AU itK A (Re. (Al

AU itK A (Re. (Al es!,c ala Deposition in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of Florida M.J. P mg, Civil Action No. CASE NO.: 9:10-cv-81111 JEFFREY EPSTEIN and WM Defendant (If the action is pending in another district, state %%here: SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION To: JEFFREY EPSTEIN, 9 East 71st Street, New York, NY 10021 Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a deposition to be taken in this civil action. If you are an organization that is not a party in this case, you must designate one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or those set forth in an attachment: I—Plitce: US LEGAL SUPPORT I_ 444 West Railroad Avenue, Suite 300 West Palm Beach, FL 33401 The deposition will be recorded by this method: Date and Time: 11/10/2010 10:00 am VIDEQDEPOSITION / COURT REPORTER O Production: You, or your representatives, must also bring with you to the deposition the following doctiments, electronically stored information, or objects, and permit their inspection, copying, testing, or stimpjjgg of the material: is The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are attached. Date: te." / 7:24 1, CLERK OF COURT Signature of Clerk or Deputy Clerk OR Amor s signature The name, address, e-mail, and telephone number of the attorney representing (name of party) PLAINTIFF, M.J. , who issues or requests this subpoena, are: BRADLEY J. EDWARD W ' g, Edwards, Fistos & Lehrman, 425 N. Andrews Avenue, Suite 2. Fort Lauderdale, FL 33301, telephone: 954-524-2820. EFTA00729603 AO BSA (Rev. 06/09) Subpoena to ic.t .11 .i /cro.nion in a Ci‘i! An Civil Action No. CASE NO.. 9.10-cv-81111 PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) This subpoena for (name of individual and title. Vat& JEFFREY EPSTEIN was received by me on (date) O I served the subpoena by delivering a copy to the named individual as follows: on (date) ; or 0 I returned the subpoena unexecuted because: Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of My fees are $ Date: for travel and $ for services, for a total of $ I declare under penalty of perjury that this information is true. Server's signature 0.00 Primed name and tide Server's address Additional information regarding attempted service, etc: EFTA00729604 Intentionally Left Blank EFTA00729605 Case 9:10-cv-81111-WPD Document 3 Entered on FLSD Docket 09/17/2010 Page 1 of 2 AO 4411 (Rev I 2.(9) Summons m a Civil Aclion UNITED STATES DISTRICT COURT for the Southern District of Florida M.J. Plaintiff v. JEFFREY EPSTEIN and Defendant Civil Action No. 10-CV-81111-DIMITROULEAS/SNOW SUMMONS IN A CIVIL ACTION To: (Defendant's name and address) JEFFREY EPSTEIN 9 East 71st Street New York, NY 10021 A lawsuit has been filed against you. Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you arc the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3)— you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address arc: BRADLEY J. EDWARDS Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. Date: SEPTEMBER 177 2010 Steven M. Larimore Clerk of Court SUMMONS s/Gregory Maestre Deputy Clerk U.S. District Courts EFTA00729606 Intentionally Left Blank EFTA00729607 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 1 of 29 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: Plaintiff, vs. JEFFREY EPSTEIN and Defendants. COMPLAINT Plaintiff, M.J., by and through her undersigned counsel, sues the Defendants, Jeffrey Epstein and and alleges: I. This is an action in an amount in excess of $15,000.00, exclusive of interest and costs and is within the jurisdictional limits of this Court. 2. This Complaint is brought under a fictitious name in order to protect the identity of the Plaintiff because this Complaint makes allegations of sensitive nature of offenses against a then minor child. 3. At all times material to this cause of action, the Plaintiff, M.J. (hereinafter referred to as "Plaintiff"), was a resident of Palm Beach County, Florida. 4. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida. 5. Defendant, Jeffrey Epstein, is currently a citizen of the United States Virgin Islands. EFTA00729608 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 2 of 29 6. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. Defendant, a , is currently a citizen of New York, where she currently resides. 8. At all times material, the Defendants Jeffrey Epstein and I. ME both owed a duty unto Plaintiff to treat her in a non-negligent manner and to not commit or conspire to commit intentional or tortious illegal acts against her. FACTUAL ALLEGATIONS 9. At all times material, Defendant, Jeffrey Epstein, was an adult male, over 50 years old. Defendant Epstein is known as a billionaire, yet even those closest to him, including family members, long time employees and those that he considers his closest friends have no idea what he does or did to earn money to support his lifestyle. 10. Defendant Epstein owns, directly or through nominee individuals used to conceal his interests, a fleet of airplanes, motor vehicles, boats and a helicopter. He owns numerous properties and homes, including a 51,000-square-foot mansion in Manhattan, a $30 Million 7,500-acre ranch in New Mexico, a 70-acre private island formerly known as Little St. James in St. Thomas, U.S. Virgin Islands (he is alleged to have renamed this island Little St. Jeff's after himself), a mansion in London, England, a home in Paris, France, and a mansion in Palm Beach County, FL. The allegations herein primarily concern the defendant's conduct while at his mansion in Palm Beach County, FL. I. Defendant Epstein has a sexual preference and obsession for underage minor females, specifically targeting female children age 12 to 17, and Defendant Epstein acts on that obsession by luring underage minor females to him where he attempts to sexually molest and batter these 2 EFTA00729609 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 3 of 29 underage minor females on an everyday basis, oftentimes 2 or 3 different underage minor females on one day. 12. Sometime prior to 1998, Defendant Epstein devised a complex plan, scheme and criminal enterprise to gain access to countless underage minor females, some as young as 12 years old, for the purpose of coercing the minor females into various acts of sexual misconduct that he committed upon them. His enterprise operated with a definite hierarchal structure with his various employees/assistants and associates, including Defendana, Jean Luc Brunel, Ghislaine Maxwell, IS In; Ma a a a, various housekeepers, butlers and pilots, performing their respective roles to ensure the goals of the enterprise: operate an organized and efficient system to maximize the number of underage minor females for Defendant Epstein (and others) to sexually abuse and exploit while avoiding law enforcement detection. 13. Defendant Epstein, with help from his assistants and associates, recruited and procured underage minor females, lured them to one of his mansions, had the underage minor female taken to a room to be alone with him, then he would appear naked or wearing only a towel and sexually batter or otherwise sexually exploit the underage minor female. He would then pay the underage minor female for the sex acts he committed against her (typically between $200 and $300 per molestation session, or as his criminal enterprise commonly refers to it — per "massage"). Prior to leaving, Defendant Epstein's assistant would get the phone number of the underage minor female and input it into his computer system or otherwise keep it on file. He would then offer the underage minor female to return to his house to make money in exchange for him committing sexual acts against her, and he also typically informed her of another option - make more money recruiting and procuring other underage minor females for him to sexually 3 EFTA00729610 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 4 of 29 abuse. He would tell the underage minor female that he will pay her for each underage minor female that she brings to him (again, typically between $200 and $300), and he encouraged, and oftentimes forcefully demanded, her to bring him as many underage minor females as she was able. Through this general pitch, Defendant Epstein created a vast pyramid of underage minor females recruiting and procuring other underage minor females for his purpose of coercing these underage females into sexual acts for money. 14. Defendants Epstein and and the criminal enterprise specifically targeted underprivileged and economically disadvantaged children to sexually exploit and molest and otherwise prey upon the vulnerabilities of these young girls. 15. It is unknown exactly how long Defendant Epstein's aforementioned criminal enterprise operated, although information and belief indicates that it was continuously and actively in operation from at least 1998 through Defendant Epstein's criminal arrest in 2006. 16. The complete list of underage minor females that were sexually abused by Defendant Epstein over the years is believed to have been kept on a computer system controlled by Defendant Epstein and accessible by several of his employees, including Defendant It is also known that much of the data regarding the names, addresses and whereabouts of each underage minor female was input by one of his assistants, including Defendant 17. Defendant was listed in the Federal Non-prosecution Agreement related to Defendant Epstein's criminal plea on sex charges against minors as a criminal co-conspirator for her role in the criminal activity that was committed by Defendant Epstein against many underage minor females. She was employed by Defendant Epstein to maintain his schedule, arrange for underage minor females to be with Defendant Epstein, maintain contact with the underage minor females, schedule the underage minor females' transportation to and from Defendant Epstein's 4 EFTA00729611 Case 9:10-cv-81111-)OOOC Document 1 Entered on FLSD Docket 09/17/2010 Page 5 of 29 mansion, and greet the underage minor female at the house before taking her upstairs to be alone with Mr. Epstein. Upon information and belief, Defendant remains employed by Defendant Epstein and continues to work for Defendant Epstein in furtherance of the goals of the criminal enterprise. 18. Defendant Epstein used his vast wealth and power to lure underprivileged minor females to him, and to coerce them into prostitution once he was alone with the underage minor female. He sexually battered, molested, committed lewd and lascivious acts upon and otherwise exploited numerous underage minor females and then gave them money. So long as the underage minor female followed his demands and advances, he assumed the role of a friend or mentor or father figure to the minor female in an attempt to groom the minor female; however, if any minor female resisted his sexual advances, Defendant Epstein became frustrated, angry and threatening towards the underage minor. His intent was to groom each minor female into engaging in sexual acts with him as well as to "work" for him, i.e. bring him other underage minor females to sexually molest, batter and exploit. He was masterful in his exploitation and grooming of these minor females with an additional intent of gaining trust and cooperation from these minors to prevent any one of them from reporting his criminal acts to law enforcement. Certain of his many co-conspirator associates, including Ghislane Maxwell and Jean Luc Brunel, helped in this recruiting process by creating the impression that legitimate modeling opportunities were available for the minor females. 19. Through information and belief, Defendant Epstein has been successful in luring hundreds of underage minor girls to him for the purpose of him (and sometimes others) sexually abusing them. He intentionally preys upon underage minor females that are middle school or high school children who are not working prostitutes, and he takes pleasure in using his power 5 EFTA00729612 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 6 of 29 and influence to coerce these minor females into acts of prostitution with him personally and sometimes with his friends and associates as well, including but not limited to Ghislaine Maxwell and 20. Over time, Defendant Epstein fine-tuned his operation to further his goals of gaining access to a greater number and variety of underage girls while avoiding detection by law enforcement. He also provided the roadmap for his enterprise should the illegal sexual exploitation of the enterprise be detected — he or the criminal enterprise would (and did) retain legal representation for each criminal enterprise member who would instruct each member to invoke his/her 5th amendment rights, they would hide behind the 5th amendment to avoid turning over incriminating materials (i.e. computer system that logged information about the underage sexual molestation victims, scheduling books, message pads, and tangible items such as vibrators and dildos), they would destroy evidence and refuse all cooperation with law enforcement. 21. The plan and scheme was developed by Defendant Epstein, and he and his assistants and associates carried it out with each underage minor female in a well-planned and ritualistic manner; Epstein ran this criminal enterprise as an experienced Mob boss would run any organized crime family — in a well-planned, organized, arrogant and ruthless manner, with complete cooperation from his co-conspirator associates and underlings and an absolute dedication to carrying out the illegal operations of the criminal enterprise. 22. Defendant Epstein frequently traveled between his various mansions and either he or an authorized agent would call to inform a recruiter, assistant, or scheduler at his next destination as to his arrival time. His scheduler, usually Defendant la, would then contact an underage minor female and schedule her to be at Defendant Epstein's mansion or to bring another underage minor female to his mansion at a particular time. Once the minor female was 6 EFTA00729613 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 7 of 29 brought to Defendant Epstein's residence, she was greeted at the door of the mansion and lead inside by one of Defendant Epstein's employees, oftentimes Defendant 23. Defendant would lead the underage minor female up to Defendant Epstein's room and leave the underage minor alone in the room. Defendant, Jeffrey Epstein, himself would then appear naked or wearing only a towel. He would then demand a massage and during the massage he would attempt, usually successfully, to perform one or more lewd, lascivious, and sexual acts, including, but not limited to, masturbation, touching of the underage minor female's sexual organs, coercing or forcing the underage minor female to perform sex acts with him, using vibrators or sexual toys on the underage minor female, coercing the underage minor female into sexual intercourse with himself or others, and digitally penetrating the underage minor female. He would then give the Plaintiff money for engaging in this sexual activity. 24. Consistent with Defendants Epstein and foregoing scheme or plan, in or around the summer of 2002, Plaintiff, an economically poor and vulnerable child, was told by another one of Epstein's underage minor sex abuse victims, that she could make $300 cash by giving an old man a massage on Palm Beach. 25. Plaintiff's then minor acquaintance (also a sexual abuse victim of Epstein) telephoned Defendant Epstein and scheduled for Plaintiff to go to Defendant Epstein's house to give him a massage. During that call, Defendant Epstein himself got on the phone and spoke with Plaintiff MJ and asked her personally to come to his mansion in Palm Beach. 26. Plaintiff then took a taxicab to Defendant Epstein's mansion and was greeted by Epstein's top assistant, Defendant 27. Defendant in furtherance of the scheme to exploit Plaintiff, escorted Plaintiff upstairs to Defendant Jeffrey Epstein's large bathroom, where Defendant set up the 7 EFTA00729614 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 8 of 29 massage table and showed Plaintiff different massage lotions to use. Defendant Illlithen left Plaintiff alone in the room. Plaintiff was alone in Defendant Epstein's bathroom until Defendant Jeffrey Epstein emerged wearing only a towel. 28. Defendant Epstein then walked to the massage table that was already open in the room. He lied face down on the table and told Plaintiff to start massaging him, at which time he engaged in a conversation with Plaintiff. During the conversation, Defendant Epstein asked Plaintiff her age and she told him she had recently turned 16. 29. Consistent with all of Defendant Epstein's known underage minor female victims, Plaintiff had no massage experience whatsoever and she informed him of that, and Defendant Epstein began instructing Plaintiff on how he liked his massage. 30. After approximately 15 minutes, Defendant Epstein turned over onto his back, and he commanded Plaintiff to massage his chest. 31. Defendant Epstein then suddenly removed his towel and his penis was already erect. He then commanded Plaintiff to remove her shirt and bra and to begin "pinching his nipples" as he began masturbating with his right hand. 32. As he was masturbating, Defendant Epstein began fondling Plaintiff's breasts. 33. Defendant Jeffrey Epstein, while masturbating with his right hand, reached out his left hand and grabbed Plaintiff's vagina and butt over her clothes. Plaintiff pushed Defendant's hand away and told him repeatedly not to touch her like that. Epstein was persistent in his attempt to grab Plaintiff's vagina and continued to grab her vagina and butt on multiple occasions after she told him not to. 34. Defendant Epstein continued to masturbate his exposed penis until he ejaculated in front of the then minor Plaintiff. 8 EFTA00729615 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 9 of 29 35. Plaintiff was shocked and embarrassed by the events and Defendant Epstein talked to her to persuade her that everything he was doing with he was normal. 36. Epstein paid Plaintiff $300 for allowing him to grope her and masturbate in her presence. 37. Plaintiff returned to Epstein's home on approximately 20 occasions. On each occasion Epstein grabbed Plaintiff's bare breasts, exposed his penis, masturbated and ejaculated in Plaintiff's presence, and paid her $300 each time. 38. Defendant Epstein coerced Plaintiff into acts of prostitution, preying on her low economic status and troubled upbringing, complimenting Plaintiff for being "special" to him and having a "very pretty body" and making promises to Plaintiff such as — he told Plaintiff that if she graduated high school, then he would buy her a computer, something that she wanted yet could not afford. 39. On multiple occasions Defendant Epstein pressured Plaintiff to bring him other underage minor females to abuse; he told Plaintiff that he would pay her $300 for each girl she brought him, but Plaintiff refused to bring other girls. 40. Defendant Epstein told Plaintiff that he would pay her more money if she would give him oral sex and that he would pay her $600 for actual sexual intercourse. Plaintiff refused. 41. Defendant Epstein personally called Plaintiff at least five times to tell her when she should be at his house to "work" or give him a "massage" (Epstein's criminal enterprise's learned code words for paying minors for Epstein and others to interact with them sexually). 42. Every other time (approximately 15) Defendant called to inform Plaintiff of the date and time when she needed and was expected to be at Epstein's mansion to "work". 43. The acts referenced above, committed by Defendant, Jeffrey Epstein, against the then minor Plaintiff were committed in violation of numerous State and Federal criminal statutes 9 EFTA00729616 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 10 of 29 condemning battery, assault and the exploitation of minor children, contributing to the delinquency of a minor and other crimes, specifically including, but not limited to, those criminal offenses outlined in Chapters 796, 800, and 827 of the Florida Statutes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §796.09, §39.01, §450.151, and §827.04. 44. The above-described acts took place in Palm Beach County, Florida at the residence of the Defendant, Jeffrey Epstein. Any assertions by Defendants, Jeffrey Epstein and that they were unaware of the age of the then minor Plaintiff are belied by their actions and rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual exploitation and abuse of a minor child. The Defendants, Jeffrey Epstein and at all times material to this cause of action, knew and should have known of the Plaintiffs minority as Plaintiff specifically told Epstein her age and Defendant Epstein and criminal organization has a history of seeking out underage minor children to sexually abuse. In fact, one primary goal of the organization is to sexually abuse females who are under the age of 18, and oftentimes Defendant Epstein has turned away females (i.e. refused to engage in sexual acts with them) for being "too old" once she reaches 18 years of age, and he has reprimanded girls for bringing him other girls who are over the age of majority. 45. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, Defendant Epstein entered pleas of "guilty" to various Florida State crimes related to his exploitation of minors for sex. 46. As a condition of that plea and in exchange for the Federal Government entering into a Non-Prosecution Agreement with Defendant Epstein, wherein the Federal Government agreed to effectively stay any prosecution of Jeffrey Epstein, and other criminal co- 10 EFTA00729617 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 11 of 29 conspirators a =Mt and a Defendant Epstein agreed to admit that approximately 40 underage minor females, whose names were provided to Defendant Epstein, were his victims. Plaintiff was not included in that list as she moved away from the West Palm Beach area in part to escape from Epstein, and she has lived in fear of Epstein and his organization and has not yet been contacted by law enforcement. 47. Beginning in or about June 2008 and continuing to the present time, defendant Epstein has been aware he faces significant financial liability for his sexual offenses, both to land to many other similarly-situated girls whom he abused. I and these other girls are creditors of Epstein, in that have filed and can file ton actions against him under both Florida and Federal laws. Accordingly, Epstein has conveyed substantial assets and property into the names of other persons and into overseas bank accounts and other financial institutions. These assets and properties could have been attachable and used to pay the debts owed to ■and to the other girls that Epstein has abused. 48. As an example of the fraudulent conveyances that Epstein has attempted, in approximately October 2009, Epstein placed his personal 727 aircraft up for sale, with the intent that the proceeds of that sale would be hidden so that Nand other creditors of Epstein would not be able to secure payment from that substantial asset. 49. While Epstein is clearly distinct from the criminal enterprise that he oversees that asset, as well as his other airplanes and helicopters and other assets, have been used continuously and repeatedly to further the interest and endeavors of Epstein and his criminal enterprise. 50. As another example of the fraudulent transfers that Epstein has made, Epstein has titled a Ford F-I50 Truck in the name of Larry Visoki (Epstein's personal pilot). Visoski was unaware that the truck was titled in his name when he was questioned under oath in a deposition. II EFTA00729618 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 12 of 29 51. In approximately 2009, Defendant Epstein purchased a $68,000 Land Rover and registered it in Visoski's name with the intent to hide this asset fromUnd other creditors. 52. In approximately 2009, Defendant Epstein purchased a Mercedes-Benz 2005 by wiring funds to Visoski and then placing the car in Visoski's name. 53. In approximately 2009, Defendant Epstein bought a Jaguar X-Type 2005 so that he (Epstein) would have another car around Palm Beach available for his friends to use and then placed the car in Visoski's name. 54. In approximately September 2009, Visoski attempted to sell a Ferrari owned by Epstein for $159,000. Epstein intended for the sale to hide the value of this Ferrari and prevents and other creditors from recovering from him. 55. Epstein is concealing substantial assets through a new corporation, Shmitka Air, Inc., whose representative is Larry Visoski. In September 2010, Epstein attempted to sell a 1999 Bell Helicopter for approximately $1,900,000. This sale was an attempt to prevent sand other creditors from recovering from him. 56. Epstein is also concealing substantial assets through an entity known at JEGE, Inc. He is currently attempting to sell an aircraft for $10,000,000 through that entity in an attempt to prevent Nand other creditors from recovering from him. 57. Through information and belief, Epstein and/or his criminal enterprise provides the financial support for his various employees, co-conspirators, other criminal enterprise members and associates. 58. In addition to Epstein's various houses, he owns or controls other condominiums, including approximately 8 to 10 units at in New York City, where certain of his or his Criminal Enterprise associates live or reside, including Jean Luc Brunel, 12 EFTA00729619 Case 9:10-cv-8111140(XX Document 1 Entered on FLSD Docket 09/17/2010 Page 13 of 29 ME'S= and at times various underage minor girls are stashed at this location as well. 59. Defendant Epstein has numerous overseas contacts and accounts and sophistication in international business transactions. He previously served as a trader at Bear Steams and founded his own financial management firm. J. Epstein and Col. (later called Financial Trust Co.) located on his private island in the U.S. Virgin Islands where, until his recent incarceration, according to him he allegedly managed the assets of billionaire clients. 60. After extensive investigation into Epstein's employment history, including questioning of Epstein's family, those whom Epstein considers friends and longtime employees of Epstein, the only known client of Epstein was Limited, Inc. Founder Leslie Wexner, although it is believed that even that relationship has been severed. No other legitimate means of income have been reported. COUNT I BATTERY AGAINST DEFENDANT EPSTEIN 61. Plaintiff M.J. adopts and realleges paragraphs I through 60 above. 62. In the summer of 2002, just after Plaintiff turned 16 years old, Defendant Epstein committed battery against Plaintiff when he intentionally touched intimate areas of her body and person in an offensive manner while she was a minor child. 63. Defendant Epstein intentionally touched Plaintiff private areas multiple times against the will of 64. Defendant Epstein's tortious commission of battery upon Plaintiff was done willfully. 65. As a direct and proximate result of the offenses committed by Defendant Epstein against the then minor Plaintiff,■ she has in the past suffered and will in the future suffer injury, pain 13 EFTA00729620 Case 9:10-cv-S1111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 14 of 29 and suffering, emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of life, invasion of her privacy and other damages associated with Defendant's manipulation and leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and loss of proper and complete education. These injuries are permanent in nature and Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff demands judgment against Defendant Epstein for compensatory damages, punitive damages and such other relief as this Court deems proper and hereby demands trial by jury on all issues triable as of right by a jury. COUNT II INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS AGAINST DEFENDANT EPSTEIN 66. The Plaintiff adopts and realleges paragraphs I through 60 above. 67. Defendant Epstein's extreme and outrageous conduct towards the then minor Plaintiff was intentional and reckless. 68. Defendant Epstein acted with the intent to cause severe emotional distress or with reckless disregard for the high probability of causing severe emotional distress. 69. As a direct and proximate result of the offenses committed by Defendant Epstein against the then minor Plaintiff, ■she has in the past suffered and will in the future suffer injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of life, invasion of her privacy and other damages associated with Defendant's manipulation and leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and 14 EFTA00729621 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 15 of 29 psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, loss of proper and complete education. These injuries are permanent in nature and Plaintiff MJ will continue to suffer these losses in the future. WHEREFORE, Plaintiff ■ demands judgment against Defendant Epstein for compensatory damages, punitive damages and such other relief as this Court deems proper and hereby demands trial by jury on all issues triable as of right by a jury. COUNT HI C NSPIRACY TO COMMIT T In BATTERY AGAINST DEFENDANT 70. The Plaintiff adopts and realleges paragraphs I through 60 above. 71. Defendant = is one of Defendant Epstein's top assistants, as referenced previously in this Complaint. Defendant Epstein, Defendant = and others reached an agreement amongst and between them and otherwise conspired for the purpose of allowing Defendant Epstein and others to commit the tortious and illegal acts described above against Plaintiff. 72. Defendant aided, abetted and assisted Defendant Epstein in his organized scheme and plan to sexually exploit Plaintiff and commit battery against her and/or commit or attempt to commit numerous other crimes against her, including coercing her into prostitution. 73. Defendant conspired with Defendant Epstein to commit tortious and illegal conduct against Plaintiff, and in furtherance of the conspiracy specifically engaged in overt acts such as contacting Plaintiffs on many occasions, scheduling the then minor Plaintiff's appointment for a "massage" knowing that Defendant Epstein was going to commit battery against Plaintiff, attempt sexual battery against Plaintiff, and force her into prostitution and otherwise did everything in her ability to conceal the illegal operation and refuse cooperation with law enforcement. 15 EFTA00729622 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 16 of 29 74. Additionally, Defendant greeted Plaintiff on the occasions when Plaintiff arrived at Epstein's home and personally lead Plaintiff to Defendant Epstein's bathroom where Epstein appeared for the purposes of committing crimes against Plaintiff 75. Defendant Epstein's battery against Plaintiff was facilitated by Defendant and the conspiracy resulted in the various aforementioned crimes being committed against Plaintiff ■ as well as many other underage minor females. 76. As a direct and proximate result of Defendant, participation in the aforementioned conspiracy, Plaintiff,. she has in the past suffered and will in the future suffer injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of life, invasion of her privacy and other damages associated with Defendant's manipulation and leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, loss of proper and complete education. These injuries are permanent in nature and Plaintiff■ will continue to suffer these losses in the future. WHEREFORE, Plaintiff■ demands judgment against Defendant for compensatory damages, punitive damages and such other relief as this Court deems proper and hereby demands trial by jury on all issues triable as of right by a jury. COUNTS IV THROUGH XXIII CAUSES OF ACTION AGAINST DEFENDANTS EPSTEIN AND PURSUANT TO 18 USC 82255 IN VIOLATION OF VARIOUS ENUMERATED OFFENSES CONTAINED WITHIN THAT FEDERAL STATUTE 77. Plaintiff,. adopts and realleges paragraphs I through 60 above. 78. The allegations contained herein in Counts IV through XXIII are separate and distinct legal remedies. I6 EFTA00729623 Case 9:10-cv-81111-X)OO( Document 1 Entered on FLSD Docket 09/17/2010 Page 17 of 29 79. As a condition of 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, entered into a Non-Prosecution Agreement with the Federal Government; that agreement governed not only Defendant Epstein's conduct but also the conduct of his "co-conspirators" including Defendant as she played an essential and criminal role in the commission of these offenses. 80. The Plaintiff,■ was in fact 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, and against Defendant pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 81. Specifically, Defendants Epstein and (a) knowingly conspired with others known and unknown to use a facility or means of interstate commerce to knowingly persuade, induce, or entice minor females, including Plaintiff MJ, to engage in prostitution, in violation of title 18, United States Code, Section 2422(b). (b) knowingly and willfully conspired with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct with minors, including Plaintiff MJ, as defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e); (c) used a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females, including Plaintiff MJ, to engage in prostitution; in violation of Title 18, United States Code, Section 2422(b); 17 EFTA00729624 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 18 of 29 (d) traveled in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(0, with minor females, including Plaintiff MJ; in violation of Title l8, United States Code, Section 2423(b). 82. As a direct and proximate result of the aforementioned criminal offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of life, invasion of her privacy and other damages associated with Defendant's manipulation and leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and psychological expenses. These injuries are permanent in nature and Plaintiff Ewill continue to suffer these losses in the future. Plaintiff= has also incurred attorneys' fees. 83. With regard to each of the following counts, Plaintiff suffered personal injury, as outlined above from the acts above, as a result of the violations of federal criminal law by Defendant Epstein enumerated in paragraph 33, on approximately 20 occasions, and while the dates are not all precisely documented or diaried by Plaintiff, Defendants Epstein and committed these crimes and inflicted said injuries on or about the following dates: COUNT IV August 2002 COUNT V September 2002 COUNT VI October 2002 COUNT VII November 2002 COUNT VIII December 2002 COUNT IX January 2003 18 EFTA00729625 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 19 of 29 COUNT X February 2003 COUNT Xi March 2003 COUNT XII April 2003 COUNT XIII May 2003 COUNT XIV June 2003 COUNT XV July 2003 COUNT XVI August 2003 COUNT XVII September 2003 COUNT XV III October 2003 COUNT XIX November 2003 COUNT XX December 2003 COUNT XXI January 2004 COUNT XXII February 2004 COUNT XXIII March 2004 WHEREFORE, with regard to each and every one of these counts, Plaintiff, ■ demands judgment against Defendant, Jeffrey Epstein, for compensatory damages, loss of income, a loss of the capacity to earn income in the future, attorney's fees, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XXIV Civil Remedy for Criminal Practices 84. Plaintiff realleges paragraphs I through 60 above and for the purposes of this count incorporates and alleges the RICO Statement that has been filed contemporaneously herewith as Exhibit "A." 19 EFTA00729626 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 20 of 29 85. The allegations contained herein in Count )O(1V are a separate and distinct legal remedy brought pursuant to Florida Statute 772.104(1) and (2). 86. Defendant, Jeffrey Epstein, was associated with an enterprise, a group of individuals associated in fact although not a legal entity, which was comprised of at least Defendant Jeffrey Epstein, Jean Luc Brunel, Ghislaine Maxwell, and (and likely many other yet unknown persons); Defendant Epstein participated in this enterprise, or conspired or endeavored to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4), as further outlined in detail in the RICO statement filed with this court. 87. This enterprise was separate and distinct from Epstein himself and had a definite hierarchical structure. Epstein served informally but effectively as the leader, C.E.O, or "boss" of this organization similar to the way an experienced mob boss runs his organized crime family, directing his underlings how to recruit and procure underage girls for his sexual actii. 'tics and the sexual activities of others, developing the use of slang or code words to be used to discuss the illegal activities of the organization, designing a plan or scheme to gain the cooperation of underage minor females, developing methods and techniques to otherwise avoid detection from law enforcement including making large charitable donations to law enforcement agencies, powerful politicians, businessmen and world leaders, associating with powerful social people and highly influential politicians and attorneys, gathering information to blackmail or extort powerful people, devising a plan to attack the credibility and character of anyone that dare unveil the illegal operations of the enterprise and to take an oath to remain silent and/or lie when confronted by law enforcement about the illegal operations and activities of the criminal organization. Epstein's key "lieutenant" in the local Palm Beach branch of the National 20 EFTA00729627 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 21 of 29 organization was who served as both his scheduler and a recruiter/procurer of the girls. also served as a recruiter and helped Epstein satisfy his criminal sexual desires by, on occasion, directly participating in sexual abuse and prostitution of the minor girls. Epstein also used otherwise-legitimate business activities to help further the purpose of the criminal enterprise. These apparently legitimate activities provided "cover" for Epstein and his associates to commit the crimes. Epstein and his associates maintained the appearance of running an upstanding investment business, as well as other legitimate businesses with connections to modeling agencies and other powerful business and political people, to discourage the minor girls from reporting the abuse to law enforcement. Ghislane Maxwell and Jean Luc Brunel helped to provide "cover" by creating the impression that legitimate modeling opportunities were available for the girls. There are many other known and unknown associates of the criminal organization, that worked throughout the country and possibly internationally, who performed functions to perpetuate the criminal activities of the organization. 88. Defendant Jeffrey Epstein participated in this enterprise through a pattern of criminal activity in that he engaged in at least two incidents of criminal activity, as defined and required in Florida Statute 772.102 and as described below, that have the same or similar intents, results, accomplices, victims, or methods of commission and are not isolated incidents. 89. Defendant Jeffrey Epstein engaged in criminal activity by committing, attempting to commit, conspiring to commit or soliciting, coercing or intimidating another person to commit one or more of the following predicate acts as outlined and defined in Florida Statute 772.102: (a) Procuring for prostitution, or causing to be prostituted, any person who is under the age of 18 years in violation of Florida Statutes Chapter 796.03; (b) Acts of battery in violation of Florida Statutes Chapter 784; 21 EFTA00729628 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 22 of 29 (c) Forcing, compelling or coercing another to become a prostitute in violation of Florida Statutes Chapter 796.04; (d) knowingly recruiting, enticing, harboring, transporting, providing or otherwise obtaining by any means a person, knowing that coercion would be used to cause that person to engage in prostitution in violation of Florida Statutes Chapter 796.045; (e) tampering with a witness in violation of Florida Statutes Chapter 914.22; (f) altering, destroying, removing, or concealing records or documents or other evidence with the purpose to impair its verity or availability in violation of Florida Statutes Chapter 918.13; (g) maintaining a place (or more accurately "places") for the purpose of lewdness or prostitution; offering or securing another for the purpose of prostitution or for some other lewd or indecent act; receiving persons into his Palm Beach mansion for the purpose of prostitution or lewdness; directing, taking or transporting or agreeing to direct take or transport persons to his Palm Beach mansion with knowledge or reasonable belief that the purpose of such directing, taking or transporting was prostitution or lewdness; all in violation of Florida Statutes Chapter 796.07. 90. The criminal acts of Defendant Epstein occurred repeatedly over a substantial period of time and were not isolated events. 91. Under Defendant, Jeffrey Epstein's plan, scheme, and enterprise, Defendant, Jeffrey Epstein. paid employees and underlings, including but not limited to to bring him minor girls to his Palm Beach mansion in order for the Defendant to solicit, induce, coerce, entice, compel or force such girls to engage in acts of prostitution and sexual misconduct with 22 EFTA00729629 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 23 of 29 Defendant Epstein and sometimes and to otherwise commit acts of sexual battery thereon, and further Defendant Epstein worked in concert as part of the enterprise with those who were free to act independently and advance their own interests, including Ghislaine Maxwell and Jean Luc Brunel, to obtain minor girls for sexual purposes. 92. Plaintiff,. was the victim of Defendant, Jeffrey Epstein's plan, scheme, and enterprise and was so injured by reason of his violations of the provisions of s. 772.104. Plaintiff,. was called on the telephone by Defendant Epstein and other employees of his, including and transported to the Defendant, Jeffrey Epstein's residence, where she was placed in a room along with the Defendant, enticed to commit acts of prostitution, and had acts of sexual battery and sexual exploitation committed against her. Defendant, Jeffrey Epstein, conspired with his assistants and employees in order to accomplish their common motive or intent of seeking out, gaining access to, and exploiting minor children such as the Plaintiff,■ in the aforementioned ways, and he further conspired with his employees, assistants and underlings to ensure that the crimes of this criminal enterprise were concealed or undetected by law enforcement. Those who were free to act independently and advance their own interests, including Ghislaine Maxwell and Jean Luc Brunel, also worked with the enterprise to conceal the activities of the enterprise. 93. After law enforcement began to detect the criminal activities of Defendant Epstein and the other persons involved in the criminal enterprise, the enterprise used resources and information to conceal the illegal activities of the enterprise, threaten the victims of the crimes of the enterprise if they revealed the scope of the enterprise to law enforcement, and concealed or destroyed documents relevant to the prosecution of the various members of the enterprise. The enterprise also made various efforts to discourage the victims from cooperating with law 23 EFTA00729630 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 24 of 29 enforcement and from filing civil lawsuits to vindicate their rights. Epstein and other members of the enterprise made cash payments and gave gifts to the victims of the enterprise in order to discourage them from reporting crimes to law enforcement and other authorities. 94. Through information and belief, this criminal enterprise gained valuable consideration from the practice of sex-trafficking underage children and providing underage children to other adults and otherwise derived valuable consideration for running a national and oftentimes international sex-trafficking and underage prostitution ring, typically by coercing and introducing the economically disadvantaged underage minor females into prostitution and sometimes into being underage sex slaves for the enterprise. 95. The evidence clearly and convincingly establishes that Plaintiff MJ was injured by reason of violations of the provisions of 772.103, and as such is entitled to threefold the actual damages sustained and a minimum of $200, and reasonable attorney's fees and court costs. 