### IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA

JANE DOE No. 101,

Plaintiff,

VS.

JEFFREY EPSTEIN,

Defendant.

09-80591

Civil Action No.

CH-MARRA

MAGISuper

COMPLAINT AND DEMAND FOR JURY TRIAL

FILED by i th - S - D C INTAKE

APR 1 7 2009

STEVEN M LARIMORE CLERK U.S DIST. CT. \$.0 OF FLA. MIAMI

# COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiff, Jane Doe No. 101 ("Jane Doe"), brings this Complaint against Defendant, Jeffrey Epstein, and states as follows:

## PARTIES. JURISDICTION, AND VENUE

- I. At all times material to this cause of action, Plaintiff, Jane Doe, was a resident of Palm Beach County, Florida.
- 2. This Complaint is brought under a fictitious name to protect the identity of Plaintiff, Jane Doe, because this Complaint makes sensitive allegations of sexual assault and abuse of a then minor.
- 3. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida.
- 4. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is currently incarcerated in the Palm Beach County Stockade.
- 5. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953.

6. This Court has jurisdiction of this action and the claims set forth herein pursuant to 18 U.S.C. § 2255.

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

# STATEMENT OF FACTS

8. At all relevant times, Defendant, Jeffrey Epstein, was an adult male, approximately 50 years old. Epstein is known as a billionaire financier and money manager with a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth, power, and influence. He owns a fleet of aircraft that includes a Gulfstream IV, a helicopter, and a Boeing 727. Until his incarceration, he maintained his principal place of residence in the largest home in Manhattan. a 51,000-square-foot eight-story mansion on the Upper East Side. Upon information and belief, he also owns a \$6.8 million mansion in Palm Beach, Florida, a \$30 million 7,500-acre ranch in New Mexico he named "Zorro," and a 70-acre private island known as Little St. James in St. , U.S. Virgin Islands. The allegations herein concern Defendant's conduct while at his lavish estate in Palm Beach.

1. Upon information and belief, Defendant has a sexual preference for underage minor girls. He engaged in a plan, scheme, or enterprise in which he gained access in his home to countless relatively economically disadvantaged minor girls, sexually assaulted or molested these girls, and then gave them money.

1. Beginning in or around 2001 through in or around September 2007, Defendant used his resources and his influence over vulnerable minor children to engage in a systematic pattern of sexually exploitative behavior.

1. Defendant's plan and scheme reflected a particular pattern and method. Defendant coerced and enticed impressionable, vulnerable, and relatively economically less

fortunate minors to participate in various acts of sexual misconduct that he committed upon them. Defendant's scheme involved the use of underage girls as well as other individuals to recruit other underage girls. Upon information and belief, Defendant or an authorized agent would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach residence. His assistants would seek out economically disadvantaged and underage girls from West Palm Beach and surrounding areas who would be enticed by the money being offered generally \$200 to \$300 per "massage" session—and who Defendant and/or his assistants perceived as less likely to complain to authorities or have credibility issues if allegations of improper conduct were made. The then minor Plaintiff and other minor girls, some as young as 14 years old, were transported to Defendant's Palm Beach county mansion by Defendant's employees, agents, and/or assistants in order to provide Defendant with "massages."

12. Defendant would pay the procurer of each girl's "appointment" approximately \$200. Many of the instances of illegal sexual conduct committed by Defendant were perpetrated with the assistance, support, and facilitation of at least three assistants who helped him orchestrate this child exploitation enterprise. These assistants would often arrange times for underage girls to come to Defendant's residence, transport or cause the transportation of underage girls to Defendant's residence, escort the underage girls to the massage room where Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the conclusion of each "massage appointment," and, upon information and belief, take nude photographs and/or videos of the underage girls' for Defendant without their knowledge.

01. Epstein designed the scheme to secure a private place in Defendant's mansion where only persons employed and invited by Epstein would be present, so as to reduce the chance of detection of Defendant's sexual abuse and prostitution as well as to make it more difficult for the minor girls to flee the premises and/or to credibly report his actions to law enforcement or other authorities. The girls were usually transported by his employees, agents, and/or assistants or by a taxicab paid for by Defendant in order to make it difficult for the girls to flee his mansion.

