on January 25, 2012 in Support of Plaintiff's Motion for Protective Order Relating to His Deposition and Motion to Terminate Deposition. Dated: January 27, 2012. Respectfully submitted, ![](<>)Joseph L. Ackerman, Jr.\ Florida Bar No. 235954\ [REDACTED] BURNETT, P.A. BURNETT, P.A. 901 Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 Attorneys for Plaintiff Jeffrey Epstei and Florida Bar No. 607363 • E. Knight OS BU KT, P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131 Telephone: (305) 789-9200 Facsimile: (305) 789-9201 Attorneys for Plaintiff Jeffrey Epstein ## CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via e-mail and U.S. Mail on this 27th day of January, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, P.A., 2139,Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., A e y, Goldberger & Weiss, P.A., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401-5012; and Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East BroM Blvd., Suite 700, Fort Lauderdale, FL 301. se Ackerm Jr. 9La ## SUMMARY EXHIBIT # Objectionable Questions and Statements Posed by Counsel for Defendant J. at the Videotaped Deposition of Jeffrey Epstein Taken on January 25, 2012 | Transcript | Questions | | ----------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------ | | Page 6, Line 2 | Do you now or have you ever had a sexual addiction? | | Page 6, Line 20\* | Do you now or have you ever had a sexual preference for minors? | | Page 6, Line 24\* | Have you ever acted on a sexual preference for minors? | | Page 7, Line 3 | Have you ever informed anyone other than your legal counsel that you have a sexual preference for minors? | | Page 7, Line 8 | Have you ever informed anyone other than your legal counsel that you have acted on a sexual preference for minors? | | Page 7, Line 13 | Have you ever sought or received evaluation, counseling, or treatment for any form of sexual addiction? | | Page 7, Line 18 | Have you ever sought or received evaluation, counseling, or treatment for any sex-related issue? | | Page 7, Line 23 | Have you ever retained the services of a consultant to assist in changing your public image following your arrest on sex-related charges? | | Page 8, Line 3 | Have you ever discussed with anyone undertaking an effort to change your public image following your arrest for and conviction of a sex-related crime? | | Page 8, Line 23\* | How many times have you solicited for prostitution? | | Page 9, Line 1\* | How many times have you solicited a minor for prostitution? | | Page 9, Line 4 | How many times have you solicited for prostitution in the State of Florida? | | Page 9, Line 7 | How many times have you solicited a minor for prostitution in the State of Florida? | | Page 9, Line 10 | How many times have you solicited for prostitution in the Virgin Islands? | | Page 11, Line 2 | Have you ever solicited for prostitution in the Virgin Islands? | | Page 11, Line 10 | Have you ever solicited for prostitution in New York? | | Page 11, Line 13 | Have you ever solicited for prostitution in New Mexico? | | Page 11, Line 16 | Have you ever solicited for prostitution in Paris? | | Page 11, Line 19\* | Have you ever solicited for prostitution anywhere at any time? | | Page 11, Line 22 | Have you ever solicited a minor for prostitution anywhere at any time? | | Page 11, Line 25\* | Who is the prostitute that you solicited for prostitution with respect to the claim on which you were convicted? | | Page 12, Line 4\* | Who is the minor that you solicited for prostitution with respect to the claim on which you pled guilty? | | Page 12, Line 13\* | Did you, in fact, plead guilty to soliciting a minor for prostitution? | | Page 12, Line 16 | Where was it that you solicited for prostitution in the manner – in the matter in which you pled guilty? | EXHIBIT # Questions When was it that you solicited for prostitution in the matter in which you pled guilty? Page 12, Line 20\* Have you ever discussed your sex-related arrest or conviction with any reporter or news media representative? Page 12, Line 23 Have you ever discussed your sex-related activities with minors in the State of Florida with any reporter or news media representative? Page 13, Line 22 Did you, in fact, engage in any sexual conduct with LM? Page 21, Line 10\* How many times did you engage in sexual conduct with LM? Page 21, Line 17\* # Statements # Transcript # Transcript Page 23, Line 5 through Page 24, Line 7: Mr. Scarola: So that the record is clear, it is my intention to ask very questions about every factual allegation included in every claim brought by Mr. Ed (behalf of every victim in every case in which it is alleged that Mr. has abusively prosecuted that claim. CO 'S I want to know about the connection between Mr. Epstein and each one of those alleged victims. I want to know about every individual who had information concerning the events that are alleged in those complaints, every individual who was in a position to have possibly had information about the events alleged in those complaints. I want to ask this witness about every person whose deposition was taken and scheduled to be taken, the relationship of those persons to Mr. Epstein, knowledge that those persons may have with respect to Mr. Epstein's activities with minors, other crimes committed by Mr. Epstein as part of an ongoing and continuous course of conduct supportive of claims for punitive damages against Mr. Epstein and supportive of RICO claims against him. And had this deposition been permitted to continue, we would have covered each of those areas and substantially more. ^\*Questions asked before by Mr. Scarola in March 17, 2010 Deposition of Jeffrey Epstein. ## IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO. 502009CA040600XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, J. , individually, and L.M., Defenda O ## VIDEOTAPED DEPOSITI FFREY EPSTEIN 25, 2012 - 10:03 a.m. SEARC NNEY, SCAROLA, BARNHART & SHIPLEY, PA \_139 Palm Beach Lakes Boulevard Icl!tife West Palm Beach Florida 33409 > Stenographically Reported By: Tammy Nestor, RPR ## APPEARANCES: ON BEHALF OF PLAINTIFF: JACK SCAROLA, ESQUIRE SEARCY, DENNEY, SCAROLA BARNHART & SHIPLEY, PA 2139 Palm Beach Lakes Boulevar West Palm Beach, Florida 334 ° ON BEHALF or DEFENDANT: E. KNIGHT RE L. ACKERMAN, SQUIRE BURN Espirito Santo 1395 Brickell4vEnl, 14th Floor Miami, Flor JACK A. L ERGER, ESQUIRE ATTERB LDBERGER & WEISS, PA One ake Centre, Suite 1400 25 ralian Avenue South lm Beach, Florida 33401 DARKEN K. INDYKE, ESQUIRE N,--3.151 East 66th Street, #10B New York, New York 10065 ______________________________________________________________________ I N D E X ______________________________________________________________________ EXAMINATION: PAGE By Mr. Scarola 4 ______________________________________________________________________ E X H I B I T S ______________________________________________________________________ EXHIBIT DESCRIPTION PAGE 1 Third Amended Complaint in LM v. Epstein 16 THE VIDEOGRAPHER: Today's date is January 25, 2012. The time is approximately 9:34 a.m. This is the videotaped deposition of Jeffrey Epstein in the matter of Epstein versus This deposition is being condu at 2139 Palm Beach Lakes Boulevard, Web m Beach, Florida. 9 The court reporter is u Nestor of 10 Phipps Reporting. Th- 'd grapher is Chris 11 Kennedy of Legal V'd 12 association wi i s Reporting. rvices, Inc. in 13 And wi th counsel please announce 14 appearan f f the record. 15 LA: My name is Jack Scarola. 16 nsel for Brad . Brad is also 17 sent. 18 MR. KNIGHT: Knight on behalf 19 r of Jeffrey Epstein. MR. GOLDBERGER: Jack Goldberger on behalf 21 Y of Jeffrey Epstein. 22 MR. INDYKE: Darren Indyke on behalf of 23 Jeffrey Epstein. 24 MR. ACKERMAN: Ackerman on behalf 25 of Jeffrey Epstein. your current residence address? Q Would you please state your full name and A I'm Jeffrey Edward Epstein. And residence address is 6100 Red Hodk Bou var Virgin Islands. AS :C ## JEFFREY EPSTEIN Was called as a witness and after being duly sworn on oath was examined and testified as follows: ## EXAMINATION BY MR. SCAROLA: Q Do you maintain any o idenoes presently? A I have vacati An New Mexico, Palm Beach, New York, an Q Would the address of each, please. A es. flew York is 9 East 71st Street. New Hexic is Zorro P 11,44r h, 0 -C -H. And where else? Palm Beach is 358 44IS T 1044Z, illo Way. Ranch Road. Paris is 22 Avenue 'hbol THE VIDEOGRAPHER: Pardon me, sir. THE WITNESS: Yes. THE VIDEOGRAPHER: Excuse me. Do you have your mike on? Thanks. 1 BY MR. SCAROLA: 2 Q Do you now or have you ever had a sexual 3 addiction? 4 S 6 area of this abuse of process lawsui MR. KNIGHT: I'm going to instruct him not to answer the question. That's outside of the 7 8 9 10 11 12 13 14 And just to let you know, h ere to answer all the questions you %lative to the abuse of process. The j has been pretty ery regarding any of ons, et cetera. And clear relative to the the prior sexual awe just so we don' \\ I'll be con has prey t your time or our time, on that per what the judge discussed regarding discovery. 15 16 17 r rulings have been. But we'll let the 18 ourt deal with that. OLA: Well, you and I have a very t understanding of what the court's 19 Y MR. SCAROLA: Q Do you now or have you ever had a sexual 21 preference for minors? 