Case 9:09-mj-08308-LRJ Document 3 Entered on FLSD Dockttsj2/09/2009 P e 1 of 7

Case 9:09-mj-08308-LRJ Document 3 Entered on FLSD Dockttsj2/09/2009 P e 1 of 7 AO 91111cv. 5/85) Criminal Complaint Alt VILLAPAAA FILID by United States District Court SOUTHERN DISTRICT OF FLORIDA UNITED STATES OF AMERICA vs. ALFREDO RODRIGUEZ, Defendant. CRIMINAL CO DEC -1 211U9 STCViN IA /AMUCK a ER% U 5.01SL ct si) or ri.A. • wee. LAINT CASE NUMBER: 09-8308-LRJ I, the undersigned complainant, being duly sworn, state the following is true and correct to the best of my knowledge and belief. From at least as early as January 18, 2007, through on or about November 3, 2009, in Palm Beach County, in the Southern District of Florida, and elsewiere, the defendant, ALFREDO RODRIGUEZ, did corruptly conceal a record, document, or other object, with the intent to impair the object's availability for use in an official proceeding and otherwise corruptly obstructed or impeded an official proceeding, in violation of Title 18 , United States Code, Section 1512M . I further state that I am a Special Agent with the Federal Bureau of Investigation , and that this Complaint is based on the following facts: Please see attached Affidavit Continued on the attached and made a part hereof. ChnSfina J. Pryor, Special Federal Bureau of Investiga Sworn to before me, and subscribed in my presence, upon my finding of probable cause. December 2009 at Date L1NNEA R. JOHNSON D TES IST' TE West Palm Beach. Florida City and State Signature of Judie.ia EP-002 EFTA01117107 Case 9:09-mj-08308-LRJ V:ument 3 Entered on FLSD Dockti 2/09/2009 Page 2 of 7 AFFIDAVIT I, Christina J. Pryor, being duly sworn, do state and attest as follows: 1. I am a Special Agent with the Federal Bureau of Investigation (FBI) and have been so employed for three (3) months. I am currently assigned to the Safe Streets Task Force, Miami Field Division, FBI Squad PB-2. Prior to joining the Miami Field Division, I attended the FBI Academy in Quantico, Virginia, for five (5) months where I received training in federal criminal laws and investigation techniques, including the laws related to obstruction of justice. 2. This affidavit is based upon my-own personal knowledge of the facts and circumstances surrounding the investigation, and information provided to me by other law enforcement officers. This affidavit does not purport to contain all the information known to me about this case but addresses only that information necessary to support a finding of probable cause for the issuance of a criminal complaint charging Alfredo Rodriguez with obstruction of official proceedings, in violation of Title 18, United States Code, Section 1512(c). 3. On October 27, 2009, agents of the FBI met with and interviewed a cooperating witness ("CW"). The CW reported that, while conducting discovery in a pending civil case before the United States District Court for the Southern District of Florida, he came into contact with Alfredo Rodriguez ("Rodriguez"), who was a subpoenaed witness in the civil case. 4. Rodriguez had been interviewed by FBI agents on January 18, 2007, in connection with a federal criminal investigation into the sexual exploitation of minors. Prior EP-003 EFTA01117108 Case 9:09-mj-08308-LRJ Zument 3 Entered on FLSD Docket j2/09/2009 Page 3 of 7 to being interviewed by FBI, Rodriguez had also been contacted and interviewed by local police detectives, and had been asked to produce documents related to the criminal investigation. The civil litigation involving the CW related to civil damages claims made by victims of the criminal activity that formed the basis of the state and federal criminal investigations. 5. The CW explained to agents that Rodriguez had been deposed under oath on two occasions. The first deposition occurred on July 27, 2009, and the second deposition was conducted on August 9, 2009. In connection with those depositions, Rodriguez was served with a subpoena duccs tecum that called for the production of several types of documentary evidence. The CW was present for both depositions and Rodriguez testified that he had no documents responsive to the subpoena duces tecum. 6. In August 2009, after the conclusion of the second deposition, the CW received a phone call from Rodriguez. Rodriguez informed the CW that he had additional information that he had not previously disclosed to any law enforcement agency or any of the civil attorneys. Rodriguez described the information as, the Holy Grail or Golden Nugget and explained that he had compiled lists of additional victims in the case and their contact information. Rodriguez explained that the information contained hundreds of additional victims and their phone numbers from diverse geographic locations, including New York, New Mexico, and Paris, France. 7. Rodriguez asked the CW to pay him $50,000.00 and, in return, Rodriguez would turn over the documents relating to the victims. In his initial and subsequent EP-004 EFTA01117109 Case 9:09-mj-08308-LRJ Zument 3 Entered on FLSD Dockti 2/09/2009 Page 4 of 7 communications with Rodriguez, the CW explained to Rodriguez that he was under subpoena to turn over such information and that it would be illegal for Rodriguez to demand money for turning over the information. Rodriguez persisted that he would only turn over the information in his possession in exchange for $50,000.00. 8. On October 28, 2009, in a consensually-monitored phone call, the CW telephoned Rodriguez. Rodriguez again indicated that he would not turn over the information relating to the additional victims without monetary compensation. Rodriguez was told that an associate of the CW would be in touch with him regarding the information and exchange. The associate that the CW referred to was, in fact, an undercover employee (UCE) of the FBI. 9. On October 29, 2009, the FBI UCE contacted Rodriguez via telephone. Rodriguez again explained that he would only turn over the information in exchange for monetary compensation. The UCE advised Rodriguez that it would take several days to acquire the funds and that once the funds were obtained, he/she would contact Rodriguez. During the conversation, Rodriguez admitted that he knew that the information was relevant to the FBI's criminal investigation and was called for by the investigation. Rodriguez explained that he had not turned over the information to the FBI because: (1) it was his "property" and he should be compensated for it; and (2) he was afraid that the target of the investigation would make him "disappear" or otherwise harm him, and the information was his "insurance policy." 10. On November 2, 2009, the UCE made contact with Rodriguez via telephone. EP-005 EFTA01117110 Case 9:09-mj-08308-LRJ Zument 3 Entered on FLSD Docket 12/09/2009 Page 5 of 7 In that conversation, Rodriguez and the UCE continued the discussion regarding the purchase of the documents and scheduled a meeting for the following day. 11. On November 3, 2009, Rodriguez met with the UCE at a predetermined location. During the meeting, Rodriguez produced a small bound book and several sheets of legal pad paper containing hand written notes. Rodriguez explained that he had taken the bound book from his former employer's residence while employed there in 2004 to 2005 and that the book had been created by persons working for his former employer. Rodriguez discussed in detail the information contained within the book, and identified important information to the UCE. In addition, Rodriguez admitted he had previously lied to FBI. Rodriguez asked the UCE about the $50,000.00, took possession of the money, and began counting it. 12. Rodriguez was then detained for Obstruction of Official Proceedings, Title 18, U.S. Code, Section 1512(c), and questioned. After Miranda warnings were administered by agents, Rodriguez waived his rights and signed a written waiver of those rights. Rodriguez admitted that he had the documents and book in his possession and had never turned them over to local law enforcement or the FBI. In addition, Rodriguez advised he had witnessed nude girls whom he believed were underage at the pool area of his former employer's home, knew that his former employer was engaging in sexual contact with underage girls, and had viewed pornographic images of underage girls on computers in his employer's home. Rodriguez was then released from custody for further investigation. 13. The items that Rodriguez had attempted to sell to the UC for $50,000.00 EP-006 EFTA01117111 Case 9:09-mj-08308-LRJ Document 3 Entered on FLSD Docket ]2/09/2009 Page 6 of 7 %so were reviewed by an agent familiar with the underlying criminal investigation. As Rodriguez had described, the items contained information material to the underlying investigation that would have been extremely useful in investigating and prosecuting the case, including the names and contact information of material witnesses and additional victims. Had those items been produced in response to the inquiries of the state law enforcement officers or the FBI Special Agents, their contents would have been presented to the federal grand jury. Based upon the foregoing, your affiant believes that probable cause exists to believe that, from at least as early as January 18, 2007 through on or about November 3, 2009, in Palm Beach County, in the Southern District of Florida, and elsewhere, Al€redo Rodriguez did corruptly conceal a record, document, or other object, with the intent to impair the object's availability for use in an official proceeding and otherwise corruptly obstructed or impeded an official proceeding, in violation of Title 18, United States Code, Section 1512(c). FURTHER YOUR AFFIANT SAYETH NAUGHT. A J. PRYO12, ' CI ENT FEDERAL BUREAU OF VES CATION Sworn to and subscribed before me this ( day of December, 2009. R. JOHNSO UNITED STAT GISTRATE JUDGE 5 EP-007 EFTA01117112 Case 9:09-mj-08308-LRJ Iiio:ument 3 Entered on FLSD Docket i2/09/2009 Page 7 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 09-8308-LRJ UNITED STATES OF AMERICA vs. ALFREDO RODRIGUEZ, Defendant. CRIMINAL COVER SHEET 1. Did this matter originate from a matter pending in the Northern Region of the United States Attorney's Office prior to October 14, 2003? Yes X No 2. Did this matter originate from a matter pending in the Central Region of the United States Attorney's Office prior to September 1, 2007? Yes X No Respectfully submitted, JEFFREY H. SLOMAN ACTING UNITED STATES ATTORNEY By: A. MARIE VILLAFA Assistant United States Attorney Florida Bar No. 0018255 500 East 13roward Boulevard, 7th Floor Ft Lauderdale, FL 33394 Telephone: 954-660-5946 Facsimile: 954-356-7230 ann.marie.c.villafana©usdoj.gov EP-008 EFTA01117113 0 Rom Tea arageaaseas SuSjacti Strategy Doter Waktesthrt July Z9, 2001 1: 11:13 PM dank our best bet Is to go after those dose to Er/Stein. 08420 EP-001 EFTA01117114 La, Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docmd 07/27/2009 Page 1 of 82 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO: 09-CV-81092-Cohn-Seltzer Plaintiff I of vs. JEFFREY EPSTEIN, Defendant FILED by VT D.C. BECTRCNIC July 24, 2009 STEETN M. LARIMORE CLERIC U.S. DIST. CT. S.O. or FLA. • MIAMI COMPLAINT AND DEMAND FOR JURY TRIAL Plaintiff, hereby sues the Defendant, Jeffrey Epstein, and states as follows: 1. At all times material to this cause of action, M.., was a resident of Palm Beach County, Florida. 2. This Complaint is brought under a fictitious name to protect the identity of M., because this Complaint makes sensitive allegations of sexual assault and abuse of a then-minor. 3. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a mansion located at 358 El Brillo Way, Palm Beach, Palm Beach County, Florida. 4. At all times materials to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. 5. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida. This is substantiated by the residence that he maintains at 358 El Brillo Way, West Palm Beach, Florida where he spends the majority of his time, and intentions to remain at that address permanently are further evidenced by his statements to the Court during Page 1 of 234 EP-081 EFTA01117115 Case 9:09-cv-81092-JIC .iocument 1 Entered on FLSD Dock..., 07/27/2009 Page 2 of 82 his State Plea colloquy on June 30, 2008, case number 06CF009454AMB, taken before the Honorable Judge Dale Pudic, wherein he indicated that after his release from the Palm Beach County Jail he intends to reside permanently at his home at 358 El Brillo Way, West Palm Beach, Florida, and he plans to work in West Palm Beach, Florida as well. 6. This Court has jurisdiction of this action and the claims set forth herein pursuant to 18 U.S.C. § 2255.11. seeks damages in excess of 1 million dollars. 7. This Court has venue of this action pursuant to 28 U.S.C. § 1391(b), as a substantial part of the events giving rise to the claims occurred in this District. STATEMENT OF FACTS 8. Upon information and belief, the Defendant, Jeffrey Epstein, has demonstrated a sexual preference and obsession for minor girls. 9. The Defendant, Jeffrey Epstein, developed a plan, scheme, and criminal enterprise that included an elaborate system wherein the then-minor. was brought to the Defendant, Jeffrey Epstein's residence by the Defendant's employees, recruiters, and assistants. When the assistants and employees left the then-minor ■. (and, on some occasions, other minor girls) alone in a room at the Defendant's mansion, the Defendant, Jeffrey Epstein, himself would appear, remove his clothing, and direct the then-minor ■. to remove her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including, but not limited to, masturbation, touching of the then minor Plaintiffs sexual organs, coercing or forcing the then-minor. to perform oral sex on him, using vibrators or sexual toys on the then-minor .., coercing the Page 2 of 234 2 et 234 EP-082 EFTA01117116 Case 9:09-cv-81092-JIC document 1 Entered on FLSD Doctmat 07/27/2009 Page 3 of 82 then-minors into sexual acts with himself or others, and digitally penetrating the then-minor M.. He would then pay M. for engaging in this sexual activity. 10. M. was first brought to the Defendant, Jeffrey Epstein's mansion in 2002 when she was a fourteen-year old in middle school. 11. The then-minor M. was a vulnerable child without adequate parental support at all times material to this Complaint. The Defendant, Jeffrey Epstein, a wealthy financier with a lavish home, significant wealth, and a network of assistants and employees, used his resources and his influence over a vulnerable minor child to engage in a systematic pattern of sexually exploitive behavior. 12. Beginning in approximately August 2002 and continuing until approximately the end of October 2005, the Defendant, Jeffrey Epstein, repeatedly coerced, induced and/or enticed the impressionable, vulnerable, and economically deprived then-minor ■. to commit various acts of sexual misconduct and sexually abused ■. These acts included, but were not limited to, fondling and inappropriate and illegal sexual touching of the then-minor M., forcing the then-minor M. into oral sex, sexual misconduct and masturbation of the Defendant, Jeffrey Epstein, in the presence of the then-minor ■., handling and fondling of the then-minor M.'s sexual organs for the purpose of masturbation, and encouraging the then-minor M. to become involved in prostitution; Defendant, Jeffrey Epstein, committed, and conspired with others to commit, numerous criminal sexual offenses against the then minor Plaintiff including, but not limited to, sexual battery, solicitation of prostitution, coercing a minor into a life of prostitution, and lewd and lascivious assaults upon the person of the then-minor ■. Defendant Jeffrey Page 3 of 234 30234 EP-083 EFTA01117117 Case 9:09-cv-81092-JIC :Jocument 1 Entered on FLSD Docker 07/27/2009 Page 4 of 82 Epstein knowingly transported III and other minors in interstate commerce with the intent that the engage in prostitution and in other sexual activity for which he and others could be charged with criminal offenses. Defendant Jeffrey Epstein also knowingly used means of interstate commerce to knowing persuade and induce minors, including 5, to engage In prostitution and other sexual activity for which he and others could be charged with criminal offenses. 