01. Upon arrival at Defendant's mansion, each underage victim would generally be introduced to one of Defendant's assistants, who would gather the girl's personal contact information. The minor girl would then be led up a flight of stairs to a room that contained a massage table and a large shower. The staircase leading to the room was plastered with nude photographs of young girls, including some photographs depicting two or more young girls engaged in lewd acts. Upon information and belief, Defendant, Jeffrey Epstein, had such photographs in each of his four homes and on his computer.

01. At times, if it was the girl's first "massage" appointment, another female would be in the room to "lead the way" until Defendant would have her leave. Generally, Defendant would start his massage wearing only a small towel, which eventually would be removed. Defendant would direct the girl to massage him, giving her specific instructions as to where and how he wanted to be touched, and then direct her to remove her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including masturbation, fondling the minor's breasts and/or sexual organs, touching the minor's vagina with a vibrator and/or back massager, digitally penetrating her vagina, performing intercourse, oral sex, and/or anal sex, and/or coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution. The exact degree of molestation and frequency with which the sexual crimes took place varied and is not yet completely known; however, at least when Defendant was in Palm Beach, Florida, such acts occurred usually on a daily basis and, in most instances, several times a day.

01. As previously stated in paragraph 14, Defendant displayed nude photographs of underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. Upon information and belief, some of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate commerce.

01. Consistent with the foregoing plan and scheme, Defendant used his money, wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff. Plaintiff, Jane Doe, was recruited by one of Defendant's agents to give Defendant a massage for compensation. Plaintiff was apprehensive, but needed the money and finally agreed to go. Plaintiff was first brought to Defendant's mansion in or about the spring of 2003, when she was merely 17 years old and in high school. Epstein's procurer drove her to Jeffrey Epstein's mansion. Plaintiff was led up a flight of stairs by a blonde woman to a spa room with a shower and a massage table, where she was left alone. A woman with dark hair, an accent, and naked from the waist up entered and tried to coax Plaintiff to remove her shirt, but Plaintiff refused. Atter the woman showed Plaintiff how to use the lotions that were there, the woman left. Defendant walked in wearing only a small towel. He lay down on the massage table still wearing the small towel, and Plaintiff began to massage his shoulders and neck. Nervously, she asked him what he did for a living. Defendant responded that he was a scientist. Defendant asked Plaintiff what year she would graduate high school, to which Plaintiff honestly replied that she would graduate in 2004. Plaintiff massaged Defendant's lower back and calves. Defendant

told her to remove his towel. Defendant told her that he had just worked out and wanted his buttocks massaged. Although disgusted, she was afraid to refuse and did it. At some point, Defendant ordered Plaintiff to remove her clothes. In shock, fear, and trepidation, Plaintiff partly complied, removing only her shirt and bra. When Defendant turned over, Plaintiff was afraid and embarrassed and she wanted to leave. Defendant repeatedly told her to relax and complimented her, saying that she had a nice body. Defendant then pulled Plaintiff closer to him. He began masturbating and then began fondling her breasts. He asked her to do more and mentioned more money, which she adamantly declined. Defendant continued masturbating until he ejaculated. Plaintiff next recalls that she received \$200 and was transported by the procurer, whom she later learned received \$200 for having brought her to Epstein's mansion.

IR. Defendant thereafter lured the then minor Plaintiff to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003. The procurer made another appointment for her to return, but Plaintiff didn't want to sec Defendant. By having his assistants continue to contact Plaintiff and attempt to lure her to the mansion for other sexual acts, Defendant engaged in a continuous course of conduct that injured Plaintiff upon each instance of contact and/or abuse.

19. In addition to the direct sexual abuse and molestation of the then minor Plaintiff, Defendant used his money, wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff to bring him another minor girl in a promised exchange for money. Rather than go herself, Plaintiff and the procurer took another girl there one time.

01. As a result of these encounters with Defendant, Plaintiff, Jane Doe, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and

other damages associated with Defendant's controlling and manipulating her into a perverse and unhealthy way of life.

21. Any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by her telling him her high school graduation year, as well as his own actions, and are rendered irrelevant by the provision of applicable federal statutes concerning the sexual exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of Plaintiff's age of minority. In fact, his preference for underage girls was well-known to those who regularly procured them for him.