22 MR. KNIGHT: Same. 23 BY MR. SCAROLA: 24 Q Have you ever acted on a sexual preference 25 for minors? 1 MR. KNIGHT: Same. 2 BY MR. SCAROLA: 3 Q Have you ever informed anyone other than 4 your legal counsel that you have a sexual preference 5 for minors? 6 MR. KNIGHT: Same. 7 BY MR. SCAROLA: 8 9 10 Q Have you ever informed anyone other than your legal counsel that you have acted on a sexual preference for minors? 11 Ar%c ) MR. KNIGHT: 12 BY MR. SCAROLA: 13 14 15 Q Have you ever sought or received evaluation, counseling, or treatment for any form of sexual addiction? 16 MR. KNIGHT: Same. 17 BY MR. SCAROLA: 18 " Q Have you ever sought or received 19 evaluation, counseling, or treatment for any sex-related issue? 21 Y MR. KNIGHT: Same. 22 BY MR. SCAROLA: 23 Q Have you ever retained the services of a 24 consultant to assist in changing your public image 25 following your arrest on sex-related charges? 1 MR. KNIGHT: Sane. 2 BY MR. SCAROLA: 3 Q Have you ever discussed with anyone 4 undertaking an effort to change your public image 5 following 6 your arrest for and conviction of a sex-related crime? 7 MR. KNIGHT: Same. OS 8 BY MR. SCAROLA: 9 Q Have you ever be/en~con of a crime? 10 A Yes. 11 Q What was the . f which you were 12 convicted? 13 A Two c s, ne soliciting prostitution, 14 and procuring or for prostitution. 15 Q u, in fact, commit those acts? 16 17 Cl ,ndment privilege for you or you can invoke 18 t yourself. I prefer you invoke the 1 . GOLDBERGER: I can invoke the Fifth privilege. 2 21 THE WITNESS: I'm going to invoke my Fifth Amendment right. 22 BY MR. SCAROLA: 23 Q How many times have you solicited for 24 prostitution? 25 A I'm going invoke my Fifth Amendment right. How many times have you solicited a minor 2 for prostitution? 3 A Same answer. 4 Q How many times have you solicited for 5 prostitution in the State of Florida? 6 A Same answer. 7 Q How many times have you solicited a minor 8 for prostitution in the State of Florida? 9 A Same answer. 10 Q How many times have you solicited for 11 prostitution in the Virgin Islands? 12 13 a second? go off the record for one 14 MR. !MIMI . A cto a4di ^r we stop it here just for Sily, minute?. 15 1 VIDEOGRAPHER: The time is 9:39. We 16 ar oing off the record. 17 18 11?: ⁴⁹¹¹ (Thereupon, a discussion was held off the ecord.) 19 MR. SCAROLA: I would like you to take it down, please. 21 MR. KNIGHT: Fine. 22 MR. SCAROLA: And we'll go back on the 23 record. Thank you. 24 THE VIDEOGRAPHER: Stand by. 25 MR. KNIGHT: I'm wondering if you have any 1. 2 3 4 5 6 7 8 9 10 intention to ask any questions, and you may be, any questions outside of this clearly harassing area relative to issues that are outside of the four corners of the complaint or whether this is just going to be a continuance of estions of this witness that have no other of advancing this lawsuit but only •means of doing other things of which -- I don't care to list them here. Do C plan to go into other areas? 11 12 13 MR. SCAROLA: I - I am planning on taking a very 01 \\fi Du and comprehensive Assr deposition/ ;sMr Epstein. t, 14 15 16 : Are you asking -- planning to ask q tstions that are not sexual or cr i 1 in nature? 17 MR. SCAROLA: II, I'm sure there will be 18 any that you would probably not consider 19 sexual or criminal in nature, but I don't know. MR. KNIGHT: Let's proceed for a little ' 21 Y while, see what we can do, because certainly we 22 have taken the time out to come up here, 23 people's schedules have been made, et cetera, 24 people have traveled long distances, but we may 25 have to quit and go to the court. 1 BY MR. SCAROLA: 2 3 Q Have your ever solicited for prostitution in the Virgin Islands? 4 A Same answer. 5 6 Q That is that the you are invoking your A_A Fifth Amendment -- 7 A Yes. 8 Q -- right? CO ^S 9 A Yes, Mr. Scarola. 10 11 Q Have you ever solicited for prostitution in New York? 12 A Same ans 13 14 i^ Q Have you ever solicited for prostitution in new Mexic 15 nswer. 16 17 Q Have you ever solicited for prostitution in 18 Same answer. S ; 19 0 • Have you ever solicited for prostitution anywhere at any time? 21 r A Same answer. 22 Q Have you ever solicited a minor for 23 prostitution anywhere at any time? 24 A Same answer. 25 Q Who is the prostitute that you solicited 1 for prostitution with respect to the claim on which 2 you were convicted? 3 A Same answer. 4 Q Who is the minor that you solicited for 5 prostitution with respect to the claim on which you 6 pled guilty? 7 A Same answer. 8 Q Did you, in fact, plead- ilt to 9 soliciting for prostitution? 10 lit. KNIGHT: Asked and answered. 11 THE WITNESS: Yes, sir. 12 BY MR. SCAROLA: 13 Q Did you, in fact, plead guilty to 14 soliciting a minor for prostitution? 15 A No. 16 Q Where was it that you solicited for 17 prostitution in the manner -- in the matter in which 18 as; pled guilty? 19 O A Same answer. 2q7., k When was it that you solicited for 21 prostitution in the matter in which you pled guilty? 22 A Same answer. 23 Q Have you ever discussed your sex-related 24 arrest or conviction with any reporter or news media 25 representative? 1 MR. KNIGHT: I'm going to instruct you not 2 to answer the question. 3 MR. SCAROLA: And what is the basis of 4 that instruction? 5 MR. KNIGHT: What is the basis? 6 MR. SCAROLA: Yes. 7 I . KNIGHT: What does it to do with 8 this lawsuit? It's for no o ason other 9 than to harass him. There lenty of areas 10 you can go into which easonable. We are 11 here. 12 MR. SCARO the objection is 13 relevancy., th correct? 14 MR : No, it goes beyond relevancy. 15 ACk SCAROLA: Well, what is it then? 16 . KNIGHT: 17 -- it is being used to intimidate the 18 itness. It is being used for various 19 different reasons. And I believe it is improper. Well, it is harassing. It is 21 BY MR. SCAROLA: 22 23 activities with minors in the State of Florida with 24 any reporter or news media representative? Q Have you ever discussed your sex-related 25 MR. KNIGHT: Same instruction. We are 1 2 going to take a quick break if we the record. can go off 3 4 THE VIDEOGRAPHER: The time is 9:30 -- 9:40. We are going off the record. 5 6 (Thereupon, 9:43 a.m.) a recess was taken at 7 8 THE VIDEOGRAPHER: We are back on the ,..S. time 50 a.m. record. The 9 MR. KNIGHT: As 10 are here to answer qu 11 lawsuit that is at I menti tid-• 'earlier, we releVant to the 12 Relative r question earlier and the 13 instruction answer, I do believe it was 14 appropri ut I'm going to have 15 Mr. ger address what be believes the -- 16 . is y- our client is entitled to, but at the 17 time, there are other issues we want to put 18 n the record. 19 I will allow you to ask more questions, but if it's going to stay on this line, we may have 21 to adjourn. 22 MR. GOLDBERGER: Okay. This is Jack 23 Goldberger. A couple issues. First, as to the 24 questions that, Mr. Scarola, you asked 25 concerning conversations that Mr. Epstein may or may not have had with, I believe you couched 2 it as news reporters or news media, he would be 3 invoking Fifth Amendment privileges as to those 4 questions in addition to the objection raised 5 by Mr. Knight. 6 lit. KNIGHT: I'm withdrawing the====: 7 instruction. MR. GOLDBERGER: Okay. right. Anyhow he's invoking Fifth Amendmen Cot)ivileges as to that line of question \\ As to the tot 12 you are asking 13 issues, as 14 has fil wsuit in federal court where he is 15 seek overturn the non-prosecution 16 Int that Mr. Epstein is a party to. of questioning where p tein about sex-related your client, Mr. 17 I believe that you are asking these 18 questions in an effort to further Mr. 19 attempts to set aside that non-prosecution 2 agreement, and I think it serves no purpose 21 other than to assist your client in that 22 lawsuit. And I just think it's totally outside 23 the realm of the discovery that is allowed in 24 this case. And I'm simply not going to allow my 25 client to answer those questions given the fact 1 that your client has filed an action to set 2 aside the non-prosecution agreement that 3 Mr. Epstein is a party to. 4 5 MR. SCAROLA: Would you please mark this as Exhibit No. 1 to this deposition. 6 7 MR. KNIGHT: As soon as you ge A sticker on it, I'll look 'it at tha 8 9 ligigi i (Thereupon, Deposition No. I was marked for identification.) C\_ .) 10 11 THE VIDEOGRAPHER; omeone's phone by a microphone or in e cket? 12 MR. GOLD : I am. 13 14 THE VIDE : If you can put it to the sid e se. 15 16 LDBERGER: I'm all the way over here. 17 MR. KNIGHT: Mine is off. 18 MR. GOLDBERGER: I'll shut it off. 19 MR. KNIGHT: Okay. Thank you. BY MR. SCAROLA: 21 Q You have been handed a copy of what's been 22 marked as Exhibit No. 1 to this deposition. It is a 23 copy of Plaintiff's Third Amended Complaint in a 24 case styled LM versus Jeffrey Epstein. 25 Have you seen this document before? 1 A Not to the best of my recollection, no. 2 Q Do you recall having been sued by 3 on behalf of an individual who was 4 identified by the initials LM? 5 A Yes, sir. 6 Q And is this one of the cases t yo 7 contend was abusively prosecuted by 8 A I'm not sure if this islt act 9 complaint. 10 Q 1411, is thise th 11 A I don't know 12 Q Which case i )rthat you contend 13 abusively prosecuted against you? 14 A It N74' e LM case. I don't know if this 15 is the spe case. 16 Q Well, I want you to assume that there was 17 only one LM case that was filed by 18 against you. 19 A That's correct. 