13. In addition to the direct sexual abuse and molestation of the then-minor II, Defendant, Jeffrey Epstein, instructed, coerced and otherwise induced the then- minor 5 to bring him numerous other minor girls (some as young at 12 years old) for the purposes of further satisfying his deviant sexual attraction to minors and for purposes of prostitution. On information and belief, Epstein sexually abused hundreds of minor girls through his recruiting system. Defendant, Jeffrey Epstein, used his money, wealth and power to unduly and improperly manipulate and influence the then- minor 5 to bring him these other minor girls for purposes of prostitution and in exchange for money. This influence led the then-minor 5 away from the life of a middle school aged child and into a delinquent lifestyle. This conduct also involved transporting ■. and other minors in interstate commerce and using means of interstate commerce, to persuade and induce 5 and others to engage in prostitution and in other sexual activity for which he and others could be charged with criminal offenses. 14. The Defendant, Jeffrey Epstein, at all times material to this Complaint, knew and should have known of minority. The Defendant, Jeffrey Epstein, at all times Page 4 of 234 4e/234 EP-084 EFTA01117118 Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Doch, 07/27/2009 Page 5 of 82 material to this Complaint, knew and should have know of the minority of the other girls he was sexually abusing 15. The acts referenced above in paragraphs 10 through 14, committed by Defendant, Jeffrey Epstein, against the then-minor Plaintiff IN were committed in violation of numerous State criminal statutes condemning the sexual exploitation of minor children, prostitution and prostitution-related offenses, sexual performances by a child, lewd and lascivious assaults, sexual battery, contributing to the delinquency of a minor and other crimes, specifically including, but not limited to, those criminal offenses outlined in Chapters 794, 800, 827 and 847 of the Florida Statutes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §796.09, §39.01, and §827.04. 16. The acts reference above in paragraphs 10 through 15, committed by Defendant, Jeffrey Epstein, against the then-Minor Plaintiff were committed in violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(b), and § 2423(e). 17. The crimes committed against ■. by Epstein were committed, on average, four times per month from the beginning of August 2002 through the end of October 2005, the exact dates being unknown to ■.. Page 5 of 234 eat 234 EP-085 EFTA01117119 Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 6 of 82 18. In June 2008, after investigations by the Palm Beach Police Department, the Palm Beach State Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's Office for the Southern District of Florida, Defendant, Jeffrey Epstein, entered pleas of 'guilty' to various Florida state crimes Involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution in the Fifteenth Judicial Circuit in the Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability unto Plaintiff, Jane Doe No. 101. In this action, Plaintiff hereby exclusively seeks civil remedies pursuant to 18 U.S.C. § 2255. 19. As a condition of his plea, and in exchange for the Federal Government not prosecuting the Defendant, Jeffrey Epstein, for numerous federal offenses, Defendant, Jeffrey Epstein, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been Page 6 of 234 Bef234 EP-086 EFTA01117120 Case 9:09-cv-81092-JIC _document 1 Entered on FLSD Dock:. 07/27/2009 Page 7 of 82 had Mr. Epstein been convicted at trial. No more; no less? Plaintiff III is covered by this paragraph and entitled to rights under this paragraph. 20. The defendant, Jeffrey Epstein, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged in this Complaint, and must effectively admit liability to the Plaintiff, im, including admitting liability for all counts enumerated in this Complaint. Plaintiff i is entitled to damages, as further alleged below, including damages as provided in 18 U.S.C. § 2255, as amended by Pub. L. 109-248, Title VII, § 707(b) and (c), 120 Stat. 650. COUNT 1 Cause of Action Pursuant to 18 U.S.C. 6 2255 August 2002 — Incident 1 21. Plaintiff, `adopts and realleges paragraphs 1 through 20 above. 22. On or about August 2002, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated In 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). II is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to Page 7 of 234 75234 EP-087 EFTA01117121 Case 9:09-cv-81092-JIC Jocument 1 Entered on FLSD Doch..:( 07/27/2009 Page 8 of 82 this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 23. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her,El. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff.l. incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff,.., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, E., will continue to suffer these losses In the future. 24. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems Just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 2 Cause of Action Pursuant to 18 U.S.C. 4 2256 August 2002 — Incident Z 25. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. Page 8 of 234 Solis EP-088 EFTA01117122 Case 9:09-cv-81092-JIC ..socument 1 Entered on FLSD Dock, 07/27/2009 Page 9 of 82 26. On or about August 2002, the exact date being unknown tot Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). S. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Govemment. 27. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against here. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff S. Incurred medical and psychological expenses and the plaintiff, S., will In the future suffer medical and psychological expenses. The plaintiff, S., 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 Page 9 of 234 OM 214 EP-089 EFTA01117123 Case 9:09-cv-81092-JIC _ocument 1 Entered on FLSD Dock<— 07/27/2009 Page 10 of 82 injuries are permanent in nature and the plaintiff, E., will continue to suffer these losses in the future. 28. Wherefore, the plaintiff. E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 3 Cause of Action Pursuant to 18 U.S.C. & 2256 August 2002 — Incident 3 29. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 30. On or about August 2002, the exact date being unknown to.., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. Page 10 of 234 10 01214 EP-090 EFTA01117124 Case 9:09-cv-81092-JIC L.ocument 1 Entered on FLSD Docket 07/27/2009 Page 11 of 82 Itee 234 31. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■. has In the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein. controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. Incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, L.M., will continue to suffer these losses in the future. 32. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 4 Cause of Action Pursuant to 18 U.S.C. 4 2255 August 2002 — Incident 4 33. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 34. On or about August 2002, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a Page 11 of 234 EP-091 EFTA01117125 Case 9:09-cv-81092-JIC _document 1 Entered on FLSD DOChut 07/27/2009 Page 12 of 82 violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 35. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, • has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein. controlling, manipulating and coercing her Into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. Page 12 of 234 $201234 EP-092 EFTA01117126 Case 9:09-cv-81092-JIC _ocument 1 Entered on FLSD Dock-, 07/27/2009 Page 13 of 82 36. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 5 Cause of Action Pursuant to 18 U.S.C. 4 2255 September 2002 — Incident 1 37. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 38. On or about September 2002, the exact date being unknown to In, Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 39. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past Page 13 of 234 ti of 234 EP-093 EFTA01117127 Case 9:09-cv-81092-JIC _ ocument 1 Entered on FLSD Dock:. 07/27/2009 Page 14 of 82 suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. Incurred medical and psychological expenses and the plaintiff,S., will in the future suffer medical and psychological expenses. The plaintiff,III., 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. 40. Wherefore, .the plaintiff,., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 6 Cause of Action Pursuant to 18 U.S.C. § 2255 September 2002 — Incident 2 41. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 42. On or about September 2002, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to Page 14 of 234 14 of IN EP-094 EFTA01117128 Case 9:09-cv-81092-JIC acument 1 Entered on FLSD Dock:: 07/27/2009 Page 15 of 82 engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). E. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 43. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, M., will continue to suffer these losses in the future. 44. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided Page 15 of 234 150234 EP-095 EFTA01117129 Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Dock... 07/27/2009 Page 16 of 82 by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 7 Cause of Action Pursuant to 18 U.S.C. 4 2266 September 2002 — Incident 3 45. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 46. On or about September 2002, the exact date being unknown to E., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 47. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of Page 16 of 234 EP-096 44 et 214 EFTA01117130 Case 9:09-cv-81092-JIC _mcument 1 Entered on FLSD 07/27/2009 Page 17 of 82 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 conventional way of life for a minor. The then-minor plaintiff M. incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, M., will continue to suffer these losses in the future. 48. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 8 Cause of Action Pursuant to 18 U.S.C. § 2255 September 2002 — Incident 4 49. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 50. On or about September 2002, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in Mica sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, Page 17 of 234 EP-097 17 «2H EFTA01117131 Case 9:09-cv-81092-JIC Document 1 Entered on FLSD DOCK... 07/27/2009 Page 18 of 82 child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). S. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 51. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, S. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, S., will in the future suffer medical and psychological expenses. The plaintiff, S., 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. 52. Wherefore, the plaintiff, S., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. Page 18 of 234 EP-098 Uot 234 EFTA01117132 Case 9:09-cv-81092-JIC ...ocument 1 Entered on FLSD Dock-. 07/27/2009 Page 19 of 82 COUNT 9 Cause of Action Pursuant to 18 U.S.C. 4 2255 October 2002 — Incident 1 53. Plaintiff, E. adopts and realleges paragraphs 1 through 20 above. 54. On or about October 2002, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage In illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically Including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 55. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse Page 19 of 234 1101 214 EP-099 EFTA01117133 Case 9:09-cv-81092-JIC .ocument 1 Entered on FLSD Dock..., 07/27/2009 Page 20 of 82 and conventional way of life for a minor. The then-minor plaintiff S. incurred medical and psychological expenses and the plaintiff, S., will In the future suffer medical and psychological expenses. The plaintiff, S., 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, S., will continue to suffer these losses in the future. 56. Wherefore, the plaintiff, S., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 10 Cause of Action Pursuant to 18 U.S.C. 4 2255 October 2002 — Incident 2 57. Plaintiff, S. adopts and realleges paragraphs 1 through 20 above. 58. On or about October 2002, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). Page 20 of 234 20 of 214 EP-I00 EFTA01117134 Case 9:09-cv-81092-JIC .:ocument 1 Entered on FLSD Dock:.. 07/27/2009 Page 21 of 82 is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 59. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, SI. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiffs. incurred medical and psychological expenses and the plaintiff, S., will in the future suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future. 60. Wherefore, the plaintiff, S., demands judgments against the defendant, Jeffrey Epstein. for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 11 Cause of Action Pursuant to 18 U.S.C. 6 2266 Page 21 of 234 21 of 234 EP-I01 EFTA01117135 Case 9:09-cv-81092-JIC —ocument 1 Entered on FLSD Docker, 07/27/2009 Page 22 of 82 October 2002 — Incident 3 61. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 62. On or about October 2002, the exact date being unknown to S., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in Illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). S. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 63. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255. being committed against her. S. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of serf-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 conventional way of life for a minor. The then-minor plaintiff S. incurred medical and psychological expenses and the plaintiff, II., will in the future suffer medical and Page 22 of 234 62234 EP-102 EFTA01117136 Case 9:09-cv-81092-JIC Jcument 1 Entered on FLSD Dock,. J7/27/2009 Page 23 of 82 psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. 64. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 12 Cause of Action Pursuant to 18 U.S.C. 4 2255 October 2002 — Incident 4 65. Plaintiff, E. adopts and realleges paragraphs 1 through 20 above. 66. On or about October 2002, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). E. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein. pursuant to Page 23 of 234 23 c4 214 EP-103 EFTA01117137 Case 9:09-cv-81092-JIC acumen, 1 Entered on FLSD Dock;.. ,17127/2009 Page 24 of 82 this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 67. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, fl has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein. controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, II., will continue to suffer these losses in the future. 68. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein. for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 13 Cause of Action Pursuant to 18 U.S.C. 6 2255 November 2002 — Incident 1 69. Plaintiff, adopts and realleges paragraphs 1 through 20 above. Page 24 of 234 24 of 234 EP-104 EFTA01117138 Case 9:09-cv-81092-JIC c..cument 1 Entered on FLSD Dock€, //27/2009 Page 25 of 82 70. On or about November 2002, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct. child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 71. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish. humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff M. incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These Page 25 of 234 25 of 234 EP-105 EFTA01117139 Case 9:09-cv-81092-JIC ocument 1 Entered on FLSD Dock. 07/27/2009 Page 26 of 82 injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. 72. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 14 Cause of Action Pursuant to 18 U.S.C, 4 2255 November 2002 — incident 2 73. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 74. On or about November 2002, the exact date being unknown to ■., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. Page 26 of 234 EP-106 240234 EFTA01117140 Case 9:09-cv-81092-JIC ..ocument 1 Entered on FLSD Dockt., 07/27/2009 Page 27 of 82 27 of 234 75. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, 1. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■ incurred medical and psychological expenses and the plaintiff, e, will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. 