01. Defendant, Jeffrey Epstein, committed the above-referenced acts upon the then minor Plaintiff in violation of federal 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, transport of child pornography, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(b), § 2423(c), § 2251, § 2252, § 2252A(a)(1), § 2252A(g)(1), and § 1591.

01. After investigations by the Palm Beach Police Department, the Palm Beach State Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's Office for the Southern District of Florida, Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution in June 2008 in the Fifteenth Judicial Circuit in Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability unto Plaintiff, Jane Doe. Plaintiff hereby exclusively seeks civil remedies pursuant to 18 U.S.C. § 2255.

## COUNT ONE (Cause of Action for Coercion and Enticement of Minor to 1 I-maze in Prostitution or Sexual Activity pursuant to 18 U.S.C. 4 2255 in Violation of 18 U.S.C. S 2422(b)1

24. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above.

01. Defendant, Jeffrey Epstein, used a facility or means of interstate commerce to knowingly persuade, induce, or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution and/or sexual activity for which any person can be charged with a criminal offense pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(b).

01. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.

01. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. 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 Plaintiff will continue to suffer these losses in the future.

WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other 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 TWO (Cause of Action for Travel with Intent to Engage in Illicit Sexual Conduct pursuant to 18 U.S.C. 5 2255 in Violation of 18 U.S.C. 5 2423(b))

28. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above.

01. Upon information and belief, Defendant, Jeffrey Epstein, traveled in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(0, with minor females, in violation of 18 U.S.C. § 2423(b).

01. Plaintiff. Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.

01. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. 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 Plaintiff will continue to suffer these losses in the future.

WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other 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 THREE (Cause of Action for Sex Trafficking of Children pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. & 1591(a))

32. Plaintiff, Jane Doe, hereby adopts, repeats. realleges, and incorporates by reference the allegations contained in paragraphs I through 23 above.

01. Defendant, Jeffrey Epstein, knowingly, in or affecting interstate or foreign commerce, recruited. enticed, and obtained Plaintiff, Jane Doe, knowing that she had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(cX1), in violation of 18 U.S.C. § 1591(a)(1).

01. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.

01. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and

unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. 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 Plaintiff will continue to suffer these losses in the future.

WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other 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 FOUR (Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. & 22511

36. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above.

01. Defendant, Jeffrey Epstein, knowingly induced, enticed, or coerced then minor Plaintiff Jane Doe to engage in sexually explicit conduct for the purpose of producing a visual depiction of such conduct in violation of 18 U.S.C. § 2251. As previously stated in paragraphs 14 and 16, Defendant displayed a myriad of photographs of underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate commerce.

01. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.

01. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. 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 Plaintiff will continue to suffer these losses in the future.

WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other 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 FIVE (Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit Conduct pursuant to 18 U.S.C. 2255 in Violation of 18 U.S.C. \$ 2252(a)(1)1

40. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above.

01. Defendant, Jeffrey Epstein. knowingly mailed, transported, or shipped in interstate or foreign commerce child pornography in violation of 18 U.S.C. § 2252(1). As previously stated in paragraphs 14, 16, and 37, upon information and belief, Defendant displayed a myriad of photographs of underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate commerce.

01. As previously stated in paragraph 21, any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provision of applicable federal and state statutes concerning the sexual exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of Plaintiff's age of minority. In fact, his preference for underage girls was well-known to those who regularly procured them for him.

01. Plaintiff, Janc Doc, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.

01. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. 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 Plaintiff will continue to suffer these losses in the future.

WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other 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 SIX (Cause of Action for Transport of Child Pornography pursuant to 18 U.S.C. 4 2255 in Violation of 18 U.S.C. 4 2252A(a)(1))

45. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above.

01. Defendant, Jeffrey Epstein, knowingly mailed, transported, or shipped in interstate or foreign commerce child pornography in violation of 18 U.S.C. § 2252A(a)(1).

01. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.

01. Defendant, Jeffrey Epstein, is in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability unto Plaintiff, Jane Doe.

01. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. 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 Plaintiff will continue to suffer these losses in the future.

WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other 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 SEVEN (Cause of Action for Emitting in a Child Exploitation Enterprise pursuant to 18 U.S.C. 2255 in Violation of 18 U.S.C. 4 2252A(211

50. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above.

01. Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 USC § 2252A(g)(1). As more fully set forth above in paragraphs 9 through 19, Defendant's actions involved countless victims and countless incidents of abuse, and he committed those offenses against minors in concert with at least three other persons.

01. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code.

01. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of ha privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. 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 Plaintiff will continue to suffer these losses in the future.

WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other 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.

Date: April 17, 2009 Rob..4 6 WE

Robert C. Joset 473:111o. 4 0408 56

Katherine W. Ezell, Bar No. 114771

Podhurst Orseck, P.A.

25 West Flagler Street, Suite 800

Miami, Florida 33130

(305) 358-2800

(305) 358-2382 (fax)

riosefsbenfectodhurst.com

kezell@podhurst.com

Attorneys for Plaintiff

# DEMAND FOR JURY TRIAL

Plaintiff demands to have her case tried before a jury.

Robert C. Josefs Bar No. 04\\326

Katherine W. Ezell, Bar No. 114771

Podhurst Orseck, P.A.

25 West Flagler Street, Suite 800

Miami, Florida 33130

(305) 358-2800

(305) 358-2382 (fax)

riosefsbergOnodhurst.com

kezell@podhurst.com

Attorneys for Plaintiff

C • kon

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) **NOTICE: Attorneys MUST Indicate All Re-filed Cases Below.**

**I. (a) PLAINTIFFS**

Jane Doe No. 101

(b) County of Residence of First Listed Plaintiff West Palm Beach\
(EXCEPT IN U.S. PLAINTIFF CASES)

(c) Attorney's (Firm Name, Address, and Telephone Number)

Robert C. Josefsberg, Esq./Katherine W. Ezell, Esq.\
Podhurst Orseck, P.A.\
25 W. Flagler St., Suite 800\
Miami FL 33130

(d) Check County Where Action Arose: MIAMI-DADE MONROE BROWARD PALM BEACH ST. LUCIE INDIAN RIVER OKEECHOBEE HIGHLANDS

**II. BASIS OF JURISDICTION**

1 U.S. Government Plaintiff 3 Federal Question (U.S. Government Not a Party)\
2 U.S. Government Defendant 4 Diversity (Indicate Citizenship of Parties in Item III)

**III. CITIZENSHIP OF PRINCIPAL PARTIES**

(For Diversity Cases Only) 1 PTF 2 PTF 3 PTF 4 PTF 5 PTF 6 PTF 7 PTF 8 PTF 9 PTF 10 PTF 11 PTF 12 PTF 13 PTF 14 PTF 15 PTF 16 PTF 17 PTF 18 PTF 19 PTF 20 PTF 21 PTF 22 PTF 23 PTF 24 PTF 25 PTF 26 PTF 27 PTF 28 PTF 29 PTF 30 PTF 31 PTF 32 PTF 33 PTF 34 PTF 35 PTF 36 PTF 37 PTF 38 PTF 39 PTF 40 PTF 41 PTF 42 PTF 43 PTF 44 PTF 45 PTF 46 PTF 47 PTF 48 PTF 49 PTF 50 PTF 51 PTF 52 PTF 53 PTF 54 PTF 55 PTF 56 PTF 57 PTF 58 PTF 59 PTF 60 PTF 61 PTF 62 PTF 63 PTF 64 PTF 65 PTF 66 PTF 67 PTF 68 PTF 69 PTF 70 PTF 71 PTF 72 PTF 73 PTF 74 PTF 75 PTF 76 PTF 77 PTF 78 PTF 79 PTF 80 PTF 81 PTF 82 PTF 83 PTF 84 PTF 85 PTF 86 PTF 87 PTF 88 PTF 89 PTF 90 PTF 91 PTF 92 PTF 93 PTF 94 PTF 95 PTF 96 PTF 97 PTF 98 PTF 99 PTF 100 PTF 101 PTF 102 PTF 103 PTF 104 PTF 105 PTF 106 PTF 107 PTF 108 PTF 109 PTF 110 PTF 111 PTF 112 PTF 113 PTF 114 PTF 115 PTF 116 PTF 117 PTF 118 PTF 119 PTF 120 PTF 121 PTF 122 PTF 123 PTF 124 PTF 125 PTF 126 PTF 127 PTF 128 PTF 129 PTF 130 PTF 131 PTF 132 PTF 133 PTF 134 PTF 135 PTF 136 PTF 137 PTF 138 PTF 139 PTF 140 PTF 141 PTF 142 PTF 143 PTF 144 PTF 145 PTF 146 PTF 147 PTF 148 PTF 149 PTF 150 PTF 151 PTF 152 PTF 153 PTF 154 PTF 155 PTF 156 PTF 157 PTF 158 PTF 159 PTF 160 PTF 161 PTF 162 PTF 163 PTF 164 PTF 165 PTF 166 PTF 167 PTF 168 PTF 169 PTF 170 PTF 171 PTF 172 PTF 173 PTF 174 PTF 175 PTF 176 PTF 177 PTF 178 PTF 179 PTF 180 PTF 181 PTF 182 PTF 183 PTF 184 PTF 185 PTF 186 PTF 187 PTF 188 PTF 189 PTF 190 PTF 191 PTF 192 PTF 233 PTF 234 PTF 235 PTF 236 PTF 237 PTF 238 PTF 239 PTF 240 PTF 241 PTF 242 PTF 243 PTF 244 PTF 245 PTF 246 PTF 247 PTF 248 PTF 249 PTF 250 PTF 251 PTF 252 PTF 253 PTF 254 PTF 255 PTF 256 PTF 257 PTF 258 PTF 259 PTF 260 PTF 261 PTF 262 PTF 263 PTF 264 PTF 265 PTF 266 PTF 267 PTF 268 PTF 269 PTF 270 PTF 271 PTF 272 PTF 273 PTF 274 PTF 275 PTF 276 PTF 277 PTF 278 PTF 279 PTF 280 PTF 281 PTF 282 PTF 283 PTF 284 PTF 285 PTF 286 PTF 287 PTF 288 PTF 289 PTF 290 PTF 291 PTF 292 PTF 293 PTF 294 PTF 295 PTF 296 PTF 297 PTF 298 PTF 299 PTF 300 PTF 301 PTF 302 PTF 303 PTF 304 PTF 305 PTF 306 PTF 307 PTF 308 PTF 309 PTF 310 PTF 311 PTF 312 PTF 313 PTF 314 PTF 315 PTF 316 PTF 317 PTF 318 PTF 319 PTF 320 PTF 321 PTF 322 PTF 323 PTF 324 PTF 325 PTF 326 PTF 327 PTF 328 PTF 329 PTF 330 PTF 331 PTF 332 PTF 333 PTF 334 PTF 335 PTF 336 PTF 337 PTF 338 PTF 339 PTF 340 PTF 341 PTF 342 PTF 343 PTF 344 PTF 345 PTF 346 PTF 347 PTF 348 PTF 349 PTF 350 PTF 351 PTF 352 PTF 353 PTF 354 PTF 355 PTF 356 PTF 357 PTF 358 PTF 359 PTF 360 PTF 361 PTF 362 PTF 363 PTF 364 PTF 365 PTF 366 PTF 367 PTF 368 PTF 369 PTF 370 PTF 371 PTF 372 PTF 373 PTF 374 PTF 375 PTF 376 PTF 377 PTF 378 PTF 379 PTF 380 PTF 381 PTF 382 PTF 383 PTF 384 PTF 385 PTF 386 PTF 387 PTF 388 PTF 389 PTF 390 PTF 391 PTF 392 PTF 393 PTF 394 PTF 395 PTF 396 PTF 397 PTF 398 PTF 399 PTF 400 PTF 401 PTF 402 PTF 403 PTF 404 PTF 405 PTF 406 PTF 407 PTF 408 PTF 409 PTF 410 PTF 410 PTF 411 PTF 412 PTF 413 PTF 414 PTF 415 PTF 416 PTF 417 PTF 418 PTF 419 PTF 420 PTF 421 PTF 422 PTF 423 PTF 424 PTF 425 PTF 426 PTF 427 PTF 428 PTF 429 PTF 430 PTF 431 PTF 432 PTF 433 PTF 434 PTF 435 PTF 436 PTF 437 PTF 438 PTF 439 PTF 440 PTF 441 PTF 442 PTF 443 PTF 444 PTF 445 PTF 446 PTF 447 PTF 448 PTF 449 PTF 450 PTF 451 PTF 452 PTF 453 PTF 454 PTF 455 PTF 456 PTF 457 PTF 458 PTF 459 PTF 460 PTF 461 PTF 462 PTF 463 PTF 464 PTF 465 PTF 466 PTF 467 PTF 468 PTF 469 PTF 470 PTF 471 PTF 472 PTF 473 PTF 474 PTF 475 PTF 476 PTF 477 PTF 478 PTF 479 PTF 480 PTF 481 PTF 482 PTF 483 PTF 484 PTF 485 PTF 486 PTF 487 PTF 488 PTF 489 PTF 490 PTF 491 PTF 492 PTF 493 PTF 494 PTF 495 PTF 496 PTF 497 PTF 498 PTF 499 PTF 500 PTF 501 PTF 502 PTF 503 PTF 504 PTF 505 PTF 506 PTF 507 PTF 508 PTF 509 PTF 510 PTF 511 PTF 512 PTF 513 PTF 514 PTF 515 PTF 516 PTF 517 PTF 518 PTF 519 PTF 520 PTF 521 PTF 522 PTF 523 PTF 524 PTF 525 PTF 526 PTF 527 PTF 528 PTF 529 PTF 530 PTF 531 PTF 532 PTF 533 PTF 534 PTF 535 PTF 536 PTF 537 PTF 538 PTF 539 PTF 540 PTF 541 PTF 542 PTF 543 PTF 544 PTF 545 PTF 546 PTF 547 PTF 548 PTF 549 PTF 550 PTF 551 PTF 552 PTF 553 PTF 554 PTF 555 PTF 556 PTF 557 PTF 558 PTF 559 PTF 560 PTF 561 PTF 562 PTF 563 PTF 564 PTF 565 PTF 566 PTF 567 PTF 568 PTF 569 PTF 570 PTF 571 PTF 572 PTF 573 PTF 574 PTF 575 PTF 576 PTF 577 PTF 578 PTF 579 PTF 580 PTF 581 PTF 582 PTF 583 PTF 584 PTF 585 PTF 586 PTF 587 PTF 588 PTF 589 PTF 590 PTF 591 PTF 592 PTF 593 PTF 594 PTF 595 PTF 596 PTF 597 PTF 598 PTF 599 PTF 600 PTF 601 PTF 602 PTF 603 PTF 604 PTF 605 PTF 606 PTF 607 PTF 608 PTF 609 PTF 610 PTF 611 PTF 612 PTF 613 PTF 614 PTF 615 PTF 616 PTF 617 PTF 618 PTF 619 PTF 620 PTF 621 PTF 622 PTF 623 PTF 624 PTF 625 PTF 626 PTF 627 PTF 628 PTF 629 PTF 630 PTF 630 PTF 631 PTF 632 PTF 633 PTF 634 PTF 635 PTF 636 PTF 637 PTF 638 PTF 639 PTF 640 PTF 641 PTF 642 PTF 643 PTF 644 PTF 645 PTF 646 PTF 647 PTF 648 PTF 649 PTF 650 PTF 651 PTF 652 PTF 653 PTF 654 PTF 655 PTF 656 PTF 657 PTF 658 PTF 659 PTF 660 PTF 661 PTF 662 PTF 663 PTF 664 PTF 665 PTF 666 PTF 668 PTF 669 PTF 670 PTF 671 PTF 672 PTF 673 PTF 674 PTF 675 PTF 676 PTF 677 PTF 678 PTF 679 PTF 680 PTF 681 PTF 682 PTF 683 PTF 684 PTF 685 PTF 686 PTF 687 PTF 688 PTF 689 PTF 690 PTF 691 PTF 692 PTF 693 PTF 694 PTF 695 PTF 696 PTF 697 PTF 698 PTF 699 PTF 700 PTF 701 PTF 702 PTF 703 PTF

### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION

## ATTACHMENT TO CIVIL COVER SHEET

FOR: Jane Doe No. 101 v. Jeffrey Epstein

# VI. RELATED/RE-FILED CASE(S):

08-80069

08-80119

08-80232

08-80380

08-80381

08-08804

08-80811

08-80893

08-80993

08-80994

08-80469