20 r Q Do you have any recollection that is at 21 " \\ odds with that assumption? 22 A Yes, I do. 23 Q You have a recollection that there was, in 24 fact, a federal court case as well as a state court 25 case, correct? 1 A Correct. 2 Q All right. Now, is it your -- 3 A I believe that's -- 4 Q is it your contention 6 MR. KNIGHT: Finish your answer. Did you finish your answer? 7 THE WITNESS: That's all r' 8 BY MR. SCAROLA: 9 Q Is it your contention 10 11 MR. KNIGHT: And me you want to finish your answe e do so. 12 THE WITNES 13 BY MR. SCAROLA: / ,\<1 14 Q Is it your contention that 15 abusively\_\_ prosecuted the state court case on behalf 16 of LM? 17 I don't know. Sorry. 18 Q Is it your contention that 19 O abusively prosecuted the federal court case on 20 6, behalf of LM? 21 MR. KNIGHT: Objection, asks for legal 22 conclusions. Obviously there were lawsuits 23 that were raised in this case. 24 MR. SCAROLA: You don't need to make a 25 speaking objection -- MR. KNIGHT: Okay. MR. SCAROLA. -- that's intended to coach the witness, Mr. Knight. MR. KNIGHT: I'm going to object. MR. SCAROLA: So if you say you ar objecting on the basis that it calls legal conclusion, that's fine. ow I would like the witness's answer un instructing him not to answe are MR. KNIGHT: I'm structing him not to answer. 12 BY MR. SCAROLA: 14 question? Okay. (Then would you please answer the 15 A Would you repeat it? 18 ourt action on behalf of LM? Ces, sir. Is it your contention that abusively prosecuted the federal 0 A Yes, sir. Q How? 21 r A filed a 234-count federal 22 complaint in conjunction with his partner Scott 23 Rothstein to enable his partners at RRA to defraud 24 south Florida investors of millions of dollars. 25 His partner Scott. Rothstein and his partner 1 2 3 4 5 6 7 8 Mr. Adler have -- excuse me, Mr. Rothstein has now in deposition admitted that they needed to file a complaint to show investors that there was real action, in Mr. Rothstein's words, going on in federal court. The investors had not been able to find a filed complaint and had complained to Mr. Rothstein that there was&filed complaints .two days, excuse me, before Mr. filed the federal complaint for 234. te... 9 Q Were you ever served with that complaint? 10 A Not to the best my recollection. 11 12 13 14 correct? Q So one contention is that Mr. abusively prosecuted a federal court action on behalf of LM with pc chlipu were never served, 15 A 16 in fact, Gel. S - L I was notified that the case was, 17 18 Q But you were never served with the case, 19 / S t? A I was notified that the case was filed. (::4) 20 • But you were never served with the case, 21 correct? 22 A Not to the best of my recollection. 23 24 25 you were never served? Q Okay. What damage did you incur as a consequence of the filing of a complaint with which 1 A I incurred many legal -- much legal fees, 2 many legal fees, in fact, to try to figure out 3 why -- what was going on and, in fact, getting 4 prepared to defend the case though I had not yet 5 been served. 6 Q Were the allegations in the federal 7 complaint on behalf of LM any different than the 8 allegations in the state court case on behalf of LM? 9 A I don't recall. 10 11 conduct with LM? Q Did you, in fact, engage in any sexual 12 A I'm sorry Ajl4Cil o" isure -- the jury is 13 going to recogn \\ is simply meant to harass 14 me, and I'll o take the Fifth Amendment since 15 your clie, is trying to overturn my 16 prosecu agreement. 17 18 How many times did you engage in sexual \<4 r onduCt with pin 19 2 O s,o A I'm going to have to invoke my Fifth Amendment right again, sir. 21 Do you know who LM is? 22 A Again I'm going to assert my right. 23 MR. KNIGHT: We are going to go off the 24 record and take another break. 25 THE VIDEOGRAPHER: The time is 9:58. We 1 are going off the record. 2 (Thereupon, a recess was taken at 3 9:58 a.m.) 4 THE VIDEOGRAPHER: The time is 10:00. We 5 are on the record. 6 I . KNIGHT: Okay. We have ask4d-o 7 several occasions that you ask ions that 8 are relevant to the lawsuit ar There have 9 been some questions that we tting to it. 10 You are back into the I stuff which we 11 feel is inappropr' t d also relative to the 12 issues that we i ed by Mr. Goldberger. 13 As su re going to recess and ask 14 further c ion from the court on what is 15 allo nd what is not allowable in this 16 de si ion. 17 MR. SCAROLA: So you are terminating the 18 eposition at this time? 19 MR. KNIGHT: We are recessing the deposition to get direction from the court. 21 Y MR. SCAROLA: Until when? 22 MR. KNIGHT: We will find out what the 23 court says. 24 MR. SCAROLA: When? Are you contacting 25 the judge right now? 1 2 3 4 MR. KNIGHT: I am not. We are going to file an appropriate motion and we are going to take it to the judge and see what he does. Thank you. 5 MR. SCAROLA: So that the record is clear, 6 it is my intention to ask very speci 7 questions about every factual al c ion 8 included in every claim brou 9 on behalf of every victim in y case in 10 which it is alleged t has 11 abusively prdsecut claim. 12 I want to Gout the connection between 13 Mr. Epstein h one of those alleged 14 victims. wa t to know about every individual 15 who rmation concerning the events that 16 ar ged in those complaints, 17 18 19 every vidual who was in a position to have 7 o 40 ssibly had information about the events ' alleged in those complaints. 2. I want to ask this witness about every 21 person whose deposition was taken and scheduled 22 to be taken, the relationship of those persons 23 to Mr. Epstein, knowledge that those persons may 24 have with respect to Mr. Epstein's activities 25 with minors, other crimes committed by C 1 Mr. Epstein as part of an ongoing and continuous 2 course of conduct supportive of claims for 3 punitive damages against Mr. Epstein and 4 supportive of RICO clails against him. 5 And had this deposition been permi ted to 6 continue, we .would have covered each 4' those 7 areas and substantially more. 8 nut. KNIGHT: Thank you. 9 THE VIDEOGRAPHER: The is 10:03. We 10 are going off the reco 11 (Thereupon, t ition was adjourned at 12 10:03 a.m.) • ## CERTIFICATE OF REPORTER STATE OF FLORIDA COUNTY OF BROWARD I, TAMMY NESTOR, Registered Pro ional Reporter, do hereby certify that I was a Ized to and did stenographically report the fore %position of JEFFREY EPSTEIN, that a review of th nscript was requested, and that the transc t s a true record of my stenographic notes A's I further employee, attorney, nor am I a relat attorneys or connected with the action, nor am I financially rested in the action. 'f y that I am not a relative, sel of any of the parties, mployee of any of the parties' \\Zip' Dated this 25th day of January 2012. TAMMY NESTOR, RPR CERTIFICATE OF OATHSTATE OF FLORIDA\ COUNTY OF BROWARD I, the undersigned authority, certify that JEFFREY EPSTEIN personally appeared before me and was duly sworn. Witness my hand and official seal this 25th day of January 2012. ______________________________________________________________________ Tammy Nestor, Court Reporter\ Notary Public, State of Florida\ Commission No.: EE 133933\ Commission Exp. Date: 10/23/2015 January 25, 2012 BURNETT, PA 1395 Brickell Avenue, 14th Floor Miami, Florida 33131 ATTN: E. KNIGHT, ESQUIRE Re: Epstein v Case No. 502009CA040800XXXXMBAG Please take notice that on the January 25, gave your deposition in the above cause. you did not waive your signature. The tra available for your review. you time ript is now Please call (888)811-3408 or email production@phippsreporting.com to sc dlule and appointment between the hours of 0 a.m. and 4:00 p.m., Monday through Friday, f to have access on your computer to a read-only of the transcript. If you are a party in th ordered a copy of this their copy of the tra execute the Errata \$lt t of the transcript,acd to all parties. n and your attorney has script, you may wish to read . In that event, please hich can be found at the back turn it to us for distribution If you do notes d and sign the deposition within thirty (30) days, the o ginal, which has already been forwarded t th ordering attorney, may be filed with the Clerk of Ehe Court. If u wish to waive your signature now, please sign yoy name in the blank at the bottom of this letter and ur it to us. TAMMY NESTOR, RPR Phipps Reporting, Inc. 1615 Forum Place, Suite 500 West Palm Beach, Florida 33401 truly yours, I do hereby waive my signature. JEFFREY EPSTEIN 21.imel N i, Under penalties of perjury, I declare that I have read the foregoing document and that the facts are true. stated in it 24 DATE JEFFREY EPSTEIN ## ERRATA SHEET DO NOT WRITE ON TRANSCRIPT ENTER CHANGES ON THIS PAGE In Re: Epstein v Case No. 502009CA040800XXXXMBAG JEFFREY EPSTEIN January 25, 2012 ( 3 :4) |

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arrest (3)
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aside (2)
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asked (3)
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asking (3)
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assert (1)
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association (1)
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assumption (1)
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attempts (1)
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ATTERBUR...