96. In the alternative, and pursuant to s. 772.104, Plaintiff-was injured due to sex trafficking committed in violation of s. 772.103 and is thus entitled to threefold the amount gained from the sex trafficking and to a minimum amount of damages not less than 5200, reasonable attorney's fees and court costs. 97. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, loss to her property and business opportunities and other losses. WHEREFORE, under the provisions of Florida Statutes Chapter 772, Plaintiff, MJ, demands judgment against Defendant, Jeffrey Epstein, for any minimum damages authorized by law, all actual damages sustained (to be trebled as authorized by law), court costs and attorneys' fees, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. 24 EFTA00729631 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 25 of 29 COUNT XXV Cause of Action Pursuant to Florida Statute 796.09 Against Defendant, Jeffrey Epstein 98. Plaintiff adopts and realleges paragraphs 1 through 60 above. 99. The allegations contained herein in Count XXV are a separate and distinct legal remedy. 100. Defendant, Jeffrey Epstein, was a wealthy and powerful man, and Plaintiff was an economically disadvantaged and impressionable minor. 101. Plaintiff MJ had never engaged in any act of prostitution prior to meeting Epstein or being introduced to any of the members of the criminal enterprise of which Defendant Epstein was an operating member and leader. 102. Defendant, Jeffrey Epstein, used his vast wealth and power to coerce Plaintiff into prostitution and/or coerced her to remain in prostitution. 103. Defendant, Jeffrey Epstein, coerced Plaintiff into prostitution in one or more of the following ways: A. Domination of her mind and body through exploitive techniques; B. Inducement; C. Promise of greater financial rewards; D. Exploitation of a condition of developmental disability, cognitive limitation, affective disorder, and/or substance dependency; E. Exploitation of human needs for food, shelter or affection; F. Exploitation of underprivileged and vulnerable economic condition or situation; G. Use of a system of recruiting other similarly situated minor girls to further coerce and induce Plaintiff into the lifestyle of prostitution; and 25 EFTA00729632 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 26 of 29 H. Exploitation through demonstration of abundant wealth and power to impress a young and vulnerable then minor Plaintiff and to coerce her into prostitution. 104. As a direct and proximate result of the offenses committed by Defendant, Jeffrey Epstein, against Plaintiff pursuant to Florida Statutes §796.09, the Plaintiff has in the past suffered, and will in the future suffer, 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 Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe, demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, punitive damages as specifically allowed by this and other statutes and by law, attorney's fees, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XXV Cause of Action Pursuant to Florida Statute 726.101 Against Defendant, Jeffrey Epstein 105. This count alleges an action for redress of fraudulent transfers brought under Florida's Uniform Fraudulent Transfer Act, sections 726.101, et seq., Fla.Stats. ("FUFTA"). 106. Plaintiff adopts and realleges paragraphs I through 60 above. 26 EFTA00729633 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 27 of 29 107. M.J. is a creditor of defendant Jeffrey Epstein. She has various claims against him for repeated sexual molestation of her when she was a minor, as alleged in the other counts of this complaint. 108. Given the egregious acts of sexual molestation the defendant perpetrated against her, M.J. has a claim against defendant, once punitive damages are added, is worth in excess of $50,000,000. Therefore, he is facing judgments in excess of $50,000,000 from her. Epstein is thus a debtor of M.J., as defined in the FUFTA. 109. Defendant Jeffrey Epstein has numerous overseas contacts and sophistication in international business transactions. He previously served as a trader at Bear Stearns and founded his own financial management firm, J. Epstein and Col. (later called Financial Trust Co.) located on his private island in the U.S. Virgin Islands where, until his recent incarceration, he managed the assets of billionaire clients. 110. Defendant Jeffrey Epstein has transferred, is transferring, and intends to transfer in the near future his assets, to locations overseas and elsewhere and/or to nominee individuals who conceal Epstein's interest in the assets, with the actual intent to hinder, delay and defraud- To prevent■ from satisfying any judgment that she might obtain in her pending lawsuit again him, Epstein has moved and intends to move his significant financial assets to locations overseas (i.e., to Israel) or in other unreachable areas and to title his assets (including real property, aircraft, boats, vehicles, and financial instruments) in the names of other persons or entities, even though he maintains (directly or indirectly) control over those assets. These transfers arc designed by Epstein to prevent from being able to collect on any judgment she might obtain against him, including any punitive damages judgment. 27 EFTA00729634 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 28 of 29 111. In recent lawsuits against him very similar to those filed by ■, defendant Epstein has refused to answer and taken the Fifth when asked whether he intends to conceal assets from those with claims against him. 112. In recent lawsuits against him very similar to those filed by defendant Epstein refused to answer and took the Fifth Amendment when asked whether he intends to remain in the country in the future. 113. Epstein could currently post a $15 million bond to satisfy a judgment in this case without financial or other difficulty. WHEREFORE plaintiff-demands judgment against defendant Epstein as follows: (a) An accounting by defendant Jeffrey Epstein of all of his significant financial assets, whether held in this country or overseas, and all significant transfer of assets in the last three years; (b) Avoidance of the fraudulent transfers or obligations to the extent necessary to satisfy M.J.'s claims; (c) An attachment or other provisional remedy against the asset transferred or other property of the transferee in accordance with applicable law; (d) An injunction against defendant Jeffrey Epstein and such transferees as may be appropriate, or both, against further transfers of any assets pending further order of the Court and posting of a bond to protect (e) Appointment of a receiver to take charge of the assets of defendant Jeffrey Epstein until the Court is satisfied that interests in having assets available from the defendant to satisfy any judgment are fully protected; 28 EFTA00729635 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 29 of 29 (t) Posting by defendant Jeffrey Epstein of a S15,000,000 bond to satisfy any judgment obtained b). in her pending lawsuits; and (g) All other relief that the circumstances may require to protect and her ability to satisfy any judgment she might obtain. Plaintiff also demands a jury trial on all issues so triable by jury. Dated: Respectfully submitted, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PL Attorneys for Plaintiff(s) 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Fl 33301 (954)524-2820 TELEPHONE 954 524-2822 BY: Bradley J. Edwards Florida Bar No. 542075 29 EFTA00729636 Intentionally Left Blank EFTA00729637 Case 9:10-cv-811114000( Document 1-1 Entered on FLSD Docket 09/17/2010 Page 1 of 10 CIVIL RICO CASE STATEMENT PURSUANT TO LOCAL RULE 12.1 1. Plaintiffs alleges a violation of Florida Statutes §§ 772.103(3) (participation in an enterprise through a criminal activity) and 772.103(4) (conspiracy to do so). The following information describes both the § 772.103(3) claim and the § 772.103(4) conspiracy claim with the additional note that the conspiracy was between defendant Jeffrey Epstein, MI ME a Ghislaine Maxwell, Jean Luc Brunel and other persons whose identity is, at this time, unknown to M.J.. Epstein, ME and others all conspired together to violate the provisions of § 772.103(3), doing so willfully and with Ml knowledge of the criminal activities that were planned as part of the criminal enterprise. For convenience in this statement, Florida Statutes §§ 772.103(3) and (4) will be referred to as the "Florida Civil RICO provisions." 2. Epstein served as the leader, boss. and "C.E.O." of the criminal enterprise. He also II. criminally sexually abused and prostituted and other minor A were s who victims of the criminal enterprise. He also paid for and and numerous other associates to be a part of the enterprise and conspired with them to commit criminal acts of sexual abuse and prostitution of minors. The basis for Epstein's liability is also described in complaint. 3. The other wrongdoers and criaarticipants included MOM Ghislaine Maxwell, and Jean Luc Brunel. 's uncertain as to the precise spelling of their names and their full legal names.) They assisted defendant Jeffrey Epstein in recruiting and procuring minor girls to satisfy Epstein's criminal sexual purposes and for prostitution, as described in Mcomplaint, and to satisfy their own sexual interests. For example, to further the interests of the local Palm Beach chapter of this expansive criminal enterprise they helped to arrange for minor girls to travel to West Palm Beach mansion to satisfy his sexual desires for minor girls. and many others also conspired with Epstein to commit acts of sexual abuse and prostitution with minor girls and aided and abetted Epstein in the abuse and prostitution. a and other members of this criminal organization had full knowledge of the crimes of the enterprise; they knew full well that the girls who were coming to Epstein's mansion were minors and that Epstein was sexual! abusin and prostituting these minors, some of whom were as young as 12. and willfully and knowingly participated in the activities of the enterprise and intended to make the criminal activities of the enterprise succeed. Among other things, helped arrange for recruiters of the minor girls. She also spoke personally to the recruiters as well as to the minor girls who were victims of Epstein's sexual abuse. At Epstein's specific direction, spoke to the recruiters about subjects such as finding more minor girls to satisfy Epstein's criminal sexual appetite. also served as Epstein's scheduler, scheduling appointments for the minor girls to ostensibly do "work" when in fact (as she well knew) she was scheduling them to be sexually abused and prostituted by Epstein. thus procured minor girls for prostitution and caused them to be prostituted and the term "work" was a code or slang word used b the various criminal enterprise members to avoid detection by law enforcement. who is known to be Epstein's bisexual sex slave, also directly participated in the sexual abuse of the minor irls b artici ting in unlawful sexual activities and prostitution with the girls. Both and assisted Epstein in attempting to keep Epstein's criminal sexual abuse unknown EFTA00729638 Case 9:10-cv-81111-)OO(X Document 1-1 Entered on FLSD Docket 09/17/2010 Page 2 of 10 to law enforcement and other authorities and in discouraging the minor girls from reporting the crimes to law enforcement and other authorities. Maxwell and Brunel participated by helping to create the impression that the girls would be going to meet with Epstein for legitimate "modeling" purposes. Maxwell and Brunel specifically intended to have Epstein abuse the girls and acted with full awareness of Epstein's intentions. Both Brunel and Maxwell recruited minor females for Epstein as well as for themselves in an effort to further the goals of the criminal organization — to sexually abuse and molest underage minor females and avoid detection of law enforcement. Brunel used his modeling agency to locate underage girls for Epstein and others to sexually abuse. Maxwell personally brought underage girls to Epstein for him to sexually abuse, she also presented him with underage girls for him to maintain as sex slaves and to travel the globe with him and others, prostituting underage sex slaves to others. Maxwell was also a participant in sexually abusing minor females. Maxwell served many additional purposes for the criminal organization and was highly ranked within the organization, thus she was able to act on her own accord, without needing orders from Epstein. Maxwell's roles and actions on behalf of the criminal enterprise have included but not been limited to: procuring minor females for her and Epstein and others to sexually abuse, hiring personnel to work for Epstein and for the various positions in the criminal organization, developing relationships with politically connected individuals to protect the organization, managing and organizing the records of the enterprise, maintaining computer records and images of underage minor females with their names and phone numbers, threatening witnesses who have information that could hurt the enterprise, and assisting Epstein and other members of the criminal enterprise to continue the criminal activity of the organization and avoid law enforcement detection or prosecution. 