Virginia Roberts Giuffre 2009 lawsuit against Jeffrey Epstein

- Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 1 of 27 IN THE UNITED STATES DISTRICT COURT pein 09-80656 i CirRviamp “> vs. MAY - 1 2008 | JEFFREY EPSTEIN, Mace ce lL Riser Defendant. DEMAND FOR JURY TRIAL , Plaintiff, Jane Doe No. 102, brings this Complaint against Defendant, Jeffrey Epstein, and states as follows: 1 At all times material to this cause of action, Plaintiff, Jane Doe No. 102, was a 2 This Complaint is brought under a fictitious name to protect the identity of mes 4. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is s. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an SE Mheowrr  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 2 of 27 6. This Count has jurisdiction over this action and the claims set forth herein pursuant to 18 U.S.C. § 2255. 7. This Court has venue of this action pursuant to 28 USC. § 1391), as a substantial part of the events giving rise o the claim occurred inthis District STATEMENT OF FACTS 8 Atall elevant times, Defendant, Jeffrey Epstein, was an adult male, spanning the ages of 45 and 55 years old. Epstein is known as a billionaire financier and money manager with a sceret 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 Bocing 727, as well as a fleet of motor vehicles. Until his incarceration, he maintained his principal place of residence in the largest home in Manhattan, a $1,000-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. “Zoo,” a T0-acre private island known as Little St. James in St. Thomas, U.S. Virgin Islands, a ‘mansion in London's Westminster neighborhood, and a home in the Avenue Foch area of Paris. “The allegations herein concern Defendant's conduct while at his lavish homes and/or numerous other locations both nationally and internationally 9. Upon information and belicf, Defendant has a sexual preference for underage minor girls. He engaged in a plan, scheme, or enterprise in which he gained access to countless. vulnerable and relatively economically disadvantaged minor girls, and sexually assaulted, ‘molested, and/or exploited these girls, and then gave them money. 10. Beginning in or around 1998 through in or around September 2007, Defendant used his resources and his influence over vulnerable minor girl to engage in a systematic pattem of sexually exploitative behavior. Podhurst Orseck, PA. 25 West Pager Steet, Suite 800, Misr, FL 39130, Mia 3053582000 Fax 305.358.2302 + For Lauderdale 5504404546 | wee podarstoom  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 3 of 27 IL. Defendant's plan and scheme reflected a particular pattem and method. Defendant coerced and enticed impressionable, vulnerable, and relatively economically less fortunate minor girls 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 girl. Upon information and belief, Defendant andor an authorized agent would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach residence. His assistants would call economically disadvantaged and underage girls from West Palm Beach and surrounding areas who would be enticed by the money being offered 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 12 years old, were transported to Defendants Palm Beach mansion by Defendant's employees, agents, andlor assistants in order (0 provide Defendant with massages 12. 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 Defendants residence, transport or cause the transportation of underage girls to Defendant's residence, escort the underage girls 10 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 with andlor without their knowledge. Defendant would pay the procurer of each girls “appointment” hundreds of dollars 3 Podhurst Orseck, PA. 25 Wet Fogler Sret, Se 800, Via, FL 3913, Mia 05 358 2500 Fax 305 3562382 + For Loeerdale 354634346 em podem  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 4 of 27 13. Epstein designed this scheme to secure a private place in Defendant's Palm Beach ‘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 employes, agents, andor assistants or by a taxicab paid for by Defendant in order to make it difficult for the girls to flee his mansion, 14. Upon arrival at Defendants Palm Beach mansion, each underage victim would ‘generally be introduced to one of Defendant's assistants, who would gather the gir’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 girl, 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 six homes and/or on his computers. 1S. At times, if it was the girl's first “massage” appointment, another female would be in the room 10 “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 andlor the other female would direct the girl to massage him, giving the minor girl specific instructions as to where and how he wanted to be touched, and then direct her o 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 vulva, vagina, and/or anus with a vibrator and/or back massager and/or his finger(s) and/or his penis, digitally penetrating her vagina, performing intercourse, oral sex, and/or anal sex, and/or coercing or atlempting to coerce the girl to engage in lewd acts and/or prostitution and/or 4 Podhurst Orseck, PA.  