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ATTN (1)
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attorney (3)
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attorneys (1)
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Australian (1)
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authority (1)
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authorized (1)
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available (1)
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Avenue (4)
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a.m (8)
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14:7 22:3
24:12 27:9

bar (1)
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BARNHART ...
1:16 2:4
basis (3)
13:3,5 19:6
Beach (11)
1:1,16,17 2:5,5
2:13 4:7,7 5:14
5:19 27:22
behalf (14)
2:2,7 4:18,20,22
4:24 17:3
18:15,20 19:18
20:13 21:7,8
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believe (5)
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15:1,17 18:3
believes (1)
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best (3)
17:1 20:10,22
beyond (1)
13:14
blank (1)
27:18
bottom (1)
27:18
Boulevard (4)
1:16 2:5 4:7 5:9
Brad (2)
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[REDACTED] (10)
1:7 17:2,7,12,17
18:9,14,18
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break (2)
14:1 21:24
Brickell (2)
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Brillo (1)
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brought (1)
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BROWARD (2)
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BURNETT (2)
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call (1)
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called (1)
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calls (1)
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care (1)
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case (22)
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cases (1)
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cause (1)
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Centre (1)
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certainly (1)
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CERTIFICA...
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certify (3)
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cetera (2)
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change (2)
8:4 28:7
CHANGES (1)
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changing (1)
7:24
charges (1)
7:25
Chris (1)
4:10
[REDACTED] (3)
2:8 4:18 27:3
CIRCUIT (2)

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-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 1:1,1 | 21:11,18 24:2 | counsel (6) | day (2) | duly (2) | | ---------------------- | ------------------------ | --------------------- | ----------------------- | ---------------------- | | claim (4) | conducted (1) | 4:13,16 7:4,9 | 25:17 26:10 | 5:2 26:8 | | 12:1,5 23:8,11 | 4:6 - | 25:13,15 | days (2) | | | claims (2) | conjunction (1) | counseling (2) | 20:7 27:15 | E | | 24:2,4 | 19:22 | 7:14,19 | deal (1) | E (4) | | clear (2) | connected (1) | counts (1) | 6:18 | 2:8 3:1,8 27:3 | | 6:10 23:5 | 25:15 | 8:13 | declare (1) | earlier (2) | | Clearlake (1) | connection (1) | COUNTY (3) | 28:21 | 14:9,12 | | 2:12 | 23:12 | 1:1 25:4 26:4 | defend (1) | East (2) | | clearly (1) | consequence (1) | couple (1) | 21:4 | 2:15 5:17 | | 10:2 | 20:24 | 14:23 | DEFENDAN... | Edward (1) | | Clerk (1) | consider (1) | course (1) | 2:7 | 5:8 | | 27:16 | 10:18 | 24:2 | Defendant(s) (1) | [REDACTED] (20) | | client (6) | consistent (1) | court (18) | 1:9 | 1:7 4:5,16 15:13 | | 14:16 15:13,21 | 6:13 | 1:1 4:9 6:18 | defraud (1) | 15:18 17:3,7 | | 15:25 16:1 | consultant (1) | 10:25 15:14 | 19:23 | 17:13,17 18:14 | | 21:15 | 7:24 | 17:24,24 18:15 | DENNEY (2) | 18:18 19:17,21 | | coach (1) | contacting (1) | 18:19 19:18 | 1:16 2:4 | 20:7,11 21:15 | | 19:2 | 22:24 | 20:4,12 21:8 | deposition (17) | 23:8,10 27:4 | | come (1) | contend (2) | 22:14,20,23 | 1:10 4:3,6 10:13 | 28:3 | | 10:22 | 17:7,12 | 26:13 27:16 | 16:5,8,22 20:2 | EE (1) | | Commission (2) | contention (6) | court's (1) | 22:16,18,20 | 26:14 | | 26:14,14 | 18:4,9,14,18 | 6:16 | 23:21 24:5,11 | effort (2) | | commit (1) | 19:16 20:11 | covered (1) | 25:8 27:6,15 | 8:4 15:18 | | 8:15 | continuance (1) | 24:6 | DESCRIPTI... | El (1) | | committed (1) | 10:5 | crime (3) | 3:11 | 5:20 | | 23:25 | continue (1) | 8:6,9,11 | different (3) | email (1) | | complained (1) | 24:6 | crimes (1) | 6:16 13:19 21:7 | 27:8 | | 20:6 | continuous (1) | 23:25 | direction (2) | employee (2) | | complaint (11) | 24:1 | criminal (2) | 22:14,20 | 25:13,14 | | 3:12 10:4 16:23 | conversations ... | 10:16,19 | discovery (3) | enable (1) | | 17:9 19:22 | 14:25 | current (1) | 6:10,14 15:23 | 19:23 | | 20:2,5,8,9,24 | convicted (3) | 5:7 | discussed (4) | engage (2) | | 21:7 | 8:9,12 12:2 | | 6:14 8:3 12:23 | 21:10,17 | | complaints (3) | conviction (2) | | 13:22 | ENTER (1) | | 20:7 23:16,19 | 8:5 12:24 | D (1) | discussion (1) | 28:2 | | comprehensiv... | copy (4) | 3:1 | 9:17 | entitled (1) | | 10:12 | 16:21,23 27:12 | damage (1) | distances (1) | 14:16 | | computer (1) | 27:12 | 20:23 | 10:24 | Epstein (28) | | 27:10 | corners (1) | damages (1) | distribution (1) | 1:4,10 3:12 4:4 | | concerning (2) | 10:4 | 24:3 | 27:13 | 4:4,19,21,23 | | 14:25 23:15 | correct (7) | Darren (2) | document (2) | 4:25 5:1,8 | | conclusion (1) | 13:13 17:19,25 | 2:14 4:22 | 16:25 28:21 | 10:13 14:25 | | 19:7 | 18:1 20:14,18 | date (3) | doing,(1) | 15:12,16 16:3 | | conclusions (1) | 20:21 | 4:1 26:14 28:24 | 10:8 | 16:24 23:13,23 | | 18:22 | couched (1) | Dated (1) | dollars (1) | 24:1,3 25:9 | | conduct (3) | 15:1 | 25:17 | 19:24 | 26:7 27:4,25 | | 28:3,4,24 | feel (1) | Forum (1) | 22:12 | information (2) | | ------------------- | ---------------------- | ---------------------- | ------------------------- | ---------------------- | | Epstein's (1) | 22:11 | 27:21 | guilty (5) | 23:15,18 | | 23:24 | fees (2) | forwarded (1) | 12:6,8,13,18,21 | informed (2) | | Errata (2) | 21:1,2 | 27:16 | | 7:3,8 | | 27:13 28:1 | Fifth (8) | found (1) | H | initials (1) | | Espirito (1) | 8:16,20,25 11:6 | 27:13 | H (1) | 17:4 | | 2:9 | 15:3,9 21:14 | four (1) | 3:8 | instruct (2) | | ESQUIRE (6) | 21:19 | 10:4 | hand (1) | 6:4 13:1 | | 2:3,8,8,11,14 | figure (1) | (2) | 26:9 | instructing (2) | | 27:3 | 21:2 | 2:9 27:2 | handed (1) | 19:9,10 | | et (2) | file (2) | Friday (1) | 16:21 | instruction (4) | | 6:11 10:23 | 20:2 23:2 | 27:10 | harass (2) | 13:4,25 14:13 | | evaluation (2) | filed (10) | full (1) | 13:9 21:13 | 15:7 | | 7:14,19 | 15:14 16:1 | 5:6 | harassing (2) | intended (1) | | event (1) | 17:17 19:21 | further (3) | 10:2 13:16 | 19:2 | | 27:12 | 20:5,6,7,16,19 | 15:18 22:14 | held (1) | intention (2) | | events (2) | 27:16 | 25:12 | 9:17 | 10:1 23:6 | | 23:15,18 | filing (1) | F-O-C-H (1) | homes (1) | interested (1) | | exact (1) | 20:24 | 5:19 | 5:13 | 25:16 | | 17:8 | financially (1) | | Hook (1) | intimidate (1) | | EXAMINATI... | 25:16 | | 5:9 | 13:17 | | 3:3 5:4 | find (2) | getting (2) | hours (1) | investors (3) | | examined (1) | 20:5 22:22 | 21:3 22:9 | 27:9 | 19:24 20:3,5 | | 5:3 | fine (2) | give (1) | | invoke (6) | | excuse (3) | 9:21 19:7 | 5:15 | | 8:16,17,18,20 | | 5:23 20:1,7 | finish (3) | given (1) | identification ... | 8:25 21:19 | | execute (1) | 18:5,6,11 | 15:25 | 16:9 | invoking (3) | | 27:13 | First (1) | go (7) | identified (1) | 11:5 15:3,9 | | Exhibit (4) | 14:23 | 9:13,22 10:9,25 | 17:4 | Islands (3) | | 3:11 16:5,8,22 | Floor (2) | 13:10 14:1 | image (2) | 5:10 9:11 11:3 | | Exp (1) | 2:10 27:2 | 21:23 | 7:24 8:4 | issue (2) | | 26:14 | Florida (15) | goes (1) | improper (1) | 7:20 14:11 | | | 1:1,17 2:5,10,13 | 13:14 | 13:20 | issues (5) | | | 4:8 9:5,8 13:23 | going (23) | inappropriate... | 10:3 14:17,23 | | fact (9) | 19:24 25:3 | 6:4 8:20,25 9:16 | 22:11 | 