4. The na f all of the victims are unknown to the plaintiff at this time. However, they include herself as well as the victims in the multitude of other civil cases, both filed and unfiled, against Epstein. A list of more than 30 such minor female victims was previously providelithe U.S. Attorney's Office for the Southern District of Florida to Epstein (but not to The injuries to those victims resulted from criminal sexual activity and prostitution with Epstein and and at times Maxwell. The injuries they suffered 'N ike those suffered by in this action, as described in her complaint. For example, and the other victims suffered grave emotional distress and financial injury from being forced to engage in unlawful sexual activities with him to which, as minors, they could not lawfully consent, and from being introduced into a deviant sexual lifestyle. They also suffered distress and financial injury from being prostituted by him. 5. The pattern of racketeering and/or criminal activity is also described in the complaint, which incorporates by reference into this statement here and at all other points in the statement. The criminal activit included Epstein using paid employees and underlings (including and to repeatedly find, procure, and bring to him minor girls in order for Epstein to solicit, induce, coerce, entice, compel or force these minor girls to engage in unlawful sexual activity and acts of prostitution and Epstein using Ghislaine Maxwell and Jean Luc Brunel and others yet unnamed to create the impression that he was involved in legitimate modeling and other activities. a. The criminal activity and specific statutes violated are listed in the complaint and include, but are not necessarily limited to: (i) procuring for prostitution, or causing to be prostituted, minors, in violation of Florida Statutes Chapter 796; (ii) acts of battery in violation of Florida Statutes Chapter 784; (iii) commercial sexual exploitation of a 2 EFTA00729639 Case 9:10-cv-81111-XXXX Document 1-1 Entered on FLSD Docket 09/17/2010 Page 3 of 10 child in violation of Florida Statues § 827.071; and (iv) tampering with a witness in violation of Florida Statutes § 914.22. The criminal activities also include violations of federal criminal statutes, including sexual trafficking of children by fraud, in violation of 18 U.S.C. § 1591, use of a means of interstate commerce to entice a minor to commit prostitution, in violation of 18 U.S.C. § 2422, as well as wire fraud, in violation of 18 U.S.C. § 1343. b. The dates of the events are not fully known to at this time. However, at a minimum, Epstein obtained minor girls (including for sexual purposes of the period of approximately 1998 through November 2005. Epstein could better determine than the precise dates of his abuse of her by reviewing his schedule or computer records for this period of time and looking for notations of days on which she performed "work" for him. Epstein has pled guilty to two such criminal offenses against minor girls, although the total number of indictable or chargeable offenses would easily number more than 1000. On each of these occasions, as described in the complaint, Epsin would have his underlings, co-conspirators or associates (including M) procure a minor girl to satisfy his sexual desires and then would satisfy his sexual desires throw h criminal sexual contact with the minor girls. Epstein would also watch or Maxwell sexually abuse the minor girls to satisfy his sexual desires. Epstein had a particular interest in minor girls, including girls as young as 12. On occasion, he would turn away girls who were 18 or over because of his perverse and unlawful sexual interest in young girls. Epstein recruited and paid the girls for the sexual activities. In doing so, he procured for prostitution, and caused to be prostituted, many young girls under the age of 18, in violation of (among other statutes) Florida Statute § 796.03. The pattern of criminal and unlawful sexual activity extended from at least 1998 through November 2005 and upon information and belief actually existed and operated in a criminal organizational strut many years prior to 1998. Epstein committed unlawful sexual abuse againtislikat least 20 times between Summer of 2002 to Spring 2004 while she was a minor. Other criminal activities involving tampering with and harassing witnesses occurred from June 2002 through early 2008 (and perhaps later). c. many of the occasions, the exact dates of which are not as yet determined by the Epstein would represent that he was interested in a "massage" or legitimate "work" when in fact he was interested in unlawful sexual activity with the minor girls, including fondling the girls, masturbating in their presence, and vaginally penetrating them or causing them to be penetrated. Epstein and others acting under his direction falsely represented to the minor girls that he was interested in a "massage" or "work" when in fact he was interested in procuring the girls for unlawful sexual activity and acts of prostitution. Epstein and others acting under his direction used means of interstate communications to make these false representations, including cellular telephones. Similar to all known crime families or criminal organizations that operate to commit crimes, this criminal enterprise made use of seemingly innocuous code words such as "message" and "work" to describe the continuous criminal activity of procuring underage girls to sexually molest, abuse and exploit. d. Epstein has pled guilty to two Florida felony criminal offenses against minor girls, as alleged in the complaint and Epstein is a Registered Sexual Offender for life. 3 EFTA00729640 Case 9:10-cv-81111-XXXX Document 1-1 Entered on FLSD Docket 09/17/2010 Page 4 of 10 e. The relationship of the criminal activity to the enterprise is also described in the complaint. The Florida offenses to which Epstein pled guilty are but a few of the many instances of his plan succeeding. The acts are all related to each other, are arranged, and are part of common plan for these reasons: they have the same intent (to gratify Epstein's unlawful sexual interest in minor girls as well as to gratify the unlawful sexual interests in minor girls of others at times); the same results (the unlawful sexual abuse and prostitution of minor girls); the same accomplices (including and frequently Maxwell, and Brunel); the same victim was herself victimized more than 20 times, and many other girls were also victimized repeatedly); the same means (there was a standard payment of several hundred dollars for going to the mansion, and standard escalation feature depending on the nature of the sexual acts that Epstein performed); the same methods of commission (Epstein obtained young, skinny, and attractive girls to satisfy his sexual desires while they were economically disadvantaged and lacked a stable family life and therefore, he perceived, would be interested in obtaining money and unlikely to report his crimes to law enforcement); and the same frequency (remarkably Epstein's criminal enterprise operated constantly to procure underage minor females to be sexually abused by Epstein every single day, oftentimes 2 or 3 different underage females in a single day). The acts were also interrelated b common characteristics, namely the identity of the perpetrator (Epstein and often or sometimes Maxwell) and the common results of his crimes (sexual abuse and acts of prostitution with minor girls). The acts also constituted a clear pattern of criminal activity, including giving the impression to the girls who were being recruited that they would have legitimate modeling opportunities. 6. The criminal acts of Epstein occurred repeatedly over a substantial period of time and were not isolated events. Iiiticular, Epstein committed repeated (more than 20) criminal acts of sexual abuse against from approximately Summer 2002 to Spring 2004. He committed similar criminal acts of unlawful sexual activity and prostitution against other minor girls for a period of time from at least 1998 to November 2005. The acts occurred frequently during this time, so frequently that it is impossible to calculate how many different illegal sexual acts were committed by Epstein and his criminal enterprise, but it is fair to say that serious felonies were committed by this criminal organization on an everyday basis. The acts were part of Epstein's regular way of doing business (e.g., obtaining sexual gratification from li ) during this period of time. Epstein and others acting at his direction (including made hundreds of telephone calls in furtherance of these illegal activities. The sexual acts against minors may have temporarily ceased in approximately November 2005 when Epstein learned that law enforcement authorities were investigating his crimes. Given Epstein's long history of sexually abusing minors and the frequency at which he has done so and the fact that despite his arrest and jail sentence his criminal organization remains intact, it is highly likely that he will continue his sexual desires for minor girls. In addition, Epstein committed criminal acts of tampering with witnesses in violation of Florida Statutes § 914.22. For example, Epstein paid the minor girls money not only with the intent to prostitute them but also with the specific intent of causing the minor girls not to communicate to law enforcement officers information about the sexual abuse committed against them. Epstein made bigger payments to the minor girls depending on the degree of force he used towards them, making larger payments when he was more concerned about the 4 EFTA00729641 Case 9:10-cv-81111-XXXX Document 1-1 Entered on FLSD Docket 09/17/2010 Page 5 of 10 fact they might report the crimes committed against them. Without specifically detailing acts committed against certain known minors, Epstein has paid $1000 on occasion after forcibly holding the head of a minor down and pumping his penis inside her against her will. Epstein has also intimidated and reprimanded his co-conspirators and associates for any cooperating with law enforcement and has made it known that his associates must stay loyal to the criminal enterprise above all else. These obstructions may interfere with the ability of law enforcement to discover and prosecute all of Epstein's crimes. They may likewise interfere with the ability ofM to discover all of the information supporting her claim. Epstein also selected impoverished girls for his crimes, believing that the payments would be more effective in obtaining their silence and that their economic circumstances might make them less likely to report to law enforcement. If all else failed, after having unlawful sex with the minor girls, Epstein would tell them not to tell anyone about their unlawful encounter or "bad things" would happen. In addition, since November 2005 and through the early part of 2008 (and perhaps later), Epstein and others acting at his direction have attempted to discourage the victims of his crimes from reporting his crimes and cooperating with law enforcement. For example, persons acting at the direction of Epstein have aggressively attempted to "interview" the victims or to "tail" the victims in their cars. They also harassed a victim shortly before she was to testify at a grand jury investigating Epstein and aggressively intimidated a victim to scare her away from proceeding to trial against him. These efforts have been made not for legitimate investigative reasons but rather for the purpose of discouraging the victims from cooperating with law enforcement (and, in at least one case, the investigating grand jury) and from filing civil lawsuits to vindicate their rights. 7. The enterprise is also described in the complaint, which allegations expressly incorporates into this statement as part of the description of the enterprise. The enterprise included, at a minimum, a group of individuals associated in fact to assist Epstein in recruiting and procuring minor girls and obtaining criminal gratification of his illegal sexual interest in minor girls and at least two individuals (Ghislaine Maxwell and Jean Luc Brunel) who were free to act independently and advance their own interests, including their own sexual interests. a. The persons constituting the enterprise includeciaroirindividuals associated in fact. These individuals include Epstein, Ghislaine Maxwell, and Jean Luc Brunel, as well as other yet unnamed persons whose names M.J. intends to identify during the discovery phase of this case. b. The criminal enterprise had a definite hierarchal structure, although all the details of that structure are not completely know to Through discovery, intends to ascertain the precise structure of the enterprise that enabled Epstein to commit sexual crimes against here. While does not currently know all of the details of the structure, she does know that the enterprise operated together on a continuing basis, in an extremely efficient and organized manner, with largely the same personnel for a common purpose. The shared purpose of the enterprise was to satisfy Epstein's, as well as certain other individual's, illegal interest in having sexual activities with minor girls as well. The enterprise was not a mere informal conspiracy, but had a definite clear structure. Epstein served effectively as the leader, C.E.O. or "Boss" of this organization, directing his various levels of underlings how to recruit and procure young girls for his sexual activities and when to bring the girls to his mansion as well as how to avoid law enforcement 5 EFTA00729642 Case 9:10-cv-81111-XXXX Document 1-1 Entered on FLSD Docket 09/17/2010 Page 6 of 10 detection. Epstein's key "lieutenant" in the Palm branch of this national and possibly international organization was who served as both his scheduler and a recruiter/procurer of the girls. This was an important function, as the recruiting was necessary to satisfy Epstein's desire to abuse a large number of different minor girls with different (albeit similar) physical attributes and the scheduling was necessary to insure that the minor girls would be brought to Epstein's mansion to be sexually abused and prostituted at a time when Epstein was there (but not at the same time, when they might learn of other girls' identities and possibly become emboldened to report his activities to law enforcement.) Scheduling was also necessary to ensure secrecy, so that as few persons as possible were aware that minor girls were coming at unusual hours to Epstein's mansion. also needed (directly or indirectly) to make transportation arrangements for many of the irls as were often too young to drive themselves to and from the mansion. also served as a recruiter and helped Epstein satisfy his criminal sexual desires by, on occasion, participating in sexual abuse and prostitution of the minor girls. Epstein, and all took steps to conceal the existence of the enterprise and to discourage the girls from reporting the sexual abuse and prostitution to law enforcement or other authority figures. Epstein also used otherwise-legitimate business activities to help further the purpose of the criminal enterprise. These apparently legitimate activities provided "cover" for Epstein and his associates to commit the crimes. Ghislaine Maxwell and Jean Luc Brunel also helped to provide "cover" for the enterprise by creating the impression that there were legitimate modeling opportunities and other legitimate opportunities available for the girls if they went to see Epstein. Epstein also maintained the appearance of an extremely wealthy, upstanding and prominent figure to discourage the minor girls from reporting the abuse to law enforcement. To further impress the underage minor victims, he would tell them that he was a famous scientist, a brain surgeon, an inventor of various products including a state of the art liposuction device. He would also brag about the famous people with whom he was good friends. By projecting an image of financial power (and, relatedly, strong political connections to prominent politicians and current and former government officials and personal connections to prominent scientists), Epstein hoped to discourage the minor girls from reporting what he was doing to them by making it appear that they would not be believed. These business activities helped Epstein secure the financial resources to commit the crimes against the minor girls and to pay for prostituting them. For example, the activities paid for maintaining the mansion where the girls were abused and paid for the cellular telephones and other means