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page § of 27 enticing the then minor girl to engage in seual acts with another female in Defendant's presence. The exact degree of molestation and frequency with which the sexual exploitation took place varied and is not yet completely known; however, Defendant committed such acts regularly on a daily basis and, in most instances, several times a day. In order to facilitate the daily exchanges of money for sexual assault and abuse, Defendant kept U.S. currency readily available 16. Defendant, Epstein, traveled to his mansion in Palm Beach for the purpose of uring minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to contact these minor girls for the purpose of coercing them into acts of prostitution and to enable himself to commit sexual battery against them and/or acts of lewdness in their presence, and he conspired with others, including assistants and/or his driver(s) and/or pilots), and his socialite friend/partner, Ghislaine Maxwell, to further these acts and to avoid police detection. Defendant's systematic pattem of sexually exploitative behavior referred to in paragraph 10 and. described in paragraphs 11 through the present paragraph occured in all of Defendant's ‘domestic and international residences and/or places of lodging and/or modes of transportation. 17. 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 A vulnerable young girl, Plaintiff was working as a changing room assistant at The Mar-A-Lago Club in Palm Beach making approximately $9 an hour when she was first lured into Defendant's sexually exploitative world. In or about the summer of 1998, when Plaintiff was merely fifteen years old while attending to her duties at Mar-A-Lago, Plaintiff was recruited by Ghislaine Maxwell, who lived, traveled, socialized, and worked with Defendant. Ms. Maxwell asked Plaindff if she was interested in leaming massage therapy and eaming a great deal of money while leaming the profession. PlaintifPs father, who was a maintenance manager at The Mar-A- 5 Podhurst Orseck, PA. 25 Wet Flagler Steet Sut 00 Mm, L513, Mia 305358280 Fox 305 3582562 + Fort Lindale 50463506 [remm——  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 6 of 27 Lago Club, was not apprehensive because he felt comforted that an older woman had approached Plaintiff with this opportunity. As a result, PlaintfF’s father dropped off Plaintiff at Defendant's mansion that same day. Ms. Maxwell met Plaintiff and her father outside of Defendant's Palm Beach mansion, where Ms. Maxwell assured the minor girls father that Ms. Maxwell would provide transportation home for his tecnaged daughter. Ghislaine Maxwell led Plaindff up a flight of stairs to a spa room with a shower and a massage table. Defendant was lying naked on the massage table. Plaintiff was shocked, but, with no experience with massages, thought this could be massage therapy protocol. Ms. Maxwell then (00k off her own shirt and left on her underwear and started rubbing her breasts across Defendant's body, impliedly showing Plaintiff what she was expected to do. Ms. Maxwell then tld Plaintiff to take off her clothes. The minor girl was apprehensive about doing this, bu, in fear, proceeded to follow Ms. Maxwell by removing everything but her underwear. She was then ordered (0 remove her underwear and to straddle Defendant, The encounter escalated, with Defendant and Ms. Maxwell sexually assaulting, battering, exploiting, and abusing Plaintiff in various ways and in various locations, including the steam room and shower. At the end of this sexually exploitive abuse, Defendant and Ms. Maxwell giddily told Plaintiff to return the following day and told her she had “lots of potential.” Defendant paid Plaintiff hundreds of dollars, old her it was for two hours of work, and directed one of his employees to drive her home. 18. Defendant andlor his procurers thereafle lured the then minor Plaintiff (© his Palm Beach mansion every day for the next two weeks in order to engage in a similar pattern of sexual exploitation. Defendant and/or his procurers arranged at the end of each incident the transportation and scheduling for the following day's appointment. Additionally, Defendant telephoned the minor Plaintiff himself and/or had Ms. Maxwell telephone Plaintiff to make amangements. Plaintiff was often times driven to and from Epstein’s mansion by Epstein 6 Podhurst Orseck, PA.  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 7 of 27 himself or his driver. Altematively, Defendant or Ms. Maxwell would amange and pay for Plaintiff's transportation home by taxicab. 