15:13 22:12 | | 8:15 12:8,13 | 26:3,13 27:3 | 10:5 13:1 14:1 | included (1) | | | 15:25 17:24 | 27:22 | 14:4,14,20 | 23:8 | | | 20:16 21:2,3 | Foch (1) | 15:24 19:4 | incur (1) | J (1) | | 21:10 | 5:19 | 20:4 21:3,13 | 20:23 | 1:7 | | facts (1) | following (2) | 21:19,22,23 | incurred (1) | Jack (5) | | 28:21 | 7:25 8:5 | 22:1,13 23:1,2 | 21:1 | 2:3,11 4:15,20 | | factual (1) | follows (1) | 24:10 | individual (3) | 14:22 | | 23:7 | 5:3 | Goldberger (13) | 17:3 23:14,17 | January (7) | | federal (9) | foregoing (2) | 2:11,12 4:20,20 | individually (3) | 1:12 4:2 25:17 | | 15:14 17:24 | 25:8 28:21 | 8:16 14:15,22 | 1:7,7,8 | 26:10 27:1,6 | | 18:19 19:17,21 | form (1) | 14:23 15:8 | Indyke (3) | 28:5 | | 20:4,8,12 21:6 | 7:14 | 16:12,15,18 | 2:14 4:22,22 | Jeffrey (15) | | 1:4,10 4:4,19 | 1:16 2:5 4:7 | meant (1) | 20:13,17,20,25 | ordering (1) | | --------------- | ---------------- | ---------------- | ---------------- | ---------------- | | 4:21,23,25 5:1 | lawsuit (7) | 21:13 | new (8) | 27:16 | | 5:8 16:24 25:9 | 6:6 10:7 13:8 | media (3) | 2:15,15 5:13,14 | original (1) | | 26:7 27:25 | 14:11 15:14,22 | 12:24 13:24 | 5:17,17 11:11 | 27:15 | | 28:4,24 | 22:8 | 15:2 | 11:14 | outside (4) | | [REDACTED] (2) | lawsuits (1) | mentioned (1) | news (4) | 6:5 10:2,3 15:22 | | 2:8 4:24 | 18:22 | 14:9 | 12:24 13:24 | overturn (2) | | JR (1) | legal (8) | Mexico (3) | 15:2,2 | 15:15 21:15 | | 2:8 | 4:11 7:4,9 18:21 | 5:13,18 11:14 | non-prosecuti... |

P | | judge (4) | 19:7 21:1,1,2 | Miami (2) | 15:15,19 16:2 |

PA (5) | | 6:9,13 22:25 | letter (1) | 2:10 27:3 | Notary (1) | 1:16 2:4,9,12 | | 23:3 | 27:18 | microphone (1) | 26:13 | 27:2 | | JUDICIAL (1) | Let's (1) | 16:11 | notes (1) | PAGE (4) | | 1:1 | 10:20 | mike (1) | 25:11 | 3:3,11 28:2,7 | | jury (1) | line (4) | 5:24 | notice (1) | Palm (11) | | 21:12 | 14:20 15:10,11 | millions (1) | 27:6 | 1:1,16,17 2:5,5 | |

K | 28:7 | 19:24 | notified (2) | 2:13 4:7,7 5:13 | | K (1) | list (1) | Mine (1) | 20:15,19 | 5:19 27:22 | | 2:14 | 10:9 | 16:17 |

O | Pardon (1) | | Kennedy (1) | little (1) | minor (6) | oath (2) | 5:21 | | 4:11 | 10:20 | 8:14 9:1,7 11:22 | 5:2 26:1 | Paris (3) | | Knight (44) | LM (14) | 12:4,14 | object (1) | 5:14,18 11:17 | | 2:8 4:18,18 6:4 | 3:12 16:24 17:4 | minors (6) | 19:4 | part (1) | | 6:22 7:1,6,11 | 17:14,17 18:16 | 6:21,25 7:5,10 | objecting (1) | 24:1 | | 6:22 7:1,6,11 | 18:20 19:18 | 13:23 23:25 | 19:6 | parties (3) | | 7:16,21 8:1,7 | 20:13 21:7,8 | minute (1) | objection (4) | 25:13,14 27:14 | | 9:12,21,25 | 21:11,18,21 | 9:14 | 13:12 15:4 | partner (3) | | 10:14,20 12:10 | long (1) | Monday (1) | 18:21,25 | 19:22,25,25 | | 13:1,5,7,14,16 | 10:24 | 27:10 | Obviously (1) | partners (1) | | 13:25 14:9 | look (1) | motion (1) | 18:22 | 19:23 | | 15:5,6 16:6,17 | 16:7 | 23:2 | occasions (1) | party (3) | | 16:19 18:5,10 | L.M (1) |

N | 22:7 | 15:16 16:3 | | 18:21 19:1,3,4 | 1:8 |

N (1) | odds (1) | 27:11 | | 19:10 21:23 |

M | N (1) | 17:21 | penalties (1) | | 22:6,19,22 | maintain (1) | 3:1 | official (1) | 28:21 | | 23:1 24:8 27:3 | 5:11 | name (3) | 26:9 | people (1) | | know (9) | manner (1) | 4:15 5:6 27:18 | [REDACTED] (1) | 10:24 | | 6:7 10:19 15:13 | 12:17 | nature (2) | 10:17 | people's (1) | | 17:11,14 18:17 | 12:17 | 10:16,19 | Okay (7) | 10:23 | | 21:21 23:12,14 | mark (1) | need (1) | 14:22 15:8 | perjury (1) | | knowledge (1) | 16:4 | 18:24 | 16:19 19:1,13 | 28:21 | | 23:23 | marked (2) | needed (1) | 20:23 22:6 | permitted (1) | |

L | 16:9,22 | 20:2 | ongoing (1) | 24:5 | | L (1) | matter (3) | Nestor (6) | 24:1 | person (1) | | 2:8 | 4:4 12:17,21 | 1:21 4:9 25:6,19 | ordered (1) | 23:21 | | Lakes (3) | means (2) | 26:13 27:20 | 27:12 | personally (1) | | | 10:6,7 | never (4) | | | | 26:7 | 5:12 | Q | | 17:1,20,23 | retained (1) | | ----------------------- | ------------------------- | ----------------------- | ------------------------ | ---------------------- | ---------------------- | | persons (2) | pretty (1) | question (4) | record (15) | 20:10,22 | 7:23 | | 23:22,23 | 6:9 | 6:5 13:2 14:12 | 4:14 9:13,16,18 | 27:13,18 | return (2) | | Phipps (3) | previously (1) | 19:14 | 9:23 14:2,4,8 | review (2) | review (2) | | 4:10,12 27:21 | 6:14 | questioning (2) | 14:18 21:24 | 25:9 27:7 | RICO (1) | | phone (1) | prior (2) | 15:10,11 | 22:1,5 23:5 | 24:10 25:10 | 24:4 | | 16:10 | 6:11,17 | questions (14) | 24:10 25:10 | Red (1) | right (9) | | Place (1) | privilege (2) | 6:8 10:1,2,5,15 | 5:9 | 8:21,25 11:8 | regarding (2) | | 27:21 | 8:17,19 | 14:10,19,24 | 6:10,14 | 15:8 18:2,7 | 21:20,22 22:25 | | PLAINTIFF (1) | privileges (2) | 22:7,9 23:7 | Registered (1) | Road (1) | Rothstein (5) | | 2:2 | 15:3,9 | quick (1) | 25:6 | 5:18 | Rothstein (5) | | Plaintiff's (1) | probably (1) | 14:1 | relationship (1) | Rothstein's (1) | Rothstein's (1) | | 16:23 | 10:18 | 14:1 | 23:22 | 20:4 | RPR (3) | | Plaintiff(s) (1) | proceed (1) | quit (1) | relative (7) | RPR (3) | Rothstein (5) | | 1:5 | 10:20 | 10:25 | 23:22 | 1:21 25:19 | RRA (1) | | plan (1) | process (2) | | relevancy (2) | rulings (1) | rulings (1) | | 10:9 | 6:6,9 | | relative (7) | 6:17 | | | planning (2) | procuring (1) | raised (3) | relevancy (2) | S | | | 10:11,14 | 8:14 | 15:4 18:23 | 6:8,10 10:3 | S (1) | | | Plaza (1) | production@... | 22:12 | 14:12 22:11 | 3:8 | Santo (1) | | 2:9 | 27:9 | Ranch (1) | 25:12,14 | Says (1) | Scarola (44) | | plead (2) | Professional (1) | 5:18 | 13:13,14 | Says (1) | Scarola (44) | | 12:8,13 | 25:6 | read (3) | 14:10 22:8 | Scarola (44) | Scarola (44) | | please (12) | prosecuted (7) | 27:12,15 28:21 | relevant (2) | Says (1) | Scarola (44) | | 4:13 5:6,16 9:20 | 17:7,13 18:15 | 27:10 | 14:10 22:8 | Says (1) | Scarola (44) | | 16:4,14 18:11 | 18:19 19:17 | 27:10 | repeat (1) | Says (1) | Scarola (44) | | 19:13 27:6,8 | 20:12 23:11 | 27:10 | 19:15 | Says (1) | Scarola (44) | | 27:12,17 | prosecution (1) | real (1) | report (1) | Says (1) | Scarola (44) | | pled (3) | 21:16 | 20:3 | 25:8 | Says (1) | Scarola (44) | | 12:6,18,21 | prostitute (1) | realm (1) | Reported (1) | Says (1) | Scarola (44) | | plenty (1) | 11:25 | 15:23 | 1:21 | Says (1) | Scarola (44) | | 13:9 | prostitution (1... | reason (2) | reporter (6) | Says (1) | Scarola (44) | | pocket (1) | 8:13,14,24 9:2,5 | 13:8 28:7 | 4:9 12:24 13:24 | Says (1) | Scarola (44) | | 16:11 | 9:8,11 11:2,10 | reasonable (1) | 25:1,7 26:13 | Says (1) | Scarola (44) | | position (1) | 11:13,16,19,23 | 13:10 | reporters (1) | Says (1) | Scarola (44) | | 23:17 | 12:1,5,9,14,17 | reasons (1) | 15:2 | Says (1) | Scarola (44) | | possibly (1) | 12:21 | 13:19 | Reporting (3) | Says (1) | Scarola (44) | | 23:18 | public (3) | recall (2) | 4:10,12 27:21 | Says (1) | Scarola (44) | | prefer (1) | 7:24 8:4 26:13 | 17:2 21:9 | representative... | Says (1) | Scarola (44) | | 8:18 | punitive (1) | received (2) | 12:25 13:24 | Says (1) | Scarola (44) | | preference (4) | 24:3 | 7:13,18 | requested (1) | Says (1) | Scarola (44) | | 6:21,24 7:4,10 | purpose (1) | recess (3) | 25:10 | Says (1) | Scarola (44) | | prepared (1) | 15:20 | 14:5 22:2,13 | residence (2) | Says (1) | Scarola (44) | | 21:4 | put (2) | recessing (1) | 5:7,9 | Says (1) | Scarola (44) | | present (1) | 14:17 16:13 | 22:19 | residences (1) | Says (1) | Scarola (44) | | 4:17 | p.m (1) | recognize (1) | 5:11 | Says (1) | Scarola (44) | | presently (1) | 27:10 | 21:13 | respect (3) | Says (1) | Scarola (44) | | | | recollection (5) | 12:1,5 23:24 | Says (1) | Scarola (44) | | 22:21,24 23:5 | side (1) | 1:21 25:8 | things (1) | 26:6 | | ---------------------- | ----------------------- | ------------------------ | --------------------- | ----------------------- | | schedule (1) | 16:14 | sticker (1) | 10:8 | understandin... | | 27:9 | sign (2) | 16:7 | think (2) | 6:16 | | scheduled (1) | 27:15,17 | stop (1) | 15:20,22 | undertaking (1) | | 23:21 | signature (3) | 9:12 | Third (2) | 8:4 | | schedules (1) | 27:7,17,23 | Street (2) | 3:12 16:23 | | | 10:23 | simply (2) | 2:15 5:17 | thirty (1) | | | Scott (3) | 