of communications that were used to recruit and procure the gi business activities also helped to provide the funds to pay and large sums of money to participate in the illegal enterprise and make payments to the girls for performing sexual acts. In sum, Epstein and the persons under his direction associated in fact and functioned as a continuing unit. This enterprise produced a course of conduct that lead to a pattern of criminal activity involving enterprise was the vehicle for Epstein to commit his crimes against more than 100 instances of sexual abuse and prostitution of minkrls. This i and other 6 EFTA00729643 Case 9:10-cv-81111-XXXX Document 1-1 Entered on FLSD Docket 09/17/2010 Page 7 of 10 minor girls and operated on a continuing basis from June 2002 to November 2005 (and, in regard to witness tampering and harassment, through at least early 2008). The enterprise enabled Epstein to sexually abuse and prostitute in particular on more than 20 occasions from February 2003 through June 2005. c. Epstein served as the effective leader or "C.E.O." of the enterprise. d. Epstein was associated with the enterprise as its effective leader or "C.E.O." e. Epstein directed the affairs of the enterprise and the others in the enterprise responded to his commands, although Ghislaine Maxwell and Jean Luc Brunel acted independently to advance their own interests (including sexual interests) along with the interests of Epstein. pi f. Based on the facts that she currently possesses, specifically alleges and intends to prove both that (i) Epstein was an individual separate and disctinct from the enterprise and (ii) the defendant was a member of the enterprise, namely that he served as the effective leader of the enterprise. With regard to point (i), the illegal enterprise had a definite structure and operational function apart from Epstein. The structure is described in greater detail in this statement in answer 5.b above. With regard to point (ii), the defendant was a member of the enterprise and served to execute many of the decisions and activities of the enterprise and to command the execution of others. Epstein personally engaged in sexual abuse of minor girls, including E stein also directed others to engage in sexual abuse of minor girls, including Epstein also procured girls for prostitution and caused these girls to be prostituted. Epstein also served as the leader of the enterprise. g. Epstein was a direct perpetrator of the racketeering activity. In particular, Epstein engaged in criminal acts of sexual abuse and prostitution with minor irls as well as procuring girls for prostitution. He also directed others (i.e., to engage in such criminal acts and served as the leader of the criminal enterprise. 8. The relationship between the pattern of criminal activity and the enterprise is not completely known to at this time, and it is not known how much money or other consideration was generated by the enterprise through these illegal means. Through discovery, she intends to understand the relationship more fully. At this time, however, as described in addition in the complaint and parts 5, 6 and 7 in this statement, there was a criminal entity separate and apart from the pattern of activity in which it engaged. The pattern of criminal activity was the series of crimes committed by Epstein and others, and includes the specific crimes identified in part 5.a. above. These offenses were closely related and formed a clear pattern, as described in part 5.b above. These acts included acts of sexual abuse and procuring the prostitution of minors by Epstein personally and by acting at Epstein's direction. In contrast, the enterprise was the group of persons who associated together for the common purpose of engaging in the criminal course of conduct described at greater length elsewhere in this statement, including part 5.e above. The group of persons included Epstein, =, Maxwell, and Brunel and others whose identity is, at this time, unknown to 9. In this part of the statement, M will provide a description of the relationship between the otherwise-lawful activities of the enterprise and the criminal activities of the enterprise. The lawful and unlawful activities of the enterprise have been described in addition in paragraphs 10 through 18 and 42 through 43 of the complaint and previous answers found in parts 5, 6 7 EFTA00729644 Case 9:10-cv-81111-XXXX Document 1-1 Entered on FLSD Docket 09/17/2010 Page 8 of 10 and 7 above (which expressly incorporates into her answer here). The usual and daily activities of the criminal enterprise included scheduling meetings, activities, and other events for Epstein — including scheduling S" ate time" in his mansion for Epstein to commit sexual crimes against minor girls. served as Epstein's scheduler, scheduling both otherwise-lawful activities to provide "cover" for Epstein as well as the illegal sexual activities. The exact fr- cy with which the sexual crimes took place varied and is not known, at this time, to = However, when Epstein was in West Palm Beach, it often occurred on a weekly or daily basis (and, in some instances, took place on several times during a single day). The scheduling was designed to secure a private place in Epstein's mansion when few other persons would be present at the mansion, so as to reduce the chance of detection of Epstein's sexual abuse and prostitution as well as to make it more difficult for the minor girls to report his actions to law enforcement or other authorities. The usual activities of the enterprise also included maintaining the mansion and securing means of communication (i.e., cellular telephones) to recruit minor girls and procure them for prostitution. The activities further included arranging transportation for the girls to and from the mansion if it was necessary. The enterprise also attempted to make Epstein appear to be an upstanding and law-abiding member of community and a successful businessperson, for reasons described in paragraph 6.b above. The enterprise served as the usual way in which Epstein would obtain sexual gratification. 10. Through his criminal enterprise, Epstein received perverse and unlawful sexual gratification from sexually abusing minor girls and engaging in acts of prostitution with them. He also received perverse sexual gratification from directing others (e.g., to sexually abuse and prostitute minor girls. 11. While civil action alleges violations of the Florida Civil RICO statute rather than violations of the federal civil RICO statute, it should be noted that means of interstate communications were used to perpetrate the crimes against minor girls (including =, including cellular and other telephones that Epstein used, or caused to be used, to arrange his illegal sexual activities and to recruit additional minor girls to participate in these activities. Through his recruitment and procuring of young girls, Epstein's activities directly affected interstate commerce. 12. Based on the information currently known to her does not allege that Epstein, who is a billionaire banker, used the enterprise to personally make a financial profit or to obtain the c 1 on of an unlawful debt, only because that information has not yet been made available Epstein did, however, make payments to and prostitute the minor girls for the sexual gran cation that he obtained from them and to discourage them from reporting his crimes to law enforcement and other authorities. Epstein also has, through his criminal organization, prostitutes underage girls to others, and Epstein and the criminal organization gained valuable consideration from that activity, although it is unknown the type and amount of remuneration at this time. 13. Based on the information currently known to her, Woes not allege that Epstein, who is a billionaire banker, used the enterprise to obtain or maintain control of a business enterprise or real property. Epstein did, however, use his West Palm Beach mansion (and his various other properties including his personal island) to perpetrate the crimes against the then-minor girls. He also used his financial success to provide "cover" for his crimes, as described in part 6.b above. 14. The criminal enterprise is described in the complaint and part 6 of this statement above, 8 EFTA00729645 Case 9:10-cv-81111-XXXX Document 1-1 Entered on FLSD Docket 09/17/2010 Page 9 of 10 which description incorporates here. a. The enterprise including persons unkn but at least included Epstein and his paid assistants and as well as associates of Epstein (who were free to act in ependently and to advance their own interests) Ghislaine Maxwell and Jean Luc Brunel b. Under the direction of Epstein, MI, and others whose names are unknown to M.J. arranged for minor girls to come to Epstein's mansion where he could sexual abuse them and prostitute them to satisfy his perverse sexual des' s well as the perverse sexual desires of Ghislaine Maxwell and Jean Luc Brunel. and were responsible for recruiting the girls and procuring them for prostitution. was also responsible for scheduling a time when both Epstein and the minor girl cold—meet meet together at Epstein's mansion for the sexual abuse and for making travel arrangements (if necessary) for the girls. was also responsible for ensuring the privacy of the room in Epstein's mansion where Epstein would sexually abuse the girls. would articipate in abusin and prostituting the girls for Epstein's sexual grati ication. and received payments and other forms of compensation from ps illegal activities and for participating in the enterprise. Epstein, and also all took steps to discourage the girls from reporting these crimes to law en orcement, including making cash payments to the girls. Ghislaine Maxwell and Jean Luc Brunel helped to persuade the girls that legitimate modeling opportunities could be had if they went tlat Epstein. c. As a result of the criminal enterprise, ME (then a minor) suffered criminal sexual abuse at the hands of Epstein. As alleged in greater detail in the complaint, this abuse lead to significant past and future physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self- esteem, loss of dignity, invasion of privacy, and other damages, including consequential damages from Epstein controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. In addition, the time involved in the abuse created lost opportunities to pursue other activities (indult economic activities) and lead to past and fu ncial and proprietary losses to as well as the need for psychiatric service:11a has also suffered a loss of income, a loss of capacity to earn income in the future, and a loss of the capacity to enjoy life. It has also lead to the need to file this civil suit, with consequent attorney's fees. All of these damages were caused by, and proximately caused by, the criminal enterprise and its criminal acts. All of these injuries were inflicted directly on and occurred by reason of the criminal acts of the enterprise, including the acts of sexual abuse by Epstein. d. The defendant "person" in the Florida Civil RICO action is, at this time, only defendant Epstein. Defendant Epstein is associated with a criminal enterprise that conducted and participated, both directly and indirectly, in a pattern of criminal activity in violation of both Florida and federal criminal law. The exact relationship between Epstein and the criminal enterprise is described in greater detail in parts 5 and 6 above. 15. The criminal conspiracy involving the enterprise is described in the complaint as well as parts 5, 6, and 7 above. expressly so information into her statement here. The conspiracy was formed of Epstein, and many others, who agreed to arrange for illegal sexual gratification by Epstein through t use and prostitution of minor girls both by Epstein personally and by others (i.e., while he watched, as 9 EFTA00729646 Case 9:10-cv-81111-XXXX Document 1-1 Entered on FLSD Docket 09/17/2010 Page 10 of 10 well as to provide illegal sexual gratification to Ghislaine Maxwell and Jean Luc Brunel. Certain other names of other criminal enterprise members and co-conspirators are known yet currently unnamed, and many other names are currently unknown but Plaintiff intends to learn the names and roles of all involved in the criminal activity of this enterprise. The many enterprise members conspired to commit similar crimes and to conceal those crimes also in furtherance of the criminal enterprise. The object and substance of the conspiracy was to obtain minor girls for Epstein so that he could satisfy his perverse sexual interest in minor girls, to recruit minor girls to be abused and prostituted for his gratification, to keep the existence of the sexual abuse from being learned by law enforcement and other authorities, and to discourage the victims from reporting the abuse to authorities, as well as to provide sexual gratification to Maxwell and Brunel. The conspiracy started in approximately June 2002 in West Palm Beach, Florida, and other locations. The sexual abuse of the minor girls appears to have, at least temporarily, ceased in approximately 2005. The conspiracy extended beyond November 2005 to early 2008 (and perhaps later) in its efforts to keep the criminal conspiracy unknown, as described in n 5.f above. The conspiracy committed numerous overt acts. For example, and arranged for minor girls to be brought to Epstein's West Palm Beach mansion so that he could sexually abuse the girls and obtain sexual gratification. Epstein sexually abused minor girls at his mansion and made wilts to them and otherwise prostituted them there. 16. suffered injuries, including financial and proprietary injuries, as described in part I3.0 above. 17. The enterprise injured ■ and the other minor girls by enabling Epstein to sexually abuse and prostitute the girls. 18. Defendant Epstein is liable for all the damages for his criminal activity and the activity of his criminal enterprise. (If additional defendants are added to the complaint, these other defendants may also be jointly and severable liable for the damages.) The damages for which Epstein is liable include compensatory damages (including damages for emotional distress as well as damages for financial and proprietary losses), attorney's fees, and such further relief as the Court deems just and proper. The amount of these damAges is significant. These damages are trebled by operation of Florida Statutes 772.104. =is aware of the provision in Florida Statutes 772.104(3) ("In no event shall punitive damages be awarded under this section"), but is nonetheless entitled to punitive damages by virtue of her other counts in her complaint. She is seeking punitive damages for Epstein's outrageous and egregious conduct and crimes under other provisions of law in this lawsuit. 19. All o bove answers must be read in light of the complaint that has been filed in this case. xpressly incorporates by reference her complaint as part of the answer to each of the above questions. Whenever the word "include" or its variations appears in this statement, the information that follows is not intended to be an exclusive listing. 