Case 9:08-cv-80811-KAM

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 1 of 91 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff(s), vs. JEFFREY EPSTEIN and Defendant(s). FIRST AMENDED COMPLAINT Parties. Jurisdiction and Venue COMES NOW the Plaintiff, and brings this First Amended Complaint against the Defendants, JEFFREY EPSTEIN and SARAH KELLEN, and states as follows: 1. This is an action for damages in excess of $75,000.00, exclusive of interest and costs. 2. This Complaint is brought under a fictitious name in order to protect the identity of the Plaintiff, because this Complaint makes allegation of sexual assault and child abuse of a then minor. 3. At all times material to this cause of action, the Plaintiff, = was a resident of 3505-025 Page I of 9I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003349 EFTA00157731 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 2 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 4. At all times material to this cause of action, the Defendant, JEFFREY EPSTEIN, had a residence located in Pakn Beach County, Florida. 5. At all times material to this cause of action, the Defendant, JEFFREY EPSTEIN, was an adult male, born in 1953. 6. This Court has jurisdiction of this action and the claim set forth herein pursuant to 18 U.S.C. §2255. 7. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial part of the events or omissions giving rise to the claim occurred in this district. 8. At all times material, the Defendant. JEFFREY EPSTEIN, owed a duty unto Plaintiff, to treat her in a non-negligent manner and to not commit intentional or tortious illegal acts against her. Factual Allegations 9. Upon information and belief, the Defendant, JEFFREY EPSTEIN, has demonstrated a sexual preference and obsession for minor girls. He engaged in a plan, scheme, and enterprise in which he gained access to economically disadvantaged minor girls, such as Plaintiff, sexually assaulted these girls, and/or coerced them to engage in prostitution, and in return gave these girls money. 10. The Defendant's plan, scheme and enterprise included an elaborate system wherein the then minor Plaintiff and other minor girls were brought to the 2 3505-025 Page 2 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003350 EFTA00157732 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 3 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRNJOHNSON First Amended Complaint Defendant, JEFFREY EPSTEIN'S, residence by the Defendant's employees and assistants. When the employees and assistants left the then minor Plaintiff and other minor girls alone in a room at the Defendant's mansion, the Defendant, JEFFREY EPSTEIN, himself would appear, remove his clothing, and direct the then minor Plaintiff to remove her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including, but not limited to, masturbation, touching of the then minor Plaintiffs breasts and buttock, and solicitation and enticement of the then minor Plaintiff to engage in sexual acts with another female in JEFFREY EPSTEIN'S presence. 11. The Plaintiff,= was the first brought to the Defendant, JEFFREY EPSTEIN'S, mansion in late May or early June of when she was fifteen-years old and in middle school. 12. The Defendant, JEFFREY EPSTEIN, a wealthy financier with a lavish home, significant wealth, a network of assistants and employees, used his resources and his influence over a vulnerable minor child to engage in a systematic pattern of sexually exploitive behavior. 13. Beginning in approximately late May or early June of M , and continuing until approximately August of the Defendant coerced and enticed the impressionable, vulnerable, and economically deprived then minor Plaintiff to commit various acts of sexual misconduct. These acts occurred, on average, one to three times per week from late May or early June of= until August of M. At a bare minimum, 3 3505-025 Page 3 M91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003351 EFTA00157733 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 4 of 91 vs. Epstein, et al. 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint these acts occurred twice a month from June until August of While the precise dates these acts occurred are unknown to Plaintiff, including those weeks in which no acts occurred, these dates are known by Defendant, JEFFREY EPSTEIN, as he is reported to have kept a written log of each and every instance in which he engaged in these illegal acts with the then minor Plaintiff, and others. These acts included, but were not limited to, fondling and inappropriate and illegal sexual touching of the then minor Plaintiff, sexual misconduct and masturbation of the Defendant, JEFFREY EPSTEIN, in the presence of the then minor Plaintiff, soliciting and enticing the then minor Plaintiff to engage in sexual acts with another female in JEFFREY EPSTEIN'S presence, and encouraging the then minor Plaintiff to become involved in prostitution; Defendant, JEFFREY EPSTEIN, committed numerous criminal sexual offenses against the then minor Plaintiff including, but not limited to, sexual battery, solicitation of prostitution, procurement of a minor for the purpose of prostitution, and lewd and lascivious assaults upon the person of the then minor Plaintiff. 14. Defendant, JEFFREY EPSTEIN, used his money, wealth and power to unduly and improperly manipulate and influence the then minor Plaintiff. 15. The acts referenced in paragraphs 9 through 14, committed by Defendant, JEFFREY EPSTEIN, against the then minor Plaintiff, were committed in violation of numerous criminal State and Federal statutes condemning the sexual 4 3505-025 Page 4 of 9I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003352 EFTA00157734 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 5 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint exploitation of minor children, prostitution, sexual performance by a child, lewd and lascivious assaults, sexual battery, contributing the delinquency of a minor and other crimes, specifically including, but not limited to, those crimes designated in 18 USC §2241, §2242, §2243, §2421, and §2423, criminal offenses outlined in Chapter 800 of the Federal Codes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §39.01; and §827.04. 16. The above-described acts took place in Palm Beach County, Florida, at the residence of the Defendant, JEFFREY EPSTEIN. Any assertions by the Defendant, JEFFREY EPSTEIN, that he was unaware of the age of the then minor Plaintiff are belled by his actions and rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual exploitation and abuse of a minor child. The Defendant, JEFFREY EPSTEIN, at all times material to this cause of action, knew and should have known of the Plaintiff, MI3 minority. 17. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, the 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 purpose of prostitution. 18. As a condition of that plea, and in exchange for the Federal Government not prosecuting the Defendant, JEFFREY EPSTEIN, for numerous federal offenses, Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the 5 3505-025 Page 5 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003353 EFTA00157735 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 6 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint Federal Government to the following: "Any person, who white a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of Implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less". 19. The Defendant, JEFFREY EPSTEIN, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged in this Complaint, and must effectively admit liability to the Plaintiff, COUNT I Cause of Action Pursuant to 18 USC 82255 Mav/June 20. The Plaintiff, S adopts and realleges paragraphs 1 through 19 above. 