15:24 21:13 | stuff (1) | 27:15 | v (3) | | 1:7 19:22,25 | sir (6) | 22:10 | thorough (1) | 3:12 27:4 28:3 | | seal (1) | 5:21 12:11 17:5 | styled (1) | 10:12 | vacation (1) | | 26:9 | 19:16,19 21:20 | 16:24 | time (16) | 5:13 | | SEARCY (2) | solicited (15) | substantially (1) | 4:2 6:12,12 9:15 | various (1) | | 1:16 2:4 | 8:23 9:1,4,7,10 | 24:7 | 10:22 11:20,23 | 13:18 | | second (1) | 11:2,10,13,16 | sued (1) | 14:3,7,17 | version (1) | | 9:13 | 11:19,22,25 | 17:2 | 18:10 21:25 | 27:10 | | see (2) | 12:4,16,20 | Suite (2) | 22:4,18 24:9 | versus (2) | | 10:21 23:3 | soliciting (3) | 2:12 27:21 | 27:6 | 4:4 16:24 | | seeking (1) | 8:13 12:9,14 | supportive (2) | times (6) | victim (1) | | 15:15 | someone's (1) | 24:2,4 | 8:23 9:1,4,7,10 | 23:9 | | seen (1) | 16:10 | sure (4) | 21:17 | victims (1) | | 16:25 | soon (1) | 10:17 17:8 | Today's (1) | 23:14 | | served (6) | 16:6 | 18:12 21:12 | 4:1 | Video (1) | | 20:9,13,17,20 | sorry (3) | sworn (2) | 15:11 | 4:11 | | 20:25 21:5 | 18:17 19:15 | 5:2 26:8 | | videographer ... | | serves (1) | 21:12 | | totally (1) | 4:1,10 5:21,23 | | 15:20 | sought (2) | | 15:22 | 9:15,24 14:3,7 | | services (2) | 7:13,18 | T (1) | transcript (8) | 16:10,13 21:25 | | 4:11 7:23 | south (2) | 3:8 | 25:9,10 27:7,10 | 22:4 24:9 | | set (2) | 2:13 19:24 | take (6) | 27:12,12,13 | videotaped (2) | | 15:19 16:1 | speaking (1) | 9:19 14:1 21:14 | 28:2 | 1:10 4:3 | | sexual (12) | 18:25 | 21:24 23:3 | traveled (1) | Virgin (3) | | 6:2,11,20,24 7:4 | specific (2) | 27:6 | 10:24 | 5:10 9:11 11:3 | | 7:9,15 10:15 | 17:15 23:6 | taken (5) | treatment (2) | vs (1) | | 10:19 21:10,17 | Stand (1) | 10:22 14:5 22:2 | 7:14,19 | 1:6 | | 22:10 | 9:24 | 23:21,22 | true (2) | | | sex-related (6) | state (10) | Tammy (6) | 25:10 28:22 | W | | 7:20,25 8:6 | 5:6 9:5,8 13:23 | 1:21 4:9 25:6,19 | truly (1) | waive (3) | | 12:23 13:22 | 17:24 18:15 | 26:13 27:20 | 27:19 | 27:7,17,23 | | 15:12 | 21:8 25:3 26:3 | terminating (1) | try (1) | want (7) | | Sheet (2) | 26:13 | 22:17 | 21:2 | 6:8 14:17 17:16 | | 27:13 28:1 | stated (1) | testified (1) | trying (1) | 18:10 23:12,14 | | SHIPLEY (2) | 28:21 | 5:3 | 21:15 | 23:20 | | 1:16 2:4 | stay (1) | Thank (4) | two (2) | waste (1) | | show (1) | 14:20 | 9:23 16:19 23:4 | 8:13 20:7 | 6:12 | | 20:3 | stenographic (1) | 24:8 | | way (2) | | shut (1) | 25:11 | Thanks (1) | | 5:20 16:15 | | 16:18 | stenographica... | 5:24 | | WEISS (1) | | 2:12 | 10:00 (1) | 33131 (2) | 9:43 (1) | | ---------------------- | -------------------- | ----------------------- | --------------- | | West (5) | 22:4 | 2:10 27:3 | 14:6 | | 1:17 2:5,13 4:7 | 10:03 (3) | 33401 (2) | 9:50 (1) | | 27:22 | 1:13 24:9,12 | 2:13 27:22 | 14:7 | | we'll (2) | 10065 (1) | 33409 (2) | 9:58 (2) | | 6:17 9:22 | 2:15 | 1:17 2:5 | 21:25 22:3 | | [REDACTED] (2) | 133933 (1) | 358 (1) | | | 2:9 27:2 | 26:14 | 5:19 | | | wish (2) | 1395 (2) | | | | 27:12,17 | 2:10 27:2 | 4 | | | withdrawing (1) | 14th (2) | 4 (1) | | | 15:6 | 2:10 27:2 | 3:4 | | | witness (11) | 1400 (1) | 4:00 (1) | | | 5:2,22 8:20 10:6 | 2:12 | 27:9 | | | 12:11 13:18 | 15TH (1) | | | | 18:7,12 19:3 | 1:1 | | | | 23:20 26:9 | 16 (1) | 500 (1) | | | witness's (1) | 3:12 | 27:21 | | | 19:8 | 1615 (1) | 502009CA040... | | | wondering (1) | 27:21 | 1:2 27:5 28:4 | | | 9:25 | | | | | words (1) | 2 | 6 | | | 20:4 | 2012 (7) | 6100 (1) | | | WRITE (1) | 1:12 4:2 25:17 | 5:9 | | | 28:2 | 26:10 27:1,6 | 66th (1) | | | | 28:5 | 2:15 | | | X | 2139 (3) | | | | X (2) | 1:16 2:5 4:6 | 7 | | | 3:1,8 | 22 (1) | 71st (1) | | | | 5:18 | 5:17 | | | Y | 234 (1) | | | | York (5) | 20:8 | 8 | | | 2:15,15 5:14,17 | 234-count (1) | 888)811-3408 ... | | | 11:11 | 19:21 | 27:8 | | | Z | 25 (5) | 9 | | | Zorro (1) | 1:12 4:2 27:1,6 | 9 (1) | | | 5:18 | 28:5 | 5:17 | | | # | 25th (2) | 9:00 (1) | | | #10B (1) | 25:17 26:9 | 27:9 | | | 2:15 | 250 (1) | 9:30 (1) | | | | 2:13 | 14:3 | | | 1 | 3 | 9:34 (2) | | | 1 (4) | 30 (1) | 1:13 4:3 | | | 3:12 16:5,8,22 | 27:15 | 9:39 (1) | | | 10/23/2015 (1) | 301 (1) | 9:15 | | | 26:14 | 2:15 | 9:40 (1) | | | | | 14:4 | | #### IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA ## CIVIL DIVISION CASE NO.: 50 2008 CA 028051 =OMB AB L.M., Plaintiff, vs. JEFFREY EPSTEIN, Defendant. # pLAINTIFF'S THIRD AMENDED COMPLAINT ^O SA Plaintiff, L.M., by and through her undersigned counsel, Sun ( 1141) Jeffrey Epstein, and alleges: #### GENERAL ALLEGATIONS AS TO ALL COUNTS - 1. This is an action In an amount In exr s 000.00, exclusive of interest and costs and is within the jurisdictional limits Of this Court. - 2. This Complaint is brought under a fictitious name In order to protect the Identity of the plaintiff because this Complaint makes allegations of a sensitive sexual nature. - 3. At all times mate cause of action, the plaintiff, L.M. (hereinafter referred to as -Plaintifr), was a resident of Palm Beach County. Florida. - 4. At all limes material to this cause of action. Defendant, Jeffrey Epstein. had a residence bled at 358 El Eirillo Way. West Palm Beach, Palm Beach County, Florida. ![](_page_39_Picture_12.jpeg) 5. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he currently resides at 358 El Brillo Way, West Palm Beach, Florida where he is currently under community control as a condition of his sentence in criminal case number 06CF009454AMB. 1. At all times material to this cause of action, Defendant, Jeffrey Epstein. was an adult male born In 1953. 1. All of the allegations within this Complaint occurred in West Palm . Florida. 1. Upon information and belief, Defendant, Jeffrey En eln, demonstrated a sexual preference and obsession for minor girls. 1. Defendant, Jeffrey Epstein, along with numerous assistants, developed a plan, scheme, and criminal enterprise that Included an elaborate system wherein the then minor Plaintiff was brought to Defendant Jeffrey Epstein's residence by the Defendant's employees, recruiters, and assistants. When the assistants and employees left the then minor Plaintiff and other mirror e In a room at the defendant's mansion, Defendant, Jeffrey Epstein, h appear, remove his clothing, and direct the then minor Plaintiff to rein- her ClOthing. He would then perform one or more lewd, lascivious, and sexual acts, including, but not limited to. masturbation, touching of the then minor Plaintiffs sexual organs, using vibrators or sexual toys on the then minor Plaintiff, coercing the then minor Plaintiff into sexual acts with himself or others, and digitally penetrating the then minor Plaintiff. He would then pay the plaintiff for engaging in this sexual activity. 1. The plaintiff was first brought to Defendant, Jeffrey Epstein's mansion In 2002 when she was a thirteen or fourteen-year old. 1. The then minor Plaintiff 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 miner child to engage in a systematic pattern of sexually exploitive behavior. 1. Beginning in approximately July 2002 and continuing until approximately September 2005, Defendant, Jeffrey Epstein, coerced, Induced impressionable, vulnerable. and economically deprived then minor various acts of sexual misconduct. These acts Included, fondling and Inappropriate and illegal sexual touching of the then m and/or enticed the until( to commit not limited to. Plaintiff, forcing or inducing the then minor Plaintiff into sexual misconduct, masturbation of Defendant. Jeffrey Epstein, in the presence of the then minor Plaintiff, handling and fondling of the then minor Plaintiff's sexual organs, and encouraging the then minor Plaintiff to become involved in prostitution; Defendant. J Epstein. committed numerous criminal sexual offenses against the then minor Plaintiff including, but not limited to. sexual battery, solicitation of prostitution, molestation, coercing a minor into prostitution, contributing to the delinquency of a minor, and the commission of lewd and lascivious acts upon the person of the then minor Plaintiff. 1. In addition to the direct sexual abuse and molestation of the then minor Plaintiff. 