10 EFTA00729647 Intentionally Left Blank EFTA00729648 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: CASE NO.: 9: I O-CV-81111 -DIMITROULEAS/SNOW Plaintiff, VS. JEFFREY EPSTEIN and Defendants. PLAINTIFF'S FIRST REQUEST FOR PRODUCTION TO DEFENDANT COMES NOW the Plaintiff by and through her undersigned counsel, and requests the Defendant, Jeffrey Epstein, to produce the original or best copy of the items listed hereinbelow, at the offices of the Plaintiff's undersigned counsel, for inspection and/or copying, pursuant to the applicable Florida Rules of Civil Procedure, the following: DEFINITIONS The term "documents" means and includes, without limitation, all writings of any kind, including the originals and all non-identical copies or drafts, whether different from the original by reason of any notation made on such copy or draft or otherwise including, without limitation, correspondence, memoranda, notes, diaries, statistics, letters, e-mail, electronic computer files, telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, interoffice communications, offers, notations of any sort of conversation, telephone calls, meetings or other communications, bulletins, printed matter, computer print-outs, teletypes, facsimiles, invoices, work sheets and all drafts, alterations, modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records or representations of any kind including, without limitation, photographs, charts, graphs, microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or electric records or representations of any kind including, without limitation, tapes, cassettes and disc recordings, and writings and printed material of every kind, whether or not the document is out of your possession, custody or control. EFTA00729649 The term "correspondence" means any tangible object that conveys information or memorializes information that was conveyed in tangible or oral form including, but not limited to, writings, letters, memoranda, reports, notes, telegrams and interoffice communication. DOCUMENTS REQUESTED 1. Copies of all telephone records in your or your attorneys' possession from 2002 — 2005 that in any way relate to you (including all phone lines owned by you or that were used to contact girls for the purposes of scheduling massages for you). 2. All massage appointment books, diaries, computer calendars or scheduling entries, scheduling books or any other writing or correspondence that contains the names of any of the girls that were called, contacted, scheduled, or who otherwise went to your home located at 358 El Brillo Way, West Palm Beach, Florida, for the purpose of giving you a massage. 3. Any and all documentation in your possession that contains Plaintiff's name or that refers to Plaintiff, directly or indirectly, (including but not limited to emails, letters, message pads, diaries, appointment books, computer print outs). 4. Any and all photos, videos, downloaded digital prints or any other visual depiction of Plaintiff or other known or suspected minor females introduced to you, directly or indirectly, by Plaintiff. 5. Photos of the inside of your home located at 358 El Brillo Way, West Palm Beach, Florida, that depict the room(s) where the massages took place (including massage table). 6. Any and all documentation of cancelled checks or evidence of payment to Plaintiff of any kind and for any reason whatsoever. 7. All information obtained by you or your attorneys as a result of the exchange of information with law enforcement or prosecuting agencies relating to the State criminal case against you or the Federal investigation against you. EFTA00729650 8. Tax returns filed with the United States Internal Revenue Service from 2002 through the present. 9. Photocopies of your passport, including any supplemental pages reflecting visa's or entries to locations outside of the 50 United States. 10. Any documents, photographs, witness interviews, summaries of investigations. police reports, and all other materials provided by local, state, or federal law enforcement investigators or local, state or federal prosecutors investigating you for sexual offenses against minors, including all such materials related to the guilty pleas you entered in state court and the non-prosecution agreement you executed with the U.S. Attorney's Office for the Southern District of Florida. 11. All documents and correspondence between you, your agents, and your attorneys and (a) state or federal law enforcement officials and (b) local, state, and federal prosecutors (including, but not limited to, letters and e-mails to and from the State Attorney's office or any agents thereof and letters and e-mails to and from the U.S. Attorney's office or any agents thereof). 12. All medical records of Defendant Epstein from any psychologist or psychiatrist, including but not limited to Dr. Stephan Alexander or any court appointed doctor. 13. All medical records from any other doctor who has treated Defendant Epstein for sexual issues or who has provided prescriptions for Epstein related to sex issues. 14. All bank and financial records and documents for bank accounts, checking accounts, savings accounts, stocks and bonds, and any other financial instruments or assets controlled, directly or indirectly, by Defendant Epstein for the period 2002 to the present. EFTA00729651 15. All records and documents reflecting ownership, directly or indirectly, of any real properties, vehicles, boats, and aircraft by Defendant Epstein for the period 2002 to the present. I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided together with service of the Complaint herein. FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PL Attorneys for Plaintiff(s) 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Fl 33301 (954)524-2820 TELEPHONE 954)524-2822 Fax BY: / era Bradley J. Ed icC Florida BafNo. 542075 EFTA00729652 Intentionally Left Blank EFTA00729653 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: CASE NO.: 9: I 0-cv-8 -DIMITROULEAS/Snow Plaintiff, VS. JEFFREY EPSTEIN and Defendants. NOTICE OF SERVICE OF PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT PLEASE TAKE NOTICE that the Plaintiff, by and through her undersigned counsel, has propounded unto the Defendant, Jeffrey Epstein, her First Set of Interrogatories, numbered I through 16, inclusive, to be answered in writing, under oath, pursuant to the applicable Florida Rules of Civil Procedure. I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided together with service of the Complaint herein. FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PL Attorneys for Plaintiff(s) 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Fl 33301 (954)524-2820 TELEPHONE BY: 5,4,O radley J. Ed s Florida B o. 542075 EFTA00729654 UNITED STATES SOUTHERN DISTRICT OF FLORIDA Case #: CASE NO.: 9:10-cv-III III -DIMITROULEAS/Snow Plaintiff, vs. JEFFREY EPSTEIN and Defendants. . PLAINTIFF'S FIRST SET OF : INTERROGATORIES TO DEFENDANT COMES NOW the Plaintiff, by and through her undersigned counsel, and propounds unto the Defendant, JEFFREY EPSTEIN, her First Set of Interrogatories, numbered 1 through 16, inclusive, to be answered in writing, under oath, pursuant to the applicable Florida Rules of Civil Procedure. I HEREBY CERTIFY that the original and one true and correct copy of the above and foregoing has been provided together with service of the Complaint herein. FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PL Attorneys for Plaintiff(s) 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Fl 33301 (954)524-2820 TELEPHONE BY: wards Florida ar No. 542075 EFTA00729655 DEFINITIONS 1. The term "document" as used herein means and includes, without limitation, all writings of any kind, including the originals and all non-identical copies or drafts, whether different from the original by reason of any notation made on such copy or draft or otherwise including, without limitation, correspondence, memoranda, notes, diaries, statistics, letters, e- mail, electronic computer files, telegrams, minutes, contracts, reports, studies, checks. statements, receipts, returns, summaries, pamphlets, books, prospectuses, interoffice communications, offers, notations of any sort of conversation, telephone calls, meetings or other communications, bulletins, printed matter, computer print-outs, teletypes, facsimiles, invoices, work sheets and all drafts, alterations, modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records or representations of any kind including, without limitation, photographs, charts, graphs, microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or electric records or representations of any kind including, without limitation, tapes, cassettes and disc recordings, and writings and printed material of every kind, whether or not the document is out of your possession, custody or control. 2. The term "correspondence" as used herein is defined to mean any tangible object that conveys information or memorializes information that was conveyed in tangible or oral form including, but not limited to, writings, letters, memoranda, reports, notes, telegrams and interoffice communication. 3. The term "relating to" as used herein is defined to mean evidencing, referring to, pertaining to, consisting of, reflecting, concerning, or in any way logically or factually connected with the matter discussed. 4. The phrase "describe and explain" and the term "state" as used herein are intended to and shall be interpreted to request a full and fair statement of the fact or matter being described and explained, including a statement of all facts, statements, events and circumstances necessary to understand and evaluate the fact or matter being described and explained. 5. The term "identify" as used in each of the following Interrogatories requesting an identification of documents is intended to be interpreted to request and require: A. The date of the document; B. The originator of the document; C. The type of document; D. The addressee of the document, if any; E. Identification of persons to whom copies of the documents were furnished; F. Details as to the custody of the document on the date the Interrogatories are answered; EFTA00729656 G. Specific page numbers where the information requested may be found, if appropriate; or, alternatively, documents may be identified by numbering each such document and referring to the number in the answer and providing a true copy of each such numbered document with the Answers to Interrogatories. 6. The term "identify" as used in each of the following Interrogatories requesting the identification of persons is intended to be interpreted to request and require for each witness known: A. The full name of the individual; B. The last known address and phone number of the individual; C. The last known place, address and phone number of employment of the individual; D. The substance of the witness' knowledge or information relating to the information requested. INSTRUCTIONS Before answering the following Interrogatories, will you please make such inquiries of your agents, servants, employees and/or attorneys as will enable you to make full and true answers to the following, in accordance with the applicable Florida Rules of Civil Procedure. Additionally, if more space is required, please use a separate sheet of paper and attach same behind the sheet where the respective question appears. EFTA00729657 PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT (If answering for another person or entity, answer with respect to that person or entity, unless otherwise stated.) I. What is the full name and Florida address of the person answering these interrogatories, and, if applicable, the person's official position or relationship with the party to whom the interrogatories are directed? 2. Who is currently in possession of the computer equipment that was removed from your home in 2005, just prior to the execution of the search warrant? 3. List each telephone number used by you or your assistants to call minor females directly, or indirectly, for the purpose of scheduling a massage to take place at your house located at 358 El Brillo Way, West Palm Beach (includes landlines, cell phones, and private jet or airplane lines). For each cell phone, list the provider. EFTA00729658 4. Last known name, address, and telephone numbers of all persons that may have any knowledge about any of the allegations in the Complaint, including, but not limited to, friends, acquaintances, employees, or others to whom you have spoken about the subject matter which forms the basis of this Complaint or who have observed such activity. 5. Provide a complete list of the names of all females with whom you interacted sexually, who were at the time under 18 years of age. This is meant to include interactions at any time or any place. 6. Provide a complete list of the names of all known or suspected minors with whom you had sexual activities from 2002 to date. EFTA00729659 7. Describe with as much specificity as possible where you resided from August 2002 through the present (this interrogatory is meant to include time spent at each of your houses since August 2002). 8. List of all employees, servants, cleaning staff, personal staff or assistants employed by you or your companies who worked out of or visited your residence in West Palm Beach between August 2002 and the present, including their dates of employment, their job duties and title, and their last known address and telephone numbers. 9. State with as much specificity as possible when you met the Plaintiff, and include in your answer the following: (a) the circumstances and location of how and where you met, (b) describe the nature of your relationship; (c) describe how many occasions she was with you at your residence located at 358 El Brillo Way in West Palm Beach, Florida. EFTA00729660 . . EFTA00729661 10. Was there ever an employment or business relationship between you and the Plaintiff, and if so specify the duration of this relationship and how this relationship ended, including the nature of the remuneration to Plaintiff and what evidence or documentation exists of that relationship. 11. Describe in your own words the method you used to procure females to provide you with but not limited to — Ghislaine Maxwell, massages. Include in your response the specific roles of eachitoshat assisted you, Ellt joss , your housekeepers, Jean Luc Brunel, or any of ers. 12. Did you ever engage in sexual activity of any kind whatsoever with the Plaintiff, and include in your answer what type of sexual activity took place, where it took place, and the dates or general timeframe when this activity occurred. 4 EFTA00729662 13. Was it your intent to harm or injure the Plaintiff when you were interacting with her? 14. Describe any words or actions that you made to assure the Plaintiff that sexual activity with you was proper or appropriate? 