19. During Plaintiff's second incident of being sexually exploited and assaulted by Defendant at Defendant's Palm Beach mansion, Defendant asked Plaintiff to quit her job at The Mar.A-Lago Club and travel with him (© eam much more money while learning the massage profession. Thus, Plaintiff, an impressionable and vulnerable young girl of modest means, quit her job as a changing room assistant, was lured by Defendant, and continued to be victimized by Defendant, who immersed the minor Plaindff into Defendant's lewd and abusive lifestyle. Under Defendant's dominion and control, Defendant continuously “groomed” the minor adolescent. Defendant's daily routine required the minor Plaintiff (0 perform sexually on Defendant multiple times per day and to provide Defendant massages multiple times per day. Plaintiff had absolutely no say as to when, how many times, or what was done during cach sexual encounter. Often, Plaintiff was joined by Ms. Maxwell, Ms. Maxwell's assistant, and/or a countless array of young women who would be brought to one of Defendants homes for the. sexual trysts and then be sexually exploited by Defendant. 20. The first time that Defendant transported Plaintiff to another state in order to engage in sexual acts with her occurred when she was merely fifteen years old and after only two weeks of daily sexually abusive encounters with Defendant. Defendant used his private jet to transport the minor Plaintiff to Manhattan, where he provided her with spending money and accommodations with him at his mansion. From the time that Plaintiff was 15 years old, Defendant abused her to serve his every sexual whim, obtaining and purchasing passports and whatever was needed for her to travel with him andor for him. Defendant transported Plaintiff in his private jet to locations that included Palm Beach, New York City, Santa Fe, Los Angeles, San Francisco, St. Louis, and numerous other domestic destinations, as well as intemational 7 Podhurst Orseck, PA. 25 Wet Flagler trot Sti 0, Mis, LOI, Mia 505350280 Fox 3053562362 + Fort Lauderdale 956.406 ow pots com  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 8 of 27 destinations, including Europe, the Caribbean, and Africa. He provided accommodations with him in order to have her available to him at all times wherever he went, including while transporting the minor Plaintiff on his private jet. Each time they would travel to one of these destinations, the same patter of sexual abuse would occur, often with a vast array of aspiring modes, actresses, celebrities, and/or other females, including minors, from all over the world Upon information and belief, Defendant transporied minor girls from Turkey, the Czech Republic, Asia, and numerous other countries, many of whom spoke no English. To PlaintfP’s knowledge, the only females specifically excluded from Defendant's sexual escapades were African-American 21. In addition to being continually exploited to satisfy Defendants every sexual whim, Plaintiff was also required to be sexually exploited by Defendants adult male peers, including royalty, politicians, academicians, businessmen, andor other professional and personal acquaintances. Whenever Defendant transported Plaintiff with him in his private jet to any destination, Defendant would pay Plaintiff a flat rate per day while he andlor his above- ‘mentioned associates would sexually exploit and abuse minor Plaintiff 22. Most of these acts of abuse occurred during a time when Defendant knew that Plaintiff was approximately 15, 16, and 17 years old, and, after years of daily sexual exploitation, continued into her adulthood. Despite Defendant's stating shortly before PlaintfPs sixteenth birthday that he soon would have to trade her in because she was getting 100 old, Defendant continued to sexually exploit Plaintiff until she fled at age 19. Defendant's predilection for young girls was well known (0 those who regularly procured them for him and to his circle of friends. On one of Defendant's birthdays, frend of Defendant sent him three 12-year-old girls from France who spoke no English for Defendant to sexually exploit and abuse. Afer doing so, they were sent back to France the next day. 8 Podhurst Orseck, PA. 25 Wo Far Stet, Sie 60, Mas FL. 3930, Mian 30535280 Fx 05 562552 + Fort Laverda S5L4G45%6 ww podhasteom,  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 9 of 27 23. Any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by 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, Jeffiey Epstein, at all times material to this cause of action, knew and should have known of PlaintifTs age of minority. Defendant and Ms. Maxwell acknowledged and celebrated PlaintifF’s 16” birthday. Defendant's preference for underage girls was well-known to those who regularly procured them for him. 24. As previously stated in paragraph 14, Defendant displayed nude photographs of underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Plaindf, Jane Doe No. 102, saw photographs of naked young girls in each of Defendants homes, including a photograph of herself naked at Defendant’s home in Palm Beach. When she asked Defendant about i, he stated dismissively that he had naked photographs of her in al of his homes. 25. Upon information and belief, some of the photographs in Defendants possession were taken with hidden cameras set up in 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 Defendants home. Upon information and belief, Defendant may have taken lewd photographs of Plaintiff, Jane Doe No. 102, 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 and/or foreign commerce. In addition, while Plaintiff was a minor teenager and upon Ms. Maxwell's insistence after Ms. Maxwell rejected as inappropriate photographs that Plaintiff presented of herself fully clothed, Ms. Maxwell photographed Plaintiff naked in different sexually explicit positions. Ms. Maxwell then presented these nude Photographs of Plaintiff to Defendant as a birthday present for Defendant from Ms. Maxell. 9 Podhurst Orseck, PA. 25 Wot Faget Site 800 Ms, FL S519, Mia 3053502500 Fox 05358282 + For Lauded 504630546 | wwe poco  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 10 of 27 Upon information and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Sherif’s Office during its execution of a search warrant of Defendants Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are sill in the custody of law enforcement. 26. Its virtually impossible to calculate the exact number of times that Defendant sexually exploited and abused Plaintiff, From the age of 15, Plaintiff was sexually exploited and abused by Defendant on a daily basis and, most often, multiple times each day. While some of the precise dates these acts occurred are unknown to Plaintiff, these dates are known to Defendant, as he is reported to have kept a written log of each instance in which he engaged in these lewd acts with then minor Plaintiff and others. Upon information and belie, these logs are also in the custody of law enforcement 27. In or around September 2002, Defendant purchased a commercial round-trip airline ticket, and provided a passport, U.S. currency, and accommodations for Plaintiff to fly to Thailand. While thousands of miles away from Defendant on this extended trip alone for the first time in more than four years, Plaintiff met, fell in love, and married a young man. She escaped from Defendant's abuse with the help and insistence of her new husband and, instead of retuming to Defendant, boarded a plane to Australia with one suitcase. 28. Since November 2002, Plaintiff has lived a modest life in Australia, while ‘maintaining lines of communication with her family and without contact with Defendant or any of the people in his entourage. However, suddenly, in 2008, Plaintiff received numerous phone calls from one of Defendant's agents. During these phone calls to Plaintiff he repeatedly asked whether she knew anything about the civil cases against Defendant, whether she knew any of the females who were proceeding with the civil suits, whether she was planning on filing suit, whether she was communicating and/or cooperating with anyone against Defendant, and whether 10 Podhurst Orseck, PA.  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 11 of 27 she would retum to the United States to testify. Terrified by Defendant's demonstrated ability to track her down on her changed cell phone number halfway across the world, Plaintiff attempted to reassure Defendant's agent that she would remain quiet. During the course of one of these. phone calls from Defendant's agents, Defendant himself spoke on the phone, continued to question her intentions, and, upon being reassured by Plaintiff, thanked her for not getting involved. 29. Around January 2009, Plaintiff received a letter rom the United States Atomey’s Office for the Southern District of Florida, informing her of her potential civil claims against Defendant under 18 U.S.C. § 2255. Plaintiff contacted undersigned counsel within days and diligently and repeatedly pursued a good faith viable settlement of her clams against Defendant. Unable to reach a settlement, this lawsuit followed. 30. Asa result of these encounters with Defendant, Plaintiff, Jane Doe No. 102, has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological andlor psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's controlling and manipulating her on a daily basis for years into a perverse and unhealthy way of life. 31. Defendant, Jeffrey Epstein, committed the above-referenced acts upon 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 pomography, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated n Podhurst Orseck, PA. 25 West Flagler Street, Sulte800, Mimi, FL 3313, Mia 35.358 2800 Fa 05358232 + For Ldrdal 354463646 ‘whew podhursteom  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 12 of 27 in 18 USC. § 2421, § 2422(a), § 242200), § 2423(a), § 2423(b), § 2423(e), § 2251, § 2252, § 2252A)(1), and § 2252A)(1). 32. In June 2008, aftr investigations by the Palm Beach Police Department, the Palm Beach State Attomey’s Office, the Federal Bureau of Investigation, and the United Stes Attomey’s Office for the Southem District of Florida, Defendant, Jeffrey Epstein, entered pleas of “guilty” to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution in the Fificenth Judicial Circuit in Palm Beach County, Florida. Defendant, Jefliey Epstein, is in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability unto Plaintiff, Jane Doe No. 102. 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 Engage in Prostitution or ‘Sexual Activity pursuant to 18 UsS.C. § 2255 in Violation of 18 U.S.C. § 2422(b)) 33. Plaintiff Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs | through 32 above. 34. Defendant, Jeffrey Epstein, used a facility or means of interstate and/or foreign commerce to knowingly persuade, induce, entice, or coerce Jane Doe No. 102, when she was under the age of 18 years, o engage in prostitution and/or sexual activity for which any person can be charged with a criminal offense, or attempted to do so, pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(b). 35. Plaindft, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 US.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 12 Podhurst Orseck, PA. 25 West Flagler Street, Sule 500, Mimi, FL 3313, Mia 305.358 280 Fan 35358297 + For Lderdal 354654546 ew potbsteom  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 13 of 27 36. Asa direct and proximate result of the offenses enumerated in 18 US.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological andor psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, Separation from her family, and other damages associated with Defendant's manipulating and leading her ino 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 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, Jane Doe No. 102, demands judgment against Defendant, Jeffiey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attomey’s fies, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on al issues triable as of right by ajury. COUNT TWO (Cause of Action for Transportation of Minor with Intent to Engage in Criminal Sexual ‘Activity pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2423(a) 37. Plaintiff Jane Doe No. 102, hercby adopts, repeats, realleges, and incorporates by. reference the allegations contained in paragraphs 1 through 32 above. 38. Defendant, Jeffrey Epstein, knowingly transported then minor Plaintiff Jane Doe No. 102, in interstate andlor foreign commerce, with the intent that Plaintif§ engage in prostitution, or in any sexual activity for which any person can be charged with a criminal offense, in violation 18 U.S.C. § 2423(a). As previously stated in paragraphs 20, 21, and 27, 13 Podhurst Orseck, PA. 25 Wot Flagler Strat Sue S00, Mia, FL 313, Mia 05358 2500 Fon 305 356.2082 + Fort Lard F4634346 ww podiustoom  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 14 of 27 Defendant transported Plaintiff, Jane Doe No. 102, across state lines and across intemational borders numerous times from the time that Plaintiff was merely 15 years old through adulthood with the primary intent of sexually exploiting her 30. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 US.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 40. As a direct and proximate result of the offenses enumerated in 18 USC. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and wil in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological andor psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, oss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant’s manipulating and leading her into a perverse and unhealthy way of life for a minor. The then minor Plainiff 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 cam 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 No. 102, 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. 14 Podhurst Orseck, PA. 25 West Fogler Srot, Suite 800 Mian, FL 35130, Mi 05 358 2500 Fou 305 358.2982 + Fort Lacerda S54A83. 4346 ve podbamteom  Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 15 of 27 COUNT THREE (Cause of Action for Travel with Intent to Engage in lc Sexual Conduct pursuant to 18 41. Plain, Jane Doe No. 102, hereby adopt, repeats, ealeges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above. 42. Upon information and belief, Defendant, Jeffrey Epstein, traveled in interstate and/or foreign commerce with the intent to engage in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females, including the then minor Plaintiff, in violation of 18 USC. §2423(0) 43. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 US.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 44. Asa 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 continue to 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, Separation from her family, and other damages associated with Defendant's manipulating and leading he 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 futur, 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 No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 1s Podhurst Orseck, P.A. vrata Se Sat 80 WF ST Sa TSR Fe RE + Foie | pedro  Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 16 of 27 actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as {is Court deems just and proper, and hereby demands tia by jury onal issues triable as of right by ajury. COUNT FOUR (Cause of Action for Coercion and Enticement to Engage in Prostitution or Sexual Activity 45. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, ralleges, and incorporates by reference the allegations contained in paragraphs | through 32 above. 46. Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, and/or coerced Jane Doe No. 102 to travel in interstate andlor foreign commerce to engage in prostitution and/or sexual activity for which any person can be charged with a criminal offense, or attempted to do so, pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(a). 47. Plaindff, Jane Doe No. 102, was a victim of one of more offenses enumerated in 18 USC. § 2255, and, as such, assets a cause of action against Defendant, Jeffey Epsicin, pursuant to this Section of the United States Code. 48. Asa 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 continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of cducational opportuitics, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way off. 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 eam 16 Podhurst Orseck, PA. tage See Sate mma LE Mant I Fox BERR + Po amt pot  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 17 of 27 income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue o suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attomey’s fees, costs of suit, and such other further relief as this Court deems just and proper, and hercby demands trial by jury on all issues triable as of right bya jury. COUNT FIVE, (Cause of Action for Transportation with Intent to Engage in Criminal Sexual Activity ‘pursuant to 18 U.S.C. § 2255 in Violation of 18 US.C. § 2421) 49. Plaintiff Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by. reference the allegations contained in paragraphs 1 through 32 above. 50. Defendant, Jeflrey Epstcin, knowingly transported, or attempted to transport, Plaintiff, Jane Doc No. 102, in interstate and/or foreign commerce, with the intent that Plaintiff engage in prostitution and/or in any sexual activity for which any person can be charged with a criminal offense, in violation of 18 U.S.C. § 2421. As previously stated in paragraphs 20, 21, and 27, Defendant transported Plaintiff, Jane Doe No. 102, across state lines and across international borders numerous times from the time that Plaintiff was merely 15 years old through adulthood with the primary intent of sexually exploiting her. 51. Plaindff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 USC. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant (0 this Section of the United States Code. 52. Asa direct and proximate result of the offenses enumerated in 18 US.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintif has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 7 Podhurst Orseck, PA. 25 West lager trot, Sule 800, Mi, FL 39130, Mia 305358280 Fax 535822 + For Lderdal 54460846 [E———  | Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 18 of 27 psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, oss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life for a minor. 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 cam 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 No. 102, 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 byajury. COUNT SIX (Cause of Action for Sexual Exploitation of Children pursuant to 18 US.C. § 2255 in Violation of 18 U.S.C. § 2251 53. Plaintiff Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above. 54. Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, or coerced the then minor Plaintiff 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 14,24, and 25, Defendant kept and displayed a myriad of nude photographs of underage girls throughout his homes, including his homes in New York City, Palm Beach, Santa Fe, and the USS. Virgin Islands. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each of Defendant's homes, including a photograph of herself naked at Defendant’s home in Palm 18 Podhurst Orseck, PA. 25 Wet ger Set, Sle 60, Mia FL 3150, Mia 30505280 Fo 05 56.252 + Fort Landed S646 rw podhastcom  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 19 of 27 Beach. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up in 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 No. 102, 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 and/or foreign commerce. Upon information and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were. confiscated by the Palm Beach Sheri’s Office during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those Photographs are sil in the custody of law enforcement. 55. Plaintiff Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 USC. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 56. Asa 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 continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, oss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plain 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 cam 19 Podhurst Orseck, PA.  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 20 of 27 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 No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attomey’s fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands tial by jury on all issues triable as of right bya jury. COUNT SEVEN (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) 57. Plaintifl, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above. 58. Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via computer andor facsimile in or affecting interstate and/or foreign commerce at least one visual depiction of the minor Plaintiff engaging in sexually explicit conduct, in violation of 18 U.S.C. § 2252(a)(1). As previously stated in paragraphs 14, 24, and 25, Defendant displayed a myriad of nude photographs of underage girls throughout his homes, including his homes in New York City. Palm Beach, Sania Fe, and the US. Virgin Islands. Plaintiff, Jane Doe No. 102, saw Photographs of naked young girls in cach of Defendant's homes, including a photograph of herself naked as a minor at Defendant's home in Palm Beach. As previously stated in paragraph 24, Defendant told Plaintiff that he had photographs of her naked in all of his homes. 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 nude photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd 20 Podhurst Orseck, PA.  Case 9:09-0v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 21 of 27 photographs of Plaintif, Jane Doe No. 102, 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 and/or foreign commerce. Upon information and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Sheriff's Office during its execution of a search warrant of Defendants Palm Beach mansion on October 20, 2005. Upon information and belief, those ‘photographs are sil in the custody of law enforcement. 59. As previously stated in paragraph 23, 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. Defendant's preference for underage girls was well-known to those who regularly procured them for him. 60. Plainiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 USC. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 61. Asa direct and proximate result of the offenses enumerated in 18 US.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological andor psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of digity, invasion of her privacy, separation from her family, 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 2 ‘Podhurst Orseck, PA. 25 Wt Fagen Stet, Sle 0, Mas, FL 39150, 306.39 280 Fx 053502352 + Fort Laderdale 354463456 ww podhasom,  Case 9:09-v-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 22 of 27 psychological expenses. Plaintiff has suffered a loss of income, a 1oss of the capacity to cam 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 No. 102, demands judgment against Defendant, Jeffrey Epstein, for al damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fies, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all sues triable as of right byajury COUNT EIGHT (Cause of Action for Transport of Child Pornography pursuant to 18 US.C. § 2255 in Violation of 18 US.C. § 2282A@)1) 62. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above. 63. Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via computer and/or facsimile in or affecting interstate and/or foreign commerce child pomography in violation of 18 U.S.C. § 2252A@)(1). 64. Plaindff Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 USC. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant (0 this Section of the United States Code. 65. Asa 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 continue to suffer, physical injury, pain and suffering, emotional distress, psychological andor psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, Toss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and 2 Podhurst Orseck, PA. 25 West Flagler trot Su 0, Mia, L010, Mia 505358 250 Fox 3053552562 + Fort Lderdale 54.463. 046 ow goths com  © Case 9:.09-cv-80656-KAM Document1 Entered on FLSD Docket 05/04/2009 Page 23 of 27 Leading her nto 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. Plaintil has suffered a loss of income, a loss of the capacity to cam income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaind ff wil continue to suffer these loses inthe future. WHEREFORE, Plaintiff, Jane Doe No. 102, 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 bya jury. COUNT NINE (Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to 18 US.C. § 2255 in Violation of 18 US.C. § 2252A(g) 66. Plaintiff Jane Doc No. 102, hereby adops, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above and Counts One through Eight above. 67. Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, as defined in 18 US.C. § 2252A()(2), in violation of 18 US.C. § 2252A@)(1). As more fully set forth above, Defendant engaged in actions that constitute countless violations of 18 US.C. § 1591 (sex trafficking of children), Chapter 110 (sexual exploitation of children in violation of 18 USC. §§ 2251, 2252(a)(1), and 2252(A)a)(1), and Chapter 117 (transportation for illegal sexual activity in violation of 18 U.S.C. §§ 2421, 2422, and 2423). As more fully set orth above in paragraphs 9 through 32, Defendant's actions involved countless victims and countless separate incidents of sexual abuse, which he committed against minors, including Plaintiff in ‘concert with at least three other persons. 5 Podhurst Orseck, PA. 25 Wet Fagr Stet, Sule 605, Mitr FL 30130, Miay 35.35 280 Fax 05350282 + Fort Laoderdale 354014546 | wre podhunteom  . Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 24 of 27 68. Plaintiff, Jane Doe No. 102, 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. 65. As diet and primate esl of the offenses enumerated in 18 US.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and wil in the future continue t suffer, hysiea infor, pin and suffering, ential disse, payehoogical andlor payers turns, mental anguish, ratio, confusion, embarrass loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, seporsion for es fly, snd thos deg ssfod wih Deftont’s macpuloing snd 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 cam 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, Plan, Jane Doe No. 102, demands judgment aginst 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 ajury Date: May 1, 2009 Y Blunt Cobre boy WIE Robert C. Josefsherg, Bar No. 04085 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, Florida 33130 (309 3582800 (309 3982582 1) [email protected] pA Podhurst Orseck, P.A. er fo TS FA orm | open  . Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 25 of 27 kezell@podhurstcom Attorneys for Plaintiff DEMAND FOR JURY TRIAL Plaintiff demands to have her case tried before a jury. Brood £- po Aenrf bo Hua Robert C. JosefSberg, Bar No. 040856 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, Fonda 33130 (305) 358-2800 (305) 358-2382 (fax) osefsberg @podhurstcom kezell@podhusicom Atorneys for Plaintiff 23 Podhurst Orseck, PA. tage Se, Ste 8 Mam FL 50, ant 05-5550 Fox 49 856 + For aera SA ts | pric.  Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 26 of 27 A842 dhe. 005) CIVIL COVER SHEET ee Bee ie BERS er ETE i Ros or goss NOTICE: tones MUST Indic All Re fed Cavs Bion: To) PLAINTIFFS DEFENDANTS Jane Doc No. 102 Jeffrey Epscn (b) County of Residence of Fis Listed Painitt West Palm Beach County of Residence of First Lisied Defendant West Palm Beach OF re Mom Teo Le T= ‘Robert C. Josefsberg, Esq Katherine W. Ezell, Esq. . Podhurs Oreck, PA Ter FT 25W. Flagler ., Sai 800 Jk A Goldner, a. Aten God bons. | Misi FI_11%0 -Cy ~ BOLS bo] fa | Rusisian Ave. #1400, West Pam Beachy Bex 1848} ay@obekt Do TC ToT Reon Fo ST oo Sook fk JAC SWAT 3% Tk AEA aa TT BASIS OF JURISDICTION ror meio [Wl CITIZENSHIP OF PRINGIPAL PARTIES ci -0e boc ric 31 sts Tetrion Onn Cay fo hr EE arr commis =" 2 terre 5 5 01 USGmmmen 34 doen Cuatro 0 3 03 Inemaiocine 95 35 sede (nice Czas of Pais i em 1) of Sutton Avo Cumatts 3 3 33 rpm 0 ae NATURE OF SUIT oar eos CR OF SU ee RATT EAPC TOIT) Tem Tro PSII [3 Ago Fees grr — 3h lo o nie [3 Sho ae [3 BT [3 Ham 3a. BAT noe tre [3 See, PONE [3 he 3 at ees [7 J ol ee 3 oem 3 ites [ooh ha Tne, [a adler ppm ob ei int 3 tea [3 fATain [EE 3 Sorat hnectis Pty orm? na [3 sare [3soror froin 3 a | me Ras Ri 0 acm vo [Sines 3 orn [ost EEL oso tie hey mes | 3 ey 1 rrrr—3 Hoa comenes pronto IOC SURE Jib co Fier] Se fry 3 when |b pant teen [3 mci cutee JE EE ER [ mee = I map ivimay [mas e rE [3 TAA [3 Ren |o sms ves 9 ara p prone pnd KAORI Hhapebndy CpG hi. [FRESE Dm 2 orem. 0 Ec Sevens 5 Primera betat, 5 Sit sonra SBR me [00 | pc EU on [3 Si 0 25 TomProduct Listy | 488 Wetare 3 53 Desh resshy [> 0Appest of Fcc Detcmimion: ESLER caer OO proiivien meee |B Set Feit ow Te [3 Sn o smn bo wiommcusnin ho a — J Totton pros 2m "hy refer 0 4 puter 35 125 0 usta 2 7 SSR Pe 72 A fe Whetom re ad reson me owe Es vo acd Cos GV 0 [OT — ELL Reset Coe 7 CASES). [SSE ook Kenneth A. Mama DOCKET See Atached LETTS CTS re oe Tog Te Se Coe oe res es [Foe $1 OASEON TTC cs rts Sots USC. 2420) 4230), 24250) 21 222 22A0K1) 257A) nom or TAL vs 8 _ ins cmt trots cr VI REQUESTED TN 13 CHECK FTI K ACLs ACTON DPD CHEERS a Tae ie COMPLAINT: UNDER FRCP. 23 JURY DEMAND: [J Yes [7 No. OTT TROT TRIE & CORRECT To Sy oom 77° oo Emr oF Ah KNOWLEDGE 2 R Wey st s]i)ea 77 = woot § 2 CC “sizes 7 OCR os) log  Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 27 of 27 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION ATTACHMENT TO CIVIL COVER SHEET FOR: Jane Doe 101Lv. Jeffrey Epstein VE RELATED/RE-FIELD CASE(S): 08-80069 08-80119 08-80232 08-80380 08-80381 08-08804 08-8081 08-80893 08-80993 08-80994 08-80469 09-80591