0efendertOeffrey Epstein, instruCted, coerced and otherwise induced the then minor Plaintiff to bring him numerous other minor children for the purposes of further satisfying his deviant sexual attraction to minors. Defendant. Jeffrey Epstein, used his money, wealth and power to unduly and improperly manipulate and influence the then minor Plaintiff to bring him these other minor girls in exchange for money. This influence led the then minor Plaintiff away from the life of en adolescent teenage child and into a delinquent lifestyle. 1. The above-described acts took place in Palm Beach County. Florida at the residence of the Defendant. Jeffrey Epstein. Any assertions by Defendant, Jeffrey Epstein, that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provisions of applicable iidStbtos concerning the sexual exploitation and abuse of a minor child. T defendant, Jeffrey Epstein, at all times material to this cause of action, knew a Plaintiffs minority. a ye known of the 1. The above-described acts were perpetrated uairt the person of the then minor Plaintiff on numerous occasions. ## COUNT I ## Neminencs Per Se, violation of criminal statutes 16. The plaintiff adopts and welleges paragraphs 1 through 15 above. 01. Defendant. Jeff, negligently Injured Plaintiff, and/or failed to understand or appreciatLlhat)ki conduct as alleged herein would Injure Plaintiff, on numerous occasions between approximately July 2002 and approximately September 2005. O 18. In acting in the manner described in paragraphs 1 through 15, Defendant. Jeffrey Epstein, violated a duty to refrain from committing criminal actions against Plaintiff that proximately caused damages to Plaintiff. 01. In committing various crimes against Plaintiff, Defendant violated penal statutes that were designed to protect a class of persons, of which Plaintiff is a member, against a particular type of harm. 01. Particularly, the Florida Statutes which Epstein violated include, but may not be limited to: A. Chapter 800.04(4-7) — Lewd or lascivious offenses; Defendant Epstein engaged in sexual activity with Plaintiff when Plaintiff was less then 1 years of age, and also encouraged or enticed her at that time to bec involve prostitution or some other act of sexual activity; Defendant also violate& 1 tatule by touching in a lewd or lascivious manner the breasts, genitals. genital area or buttocks, or the clothing covering them, of Plaintiff at a time when Plaintiff was less than 16 years old, or enticed Plaintiff at that time to so touch Epstein. \*stein masturbated in the presence of Plaintiff when Plaintiff was less than 16 ye of B. Section 827.04 — Contributing to the delinquency of a child: Defendant induced or endeavored to Induce by act, threat, command, or persuasion, the then minor Plaintiff to commit or perform acts. follow a course of conduct, and live in a manner that caused or tended to MUSE, Plaintiff to become or remain delinquent. when he committed the acts described in paragraphs 12-15 above against Plaintiff. C. Section 796.03 - Procuring a minor for prostitution; Defendant procured for prostitution, or caused to be prostituted, Plaintiff when Plaintiff was under the age of 18. D. Section 796.07 — Prohibiting prostitution; Defendant owned. maintained and operated 8 place, to wit: his home located at 358 El Ballo Way, West Palm Beach, Palm Beach County. Florida, for the purpose of lewdness or prostitution. he received minors into his house for the purpose of lewdness or prostitution, and -Air directed, took, transported, or offered or agreed to transport Plaintiff to and from is house with the reasonable belief that the purpose of such directIngita transporting was lewdness or prostitution; E. Section 796.045 — Sex trafficking; Defends recruited, enticed, harbored, transported, or obtained Plaintiff, kn don would be used to cause Plaintiff to engage in prostitution; > F. Section 796.04 — Forcing, or coercing another to become a prostitute; Dot coed Plaintiff to become a prostitute; and a Section 39.01 (67) icualtlrse of a child; Defendant intruded Into the genitals of Plaintiff, when Plaintiff was a child, and touched her genitals or intimate parts, he Intentionally masturbated in front of her, he Intentionally exposed his genitals in her presence, and encouraged Plaintiff to engage in prostitution. 21. As to ea above referenced criminal statutes. Plaintiff was a member of the class of persons intended to be protected, the injury was of the type the statute Intended to protect, and the injuries suffered by Plaintiff proximately resulted from the violation of the criminal statute. 01. As a direct and proximate result of Defendant, Jeffrey Epstein's acts on Plaintiff, the plaintiff has In the past suffered, and will In the future suffer, physical injury. pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, Jeffrey Epstein. central, manipulating and coercing her into a perverse and unconventional way of life f minor. The then minor Plaintiff incurred medical and psychological expenses art i ie plaintiff will in the future suffer additional medical and psychological expenseinhe plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff will continue to suffer these losses in the future. WHEREFORE, the plaintiff, L.M., demands judgment against the defendant. Jeffrey Epstein, for compensatory damages, punitive damages, and such other and further relief as this Court deems just and p c r:ilpd hereby demands trial by jury on all issues triable as of right by a Jury..t ## OUNT II ## Intentional Sexual Tort Per Se In Violation of Criminal Statutes 23. The plaintiff adopts and realleges paragraphs I through 15 above. 01. Defendant, Jeffrey Epstein, intentionally injured Plaintiff sexually on numerous occasions between approximately July 2002 and approximately September not be limited to: 27. Particularly, the Florida Statutes which Epstein violated include, p.. 14/ ) 2005, and further sexually exploited her and contributed to her delinquency during that time. 25. In sexually abusing, battering and exploiting Plaintiff in the manner described in paragraphs 1 through 15, Defendant. Jeffrey Epstein, violated a duty to refrain from committing criminal actions against Plaintiff that proximately caused damages to Plaintiff. 01. In committing various crimes against Plaintiff, Defendant violated penal statutes that were designed to protect a class of persons, of which Plaintiff is a mamas:, against a particular type of harm. A Chapter 800.04(4.7) — Lewd or lascivious offenses: Defendant Epstein engaged in sexual activity with Plaintiff when Plaintiff was less than 16 years of age, and also encouraged or enticed her at that time to become involved in prostitution or some other act of sexual activity; Defendant also * sled this statute by touching in a lewd or lascivious manner the breasts, genitals. Ala I area or buttocks. or the clothing covering them, of Plaintiff at a time when Plaintiff was Less than 16 years old, or enticed Plaintiff at that time to so touch Epstein. Epstein masturbated in the presence of Plaintiff when Plaintiff was less than 16 years of age. B. Section 827.04 — Contributing to the delinquency of a child; Defendant induc endeavored to induce by act, threat, command, or persuasion. the thens Pbin e, ff to commit or perform acts. follow a course of conduct, and live in a manner that caused or tended to cause Plaintiff to become or remain delinquent. when he committed the acts described in paragraphs 12.15 above against Plaintiff. C. Section 796.03 — Procuring a minor for prostitution; Defendant procured for prostitution, or caused to be prostituted. Plaintiff when Plaintiff was under the age of 18. D. Section 796.07 — Prohibiting prostitution; Defendant owned, maintained and operated a place. to wit: his home located at 358 El Brilo Way, W Palm Beach, Palm Beach County. Florida, for the purpose of lewdness or prostit he received minors Into his house for the purpose of lewdness or prostffutIon, e directed, took, transported, or offered or agreed to transport Plaintiff 'to prs 01 his house with the reasonable belief that the purpose of such dire eking. or transporting was lewdness or prostitution; E. Section 796.045 — Sex trafficking; Def t knowingly recruited, enticed, harbored, transported, or obtained Plaintiff, kno that coercion would be used to cause Plaintiff to engage in prostitution; > F. Section 796.04 — Forcing, compelling, or coercing another to become a prostitute: Defendant coerced Plaintiff to become a prostitute: and G. Section 39.01 ( Sexual abuse of a child; Defendant intruded into the genitals of Plaintiff, when Plaintiff was a child, and touched her genitals or Intimate parts, he intentionally masturbated in front of her, he intentionally exposed his genitals In her presence, and encouraged Plaintiff to engage In prostitution. 28. As to each of the above referenced criminal statutes. Plaintiff was a member of the class of persons intended to be protected, the injury was of the type the statute intended to protect, and the injuries suffered by Plaintiff proximately resulted from the violation of the criminal statute. 01. As a direct and proximate result of Defendant, Jeffrey Epstein's criminal acts on Plaintiff, the plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress. psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion privacy and other damages associated with Defendant, Jeffrey Epstein, manipulating end coercing her Into a perverse and unconventional minor. The then minor plaintiff Incurred medical and psychological -a and the plaintiff will in the future suffer additional medical and psychological expenses. The plaintiff has suffered a loss of Income, a loss or the capacity to earn income in the future, and a loss of the capacity to enjoy life. These Injuries are permanent in nature and the plaintiff will continue to suffer these losses In the future. or a WHEREFORE, the plaintiff, L. ds judgment against the defendant, Jeffrey Epstein, for compensatory damages, punitive damages, 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. #### Cause o hAtif) COUNT III S on Pursuant to Florida Statute 798.09 Against Defendant. Jeffrey Epeteln ?30. S The y plaintiff adopts and realleges paragraphs 1 through 15 above 31. The allegations contained herein in Count II are a separate and distinct legal remedy. 01. Defendant, Jeffrey Epstein, was a wealthy and powerful man, and Plaintiff was an economically disadvantaged and impressionable minor. 01. Defendant, Jeffrey Epstein, used his vast wealth and power to coerce Plaintiff into prostitution and/or coerced her to remain in prostitution. 01. Defendant, Jeffrey Epstein, coerced Plaintiff into prostitution in one. more of the following ways: - A. Domination of her mind and body through exploitive technleunt - B. Inducement; - C. Promise of greater financial rewards; - O. Exploitation of a condition of developmental disability. cognitive limitation, affective disorder, and/or substance dependenoY; - E Exploitation of human needs for f ootIc heifer or affection; - F. Exploitation of underprivileged and vulnerable economic condition tit or situation; - G. Use of a system of recruiting other similarly situated minor girls to further coerce and induce Plaintiff into the lifestyle of prostitution; and - H. Exploitation through demonstration of abundant wealth and power to impress a young and vulnerable then minor Plaintiff and to coerce her into prostitution. 35. As a direct and proximate result of the offenses committed by Defendant, Jeffrey Epstein, against Plaintiff pursuant to Florida Statutes §798.09, the plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering. emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, boss of dignity, invasion of her privacy and other damages associated with Defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the plaintiff will in the future suffer additional medical and psychological expenses. The plaintiff has suffered a loss of income. a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff will continue to suffer these losses in the future. WHEREFORE, the plaintiff, L.M.. demands judgment against the defendant, Jeffrey Epstein, for compensatory damages, punitive damages, attorney's fees. 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 Jury' #### COUNT Intentional Infliction of Emotional Distress Against Defendant, Jeffrey Epstein 38. The plaintiff adopts and rooftops paragraphs 1 through 15 above. 01. The defendant, Jeffrey Epstein's conduct towards the then minor plaintiff was intentional and reckless and was outrageous in character, and so extreme in degree, going beyond all bounds of decency. 01. The defendant, Jeffrey Epstein's Intentional, deliberate and reckless conduct caused severe emotional distress to the plaintiff. Defendant, at the lime he committed these numerous sexual assaults on Plaintiff, had a specific Intent to harm the then minor Plaintiff and his conduct did so harm the plaintiff. 01. As a direct and proximate result of the defendant. Jeffrey Epstein's intentional and reckless conduct, the plaintiff has in the past suffered and in the future will continue to 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 itAth defendant, Jeffrey Epstein. controlling, manipulating and coercing hetinto llalitalKerse and unconventional way of life for a minor. The then minor Plaintiff Incurred medical and psychological expenses and the plaintiff will in the future suffer additional medical and psychological expenses. The plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent In nature and the plaintiff will continue to suffer these losses in the future, WHEREFORE, the plaintiff, L.M., demands Judgment against the defendant, Jeffrey Epstein, for compensatory damages, punitive damages, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. #### COUNT IV Battery - 40. The plaintiff, L.M., repeals and reafleges paragraphs 1 through 15 above. - 41. On numerous occasions, Defendant Epstein did in fact intentionally touch Plaintiff, L.M., on her person against her will and/or without her legal consent. - 42. Defendant Epstein battered Plaintiff sexually, in that he touched her in Intimate areas of her body and person In an offensive manner while she was a minor child. and therefore the touchings were without legal consent. - 43. Defendant Epstein touched her in Intimate areas of her body on goons of occasions between approximately July 2002 and September 20O5. - 44. The conduct described in this count constitutes battery a tgf . person of the then minor Plaintiff. - 45. As a direct and proximate result of Defendan Jeffrey Epsteln's battery on Plaintiff, the plaintiff has in the past suffered, and will I lure suffer, physical injury, "A' pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of her childhood, loss of dignity, invasion of her privacy and other damages associated with Defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then 4 Incurred medical and psychological expenses and Plaintiff will in the lure suffer additional medical and psychological expenses. Plaintiff 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 Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, demands judgment against the defendant, Jeffrey Epstein, for compensatory damages, punitive damages, 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. #### CERTICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been provided thi day of May 2010 via U.S. Mail and email transmittal to all those on the attached list. • > Ill Jaffe, WeissIna, Flatos & Lehrman, P.L. .Andrews Ave., Suite 2 Fort Lauderdale, FL 33301\_ (954) 524-2820 (954) 5 822 fax brad@ ustice.com By. SERVICE LIST Robert D. Critton, Jr.\ BURMAN, CRITTON, et al.\ 303 Banyan Boulevard, Suite 400\ West Palm Beach, FL 33401 Jay Howell, Esq.\ Jay Howell & Assoc.\ 644 Cesary Boulevard\ Suite 250\ Jacksonville, FL 32211 Jack Alan Goldberger, Esq.\ Atterbury Goldberger et al.\ 250 Australian Avenue South\ Suite 1400\ West Palm Beach, FL 33401 NOT A CERTIFIED COPY