15. Describe what age you thought the Plaintiff was when you first had sexual activity with her, including your reasons for that belief. 16. State the facts upon which you rely for each affirmative defense in your answer. EFTA00729663 17. Do you have any remorse for your sexual interaction with then minor Plaintiff ■ 18. Do you have any remorse for interacting sexually with other minor females? 19. Do you intend to interact sexually with minors in the future? 20. Do you derive any income from trafficking underage minor females for sex? Please explain in detail how much money you have made from sex trafficking since 1998. EFTA00729664 21. On how many occasions have you committed the following acts with underage minor females: A) felt her breasts B) inserted your fingers into her vagina C) engaged in full sexual intercourse D) rubbed her vagina or buttock over her clothes E) masturbated in her presence F) had her pinch your nipples while you mastubated 22. Provide the names, addresses and telephone numbers of all the people that know of you interacting sexually with underage minors. EFTA00729665 I have read the foregoing Answers to Interrogatories and do swear that they are true and correct. Jeffrey Epstein, Defendant STATE OF FLORIDA : ss. COUNTY OF The foregoing instrument was acknowledged before me this day of 2010, by JEFFREY EPSTEIN, who is personally known to me or who has produced as identification. My Commission Expires: Signature of Acknowledger Typed/Printed Name of Acknowledger Title or Rank Serial Number, if any EFTA00729666 Intentionally Left Blank EFTA00729667 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: CASE NO.: 9: I 0-ev-81 III -DIMITROULEAS/Snow Plaintiff, vs. JEFFREY EPSTEIN and Defendants. NOTICE OF SERVICE OF PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT PLEASE TAKE NOTICE that the Plaintiff, by and through her undersigned counsel, has propounded unto the Defendant, Jeffrey Epstein, her First Set of Interrogatories, numbered I through 16, inclusive, to be answered in writing, under oath, pursuant to the applicable Florida Rules of Civil Procedure. I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided together with service of the Complaint herein. FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PL Attorneys for Plaintiffs) 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Fl 33301 (954)524-2820 TELEPHONE 954 524-2822 Fax BY: radley J. Ed ds Florida B• o. 542075 EFTA00729668 UNITED STATES SOUTHERN DISTRICT OF FLORIDA Case #: CASE NO.: 9:10-ev-8I III -DIMITROULEAS/Snow Plaintiff, vs. JEFFREY EPSTEIN and Defendants. PLAINTIFF'S FIRST SET OF : INTERROGATORIES TO DEFENDANT COMES NOW the Plaintiff, by and through her undersigned counsel, and propounds unto the Defendant, JEFFREY EPSTEIN, her First Set of Interrogatories, numbered 1 through 16, inclusive, to be answered in writing, under oath, pursuant to the applicable Florida Rules of Civil Procedure. I HEREBY CERTIFY that the original and one true and correct copy of the above and foregoing has been provided together with service of the Complaint herein. FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PL Attorneys for Plaintiff(s) 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Fl 33301 (954)524-2820 TELEPHONE 954 524-2822 Fax BY: Bradley J. wards Flori No. 542075 EFTA00729669 DEFINITIONS 1. The term "document" as used herein means and includes, without limitation, all writings of any kind, including the originals and all non-identical copies or drafts, whether different from the original by reason of any notation made on such copy or draft or otherwise including, without limitation, correspondence, memoranda, notes, diaries, statistics, letters, e- mail, electronic computer files, telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, interoffice communications, offers, notations of any sort of conversation, telephone calls, meetings or other communications, bulletins, printed matter, computer print-outs, teletypes, facsimiles, invoices, work sheets and all drafts, alterations, modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records or representations of any kind including, without limitation, photographs, charts, graphs, microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or electric records or representations of any kind including, without limitation, tapes, cassettes and disc recordings, and writings and printed material of every kind, whether or not the document is out of your possession, custody or control. 2. The term "correspondence" as used herein is defined to mean any tangible object that conveys information or memorializes information that was conveyed in tangible or oral form including, but not limited to, writings, letters, memoranda, reports, notes, telegrams and interoffice communication. 3. The term "relating to" as used herein is defined to mean evidencing, referring to, pertaining to, consisting of, reflecting, concerning, or in any way logically or factually connected with the matter discussed. 4. The phrase "describe and explain" and the term "state" as used herein are intended to and shall be interpreted to request a full and fair statement of the fact or matter being described and explained, including a statement of all facts, statements, events and circumstances necessary to understand and evaluate the fact or matter being described and explained. 5. The term "identify" as used in each of the following Interrogatories requesting an identification of documents is intended to be interpreted to request and require: A. The date of the document; B. The originator of the document; C. The type of document; D. The addressee of the document, if any; E. Identification of persons to whom copies of the documents were furnished; F. Details as to the custody of the document on the date the Interrogatories are answered; EFTA00729670 G. Specific page numbers where the information requested may be found, if appropriate; or, alternatively, documents may be identified by numbering each such document and referring to the number in the answer and providing a true copy of each such numbered document with the Answers to Interrogatories. 6. The term "identify" as used in each of the following Interrogatories requesting the identification of persons is intended to be interpreted to request and require for each witness known: A. The full name of the individual; B. The last known address and phone number of the individual; C. The last known place, address and phone number of employment of the individual; D. The substance of the witness' knowledge or information relating to the information requested. INSTRUCTIONS Before answering the following Interrogatories, will you please make such inquiries of your agents, servants, employees and/or attorneys as will enable you to make full and true answers to the following, in accordance with the applicable Florida Rules of Civil Procedure. Additionally, if more space is required, please use a separate sheet of paper and attach same behind the sheet where the respective question appears. EFTA00729671 PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT (If answering for another person or entity, answer with respect to that person or entity, unless otherwise stated.) 1. What is the full name and Florida address of the person answering these interrogatories, and, if applicable, the person's official position or relationship with the party to whom the interrogatories are directed? 2. Who is currently in possession of the computer equipment that was removed from your home in 2005, just prior to the execution of the search warrant? 3. List each telephone number used by you or your assistants to call minor females directly, or indirectly, for the purpose of scheduling a massage to take place at your house located at 358 El Brillo Way, West Palm Beach (includes landlines, cell phones, and private jet or airplane lines). For each cell phone, list the provider. EFTA00729672 4. Last known name, address, and telephone numbers of all persons that may have any knowledge about any of the allegations in the Complaint, including, but not limited to, friends, acquaintances, employees, or others to whom you have spoken about the subject matter which forms the basis of this Complaint or who have observed such activity. 5. Provide a complete list of the names of all females with whom you interacted sexually, who were at the time under 18 years of age. This is meant to include interactions at any time or any place. 6. Provide a complete list of the names of all known or suspected minors with whom you had sexual activities from 2002 to date. EFTA00729673 7. Describe with as much specificity as possible where you resided from August 2002 through the present (this interrogatory is meant to include time spent at each of your houses since August 2002). 8. List of all employees, servants, cleaning staff, personal staff or assistants employed by you or your companies who worked out of or visited your residence in West Palm Beach between August 2002 and the present, including their dates of employment, their job duties and title, and their last known address and telephone numbers. 9. State with as much specificity as possible when you met the Plaintiff, and include in your answer the following: (a) the circumstances and location of how and where you met, (b) describe the nature of your relationship; (c) describe how many occasions she was with you at your residence located at 358 El Brillo Way in West Palm Beach, Florida. EFTA00729674 . EFTA00729675 10. Was there ever an employment or business relationship between you and the Plaintiff, and if so specify the duration of this relationship and how this relationship ended, including the nature of the remuneration to Plaintiff and what evidence or documentation exists of that relationship. II. Describe in your own words the method you used to procure females to provide you with massages. Include in your response the specific role loshmitecir, includi Silo - hi lain Maxwell, your housekeepers, Jean Luc Brunel, or any others. 12. Did you ever engage in sexual activity of any kind whatsoever with the Plaintiff, and include in your answer what type of sexual activity took place, where it took place, and the dates or general timeframe when this activity occurred. 1 EFTA00729676 13. Was it your intent to harm or injure the Plaintiff when you were interacting with her? 14. Describe any words or actions that you made to assure the Plaintiff that sexual activity with you was proper or appropriate? 15. Describe what age you thought the Plaintiff was when you first had sexual activity with her, including your reasons for that belief. 16. State the facts upon which you rely for each affirmative defense in your answer. EFTA00729677 17. Do you have any remorse for your sexual interaction with then minor Plaintiff 18. Do you have any remorse for interacting sexually with other minor females? 19. Do you intend to interact sexually with minors in the future? 20. Do you derive any income from trafficking underage minor females for sex? Please explain in detail how much money you have made from sex trafficking since 1998. EFTA00729678 21. On how many occasions have you committed the following acts with underage minor females: A) felt her breasts B) inserted your fingers into her vagina C) engaged in full sexual intercourse D) rubbed her vagina or buttock over her clothes E) masturbated in her presence F) had her pinch your nipples while you mastubated 22. Provide the names, addresses and telephone numbers of all the people that know of you interacting sexually with underage minors. EFTA00729679 I have read the foregoing Answers to Interrogatories and do swear that they are true and correct. Jeffrey Epstein, Defendant STATE OF FLORIDA : ss. COUNTY OF The foregoing instrument was acknowledged before me this day of , 2010, by JEFFREY EPSTEIN, who is personally known to me or who has produced as identification. My Commission Expires: Signature of Acknowledger Typed/Printed Name of Acknowledger Title or Rank Serial Number, if any 4 EFTA00729680 Intentionally Left Blank EFTA00729681 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 9:10-cv-81111 -DIMITROULEAS/Snow Plaintiff, vs. JEFFREY EPSTEIN and Defendants. NOTICE OF VIDEO DEPOSITION OF JEFFREY EPSTEIN PLEASE TAKE NOTICE that the attorney for the plaintiff in the above-styled cause will take the video deposition of Jeffrey Epstein on Wednesday, November 10, 2010 at 10:00 a.m. for the purposes of discovery at the following location: US LEGAL SUPPORT 444 West Railroad Avenue, Suite 300 %Vest Palm Beach, FL 33401 Said deposition will be taken before US Legal Support, a Notary Public or any officer authorized to administer oaths by the laws of the State of Florida, and a person who is neither a relative, nor employee, nor attorney, nor counsel of any of the parties and who is neither a relative nor employee of such attorney or counsel, and who is not financially interested in the action. Said deposition will be taken pursuant to Florida Rules of Civil Procedure in such cases provided. Said oral examination will continue from hour to hour and from day to day until completed. EFTA00729682 CERTICATE OF SERVICE I HEREBY CERTIFY that the original of the above and a copy of the foregoing has been Served on Defendant, Jeffrey Epstein, with the Summons and Complaint. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954) 524-2820 524-2822 By: f MRRADLEY,ktDWARDS No.: 542075 'cc: US Legal Support via email EFTA00729683 Intentionally Left Blank EFTA00729684 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: CASE NO.: 9: 10-cv-81 1 11 -DIMITROULEAS/Snow Plaintiff, vs. JEFFREY EPSTEIN and Defendants. NOTICE OF VIDEO DEPOSITION OF PLEASE TAKE NOTICE that the attorney for the plaintiff in the above-styled cause will take the video deposition of on Thursday, November 18, 2010 at 10:00 a.m. for the purposes of discovery at the following location: US LEGAL SUPPORT 444 West Railroad Avenue, Suite 300 West Palm Beach, FL 33401 Said deposition will be taken before US Legal Support, a Notary Public or any officer authorized to administer oaths by the laws of the State of Florida, and a person who is neither a relative, nor employee, nor attorney, nor counsel of any of the parties and who is neither a relative nor employee of such attorney or counsel, and who is not financially interested in the action. Said deposition will be taken pursuant to Florida Rules of Civil Procedure in such cases provided. Said oral examination will continue from hour to hour and from day to day until completed. EFTA00729685 CERTICATE OF SERVICE I HEREBY CERTIFY that the on of the above and a copy of the foregoing has been Served on Defendant, MI= with the Summons and Complaint. Farmer, .Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954) 524-2820 954 524-2822 fax By: f2 cc: US Legal Support via email ARDS .:542075 EFTA00729686