76. Wherefore, the plaintiff, ■, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury COUNT 15 Cause of Action Pursuant to 18 U.S.C. 4 2255 November 2002 — Incident 3 77. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 78. On or about November 2002, the exact date being unknown to ■., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a Page 27 of 234 EP-107 EFTA01117141 Case 9:09-cv-81092-JIC ..:Jcument 1 Entered on FLSD Dock. 07/27/2009 Page 28 of 82 violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). El. Is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 79. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff .. incurred medical and psychological expenses and the plaintiff, .., will in the future suffer medical and psychological expenses. The plaintiff, .., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, .., will continue to suffer these losses in the future. Page 28 of 234 EP-108 21 of 234 EFTA01117142 Case 9:09-cv-81092-JIC ,..,current 1 Entered on FLSD Docktl o7/27/2009 Page 29 of 82 80. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 16 Cause of Action Pursuant to 18 U.S.C. 6 2255 November 2002 - Incident 4 81. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 82. On or about November 2002, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). E. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 83. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, M. has in the past Page 29 of 234 2f. d234 EP-109 EFTA01117143 Case 9:09-cv-81092-JIC L.,-...cument 1 Entered on FLSD Docket 4/27/2009 Page 30 of 82 suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff E. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, E., 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, E., will continue to suffer these losses in the future. 84. Wherefore, the plaintiff, E , demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 17 Cause of Action Pursuant to 18 U.S.C. 4 2255 December 2002 — Incident 1 85. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 86. On or about December 2002, the exact date being unknown to ■., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to Page 30 of 234 EP-110 36 of 234 EFTA01117144 Case 9:09-cv-81092-JIC ,ocument 1 Entered on FLSD Docket 07/27/2009 Page 31 of 82 engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 87. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, a. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff a incurred medical and psychological expenses and the plaintiff, L M., will in the future suffer medical and psychological expenses. The plaintiff, a., 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, II., will continue to suffer these losses in the future. 88. Wherefore, the plaintiff, a., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided Page 31 of 234 EP-111 31 at U. EFTA01117145 Case 9:09-cv-81092-JIC cocument 1 Entered on FLSD Dockt.. J7/27/2009 Page 32 of 82 by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 18 Cause of Action Pursuant to 18 U.S.C. 4 2255 December 2002 — Incident 2 89. Plaintiff,.. adopts and realleges paragraphs 1 through 20 above. 90. On or about December 2002, the exact date being unknown to.., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). 5. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 91. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of Page 32 of 234 320234 EP-112 EFTA01117146 Case 9:09-cv-81092-JIC ,,cement 1 Entered on FLSD Dockbe J7/27/2009 Page 33 of 82 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 conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, M., will continue to suffer these losses in the future. 92. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 19 Cause of Action Pursuant to 18 U.S.C. 6 2255 December 2002 — Incident 3 93. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above 94. On or about December 2002, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, Page 33 of 234 fl ag 234 EP-113 EFTA01117147 Case 9:09-cv-81092-JIC L.....cument 1 Entered on FLSD Docks. ..7/2712009 Page 34 of 82 child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 95. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, M. has in the past suffered, and will in the future suffer, physical Injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff M. incurred medical and psychological expenses and the plaintiff, E., will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn Income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, M., will continue to suffer these losses in the future. 96. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. Page 34 of 234 EP-114 34 it 234 EFTA01117148 Case 9:09-cv-81092-JIC uocument 1 Entered on FLSD Dockei 07/27/2009 Page 35 of 82 COUNT 20 Cause of Action Pursuant to 18 U.S.C. & 2255 pecember 2002 — Incident 4 97. Plaintiff, al adopts and realleges paragraphs 1 through 20 above. 98. On or about December 2002, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with Intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). a Is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 99. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, II has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse Page 35 of 234 EP-115 315e4 234 EFTA01117149 Case 9:09-cv-81092-JIC tucument 1 Entered on FLSD Docket 07/27/2009 Page 36 of 82 and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future. 100. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 21 Cause of Action Pursuant to 18 U.S.C. 4 2255 January 2003 — Incident 1 101. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 102. On or about January 2003, the exact date being unknown to ■., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with Intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). Page 36 of 234 EP-116 3$& EFTA01117150 Case 9:09-cv-81092-JIC i..ocument 1 Entered on FLSD Docket o7/27/2009 Page 37 of 82 M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 103. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical Injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff E. incurred medical and psychological expenses and the plaintiff, E., will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. 104. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorneys fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 22 Cause of Action Pursuant to 18 U.S.C. § 2266 Page 37 of 234 EP-117 37 0234 EFTA01117151 Case 9:09-cv-81092-JIC L,..icument 1 Entered on FLSD Dockb. ,i7/2712009 Page 38 of 82 January 2003 — Incident 2 105. Plaintiff,t. adopts and realleges paragraphs 1 through 20 above. 106. On or about January 2003, the exact date being unknown to., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 107. As a direct and proximate result of the offenses enumerated in Title 18, United States Code. Section 2255, being committed against her, ■. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff M. incurred medical and psychological expenses and the plaintiff, N., will in the future suffer medical and Page 38 of 234 EP-118 EFTA01117152 Case 9:09-cv-81092-JIC Uucument 1 Entered on FLSD Docket a7/27/2009 Page 39 of 82 psychological expenses. The plaintiff, L.M., has suffered a loss of income, a loss of the capacity to earn income In the future, and a loss of the capacity to enjoy life. These : ,j,;.ies are permanent in nature and the plaintiff, M., will continue to suffer these : )::ses in the future. 108. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 23 Cause of Action Pursuant to 18 U.S.C. IS 2255 January 2003 — Incident 3 109. Plaintiff, E. adopts and realleges paragraphs 1 through 20 above. 110. On or about January 2003, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). E. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to Page 39 of 234 EP-119 310 1.14 EFTA01117153 Case 9:09-cv-81092-JIC Lucument 1 Entered on FLSD Docket u7/2712009 Page 40 of 82 this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 111. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2265, being committed against her,■l. has In the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her Into a perverse and conventional way of life for a minor. The then-minor plaintiff.. incurred medical and psychological expenses and the plaintiff,., will in the future suffer medical and psychological expenses. The plaintiff,.., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, It, will continue to suffer these losses in the future. 112. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all Issues triable as of right by a jury. COUNT 24 Cause of Action Pursuant to 18 U.S.C. § 2255 January 2003 — Incident 4 113. Plaintiff, II. adopts and realleges paragraphs 1 through 20 above. Page 40 of 234 EP-120 40 .31:24 EFTA01117154 Case 9:09-cv-81092-JIC LiJcument 1 Entered on FLSD Dockb, ,j712712009 Page 41 of 82 114. On or about January 2003, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b). § 2423(a), § 2423(b), and § 2423(e). E . is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 115. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, t has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation. embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff M. incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These Page 41 of 234 410234 EP-121 EFTA01117155 Case 9:09-cv-81092-JIC —Jcument 1 Entered on FLSD Dockt.: 07/27/2009 Page 42 of 82 injuries are permanent In nature and the plaintiff, E., will continue to suffer these losses in the future. 116. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 25 Cause of Action Pursuant to 18 U.S.C. e 2265 February 2003 — Incidentl 117. Plaintiff, E. adopts and realleges paragraphs 1 through 20 above. 118. On or about February 2003, the exact date being unknown to E., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. Page 42 of 234 420334 EP-122 EFTA01117156 Case 9:09-cv-81092-JIC Locument 1 Entered on FLSD Docks, J7/27/2009 Page 43 of 82 119. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff E. incurred medical and psychological expenses and the plaintiff, E., will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, M., will continue to suffer these losses in the future. 120. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by Jury on all issues triable as of right by a jury. COUNT 26 Cause of Action Pursuant to 18 U.S.C. § 2255 February 2003 — Incident 2 121. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 122. On or about February 2003, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a Page 43 of 234 EP-123 430234 EFTA01117157 Case 9:09-cv-81092-JIC uocument 1 Entered on FLSD Docke, 07/27/2009 Page 44 of 82 violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with Intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 123. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, • has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, 15, 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. Page 44 of 234 44 4n4 EP-124 EFTA01117158 Case 9:09-cv-81092-JlC 'document 1 Entered on FLSD Docker 07/27/2009 Page 45 of 82 124. Wnerefore, the plaintiff, M, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 27 Cause of Action Pursuant to 18 U.S.C. 2255 February 2003— Incident 3 125. Plaintiff, ■ adopts and realleges paragraphs 1 through 20 above. 126. On or about February 2003, the exact date being unknown to M, Defendant, Jeffrey Epstein, committed a federal sexual offense against her, Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b). § 2423(a), § 2423(b). and § 2423(e) ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 127. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■ has in the past Page 45 of 234 EP-125 4561214 EFTA01117159 Case 9:09-cv-81092-JIC document 1 Entered on FLSD Docket 07/27/2009 Page 46 of 82 suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff s incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, 5, 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, 5, will continue to suffer these losses in the future. 128. Wherefore, the plaintiff, 5, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 28 Cause of Action Pursuant to 18 U.S.C. 6 2255 February 2003 — Incident 4 129. Plaintiff, adopts and realteges paragraphs 1 through 20 above. 130. On or about February 2003. the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to Page 46 of 234 EP-126 41d U4 EFTA01117160 Case 9:09-cv-81092-JIC jocument 1 Entered on FLSD Docket 07/27/2009 Page 47 of 82 engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). fl. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 131. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her,Ill. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiffE. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income In the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, i., will continue to suffer these losses in the future. 132. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided Page 47 of 234 EP-127 47 of al EFTA01117161 Case 9:09-cv-81092-JIC 'document 1 Entered on FLSD Docket 07/27/2009 Page 48 of 82 by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 29 Cause of Action Pursuant to 18 U.S.C. 2255 March 2003 — Incident 1 133. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 134. On or about March 2003, the exact date being unknown to E., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 135. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of Page 48 of 234 EP-128 411 at 234 EFTA01117162 Case 9:09-cv-81092-JIC 'document 1 Entered on FLSD Docket 07/27/2009 Page 49 of 82 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 conventional way of life for a minor. The then-minor plaintiff E. incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, E., 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, E., will continue to suffer these losses in the future. 136. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 30 Cause of Action Pursuant to 18 U.S.C. 4 2255 March 2003 — Incident 2 137. Plaintiff, E. adopts and realleges paragraphs 1 through 20 above. 138. On or about March 2003, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, Page 49 of 234 EP-129 41M Z34 EFTA01117163 Case 9:09-cv-81092-JIC uocument 1 Entered on FLSD Docket 07/27/2009 Page 50 of 82 child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). 1.1. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 139. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her,.I. has in the past suffered, and will in the future suffer, physical Injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff.. incurred medical and psychological expenses and the plaintiff, .., will in the future suffer medical and psychological expenses. The plaintiff,.., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, .., will continue to suffer these losses in the future. 140. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. Page 50 of 234 EP-130 6440234 EFTA01117164 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 19 of 79 ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein. pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 279. As a direct and proximate result of the offenses enumerated in Tdle 18, United States Code, Section 2255, being committed against her, ■. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. Incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future. 280. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 66 Cause of Action Pursuant to 18 U.S.C. 6 2255 Page 101 of 234 EP-131 I01 el 234 EFTA01117165 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 20 of 79 December 2003 — Incident 2 281. Plaintiff, E. adopts and realleges paragraphs 1 through 20 above. 282. On or about December 2003, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with Intent to engage in Illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically Including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). E. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 283. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L M has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, Invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff E. incurred medical and psychological expenses and the plaintiff, E., will in the future suffer medical and Page 102 of 234 EP-132 *0201224 EFTA01117166 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 21 of 79 psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, E., will continue to suffer these losses in the future. 284. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 67 Cause of Action Pursuant to 18 U.S.C. 4 2256 December 2003 — Incident 3 285. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 286. On or about December 2003, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). E. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to Page 103 of 234 EP-133 103 of 234 EFTA01117167 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLS0 Docket 07/27/2009 Page 22 of 79 this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 287. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, III has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her Into a perverse and conventional way of life for a minor. The then-minor plaintiff U incurred medical and psychological expenses and the plaintiff, a, will In the future suffer medical and psychological expenses. The plaintiff, U, 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. 288. Wherefore, the plaintiff, It demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 68 Cause of Action Pursuant to 18 U.S,C. 4 2255 December 2003 — Incident 4 289. Plaintiff, U. adopts and realleges paragraphs 1 through 20 above. Page 104 of 234 EP-134 $0101N EFTA01117168 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 23 of 79 290. On or about December 2003, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated In 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 291. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff, E., 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 Page 105 of 234 EP-135 IN 6,234 EFTA01117169 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 24 of 79 injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. 292. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 69 Cause of Action Pursuant to 18 U.S.C. 4 2255 January 2004— Incident 1 293. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 294. On or about January 2004, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. Page 106 of 234 EP-136 106 02)4 EFTA01117170 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 25 of 79 295. As a direct and proximate result of the offenses enumerated in Title 18. United States Code, Section 2255, being committed against her, I. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff El incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, i, 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, II, will continue to suffer these losses in the future. 296. Wherefore, the plaintiff, a, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 70 Cause of Action Pursuant to 18 U.S.C. § 2255 January 2004 — Incident 2 297. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 298. On or about January 2004, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a Page 107 of 234 EP-137 1ST of ISI EFTA01117171 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 26 of 79 violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage In prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). E. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 299. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, E. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff E. incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, is., 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. Page 108 of 234 EP-138 1011•12141 EFTA01117172 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 27 of 79 300. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 71 Cause of Action Pursuant to 18 U.S.C. 4 2255 January 2004— Incident 3 301. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 302. On or about January 2004, the exact date being unknown to ■., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S C. § 2422(b), § 2423(a), § 2423(6). and § 2423(e) ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 303. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■. has in the past Page 109 of 234 EP-139 1010234 EFTA01117173 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 28 of 79 suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her Into a perverse and conventional way of life for a minor. The then-minor plaintiff E. incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These Injuries are permanent in nature and the plaintiff, E., will continue to suffer these losses In the future. 304. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount. provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 72 Cause of Action Pursuant to 18 U.S.C. S 2255 January 2004 — Incident 4 305. Plaintiff, E. adopts and realleges paragraphs 1 through 20 above. 306. On or about January 2004, the exact date being unknown to E., Defendant, Jeffrey Epstein. committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage In prostitution or sexual activity, travel with intent to Page 110 of 234 EP-140 110 01 234 EFTA01117174 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 29 of 79 engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 307. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, ■ , will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future. 308. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided Page 111 of 234 EP-141 Ill of 234 EFTA01117175 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 30 of 79 by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a Jury. COUNT 73 Cause of Action Pursuant to 18 U.S.C. 4 2255 February 2004— Incident 1 309. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 310. On or about February 2004, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). • is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 311. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, II. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of Page 112 of 234 EP-142 112 41214 EFTA01117176 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 31 of 79 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 conventional way of life for a minor. The then-minor plaintiff'''. incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff,.., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, E., will continue to suffer these losses in the future. 312. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 74 Cause of Action Pursuant to 18 U.S.C. 6 2255 February 2004 — Incident 2 313. Plaintiff... adopts and realleges paragraphs 1 through 20 above. 314. On or about February 2004, the exact date being unknown to .., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in Illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, Page 113 of 234 III of 214 EP-I43 EFTA01117177 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 32 of 79 child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 315. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, In has In the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■ incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, 5, will continue to suffer these losses in the future. 316. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. Page 114 of 234 EP-144 11401231 EFTA01117178 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 33 of 79 COUNT 75 Cause of Action Pursuant to 18 U.S.C. 4 2255 February 2004 — Incident 3 317. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 318. On or about February 2004, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein. and the United States Government. 319. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse Page 115 of 234 EP-145 115c42.14 EFTA01117179 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 34 of 79 and conventional way of life for a minor. The then-minor plaintiff M. incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, M., will continue to suffer these losses in the future. 320. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 76 Cause of Action Pursuant to 18 U.S.C. Q 2265 February 2004 — incident 4 321. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 322. On or about February 2004, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). Page 116 of 234 EP-146 1 le *6 234 EFTA01117180 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 35 of 79 Sr is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 323. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, S. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiffs. incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, S., 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, S., will continue to suffer these losses in the future. 324. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorneys fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 77 Cause of Action Pursuant to 18 U.S.C. 6 2255 Page 117 of 234 EP-147 It/ of 224 EFTA01117181 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 36 of 79 March 2004 - Incident 1 325. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 326. On or about March 2004, the exact date being unknown to,, Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). • is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 327. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, In has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff 5 incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and Page 118 of 234 EP-148 III of 234 EFTA01117182 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 37 of 79 psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. 328. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 78 Cause of Action Pursuant to 18 U.S.C. 4 2256 March 2004 — Incident 2 329. Plaintiff, E. adopts and realleges paragraphs 1 through 20 above. 330. On or about March 2004, the exact date being unknown to E., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to Page 119 of 234 EP-149 119..214 EFTA01117183 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 38 of 79 this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 331. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, Invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her Into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future. 332. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 79 Cause of Action Pursuant to 18 U.S.C. 4 2255 March 2004 — Incident 3 333. Plaintiff, E. adopts and realleges paragraphs 1 through 20 above. Page 120 of 234 EP-150 120 0234 EFTA01117184 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 39 of 79 334. On or about March 2004, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 335. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■ has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish. humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff 5 incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income In the future, and a loss of the capacity to enjoy life. These Page 121 of 234 EP-151 121 of 234 EFTA01117185 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 40 of 79 injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future. 336. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 80 Cause of Action Pursuant to 18 U.S.C, 4 2265 March 2004 — Incident 4 337. Plaintiff, adopts and realieges paragraphs 1 through 20 above. 338. On or about March 2004, the exact date being unknown to II., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage In illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. Page 122 of 234 EP-152 In of 2S6 EFTA01117186 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 41 of 79 339. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, N. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff. .., will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of Income, a loss of the capacity to earn income In the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, .., will continue to suffer these losses In the future. 340. Wherefore, the plaintiff, .., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury COUNT 81 Cause of Action Pursuant to 18 U.S.C. § 2255 April 2004 — Incident 1 341. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 342. On or about April 2004, the exact date being unknown to .., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of Page 123 of 234 EP-153 12304 234 EFTA01117187 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 42 of 79 numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). S. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 343. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, S. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, S., will in the future suffer medical and psychological expenses. The plaintiff, S., 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, S., will continue to suffer these losses in the future. Page 124 of 234 EP-154 $24 01234 EFTA01117188 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 43 of 79 344. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 82 Cause of Action Pursuant to 18 U.S.C. 4 2255 April 2004— Incident 2 345. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 346. On or about April 2004, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage In illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U S C § 2422(b). § 2423(a), § 2423(b), and § 2423(e). E. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 347. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past Page 125 of 234 EP-155 125 of 111 EFTA01117189 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 44 of 79 suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, S., 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. 348. Wherefore, the plaintiff, S., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 83 Cause of Action Pursuant to 18 U.S.C. S 2255 April 2004 — Incident 3 349. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 350. On or about April 2004, the exact date being unknown to ■., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual Page 128 of 234 EP-156 121 of IN EFTA01117190 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07127/2009 Page 45 of 79 conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). •. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Govemment. 351. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, L M., will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy fife. These injuries are permanent in nature and the plaintiff. E., will continue to suffer these losses in the future. 352. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided Page 127 of 234 EP-157 n70214 EFTA01117191 Case 9:09-cv-81092-JIC bocument 1-2 Entered on FLSD Docket 07/27/2009 Page 46 of 79 by law, attorneys fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 84 Cause of Action Pursuant to 18 U.S.C. § 2255 April 2004 — Incident 4 353. Plaintiff,II. adopts and realleges paragraphs 1 through 20 above. 354. On or about April 2004, the exact date being unknown toll., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with Intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). •. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant. Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 355. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of Page 128 of 234 EP-158 121 et 234 EFTA01117192 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 47 of 79 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 conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, will in the Mute suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. 356. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 85 Cause of Action Pursuant to 18 U.S.C. 4 2255 May 2004 — Incident 1 357. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above 358. On or about May 2004, the exact date being unknown to ■., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation Page 129 of 234 EP-159 129 of 224 EFTA01117193 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 48 of 79 enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 359. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, Invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff M. incurred medical and psychological expenses and the plaintiff, , will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future. 380. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. Page 130 of 234 EP-160 130 of211 EFTA01117194 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 49 of 79 COUNT 86 Cause of Action Pursuant to 18 U.S.C. S 2266 May 2004 — Incident 2 361. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 382. On or about May 2004, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with Intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government 363. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■. has in the past suffered, and will in the future suffer, physical Injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse Page 131 of 234 EP-161 131 of 214 EFTA01117195 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 50 of 79 and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, S., will in the future suffer medical and psychological expenses. The plaintiff, S., 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. 364. Wherefore, the plaintiff, S., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 87 Cause of Action Pursuant to 18 U.S.C, 4 2265 May 2004 — Incident 3 365. Plaintiff, S. adopts and realleges paragraphs 1 through 20 above. 366. On or about May 2004, the exact date being unknown to S., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). S. is Page 132 of 234 EP-162 132 & 2$ EFTA01117196 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 51 of 79 therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 367. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future 368. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 88 Cause of Action Pursuant to 18 U.S.C.; 2255 Page 133 of 234 EP-163 133 M234 EFTA01117197 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 52 of 79 May 2004— Incident 4 369. Plaintiff, NI adopts and realleges paragraphs 1 through 20 above. 370. On or about May 2004, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage In prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). fl is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 371. As a direct and proximate result of the offenses enumerated in Title 18, United States Code. Section 2255, being committed against her, L.M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff II. incurred medical and psychological expenses and the plaintiff, II., will in the future suffer medical and Page 134 of 234 EP-164 134.1234 EFTA01117198 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 53 of 79 psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. 372. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT $9 Cause of Action Pursuant to 18 U.S.C. 4 2255 June 2004 — Incident 1 373. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 374. On or about June 2004, the exact date being unknown to E., Defendant, Jeffrey Epstein. committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). E. is therefore a victim of one or more offenses enumerated In 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to Page 135 of 234 EP-165 1350214 EFTA01117199 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 54 of 79 this Section of the United Slates Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 375. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, S. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff S. incurred medical and psychological expenses and the plaintiff, S., will in the future suffer medical and psychological expenses. The plaintiff, S., 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, S., will continue to suffer these losses in the future. 376. Wherefore, the plaintiff, S., demands judgments against the defendant, Jeffrey Epstein. for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 90 Cause of Action Pursuant to 18 U.S.C. § 2255 June 2004 — Incident 2 377. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. Page 136 of 234 EP-166 EFTA01117200 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 55 of 79 378. On or about June 2004, the exact date being unknown to. Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 379. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, Invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These Page 137 of 234 EP-167 $170234 EFTA01117201 Case 9:09-cv-81092-JlC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 56 of 79 Injuries are permanent in nature and the plaintiff, •, will continue to suffer these losses in the future. 380. Wherefore, the plaintiff, la, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 91 Cause of Action Pursuant to 18 U.S.C.6 2255 June 2004 — Incident 3 381. Plaintiff, ■ adopts and realleges paragraphs 1 through 20 above. 382. On or about June 2004, the exact date being unknown to,, Defendant, Jeffrey Epstein, committed a federal sexual offense against her, Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in Illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Govemment. Page 138 of 234 EP-168 131 01211 EFTA01117202 Case 9:09-cv-81092-JIC Document 1-2 Entered on FISD Docket 07/27/2009 Page 57 of 79 383. As a direct and proximate result of the offenses enumerated In Title 18, United States Code, Section 2255, being committed against her, M. has in the past suffered, and will in the future suffer, physical Injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff M. incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. 384. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 92 Cause of Action Pursuant to 18 U.S.C. 4 2255 June 2004 - Incident 4 385. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 386. On or about June 2004, the exact date being unknown to M. Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a Page 139 of 234 EP-169 136.0234 EFTA01117203 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 58 of 79 violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 387. As a direct and proximate result of the offenses enumerated in Title 18, United States Code. Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein. controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future. Page 140 of 234 EP-170 144 e1 234 EFTA01117204 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 59 of 79 388. Wherefore, the plaintiffill., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 93 Cause of Action Pursuant to 18 U.S.C. § 2255 July 2004 — Incident 1 389. Plaintiff,li. adopts and realleges paragraphs 1 through 20 above. 390. On or about July 2004, the exact date being unknown toll., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U S C § 2422(b). § 2423(a), § 2423(b), and § 2423(e). L M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jaffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 391. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, M. has in the past Page 141 of 234 EP-171 141 a434 EFTA01117205 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 60 of 79 suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, Invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff.. incurred medical and psychological expenses and the plaintiff, S., will in the future suffer medical and psychological expenses. The plaintiff, i., 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, E., will continue to suffer these losses in the future. 392. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 94 Cause of Action Pursuant to 18 U.S.C. 4 2255 July 2004 — Incident 2 393. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 394. On or about July 2004, the exact date being unknown toe., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual Page 142 of 234 EP-172 142 of 234 EFTA01117206 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 61 of 79 conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). •. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 395. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, E. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff Incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, M., will continue to suffer these losses in the future. 396. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided Page 143 of 234 EP-173 EFTA01117207 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 62 of 79 by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 95 Cause of Action Pursuant to 18 U.S.C. § 2255 July 2004 — Incident 3 397. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 398. On or about July 2004, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in Illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). E. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein. pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 399. As a direct and proximate result of the offenses enumerated In Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of Page 144 of 234 EP-174 1440234 EFTA01117208 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 63 of 79 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 conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, M., will continue to suffer these losses in the future. 400. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 96 Cause of Action Pursuant to 18 U.S.C. d 2265 July 2004 — Incident 4 401. Plaintiff, L M adopts and realleges paragraphs 1 through 20 above 402. On or about July 2004, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation Page 145 of 234 EP-175 way EFTA01117209 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 64 of 79 enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). Is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 403. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, E. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff E. incurred medical and psychological expenses and the plaintiff, E., will in the future suffer medical and psychological expenses. The plaintiff, E., 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, E., will continue to suffer these losses in the future. 404. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. Page 146 of 234 Er-I 76 141•1234 EFTA01117210 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 65 of 79 COUNT 97 Cause of Action Pursuant to 18 U.S.C. 4 2255 August 2004 — Incident 1 405. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 406. On or about August 2004, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with Intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). E. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 407. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse Page 147 of 234 EP-177 147 of 234 EFTA01117211 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 66 of 79 and conventional way of life for a minor. The then-minor plaintiff E. incurred medical and psychological expenses and the plaintiff, E., will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, M., will continue to suffer these losses in the future. 408. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 98 Cause of Action Pursuant to 18 U.S.C. S 2265 August 2004— Incident 2 409. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 410. On or about August 2004, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). Page 148 of 234 EP-178 141 of 211 EFTA01117212 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 67 of 79 E. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 411. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff.. incurred medical and psychological expenses and the plaintiff, .., will in the future suffer medical and psychological expenses. The plaintiff, .., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, .., will continue to suffer these losses in the future 412. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amcunt provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 99 Cause of Action Pursuant to 18 U.S.C. x12255 Page 149 of 234 EP-179 14101234 EFTA01117213 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 68 of 79 August 2004 — Incident 3 413. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 414. On or about August 2004, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 415. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255. being committed against her has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff E. incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and Page 150 of 234 EP-180 100.1224 EFTA01117214 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 69 of 79 psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future. 416. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 100 Cause of Action Pursuant to 18 U$,C. 6 2255 August 2004 — Incident 4 417. Plaintiff, ll. adopts and realleges paragraphs 1 through 20 above. 418. On or about August 2004, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to Page 151 of 234 EP-181 latot314 EFTA01117215 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 70 of 79 this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 419. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her,S. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of setf-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 conventional way of life for a minor. The then-minor plaintiffs. incurred medical and psychological expenses and the plaintiff,`., will in the future suffer medical and psychological expenses. The plaintiff., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■ will continue to suffer these losses in the future. 420. Wherefore, the plaintiff, s., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 101 Cause of Action Pursuant to 18 U.S.C. +52255 September 2004 — Incident 1 421. Plaintiff, adopts and realleges paragraphs 1 through 20 above. Page 152 of 234 EP-182 162 el 234 EFTA01117216 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 71 of 79 422. On or about September 2004, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). • is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 423. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, fi has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, S., will in the future suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These Page 153 of 234 EP-t83 1530234 EFTA01117217 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 72 of 79 427. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff, .., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. 428. Wherefore, the plaintiff, .., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 103 Cause of Action Pursuant to 18 U.S.C. 4 2255 September 2004 — Incident 3 429. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 430. On or about September 2004, the exact date being unknown to .., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a Page 155 of 234 EP-184 IS4 of 214 EFTA01117218 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 73 of 79 violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). S. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 431. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255. being committed against her, ■. has in, the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling. manipulating and coercing her into a perverse and conventional way of life for a minor. The then•minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future. Page 156 of 234 EP-185 13501214 EFTA01117219 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 74 of 79 432. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 104 Cause of Action Pursuant to 18 U.S.C. 4 2255 Septomber 2004 — Incident 4 433. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 434. On or about September 2004, the exact date being unknown to E., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e) E. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 435. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, M. has in the past Page 157 of 234 EP-186 ISO x1234 EFTA01117220 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 75 of 79 suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff.. incurred medical and psychological expenses and the plaintiff, M., will In the future suffer medical and psychological expenses. The plaintiff,.., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, S., will continue to suffer these losses in the future. 436. Wherefore, the plaintiff,.., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount. provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 105 Cause of Action Pursuant to 18 U.S.C. Q 2255 October 2004 — Incident 1 437. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 438. On or about October 2004, the exact date being unknown to •., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to Page 158 of 234 EP-187 157 of 214 EFTA01117221 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 76 of 79 engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). III. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 439, As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her,.. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment,, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, .., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, III., will continue to suffer these losses in the future. 440. Wherefore, the plaintiff, .., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided Page 159 of 234 EP-188 15i oftti EFTA01117222 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 77 of 79 by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 106 Cause of Action Pursuant to 18 U.S.C. 4 2255 October 2004 — Incident 2 441. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 442. On or about October 2004, the exact date being unknown to.., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). III. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 443. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of Page 160 of 234 EP-189 IWO 334 EFTA01117223 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 78 of 79 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 conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future. 444. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 107 Cause of Action Pursuant to 18 U.S,C, 4 2255 October 2004 — Incident 3 445. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 446. On or about October 2004, the exact date being unknown to ■., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, Page 161 of 234 EP-190 IM *Int EFTA01117224 Case 9:09-cv-81092-JIC Document 1-2 Entered on FLSD Docket 07/27/2009 Page 79 of 79 child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). e is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 447. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■ has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff 5 incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future. 448. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. Page 182 of 234 EP-191 III el 234 EFTA01117225 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 1 of 73 COUNT 108 Cause of Action Pursuant to 18 U.S.C. § 2256 October 2004 — Incident 4 449. Plaintiff,fl. adopts and realleges paragraphs 1 through 20 above. 450. On or about October 2004, the exact date being unknown a., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated In 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein. and the United States Government. 451. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, Invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse Page 163 of 234 EP-192 1620234 EFTA01117226 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 2 of 73 and conventional way of life for a minor. The then-minor plaintiff au incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, a, hes 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. 452. Wherefore, the plaintiff, S, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 109 Cause of Action Pursuant to 18 U.S.G. 4 2265 November 2004— Incident 1 453. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 454. On or about November 2004, the exact date being unknown to IS, Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child, exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). Page 164 of 234 EP-193 It3 of 231 EFTA01117227 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 3 of 73 is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 455. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff II. incurred medical and psychological expenses and the plaintiff, II., will in the future suffer medical and psychological expenses. The plaintiff, E., 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. 456. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 110 Cause of Action Pursuant to 18 U.S.C. § 2255 Page 165 of 234 EP-194 %lot 231 EFTA01117228 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 4 of 73 November 2004 — Incident 2 457. Plaintiff,fl. adopts and realleges paragraphs 1 through 20 above. 458. On or about November 2004, the exact date being unknown toe., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 459. As a direct and proximate result of the offenses enumerated in Title 18, United States Code. Section 7255. being committed against her,■ has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff E. incurred medical and psychological expenses and the plaintiff, E., will in the future suffer medical and Page 166 of 234 EP-I95 165 ef 234 EFTA01117229 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 5 of 73 psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. 460. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 111 Cause of Action Pursuant to 18 U.S,C. 4 2255 November 2004 — incident 3 461. Plaintiff, Ill. adopts and realleges paragraphs 1 through 20 above. 462. On or about November 2004, the exact date being unknown to E. Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant. Jeffrey Epstein, pursuant to Page 167 of 234 EP-196 IN of 214 EFTA01117230 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 6 of 73 this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 463. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, S. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her Into a perverse and conventional way of life for a minor. The then-minor plaintiff S. incurred medical and psychological expenses and the plaintiff, S., will in the future suffer medical and psychological expenses. The plaintiff..., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ..., will continue to suffer these losses in the future. 464. Wherefore, the plaintiff, ..., demands judgments against the defendant, Jeffrey Fpstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 112 Cause of Action Pursuant to 18 U.S.C. § 2255 November 2004 — Incident 4 465. Plaintiff, adopts and realleges paragraphs 1 through 20 above. Page 168 of 234 EP-197 ICY of 234 EFTA01117231 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 7 of 73 466. On or about November 2004, the exact date being unknown to a, Defendant, Jeffrey Epstein, committed a federal sexual offense against her, Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage In prostitution or sexual activity, travel with Intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 467. As a direct and proximate result of the offenses enumerated In Title 18, United States Code, Section 2255, being committed against her, ■. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her Into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income In the future, and a loss of the capacity to enjoy life. These Page 169 of 234 EP-198 na a LH EFTA01117232 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 8 of 73 injuries are permanent in nature and the plaintiff, M., will continue to suffer these losses in the future. 468. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 113 Cause of Action Pursuant to 18 U.S.C. 6 2255 December 2004 — Incident 1 469. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 470. On or about December 2004, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b). and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. Page 170 of 234 EP-199 IN 0234 EFTA01117233 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 9 of 73 471. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, 5 has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff 5 incurred medical and psychological expenses and the plaintiff. ■, will in the future suffer medical and psychological expenses. The plaintiff, ■, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■, will continue to suffer these losses in the future. 472. Wherefore, the plaintiff, ■, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 114 Cause of Action Pursuant to 18 U.S.C. 4 2255 December 2004 — Incident 2 473. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 474. On or about December 2004, the exact date being unknown to ■., Defendant. Jeffrey Epstein, committed a federal sexual offense against her, including a Page 171 of 234 EP-200 170 S 110 EFTA01117234 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 10 of 73 violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). II is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 475. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■ has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant. Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiffM Incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, 15, 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. Page 172 of 234 EP-201 Ill DISH EFTA01117235 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 11 of 73 476. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 115 Cause of Action Pursuant to 18 U.S.C. 6 2255 !December 2004 — Incident 3 477. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 478. On or about December 2004, the exact date being unknown to ■., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically Including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b). and § 2423(e) ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 479. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past Page 173 of 234 EP-1202 333 of 234 EFTA01117236 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 12 of 73 suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, II., will in the future suffer medical and psychological expenses. The plaintiff, II., 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, M., will continue to suffer these losses in the future. 480. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 116 Cause of Action Pursuant to 18 U.S.C. 2255 December 2004 — Incident 4 481. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 482. On or about December 2004, the exact date being unknown toll., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to Page 174 of 234 EP-203 173 of 234 EFTA01117237 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 13 of 73 engage In Illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). El. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 483. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiffs. incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, S., 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, S., will continue to suffer these losses in the future. 484. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided Page 175 of 234 EP-204 t74 of 2)4 EFTA01117238 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 14 of 73 by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 117 Cause of Action Pursuant to 18 U.S.C, 4 2255 January 2005 — Incident 1 485. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 486. On or about January 2005, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jaffrey Epstein, and the United States Government. 487. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of Page 176 of 234 EP-205 175 0234 EFTA01117239 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 15 of 73 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 conventional way of life for a minor. The then-minor plaintiff S. incurred medical and psychological expenses and the plaintiff, S., will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future. 488. Wherefore, the plaintiff, , demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 118 Cause of Action Pursuant to 18 U.S.C. 4 2255 January 2005 — Incident 2 489. Plaintiff. L M. adopts and realleges paragraphs 1 through 20 above. 490. On or about January 2005, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, Page 177 of 234 EP-206 1/60234 EFTA01117240 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 16 of 73 child exploitation enterprises, and other crimes, specifically Including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). S. Is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 491. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, S. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff S. incurred medical and psychological expenses and the plaintiff, IN , will in the future suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff, S., will continue to suffer these losses in the future. 492. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. Page 178 of 234 EP-207 177 o1234 EFTA01117241 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 17 of 73 COUNT 119 Cause of Action Pursuant to 18 U.S.C. 4 2255 January 2005 — Incident 3 493. Plaintiff... adopts and realleges paragraphs 1 through 20 above. 494. On or about January 2005, the exact date being unknown to .., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging In sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated In 18 § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 495. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against herill. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, Invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse Page 179 of 234 EP-208 171 of 234 EFTA01117242 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 18 of 73 and conventional way of life for a minor. The then-minor plaintiff M. incurred medical and psychological expenses and the plaintiff,.., will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses In the future. 498. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all Issues triable as of right by a jury. COUNT 120 Cause of Action Pursuant to 18 U.S.C. 6 2265 January 2006 — Incident 4 497. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 498. On or about January 2005, the exact date being unknown to M., Defendant. Jeffrey Fpstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). Page 180 of 234 EP-209 171021g EFTA01117243 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 19 of 73 is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 499. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her. M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein. controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff M. incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future. 500. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems Just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 121 Cause of Action Pursuant to 18 U.S.C. 4 2255 Page 181 of 234 EP-210 18I of 234 EFTA01117244 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 20 of 73 February 2005 — Incident 1 501. Plaintiff, 'Ill. adopts and realleges paragraphs 1 through 20 above. 502. On or about February 2005, the exact date being unknown to ■., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 503. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and Page 182 of 234 EP-211 11101234 EFTA01117245 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 21 of 73 psychological expenses. The plaintiff, E., 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. 504. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 122 Cause of Action Pursuant to 18 U.S.C. 4 2255 February 20Q5 — Incident 2 505. Plaintiff, ■. adopts and realleges pargraphs 1 through 20 above. 506. On or about February 2005, the exact date being unknown to ■., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to Page 183 of 234 EP-212 tb1of 234 EFTA01117246 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 22 of 73 this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 507. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against hell. has in the past suffered, and will In the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff II. incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff. II., 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, II., will continue to suffer these losses in the future. 508. Wherefore, the plaintiff, II., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 123 Cause of Action Pursuant to 18 U,S.C. d 2255 February 2005 — Incident 3 509. Plaintiff... adopts and realleges paragraphs 1 through 20 above. Page 184 of 234 EP-213 1•3 of 2$4 EFTA01117247 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 23 of 73 510. On or about February 2005, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage In prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 511. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her. ■. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress. psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, leffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These Page 185 of 234 EP-214 tel of 234 EFTA01117248 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 24 of 73 Injuries are permanent in nature and the plaintiff, M., will continue to suffer these losses in the future. 512. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 124 Cause of Action Pursuant to 18 U.S.C. 2255 February 2006 — Incident 4 513. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 514. On or about February 2005, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging In sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. Page 186 of 234 EP-215 IN of 234 EFTA01117249 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 25 of 73 515. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, In has In the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her Into a perverse and conventional way of life for a minor. The then-minor plaintiff fl incurred medical and psychological expenses and the plaintiff, a , will in the future suffer medical and psychological expenses. The plaintiff, s. , has suffered a foss 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, In, will continue to suffer these losses in the future. 516. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 126 Cause of Action Pursuant to 18 U.S.C. 6 2255 March 2005 — Incident 1 517. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 518. On or about March 2005, the exact date being unknown to II., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a Page 187 of 234 EP-216 11$0234 EFTA01117250 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 26 of 73 violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 519. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in.the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein. controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff II. incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, II., will continue to suffer these losses in the future. Page 188 of 234 EP-217 187 of 234 EFTA01117251 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 27 of 73 520. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 126 Cause of Action Pursuant to 18 U.S.C. ft 2255 March 2006 — Incident 2 521. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 522. On or about March 2005, the exact date being unknown to ■., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U S C § 2422(b). § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 523. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■. has in the past Page 189 of 234 EP-218 141 *1 234 EFTA01117252 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 28 of 73 suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, Invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff Incurred medical and psychological expenses and the plaintiff= will in the future suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future. 524. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 127 Cause of Action Pursuant to 18 U.S.C. § 2255 March 2005 — Incident 3 525. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 528. On or about March 2005, the exact date being unknown to E., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to Page 190 of 234 EP-219 IN 0214 EFTA01117253 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 29 of 73 engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 527. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, M. has In the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff E. incurred medical and psychological expenses and the plaintiff, L M., will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff, E., will continue to suffer these losses in the future. 528. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided Page 191 of 234 EP-220 120 0224 EFTA01117254 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 30 of 73 by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 128 Cause of Action Pursuant to 18 U.S.C. 4 2255 March 2005 — incident 4 529. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 530. On or about March 2005, the exact date being unknown to ■., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 531. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of Page 192 of 234 1,10211 EP-221 EFTA01117255 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 31 of 73 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 conventional way of life for a minor. The then-minor plaintiff M. Incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, M., will continue to suffer these losses in the future. 532. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 129 Cause of Action Pursuant to 18 U.S.C. 6 2266 April 2005 — Incident 1 533. Plaintiff, 1_ M. adopts and realleges paragraphs 1 through 20 above 534. On or about April 2005, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation Page 193 of 234 t92 01234 EP-222 EFTA01117256 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 32 of 73 enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 535. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff M. incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. 536. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. Page 194 of 234 133 of 234 EP-223 EFTA01117257 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 33 of 73 COUNT 130 Cause of Action Pursuant to 18 U,S.C. 4 2255 Apr, 2005 — Incident 2 537. Plaintiff. adopts and realleges paragraphs 1 through 20 above. 538. On or about April 2005, the exact date being unknown to .., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 539. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse Page 195 of 234 EP-224 1940234 EFTA01117258 Case 9:09-cv-81092-jIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 34 of 73 and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. 540. Wherefore, the plaintiff, IS, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 131 Cause of Action Pursuant to 18 U.S.C. 4 2265 April 2005 — Incident 3 541. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 542. On or about April 2005, the exact date being unknown to fl ,Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(a). M. is Page 196 of 234 EP-225 III 41234 EFTA01117259 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 35 of 73 therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 543. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff S. incurred medical and psychological expenses and the plaintiff, S., will in the future suffer medical and psychological expenses. The plaintiff, IS., 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, S., will continue to suffer these losses in the future 544. Wherefore, the plaintiff, S., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 132 Cause of Action Pursuant to 18 U.S.C. 4 2255 Page 197 of 234 EP-226 191 e1234 EFTA01117260 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 36 of 73 April 2005 — Incident 4 545. Plaintiff,, adopts and realleges paragraphs 1 through 20 above. 546. On or about April 2005, the exact date being unknown to III, Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). a is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 547. As a direct and proximate result of the offenses enumerated in Title 18, United States Code. Section 2255, being committed against her, Ill has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff.. incurred medical and psychological expenses and the plaintiff, II., will in the future suffer medical and Page 198 of 234 EP-227 19/ 0334 EFTA01117261 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 37 of 73 psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These Injuries are permanent in nature and the plaintiff, ■, will continue to suffer these losses in the future. 548. Wherefore, the plaintiff, ■, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 133 Cause of Action Pursuant to 18 U.S.C. 4 2255 May 2006 — Incident 1 549. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 550. On or about May 2005. the exact date being unknown to IS, Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Page 199 of 234 EP-228 1110231 EFTA01117262 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 38 of 73 Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 551. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, Ill has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff IS incurred medical and psychological expenses and the plaintiff, ill, will in the future suffer medical and psychological expenses. The plaintiff, Ill, 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, IN, will continue to suffer these losses in the future. 552. Wherefore, the plaintiff, 11, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 134 Cause of Action Pursuant to 18 U.S.C. 4 2255 May 2005 — Incident 2 553. Plaintiff, adopts and realleges paragraphs 1 through 20 above. Page 200 of 234 EP-229 119 of 2S4 EFTA01117263 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 39 of 73 554. On or about May 2005, the exact date being unknown te■l., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage In illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■I. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 555. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her,... has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff.. incurred medical and psychological expenses and the will in the future suffer medical and psychological expenses. The plaintiffill., 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 Page 201 of 234 EP-230 200 of 234 EFTA01117264 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 40 of 73 injuries are permanent In nature and the plaintiff, M., will continue to suffer these losses in the future. 556. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 135 Cause of Action Pursuant to 18 U.S.C. 4 2255 May 2005 — Incident 3 557. Plaintiff, E. adopts and realleges paragraphs 1 through 20 above. 558. On or about May 2005, the exact date being unknown to ■., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. Page 202 of 234 EP-231 201 of 234 EFTA01117265 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 41 of 73 559. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, Invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiffM. incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, 5., will continue to suffer these losses in the future. 560. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper. and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 136 Cause of Action Pursuant to 18 U.S.C. § 2255 May 2005 — Incident 4 561. Plaintiff, 5. adopts and realleges paragraphs 1 through 20 above. 562. On or about May 2005, the exact date being unknown to U., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of Page 203 of 234 EP-232 202 0234 EFTA01117266 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 42 of 73 numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with Intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 563. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant. Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff U. incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. Page 204 of 234 EP-233 203 of 234 EFTA01117267 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 43 of 73 564. Wherefore, the plaintiff, M, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right 137 COUNT 137 Cause of Action Pursuant to 18 U.S.C. 4 2265 June 2005 — Incident 1 565. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 566. On or about June 2005, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). IS is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 567. As a direct and proximate result of the offenses enumerated in Title 18, United States Code. Section 2255, being committed against her, has in the past Page 205 of 234 EP-234 204 et 231 EFTA01117268 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 44 of 73 suffered, and will In the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaIntiffal. incurred medical and psychological expenses and the plaintiffin., will in the future suffer medical and psychological expenses. The plaintiff,.., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, , will continue to suffer these losses in the future. 568. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 138 Cause of Action Pursuant to 18 U.S.C. el 2256 June 2005 — Incident 2 569. adopts and realleges paragraphs 1 through 20 above. 570. On or about June 2005, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to Page 206 of 234 EP-235 206 a 234 EFTA01117269 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 45 of 73 engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 571. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff s. incurred medical and psychological expenses and the plaintiff, t. M , will in the future suffer medical and psychological expenses. The plaintiff, in, 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, 5, will continue to suffer these losses in the future. 572. Wherefore, the plaintiff, S., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided Page 207 of 234 EP-236 20%01234 EFTA01117270 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 46 of 73 by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 139 Cause of Action Pursuant to 18 U.S.C. 6 2255 June 2005 —Incident 3 573. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 574. On or about June 2005, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated In 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 575. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of Page 208 of 234 EP-237 207 0234 EFTA01117271 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 47 of 73 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 conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, E., will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, M., will continue to suffer these losses in the future. 576. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 140 Cause of Action Pursuant to 18 U.S.C. § 2255 June 2005 — Incident 4 577. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 578. On or about June 2005, the exact date being unknown to E., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, Page 209 of 234 EP-238 203 ot 234 EFTA01117272 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 48 of 73 child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■I. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 579. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, S. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiffs. incurred medical and psychological expenses and the plaintiff, S., will in the future suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, 10., will continue to suffer these losses in the future. 580. Wherefore, the plaintiff demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. Page 210 of 234 EP-239 20901234 EFTA01117273 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 49 of 73 COUNT 141 Cause of Action Pursuant to 18 U.S.C. 4 2265 July 2005 — Incident 1 581. Plaintiff, ■ adopts and realleges paragraphs 1 through 20 above. 582. On or about July 2005, the exact date being unknown to ■, Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 583. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse Page 211 of 234 EP-240 718 of 214 EFTA01117274 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 50 of 73 and conventional way of life for a minor. The then-minor plaintiff M. incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff, E., 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. 584. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 142 Cause of Action Pursuant to 18 U.S.C. 4 2255 July 2006 — Incident 2 585. Plaintiff, E. adopts and realleges paragraphs 1 through 20 above. 586. On or about July 2005, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is Page 212 of 234 EP-241 21101234 EFTA01117275 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 51 of 73 therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 587. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, S. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff S. incurred medical and psychological expenses and the plaintiff, S., will in the future suffer medical and psychological expenses. The plaintiff, S., 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, S., will continue to suffer these losses in the future 588. Wherefore, the plaintiff, S., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 143 Cause of Action Pursuant to 18 U.S.C. 4 2255 Page 213 of 234 EP-242 212°1234 EFTA01117276 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 52 of 73 July 2005 — Incident 3 589. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 590. On or about July 2005, the exact date being unknown to ■., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). E. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 591. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and Page 214 of 234 EP-243 213 of 2)11 EFTA01117277 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 53 of 73 psychological expenses. The plaintiff, n, 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, II., will continue to suffer these losses in the future. 592. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 144 Cause of Action Pursuant to 18 U.S.C. § 2265 July 2005 — Incident 4 593. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 594. On or about July 2005, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in Illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). N. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Page 215 of 234 EP-244 214 of 234 EFTA01117278 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 54 of 73 Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 595. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■. has in the past suffered, and will In the future suffer, physical Injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, ■., will continue to suffer these losses in the future. 596. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 145 Cause of Action Pursuant to 18 U.S.C. 4 2255 August 2006 — Incident 1 597. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. Page 216 of 234 EP-245 211 of 234 EFTA01117279 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 55 of 73 598. On or about August 2005, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 599. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■ has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her Into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These Page 217 of 234 EP-246 211 of 234 EFTA01117280 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 56 of 73 injuries are permanent in nature and the plaintiff, •., will continue to suffer these losses in the future. 600. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems Just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 146 Cause of Action Pursuant to 18 U.S.C. § 2265 August 2005 — Incident 2 601. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 602. On or about August 2005, the exact date being unknown to E. Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage In prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated In 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. Page 218 of 234 EP-247 217 of 234 EFTA01117281 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 57 of 73 603. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, El has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff, incurred medical and psychological expenses and the plaintiff, IN, will in the future suffer medical and psychological expenses. The plaintiff, IS, 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. 604. Wherefore, the plaintiff, fl , demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper. and hereby demands trial by jury on all issues triable as of right by a jury COUNT 147 Cause of Action Pursuant to 18 U.S.C. 6 2255 August 2005 — Incident 3 605. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 606. On or about August 2005, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a Page 219 of 234 EP-248 21$ of 274 EFTA01117282 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 58 of 73 violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). III. is therefore a victim of one or more offenses enumerated In 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 607. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, E. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant. Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff.. incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiffil., 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. Page 220 of 234 EP-249 219 et 234 EFTA01117283 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 59 of 73 608. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 148 Cause of Action Pursuant to 18 U.S.C, Q 2265 August 2006 — Incident 4 609. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 810. On or about August 2005, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 611. As a direct and proximate result of the offenses enumerated In Title 18, United States Code, Section 2255, being committed against her, M. has in the past Page 221 of 234 EP-250 220021234 EFTA01117284 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 60 of 73 suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, toss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein. controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff S. incurred medical and psychological expenses and the plaintiff, S., will in the future suffer medical and psychological expenses. The plaintiff, S, 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, S., will continue to suffer these losses in the future. 612. Wherefore, the plaintiff, S., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 149 Cause of Action Pursuant to 18 U.S.C. Q 2255 September 2005 — Incident 1 613. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 614. On or about September 2005, the exact date being unknown to S., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to Page 222 of 234 EP-251 224 of 234 EFTA01117285 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 61 of 73 engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). Is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 615. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her Into a perverse and conventional way of life for a minor. The then-minor plaintiff .. incurred medical and psychological expenses and the plaintiff, I_ M . will in the future suffer medical and psychological expenses. The plaintiff, .., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, •., will continue to suffer these losses in the future. 616. Wherefore, the plaintiff, .., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided Page 223 of 234 EP-252 222.1234 EFTA01117286 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 62 of 73 by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 10 Cause of Action Pursuant to 18 U.S.C. 4 2251 September 2005 — Incident 2 617. Plaintiff. adopts and realleges paragraphs 1 through 20 above. 618. On or about September 2005, the exact date being unknown tolg, Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). E. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 619. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of Page 224 of 234 EP-253 223 a 234 EFTA01117287 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 63 of 73 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 conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff, II., 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. 820. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 151 Cause of Action Pursuant to 18 U.S.C. fi 2266 September 2005 — Incident 3 621. Plaintiff, II. adopts and realleges paragraphs 1 through 20 above 622. On or about September 2005, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, Page 225 of 234 EP-254 214of 234 EFTA01117288 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 64 of 73 child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). E. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 623. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her Into a perverse and conventional way of life for a minor. The then-minor plaintiff M. Incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, M., will continue to suffer these losses in the future. 624. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. Page 226 of 234 EP-255 225 cif 234 EFTA01117289 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 65 of 73 COUNT 152 Cause of Action Pursuant to 18 U.S.C. 4 2266 September 2005 — Incident 4 625. Plaintiff, E. adopts and realleges paragraphs 1 through 20 above. 626. On or about September 2005, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in Illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant. Jeffrey Epstein, and the United States Government. 627. As a direct and proximate result of the offenses enumerated in Title 18, United States Code. Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, Invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse Page 227 of 234 EP-256 22* of 234 EFTA01117290 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 66 of 73 and conventional way of life for a minor. The then-minor plaintiff IIII incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, III, 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. 628. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 153 Cause of Action Pursuant to 18 U.S.C. 4 2255 October 2006 — Incident 1 629. Plaintiff, `adopts and realleges paragraphs 1 through 20 above. 630. On or about October 2005, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). Page 228 of 234 EP-257 227 0234 EFTA01117291 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 67 of 73 s therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 631. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, IN has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff Incurred medical and psychological expenses and the plaintiff, `will in the future suffer medical and psychological expenses. The plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the plaintiff, MI will continue to suffer these losses in the future 632. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 154 Cause of Action Pursuant to 18 U.S.C. $ 2255 Page 229 of 234 EP-258 223 of 234 EFTA01117292 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 68 of 73 October 2006 — Incident 2 633. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 634. On or about October 2005, the exact date being unknown to E., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 635. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, t M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff II. incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and Page 230 of 234 EP-259 anal 234 EFTA01117293 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 69 of 73 psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These • :: are permanent in nature and the plaintiff, M., will continue to suffer these losses in the future. 636. Wherefore, the plaintiff, E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 166 Cause of Action Pursuant to 18 U.S.C. 4 2255 October 2006 — Incident 3 637. Plaintiff, E. adopts and realleges paragraphs 1 through 20 above. 638. On or about October 2005, the exact date being unknown to ■., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. Is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to Page 231 of 234 EP-260 2300234 EFTA01117294 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 70 of 73 this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 639. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, E., will In the future suffer medical and psychological expenses. The plaintiff, E., 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. 640. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT 156 Cause of Action Pursuant to 18 U.S.C. 2255 October 2005 — Incident 4 641. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. Page 232 of 234 EP-261 231.0234 EFTA01117295 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 71 of 73 642. On or about October 2005, the exact date being unknown to n, Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 643. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2265, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jaffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff M. incurred medical and psychological expenses and the plaintiff, M., will in the future suffer medical and psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the capacity to earn income in the future. and a loss of the capacity to enjoy life. These Page 233 of 234 232 4234 EP-262 EFTA01117296 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 72 of 73 injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. 644. Wherefore, the plaintiff, M, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper. DEMAND FOR JURY TRIAL Plaintiff hereby demands trial by jury on all issues triable as of right by a jury. DATED July 24, 2009 ectfully Submitted, radley J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre 401 East Las Olas Blvd., Suite 1850 Fort Lauderdale, Florida 33301 Telephone (954) 522-3456 Facsimile (954) 527-8663 Florida Bar No.: 542075 F-mail• [email protected] Page 234 of 234 EP-263 2330/234 EFTA01117297 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 73 of 73 .SS 14 r ay. PO) The1S44crvil eon/ &beet and the inftwmation contained began neither leelnce ROI aippkinent the Mineral strike ofpleadings or ether wen incipient' by law. morn ',prided by local rules of tour. This fon% approved by the Judicial Conremice oldie United Suits is September 1974. is remaired r theuseof IMCIak &Court ler die purposed' nnuallog thecivil dodos sheer. OCR 0117 aucnous ON roll aimams' OF Slit FORM.) NOTICE: Attorneys MIJSTAndkalarallbrilletLileteilleloW. CIVIL COVER SHEET I. (a) PLAINTIFFS (b) COUTES 0(RONdldlEt of Hui LOS Plaintlff Palm Bach (EXCEPT IN US. PLAIN TITP CASES) (e) Anwar/urn* /Inv Andrew ea Tenthare Nnotar) Rothstein Rosenfeldt Adler 401 East Las Olas Blvd., Suite 1650 Pod Lauderdale, FL 33301 - Phone 954-522-3456 DEFENDANTS JEFFREY EPSTEIN County of Residcbee of Finn Listed Defendant Palm Bach (IN 0... PLAINTIFF CASES ONLY) NOTE. IN LAND CONDEMNATION CAM. USE TER LOCATION Of TEE TRACT LAND INVOLVED. Attorneys iltnemm Bradley J. Edwards on Cheek County When Acdoo Arose. 0 Illaalt• DAPS 0 MONROE 0 OROWARD fJ PALM PIACI. 3 MARTIN 0 IT.I.UCIE 0 INDIAN EITEL 0 OKEECNONIII NIONLAN OS II. BASIS OF JURISDICTION eau -a- ta on en osa) O I U.S. OrnMeneoll y/T21 tons pews. minim (US. Orinrueset Net a Percy) CI 2 US Cleverranar 0 4 Of ty 1151•Adrn Ondinta Citizen. .Pudic, in Ibta 110 I ' 0%0 V 48/Ala n- 0111? .r - III. CITIZENSHIP OF PRINCIPAL PARTIEthraw was se. Sr tonere Oinnhy Cain 0031 aw Otte let Sc DSSIM) ter REF PIP 05/ C1105 et Ten Slob 0 I 0 I beemanted PrIprIpt Nen 0 E 0 4 al Raid la I. 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N I II, ,..„.", „ Ise, No Civg Mann 0 50 Peas Cato 1 w.uCu rent, 0 441 Nottraloialirn ApelluirLin a 40 Unbar CorynAlms Denim 445 or 0 "ion t, Imetienan V. ORIGIN Jap t Original Proceeding (Nam • "X" In Oar 00. Only) CI 2 R moved from 0 3 Stale Coun VI. RELATED/RE-FILED CASE(S). wend ma JUDGE Re-fded• (ste Vi below) a) Re-Med Case 0 YES p NO 0 4 Reinstated of Tomsfened from 0 S sootherditesia 0 6 WINdiaria Reopened 0Pecik) Vacation b) Related Casa 0 YES ONO Appeal to District O 7 Judge from Magistrate Aidanstril DOCKET HIPMIffiR 9:08.cv-8 0 I 19 VII. CAUSE OF ACTION Cii the US. Civil Slade under which you aft fling end Witte a Boer SUMUNTA oceanic Mo all die Of isdictionsi Manilas eaten diversitft I S USC Section 2255 LENGTH OF TRIAL. via i p estimated (for both sides to ay table at) VIII. REQUESTED IN 0 CHECK IF TINS IS A CI 55 ION DEMAND $ I/Vat( StS CHECK YRS only if demanded In complaint. COMPLAINT: UNDER F.R.CP. 21 ),000,000.00 JURY DEMAND: 0 Yes 0 No ABOVE INFORMATION IS TRUE A CORRECT TO THE BEST OF MY KNOWLEDGE 234 el 214 Or ATTORNEY OF RECORD EP-264 LIME 1/41 roe OFFICE ittAirmv athourn59/11.% RECEIPT 4 54e 177 IFP EFTA01117298