6 3505-025 Page 6 0191 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003354 EFTA00157736 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 7 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 21. In late May or early June of was first introduced to Defendant, JEFFREY EPSTEIN. was brought to JEFFREY EPSTEIN'S residence by a female friend of hers. sat on the couch while the female friend took off her own clothes, mounted JEFFREY EPSTEIN who was wearing only a towel and lying on a table, and performed a sexual act upon JEFFREY EPSTEIN in the presence of ■ In exchange for her participation as an observer of JEFFREY EPSTEIN'S lewd and lascivious conduct, was paid $300 by JEFFREY EPSTEIN. 22. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it Is the intent of the parties to place these identified victims in 7 3505-025 Page 7 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003355 EFTA00157737 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 8 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less? 23. The Plaintiff, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 24. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, MI, and as such he must effectively admit liability unto the Plaintiff 25. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff,, will in the future suffer additional medical and psychological expenses. The Plaintiff, 8 3505-025 Page 8 of 9I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003356 EFTA00157738 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 9 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, , demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT II Cause of Action Pursuant to 18 USC 62265 June Incident 2 26. The Plaintiff, =, adopts and realleges paragraphs 1 through 19 above. 27. Approximately one week after the first incident, received a telephone call from JEFFREY EPSTEIN requesting that she return to his residence. On this occasion, JEFFREY EPSTEIN directed to undress to her brassiere and underwear and to provide him with a massage. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid C.M.A. $300 for this encounter. 9 3505-025 Page 9 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003357 EFTA00157739 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 10 of 91 vs. Epstein, et al. 08-CV-80811-CIV-MARRAJJOHNSON First Amended Complaint 28. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom It was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. My judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 29. The Plaintiff, S was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 10 3505.025 Page 10 491 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003358 EFTA00157740 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 11 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 30. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff= and as such he must effectively admit liability unto the Plaintiff, 31. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, , has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, =, will in the future suffer additional medical and psychological expenses. The Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, , demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 11 3505-025 Page II of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003359 EFTA00157741 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 12 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 III Cause of Action Pursuant to 18 USC 42255 lyjyaklcident 1 32. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. ' 33. In July again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to undress to her underwear and to provide him with a massage. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 34. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: *Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For 12 3505-025 Page 12 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003360 EFTA00157742 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 13 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less? 35. The Plaintiff, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 36. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, and as such he must effectively admit liability unto the Plaintiff, 37. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, 13 3505-025 Page 13 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003361 EFTA00157743 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 14 of 91 vs. Epstein, et al. Case No.: I38-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, , will in the future suffer additional medical and psychological expenses. The Plaintiff,M, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, , will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT IV Cause of Action Pursuant to 18 USC 62255 Jul - Incident 2 14 3505-025 Page 14 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003362 EFTA00157744 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 15 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 38. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 39. For the second time in July of again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 40. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Govemment not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Govemment to the following: Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. My judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the Intent of the parties to place these identified victims in 15 3505-025 Page 15 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003363 EFTA00157745 J Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 16 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARFtA/JOHNSON First Amended Complaint the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 41. The Plaintiff, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 42. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff.= and as such he must effectively admit liability unto the Plaintiff, 43. As a direct and proximate result of the offenses enumerated in Title 18. United States Code, Section 2255, being committed against the then minor Plaintiff, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, will in the future suffer additional medical and psychological expenses. The Plaintiff, 16 3505-025 Page 16 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003364 EFTA00157746 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 17 of 91 jjjjjjjjjjjj■vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These Injuries are permanent in nature and the Plaintiff, , will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attomey's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT V Cause of Action Pursuant to 18 USC 42255 August =— Incident 1 44. The Plaintiff, adopts and realleges paragraphs 1 through 19 above. 45. In August of again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 17 3505-025 Page 17 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003365 EFTA00157747 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 18 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 46. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: `Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens If any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.* 47. The Plaintiff,-, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 18 3505-025 Page 18 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003366 EFTA00157748 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 19 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 48. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, and as such he must effectively admit liability unto the Plaintiff, 49. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, M , has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, =, will continue to suffer these tosses in the future. WHEREFORE, the Plaintiffs demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 19 3505-025 Page 19 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003367 EFTA00157749 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 20 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 VI Cause of Action Pursuant to 18 USC §2265 Amcitsek A Iciden 2 50. The Plaintiff, adopts and realleges paragraphs 1 through 19 above. 51. For the second time in August of again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 52. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: *Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 20 3505-025 Page 20 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003368 EFTA00157750 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 21 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less? 53. The Plaintiff, , was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 54. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, and as such he must effectively admit liability unto the Plaintiff, 55. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, , has in the past suffered, and will in the future suffer, physical injury, pain and 21 3505-025 Page 21 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003369 EFTA00157751 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 22 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAMOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, , will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, a, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, =, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT VII Cause of Action Pursuant to 18 USC 62255 September =— Incident 1 56. The Plaintiff, adopts and realleges paragraphs 1 through 19 above. 22 3505-025 Page 22 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003370 EFTA00157752 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 23 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAJJOHNSON First Amended Complaint 57. In September again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed o fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 58. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less? 23 3505-025 Page 23 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003371 EFTA00157753 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 24 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 59. The Plaintiff, = was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 60. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, , and as such he must effectively admit liability unto the Plaintiff, 61. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, M, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a 24 3505-025 Page 24 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003372 EFTA00157754 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 25 of 91 vs. Epstein, et al. Case No.: 06-CV-80811-CIV-MARFtA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, , will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, , demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems Just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT VIII Cause of Action Pursuant to 18 USC §2255 S:fpitnill icklent 2 62. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 63. For the second time in September again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 25 3505-025 Page 25 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003373 EFTA00157755 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 26 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 64. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 65. The Plaintiff, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 26 3505-025 Page 26 of 9I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003374 EFTA00157756 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 27 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 68. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, and as such he must effectively admit liability unto the Plaintiff,M 67. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, will in the future suffer additional medical and psychological expenses. The PlaintiffM. has suffered a loss of income, a loss of the capacity to eam income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, =, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 27 3505-025 Page 27 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003375 EFTA00157757 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 28 of 91 vs. Epstein. et al. Case No.: 08-O1-80811-CIV-MARRA/JOHNSON First Amended Complaint relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUN IX Cause of ActIon Pursuant to 18 USC §2255 October of — Incident 68. The Plaintiff, adopts and realleges paragraphs 1 through 19 above. 69. In October of again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion. JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid In excess of $200 for this encounter. 70. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: 'Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 28 3505-025 Page 28 of 9I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003376 EFTA00157758 Case 9:08-cv-80811-I<AM Document 39 Entered on FLSD Docket 02/09/2009 Page 29 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 71. The Plaintiff, was a victim of one or more offenses enumerated in Tide 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 72. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, IM and as such he must effectively admit liability unto the Plaintiff, 73. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, , has in the past suffered, and will in the future suffer, physical injury, pain and 29 3505-025 Page 29 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003377 EFTA00157759 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 30 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, , will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, arid a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT X Cause of Action Pursuant to 18 USC 42255 October — Incident 2 30 3505-025 Page 30 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003378 EFTA00157760 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 31 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 74. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 75. For the second time in October again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 76. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, Including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in 31 3505-025 Page 31 of 9I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003379 EFTA00157761 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 32 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAMOHNSON First Amended Complaint the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 77. The Plaintiff, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 78. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, , and as such he must effectively admit liability unto the Plaintiff, 79. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, will in the future suffer additional medical and psychological expenses. The Plaintiff, 32 3505-025 Page 32 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003380 EFTA00157762 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 33 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, , will continue to suffer these losses in the future. WHEREFORE, the Plaintiff,_, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XI Cause of Action Pursuant to is USC 42255 November a — Incident 1 80. The Plaintiff,M, adopts and realleges paragraphs 1 through 19 above. 81. In November again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directedMto fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 33 3505-025 Page 33 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000033 8 1 EFTA00157763 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 34 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 82. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens ff any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 83. The Plaintiff, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 34 3505-025 Page 34 of 9l SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003382 EFTA00157764 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 35 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 84. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, , and as such he must effectively admit liability unto the Plaintiff, 85. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, , will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, , will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 35 3505-025 Page 35 of 9I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003383 EFTA00157765 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 36 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 XII Cause of Action Pursuant to 18 USC §2265 November of — Incident 2 86. above. 87. For the second time in November The Plaintiff, a adopts and realleges paragraphs 1 through 19 again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself In presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 88. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 36 3505-025 Page 36 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003384 EFTA00157766 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 37 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 89. The Plaintiff, , was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 90. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff,M, and as such he must effectively admit liability unto the Plaintiff, 91. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, has in the past suffered, and will in the future suffer, physical injury, pain and 37 3505-025 Page 37 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003385 EFTA00157767 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 38 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, , will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff,_, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, a, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attomey's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XIII Cause of Action Pursuant to 18 USC 42255 December of-- Incident 1 92. The Plaintiff, adopts and realleges paragraphs 1 through 19 above. 38 3505-025 Page 38 of 9I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003386 EFTA00157768 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 39 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAJJOHNSON First Amended Complaint 93. In December again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directecIM to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 94. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.* 39 3505-025 Page 39 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003387 EFTA00157769 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 40 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 95. The Plaintiff, VW was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 96. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, and as such he must effectively admit liability unto the Plaintiff, 97. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a 40 3505-025 Page 40 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003388 EFTA00157770 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 41 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, , will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, , demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XIV Cause of Action Pursuant to 18 USC 42255 December Incident 2 98. The Plaintiff,—, adopts and realleges paragraphs 1 through 19 above. 99. For the second time in December again retumed to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 41 3505-025 Page 41 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003389 EFTA00157771 Case 9:08•cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 42 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 100. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 101. The Plaintiff,= was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 42 3505-025 Page 42 of 9I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003390 EFTA00157772 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 43 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 102. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, , and as such he must effectively admit liability unto the Plaintiff, 103. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, S will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These Injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, , demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorneys fees, costs, and such other and further 43 3505-025 Page 43 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003391 EFTA00157773 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 44 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARFtA/JOHNSON First Amended Complaint 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 XV Cause of Action Pursuant to 18 USC O255 January of — Incident 1 104. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 105. In January again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed Ito fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 106. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: 'Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 44 3505-025 Page 44 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003392 EFTA00157774 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 45 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of Implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less? 107. The Plaintiff, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 108. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, , and as such he must effectively admit liability unto the Plaintiff, 109. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, has in the past suffered, and will in the future suffer, physical injury, pain and 45 3505-025 Page 45 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003393 EFTA00157775 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 46 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAJJOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her Into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, M, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, = demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XVI Cause of Action Pursuant to 18 USC 42255 January — Incident 2 110. The Plaintiff, adopts and realleges paragraphs 1 through 19 above. 46 3505-025 Page 46 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003394 EFTA00157776 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 47 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint • 111. For the second time in January again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 112. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 47 3505-025 Page 47 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003395 EFTA00157777 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 48 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint • 113. The Plaintiff, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 114. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, and as such he must effectively admit liability unto the Plaintiff, 115. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a 48 3505-025 Page 48 of 9I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003396 EFTA00157778 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 49 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff,-, will continue to suffer these losses in the future. WHEREFORE, the Plaintiffil., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XVII Cause of Action Pursuant to 18 USC 42255 Februar iciclent 1 116. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 117. In February again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minors At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 49 3505-025 Page 49 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003397 EFTA00157779 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 50 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRNJOHNSON First Amended Complaint 118. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: `Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of Individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less: 119. The Plaintiff, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 50 3505-025 Page 50 of 9I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003398 EFTA00157780 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 51 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRNJOHNSON First Amended Complaint 120. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, and as such he must effectively admit liability unto the Plaintiff, 121. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, , has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, , will in the future suffer additional medical and psychological expenses. The Plaintiff, M, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff,_, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 51 3505-025 Page 51 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003399 EFTA00157781 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 52 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 XVIII Cause of Action Pursuant to 18 USC 42256 February_- Incident 2 122. The Plaintiff, M, adopts and realleges paragraphs 1 through 19 above. 123. For the second time in February again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 124. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 52 3505-025 Page 52 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003400 EFTA00157782 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 53 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 125. The Plaintiff, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 126. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, Is In the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, and as such he must effectively admit liability unto the Plaintiff, 127. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, , has In the past suffered, and will in the future suffer, physical injury, pain and 53 3505-025 Page 53 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0000 340 1 EFTA00157783 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 54 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of rife for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff,_ will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XIX Cause of Action Pursuant to 18 USC §2255 March — Incident 1 128. The Plaintiff. , adopts and realieges paragraphs 1 through 19 above. 54 3505-025 Page 54 of 9l SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003402 EFTA00157784 Case 9:08-cv-80811-KAM Document 39 Entered on FL.SD Docket 02/09/2009 Page 55 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARFUVJOHNSON First Amended Complaint 129. In March again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 130. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the Intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 55 3505-025 Page 55 of 9I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003403 EFTA00157785 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 56 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CMMARRA/JOHNSON First Amended Complaint 131. The Plaintiff, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 132. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, and as such he must effectively admit liability unto the Plaintiff, 133. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, , will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to eam income in the future, and a 56 3505-025 Page 56 of 9I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003404 EFTA00157786 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 57 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAIJOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, , will continue to suffer these losses in the future. WHEREFORE, the Plaintiff,, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XX Cause of Action Pursuant to 18 USC O255 March— Incident 2 134. The Plaintiff, , adopts and realleges paragraphs 1 through 19 above. 135. For the second time in March of again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor a At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paids in excess of $200 for this encounter. 57 3505.025 Page 57 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003405 EFTA00157787 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 58 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 136. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code. Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less? 137. The Plaintiff, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 58 3505.025 Page 58 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003406 EFTA00157788 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 59 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 138. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, , and as such he must effectively admit liability unto the Plaintiff, 139. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, , has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff,_, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of Income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent In nature and the Plaintiff', will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 59 3505-025 Page 59 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003407 EFTA00157789 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 60 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 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 XXI Cause of Action Pursuant to 18 USC 42255 April of - Incident 1 140. The Plaintiff, adopts and realleges paragraphs 1 through 19 above. 141. In April again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed Ito fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid Min excess of $200 for this encounter. 142. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 60 3505-025 Page 60 of 9I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003408 EFTA00157790 Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 61 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims o