EFTA00087853

Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 1 of 91 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRAMOHNSON C.M.A., Plaintiff(s), VS. TEIN and Defendant(s). FIRST AMENDED COMPLAINT Parties, Jurisdiction and Venue COMES NOW the Plaintiff, C.M.A., and brings this First Amended Complaint against the Defendants, JEFFREY EPSTEIN an and states as follows: 1. This is an action for damages in excess of $75,000.00, exclusive of interest and costs. 2. This Complaint is brought under a fictitious name in order to protect the identity of the Plaintiff, C.M.A., because this Complaint makes allegation of sexual assault and child abuse of a then minor. 3. At all times material to this cause of action, the Plaintiff, C.M.A., was. A n EXHIBIT 3 oonitblib_ apn Duce Rpm EFTA00087853 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 2 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 4. At all times material to this cause of action, the Defendant, JEFFREY EPSTEIN, had a residence located in Palm Beach County, Florida. 5. At all times material to this cause of action, the Defendant, JEFFREY EPSTEIN, was an adult male, born in 1953. 6. This Court has jurisdiction of this action and the claim set forth herein pursuant to 18 U.S.C. §2255. 7. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial part of the events or omissions giving rise to the claim occurred in this district. 8. At all times material, the Defendant, JEFFREY EPSTEIN, owed a duty unto Plaintiff, C.M.A., to treat her in a non-negligent manner and to not commit intentional or tortious illegal acts against her. Factual Allegations 9. Upon information and belief, the Defendant, JEFFREY EPSTEIN, has demonstrated a sexual preference and obsession for minor girls. He engaged in a plan, scheme, and enterprise in which he gained access to economically disadvantaged minor girls, such as Plaintiff, C.MA., sexually assaulted these girls, and/or coerced them to engage in prostitution, and in return gave these girls money. 10. The Defendants plan, scheme and enterprise included an elaborate system wherein the then minor Plaintiff and other minor girls were brought to the 2 EFTA00087854 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 3 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARFtA/JOHNSON First Amended Complaint Defendant, JEFFREY EPSTEIN'S, residence by the Defendant's employees and assistants. When the employees and assistants left the then minor Plaintiff and other minor girls alone in a room at the Defendant's mansion, the Defendant, JEFFREY EPSTEIN, himself would appear, remove his clothing, and direct the then minor Plaintiff to remove her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including, but not limited to, masturbation, touching of the then minor Plaintiffs breasts and buttock, and solicitation and enticement of the then minor Plaintiff to engage in sexual acts with another female in JEFFREY EPSTEIN'S presence. 11. The Plaintiff, C.M.A., was the first brought to the Defendant, JEFFREY EPSTEIN'S, mansion in late May or early June of 2002, when she was fifteen-years old and in middle school. 12. The Defendant, JEFFREY EPSTEIN, a wealthy financier with a lavish home, significant wealth, a network of assistants and employees, used his resources and his influence over a vulnerable minor child to engage in a systematic pattern of sexually exploitive behavior. 13. Beginning in approximately late May or early June of 2002, and continuing until approximately August of 2003, the Defendant coerced and enticed the impressionable, vulnerable, and economically deprived then minor Plaintiff to commit various acts of sexual misconduct. These acts occurred, on average, one to three times per week from late May or early June of 2002 until August of 2003. At a bare minimum, 3 EFTA00087855 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 4 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80311-CIV-MARRA/JOHNSON First Amended Complaint these acts occurred twice a month from June 2002 until August of 2003. While the precise dates these acts occurred are unknown to Plaintiff, including those weeks in which no acts occurred, these dates are known by Defendant, JEFFREY EPSTEIN, as he is reported to have kept a written log of each and every instance in which he engaged in these illegal acts with the then minor Plaintiff, C.M.A. and others. These acts included, but were not limited to, fondling and inappropriate and illegal sexual touching of the then minor Plaintiff, sexual misconduct and masturbation of the Defendant, JEFFREY EPSTEIN, in the presence of the then minor Plaintiff, soliciting and enticing the then minor Plaintiff to engage in sexual acts with another female in JEFFREY EPSTEIN'S presence, and encouraging the then minor Plaintiff to become involved in prostitution; Defendant, JEFFREY EPSTEIN, committed numerous criminal sexual offenses against the then minor Plaintiff including, but not limited to, sexual battery, solicitation of prostitution, procurement of a minor for the purpose of prostitution, and lewd and lascivious assaults upon the person of the then minor Plaintiff. 14. Defendant, JEFFREY EPSTEIN, used his money, wealth and power to unduly and improperly manipulate and influence the then minor Plaintiff. 15. The acts referenced in paragraphs 9 through 14, committed by Defendant, JEFFREY EPSTEIN, against the then minor Plaintiff, C.M.A., were committed in violation of numerous criminal State and Federal statutes condemning the sexual EFTA00087856 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 5 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint exploitation of minor children, prostitution, sexual performance by a child, lewd and lascivious assaults, sexual battery, contributing the delinquency of a minor and other crimes, specifically including, but not limited to, those crimes designated in 18 USC §2241, §2242, §2243, §2421, and §2423, criminal offenses outlined In Chapter 800 of the Federal Codes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §39.01; and §827.04. 16. The above-described acts took place in Palm Beach County, Florida, at the residence of the Defendant, JEFFREY EPSTEIN. Any assertions by the Defendant, JEFFREY EPSTEIN, that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual exploitation and abuse of a minor child. The Defendant, JEFFREY EPSTEIN, at all times material to this cause of action, knew and should have known of the Plaintiff, C.M.A.'s minority. 17. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, the Defendant, JEFFREY EPSTEIN, entered pleas of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purpose of prostitution. 18. As a condition of that plea, and in exchange for the Federal Government not prosecuting the Defendant, JEFFREY EPSTEIN, for numerous federal offenses, Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the 5 EFTA00087857 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 6 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less". 19. The Defendant, JEFFREY EPSTEIN, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged In this Complaint, and must effectively admit liability to the Plaintiff, C.M.A. COUNT I Cause of Action Pursuant to 18 USC §2255 May/June 2002 20. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 6 EFTA00087858 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 C.M.A. vs. Epstein, et at. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 21. In late May or early June of 2002, C.M.A. was first introduced to Defendant, JEFFREY EPSTEIN. C.M.A. was brought to JEFFREY EPSTEIN'S residence by a female friend of hers. C.M.A. sat on the couch while the female friend took off her own clothes, mounted JEFFREY EPSTEIN who was wearing only a towel and lying on a table, and performed a sexual act upon JEFFREY EPSTEIN in the presence of C.M.A. In exchange for her participation as an observer of JEFFREY EPSTEIN'S lewd and lascivious conduct, C.M.A. was paid $300 by JEFFREY EPSTEIN. 22. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in 7 EFTA00087859 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 23. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 24. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 25. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.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 unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., S EFTA00087860 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 9 of 91 C.MA. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/J0HNS0N First Amended Complaint has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent In nature and the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT II Cause of Action Pursuant to 18 USC §2255 June 2002- Incident 2 26. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 27. Approximately one week after the first incident, C.M.A. received a telephone call from AFFREY EPSTEIN requesting that she return to his residence. On this occasion, JEFFREY EPSTEIN directed C.M.A to undress to her brassiere and underwear and to provide him with a massage. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. $300 for this encounter. 9 EFTA00087861 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 10 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 28. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less? 29. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 10 EFTA00087862 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 11 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 30. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 31. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.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 unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.MA„ will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.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, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 11 EFTA00087863 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 12 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/J0HNS0N First Amended Complaint relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT III Cause of Action Pursuant to 18 USC 42255 July, 2002 — Incident 1 32. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 33. In July of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to undress to her underwear and to provide him with a massage. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 34. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For 12 EFTA00087864 Case 9:08-cv-80811-KAm Document 40 Entered on FLSD Docket 02/09/2009 Page 13 of 91 C.M.A. vs. Epstein, et at Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint s shall provide Mr. Epstein's purposes of implementing this paragraph, the United State red to name in an indictment as attorneys with a list of individuals whom it was prepa authority interpreting this victims of an enumerated offense by Mr. Epstein. Any judicial burde ns if any a Plaintiff must provision, including any authority determining evidentiary these identified victims in meet, shall consider that it is the intent of the parties to place in been convicted at trial. No the same position as they would have been had Mr. Epste more; no less." ses enumerated in 35. The Plaintiff, C.M.A., was a victim of one or more offen asserts a cause of action Title 18, United States Code, Section 2255, and as such this Section of the United against the Defendant, JEFFREY EPSTEIN, pursuant to JEFFREY EPSTEIN, and the States Code and the agreement between the Defendant, United States Government. EPSTEIN, is in the 36. Pursuant to the agreement, the Defendant, JEFFREY sexual offenses committed same position as if he had been tried and convicted of the tively admit liability unto the against the Plaintiff, C.M.A., and as such he must effec Plaintiff, C.M.A. d in Title 18, 37. As a direct and proximate result of the offenses enumerate st the then minor Plaintiff, United States Code, Section 2255, being committed again r, physical injury, pain and C.M.A., has in the past suffered, and will in the future suffe al anguish, humiliation, suffering, emotional distress, psychological trauma, ment 13 EFTA00087865 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 14 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.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, C.MA., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT IV Cause of Action Pursuant to 18 USC 42266 July 2002 — Incident 2 14 EFTA00087866 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 15 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARFUVJOHNSON First Amended Complaint 38. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 39. For the second time in July of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 40. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in 15 EFTA00087867 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 16 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint Epstein been convicted at trial. No the same position as they would have been had Mr. more; no less? enumerated in 41. The Plaintiff, C.M.A., was a victim of one or more offenses as such asserts a cause of action Title 18, United States Code, Section 2255, and this Section of the United against the Defendant, JEFFREY EPSTEIN, pursuant to JEFFREY EPSTEIN, and the States Code and the agreement between the Defendant, United States Government. EPSTEIN, is in the 42. Pursuant to the agreement, the Defendant, JEFFREY sexual offenses committed same position as if he had been tried and convicted of the tively admit liability unto the against the Plaintiff, C.M.A., and as such he must effec Plaintiff, C.M.A. erated in Title 18, 43. As a direct and proximate result of the offenses enum st the then Minor Plaintiff, United States Code, Section 2255, being committed again suffer, physical injury, pain and C.M.A., has in the past suffered, and will in the future mental anguish, humiliation, suffering, emotional distress, psychological trauma, ion of her privacy and other embarrassment, loss of self-esteem, loss of dignity, invas controlling, manipulating and damages associated with Defendant, JEFFREY EPSTEIN, for a minor. The then minor coercing her into a perverse and unconventional way of life and the Plaintiff, C.M.A., will in Plaintiff incurred medical and psychological expenses nses. The Plaintiff, C.M.A., the future suffer additional medical and psychological expe 16 EFTA00087868 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 17 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/J0HNS0N First Amended Complaint has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These Injuries are permanent in nature and the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT V Cause of Action Pursuant to 18 USC §2255 August of 2002 - Incident 1 44. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 45. In August of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 17 EFTA00087869 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 18 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint criminal plea, and 46. As a condition of the Defendant, JEFFREY EPSTEIN's cuting the Defendant for numerous in exchange for the Federal Government not prose additionally entered into an federal offenses, the Defendant, JEFFREY EPSTEIN, ing: Any person, who while a agreement with the Federal Government to the follow 18, United States Code, Section minor, was a victim of an offense enumerated in Title n 2255 as she would have had, 2255, will have the same rights to proceed under sectio of an enumerated offense. For if Mr. Epstein had been tried federally and convicted s shall provide Mr. Epstein's purposes of implementing this paragraph, the United State to name in an indictment as attorneys with a list of individuals whom it was prepared judicial authority interpreting this victims of an enumerated offense by Mr. Epstein. Any ntiary burdens if any a Plaintiff must provision, including any authority determining evide place these identified victims in meet, shall consider that it is the intent of the parties to in been convicted at trial. No the same position as they would have been had Mr. Epste more; no less? ses enumerated in 47. The Plaintiff, C.M.A., was a victim of one or more offen as such asserts a cause of action Title 18, United States Code, Section 2255, and to this Section of the United against the Defendant, JEFFREY EPSTEIN, pursuant JEFFREY EPSTEIN, and the States Code and the agreement between the Defendant, United States Government. 18 EFTA00087870 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 19 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint EPSTEIN, is in the 48. Pursuant to the agreement, the Defendant, JEFFREY cted of the sexual offenses committed same position as if he had been tried and convi effectively admit liability unto the against the Plaintiff, C.M.A., and as such he must Plaintiff, C.M.A. erated in Title 18, 49. As a direct and proximate result of the offenses enum against the then minor Plaintiff, United States Code, Section 2255, being committed suffer, physical injury, pain and C.M.A., has in the past suffered, and will in the future mental anguish, humiliation, suffering, emotional distress, psychological trauma, ion of her privacy and other embarrassment, loss of self-esteem, loss of dignity, invas controlling, manipulating and damages associated with Defendant, JEFFREY EPSTEIN, for a minor. The then minor coercing her into a perverse and unconventional way of life and the Plaintiff, C.M.A., will in Plaintiff incurred medical and psychological expenses expenses. The Plaintiff, C.MA., the future suffer additional medical and psychological earn income in the future, and a has suffered a loss of income, a loss of the capacity to permanent in nature and the loss of the capacity to enjoy life. These injuries are . Plaintiff, C.M.A., will continue to suffer these losses in the future against the Defendant, WHEREFORE, the Plaintiff, C.M.A., demands judgment least the minimum amount JEFFREY EPSTEIN, for compensatory damages of at , and such other and further provided by law, punitive damages, attorney's fees, costs 19 EFTA00087871 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 20 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT VI Cause of Action Pursuant to 18 USC 42255 August of 2002 — Incident 2 50. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 51. For the second time in August of 2002, C.MA. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 52. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Govemment to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 20 EFTA00087872 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 21 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the Intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 53. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated In Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 54. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.R., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 55. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical Injury, pain and 21 EFTA00087873 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 22 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/J0HNS0N First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.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 aro permanent in nature and the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT VII Cause of Action Pursuant to 18 USC §2255 September of 2002 — Incident 1 56. The. Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 22 EFTA00087874 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 23 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint REY EPSTEIN'S 57. In September of 2002, C.M.A. again returned to JEFF EPSTEIN directed C.M.A to fully residence at his request. On this occasion, JEFFREY JEFFREY EPSTEIN, fondled undress and to provide him with a massage. Defendant, the conclusion of the massage, the breasts and buttocks of the then minor C.M.A. At presence. JEFFREY EPSTEIN JEFFREY EPSTEIN masturbated himself in C.M.A.'s paid C.M.A. in excess of $200 for this encounter. criminal plea, and 58. As a condition of the Defendant, JEFFREY EPSTEIN's the Defendant for nume rous in exchange for the Federal Government not prosecuting additionally enter ed into an federal offenses, the Defendant, JEFFREY EPSTEIN, ing: "Any person, who while a agreement with the Federal Government to the follow 18, United States Code, Section minor, was a victim of an offense enumerated in Title as she would have had, 2255, will have the same rights to proceed under section 2255 of an enumerated offense. For if Mr. Epstein had been tried federally and convicted s shall provide Mr. Epstein's purposes of Implementing this paragraph, the United State to name in an indictment as attorneys with a list of individuals whom it was prepared authority interpreting this victims of an enumerated offense by Mr. Epstein. Any judicial ns if any a Plaintiff must provision, including any authority determining evidentiary burde these identified victims in meet, shall consider that it is the intent of the parties to place in been convicted at trial. No the same position as they would have been had Mr. Epste more; no less? 23 EFTA00087875 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 24 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 59. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 60. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 61. As a direct and proximate result of the offenses enumerated in Tdle 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.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 unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., has suffered a loss of income, a loss of the capacity to earn income in the future, and a 24 EFTA00087876 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 25 of 91 C.MA. vs. Epstein, et at. Case No.: 08-CV-80811-CIV-MARFtA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by Jury on all issues triable as of right by a jury. COUNT VIII Cause of Action Pursuant to 18 USC §2255 September of 2002 — Incident 2 62. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 63. For the second time in September of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.MA. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 25 EFTA00087877 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 26 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 64. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less?" 65. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 26 EFTA00087878 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 27 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARFtA/J0HNSON First Amended Complaint 66. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.MA. 67. As a direct and proximate result of the offenses enumerated In Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.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 unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.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, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 27 EFTA00087879 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 28 of 91 C.M.A. vs. Epstein, et at Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT IX Cause of Action Pursuant to 18 USC V255 October of 2002 — Incident 1 68. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 69. In October of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.MA.'s presence. JEFFREY EPSTEIN paid C.M.A. In excess of $200 for this encounter. 70. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 28 EFTA00087880 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 29 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr: Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 71. The Plaintiff, C.MA., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 72. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 73. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and 29 EFTA00087881 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 30 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her Into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.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, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all Issues triable as of right by a jury, COUNT X Cause of Action Pursuant to 18 USC 42255 October of 2002 - Incident 2 30 EFTA00087882 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 31 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 74. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 75. For the second time in October of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 76. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of Individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in 31 EFTA00087883 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 32 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRNJOHNSON First Amended Complaint the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 77. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 78. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 79. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255,. being committed against the then minor Plaintiff, C.M.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 unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., 32 EFTA00087884 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 33 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.MA., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XI Cause of Action Pursuant to 18 USC §22S5 November of 2002 — Incident 1 80. The Plaintiff, C.MA., adopts and realleges paragraphs 1 through 19 above. 81. In November of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself In C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 33 EFTA00087885 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 34 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 82. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United Slates shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.' 83. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 34 EFTA00087886 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 35 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 84. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 85. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.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 unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.MA., 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, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 35 EFTA00087887 Document 40 Entered on FLSD Docket 02/09/2009 Page 36 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint hereby demands trial by jury on all relief as this Court deems just and proper, and issues triable as of right by a jury. COUNT XII Cause of Action Pursuant to 18 USC §2255 November of 2002 — Incident 2 raphs 1 through 19 86. The Plaintiff, C.M.A., adopts and realleges parag above. . again returned to 87. For the second time in November of 2002, C.M.A ion, JEFFREY EPSTEIN JEFFREY EPSTEIN'S residence at his request. On this occas with a massage. Defendant, directed C.M.A to fully undress and to provide him then minor C.M.A. At the JEFFREY EPSTEIN, fondled the breasts and buttocks of the urbated himself in C.M.A.'s conclusion of the massage, JEFFREY EPSTEIN mast for this encounter. presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 criminal plea, and 88. As a condition of the Defendant, JEFFREY EPSTEIN's the Defendant for numerous in exchange for the Federal Government not prosecuting additionally entered into an federal offenses, the Defendant, JEFFREY EPSTEIN, person, who while a agreement with the Federal Government to the following: "Any United States Code, Section minor, was a victim of an offense enumerated In Title 18, as she would have had, 2255, will have the same rights to proceed under section 2255 36 EFTA00087888 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 37 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 89. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated In Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 90. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 91. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and 37 EFTA00087889 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 38 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.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, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XIII Cause of Action Pursuant to 18 USC $2255 December of 2002 — Incident 1 92. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 38 EFTA00087890 Document 40 Entered on FLSD Docket 02/09/2009 Page 39 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint JEFFREY EPSTEIN'S 93. In December of 2002, C.M.A. again returned to EPSTEIN directed C.M.A to fully residence at his request. On this occasion, JEFFREY JEFFREY EPSTEIN, fondled undress and to provide him with a massage. Defendant, At the conclusion of the massage, the breasts and buttocks of the then minor C.M.A. presence. JEFFREY EPSTEIN JEFFREY EPSTEIN masturbated himself. in C.M.A.'s paid C.M.A. in excess of $200 for this encounter. criminal plea, and 94. As a condition of the Defendant, JEFFREY EPSTEIN's the Defendant for numerous In exchange for the Federal Government not prosecuting additionally entered into an federal offenses, the Defendant, JEFFREY EPSTEIN, ing: "Any person, who while a agreement with the Federal Government to the follow 18, United States Code, Section minor, was a victim of an offense enumerated in Title as she would have had, 2255, will have the same rights to proceed under section 2255 of an enum erated offense. For if Mr. Epstein had been tried federally and convicted s shall provide Mr. Epstein's purposes of Implementing this paragraph, the United State to name in an indictment as attorneys with a list of individuals whom it was prepared al authority interpreting this victims of an enumerated offense by Mr. Epstein. Any judici ns if any a Plaintiff must provision, including any authority determining evidentiary burde these identified victims in meet, shall consider that it is the intent of the parties to place in been convicted at trial. No the same position as they would have been had Mr. Epste more; no less." 39 EFTA00087891 Document 40 Entered on FLSD Docket 02/09/2009 Page 40 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint ses enumerated in 95. The Plaintiff, C.M.A., was a victim of one or more offen as such asserts a cause of action Title 18, United States Code, Section 2255, and to this Section of the United against the Defendant, JEFFREY EPSTEIN, pursuant JEFFREY EPSTEIN, and the States Code and the agreement between the Defendant, United States Government. EPSTEIN, is in the 96. Pursuant to the agreement, the Defendant, JEFFREY of the sexual offenses committed same position as if he had been tried and convicted effectively admit liability unto the against the Plaintiff, C.M.A., and as such he must Plaintiff, C.M.A. erated in Title 18, 97. As a direct and proximate result of the offenses enum against the then minor Plaintiff, United States Code; Section 2255, being committed suffer, physical injury, pain and C.M.A., has in the past suffered, and will in the future mental anguish, humiliation, suffering, emotional distress, psychological trauma, ion of her privacy and other embarrassment, loss of self-esteem, loss of dignity, invas controlling, manipulating and damages associated with Defendant, JEFFREY EPSTEIN, for a minor. The then minor coercing her into a perverse and unconventional way of life the Plaintiff, C.MA., will in Plaintiff incurred medical and psychological expenses and nses. The Plaintiff, C.M.A., the future suffer additional medical and psychological expe income in the future, and a has suffered a loss of income, a loss of the capacity to earn 40 EFTA00087892 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 41 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.MA., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XIV Cause of Action Pursuant to 18 USC §2255 December of 2002 — Incident 2 98. The Plaintiff, C.MA., adopts and realleges paragraphs 1 through 19 above. 99. For the second time in December of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself In C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 41 EFTA00087893 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 42 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 100. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 101. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 42 EFTA00087894 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 43 of 91 C.M.A. vs. Epstein, et al, Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 102. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 103. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.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 unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.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, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 43 EFTA00087895 Document 40 Entered on FLSD Docket 02/09/2009 Page 44 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint y demands trial by jury on all relief as this Court deems just and proper, and hereb issues triable as of right by a jury. COUNT XV Cause of Action Pursuant to 18 USC 42255 January of 2003 — Incident 1 parag raphs 1 through 19 104. The Plaintiff, C.M.A., adopts and realleges above. to JEFF REY EPSTEIN'S 105. In January of 2003, C.M.A. again returned EPSTEIN directed C.M.A to fully residence at his request. On this occasion, JEFFREY JEFFREY EPSTEIN, fondled undress and to provide him with a massage. Defendant, conclusion of the massage, the breasts arid buttocks of the then minor C.M.A. At the presence. JEFFREY EPSTEIN JEFFREY EPSTEIN masturbated himself in C.M.A.'s paid C.M.A. in excess of $200 for this encounter. crimi nal plea, and 106. As a condition of the Defendant, JEFFREY EPSTEIN's the Defendant for numerous in exchange for the Federal Government not prosecuting additionally entered into an federal offenses, the Defendant, JEFFREY EPSTEIN, "Any person, who while a agreement with the Federal Government to the following: United States Code, Section minor, was a victim of an offense enumerated in Title 18, as she would have had, 2255, will have the same rights to proceed under section 2255 44 EFTA00087896 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 45 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less? 107. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 108. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 109. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and 45 EFTA00087897 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 46 of 91 C.M.A. vs. Epstein, et al. Case No.: 0B-CV-80811-CIV-MARRNJOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her Into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.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, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by Jury on all issues triable as of right by a jury. COUNT XVI Cause of Action Pursuant to 18 USC 42255 January of 2003 — Incident 2 110. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 46 EFTA00087898 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 47 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 111. For the second time in January of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself In C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 112. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 47 EFTA00087899 Case 9:08-cv-80811-KAM Document 40 Entered on F LSD Docket 02/09/2009 Page 48 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 113. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 114. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 115. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.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 unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., has suffered a loss of income, a loss of the capacity to earn income in the future, and a 48 EFTA00087900 Document 40 Entered on FLSD Docket 02/09/2009 Page 49 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAJJOHNSON First Amended Complaint permanent in nature and the loss of the capacity to enjoy life. These injuries are future. Plaintiff, C.MA., will continue to suffer these losses in the against the Defendant, WHEREFORE, the Plaintiff, C.M.A., demands judgment least the minimum amount JEFFREY EPSTEIN, for compensatory damages of at , and such other and further provided by law, punitive damages, attorney's fees, costs demands trial by jury on all relief as this Court deems just and proper, and hereby issues triable as of right by a jury. COUNT XVII Cause of Action Pursuant to 18 USC 42255 February of 2003 — Incident 1 raphs 1 through 19 116. The Plaintiff, C.M.A., adopts and realleges parag above. REY EPSTEIN'S 117. In February of 2003, C.M.A. again returned to JEFF EIN directed C.M.A to fully residence at his request On this occasion, JEFFREY EPST REY EPSTEIN, fondled undress and to provide him with a massage. Defendant, JEFF conclusion of the mass age, the breasts and buttocks of the then minor C.M.A. At the nce. JEFFREY EPSTEIN JEFFREY EPSTEIN masturbated himself in C.M.A.'s prese paid C.M.A. in excess of $200 for this encounter. 49 EFTA00087901 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 50 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 118. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom It was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens If any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 119. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 50 EFTA00087902 Document 40 Entered on FLSD Docket 02/09/2009 Page 51 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, etas. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint REY EPSTEIN, is in the 120. Pursuant to the agreement, the Defendant, JEFF the sexual offenses committed same position as if he had been tried and convicted of tively admit liability unto the against the Plaintiff, C.M.A., and as such he must effec Plaintiff, C.M.A. enum erated in Title 18, 121. As a direct and proximate result of the offenses against the then minor Plaintiff, United States Code, Section 2255, being committed suffer, physical injury, pain and C.M.A., has in the past suffered, and will in the future al anguish, humiliation, suffering, emotional distress, psychological trauma, ment ion of her privacy and other embarrassment, loss of self-esteem, loss of dignity, invas controlling, manipulating and damages associated with Defendant, JEFFREY EPSTEIN, life for a minor. The then minor coercing her into a perverse and unconventional way of Plaintiff, C.M.A., will in Plaintiff incurred medical and psychological expenses and the nses. The Plaintiff, C.M.A., the future suffer additional medical and psychological expe e in the future, and a has suffered a loss of income, a loss of the capacity to earn incom anent in nature and the loss of the capacity to enjoy life. These injuries are perm . Plaintiff, C.M.A., will continue to suffer these losses in the future st the Defendant, WHEREFORE, the Plaintiff, C.M.A., demands judgment again the minimum amount JEFFREY EPSTEIN, for compensatory damages of at least such other and further provided by law, punitive damages, attorney's fees, costs, and 51 EFTA00087903 Document 40 Entered on FLSD Docket 02/09/2009 Page 52 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint hereby demands trial by jury on all relief as this Court deems just and proper, and issues triable as of right by a jury. COUNT XVIII Cause of Action Pursuant to 18 USC 42255 February of 2003 — Incident 2 raphs 1 through 19 122. The Plaintiff, C.M.A., adopts and realleges parag above. C.M.A . again returned to 123. For the second time in February of 2003, ion, JEFFREY EPSTEIN JEFFREY EPSTEIN'S residence at his request. On this occas with a massage. Defendant, directed C.M.A to fully undress and to provide him then minor C.M.A. At the JEFFREY EPSTEIN, fondled the breasts and buttocks of the urbated himself in C.M.A.'s conclusion of the massage, JEFFREY EPSTEIN mast for this encounter. presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 EPSTEIN's criminal plea, and 124. As a condition of the Defendant, JEFFREY Defendant for numerous in exchange for the Federal Government not prosecuting the additionally entered into an federal offenses, the Defendant, JEFFREY EPSTEIN, "Any person, who while a agreement with the Federal Government to the following: United States Code, Section minor, was a victim of an offense enumerated In Title 18, as she would have had, 2255, will have the same rights to proceed under section 2255 52 EFTA00087904 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 53 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the Intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 125. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 126. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 127. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and 53 EFTA00087905 Case 9:08-cv-80811-KAM Docuinent 40 Entered on FLSD Docket 02/09/2009 Page 54 of 91 G.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOI•INSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.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, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XIX Cause of Action Pursuant to 18 USC §2255 March of 2003 — Incident 1 128. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 54 EFTA00087906 Document 40 Entered on FLSD Docket 02/09/2009 Page 55 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint to JEFFREY EPSTEIN'S 129. In March of 2003, C.M.A. again returned EPSTEIN directed C.M.A to fully residence at his request. On this occasion, JEFFREY dant, JEFFREY EPSTEIN, fondled undress and to provide him with a massage. Defen the conclusion of the massage, the breasts and buttocks of the then minor C.M.A. At presence. JEFFREY EPSTEIN JEFFREY EPSTEIN masturbated himself in C.M.A.'s paid C.M.A. in excess of $200 for this encounter. EPSTEIN's criminal plea, and 130. As a condition of the Defendant, JEFFREY the Defendant for numerous in exchange for the Federal Government not prosecuting additionally entered into an federal offenses, the Defendant, JEFFREY EPSTEIN, "Any person, who while a agreement with the Federal Govemment to the following: 18, United States Code, Section minor, was a victim of an offense enumerated in Title as she would have had, 2255, will have the same rights to proceed under section 2255 of an enumerated offense. For if Mr. Epstein had been tried federally and convicted s shall provide Mr. Epstein's purposes of implementing this paragraph, the United State to name in an indictment as attorneys with a list of individuals whom it was prepared authority interpreting this victims of an enumerated offense by Mr. Epstein. Any judicial ns if any a Plaintiff must provision, including any authority determining evidentiary burde these identified victims in meet, shall consider that it is the intent of the parties to place in convicted at trial. No the same position as they would have been had Mr. Epste been more; no less." 55 EFTA00087907 Document 40 Entered on FLSD Docket 02/09/2009 Page 56 of 91 Case 9:08-cv-80811-KAM C.M.A vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAJJOHNSON First Amended Complaint ses enumerated in 131. The Plaintiff, C.M.A., was a victim of one or more offen such asserts a cause of action Title 18, United States Code, Section 2255, and as to this Section of the United against the Defendant, JEFFREY EPSTEIN, pursuant JEFFREY EPSTEIN, and the States Code and the agreement between the Defendant, United States Government. EPSTEIN, is in the 132. Pursuant to the agreement, the Defendant, JEFFREY sexual offenses committed same position as if he had been tried and convicted of the tively admit liability unto the against the Plaintiff, C.M.A., and as such he must effec Plaintiff, C.M.A. erate d in Title 18, 133. As a direct and proximate result of the offenses enum st the then minor Plaintiff, United States Code, Section 2255, being committed again r, physical injury, pain and C.M.A., has in the past suffered, and will in the future suffe al anguish, humiliation, suffering, emotional distress, psychological trauma, ment of her privacy and other embarrassment, loss of self-esteem, loss of dignity, invasion controlling, manipulating and damages associated with Defendant, JEFFREY EPSTEIN, for a minor. The then minor coercing her into a perverse and unconventional way of life Plaintiff, C.MA., will in Plaintiff incurred medical and psychological expenses and the The Plaintiff, C.M.A., the future suffer additional medical and psychological expenses. e in the future, and a has suffered a loss of income, a loss of the capacity to earn incom 56 EFTA00087908 Document 40 Entered on FLSD Docket 02/09/2009 Page 57 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARFtA/JOHNSON First Amended Complaint are permanent in nature and the loss of the capacity to enjoy life. These injuries in the future. Plaintiff, C.M.A., will continue to suffer these losses against the Defendant, WHEREFORE, the Plaintiff, C.M.A., demands judgment at least the minimum amount JEFFREY EPSTEIN, for compensatory damages of , and such other and further provided by law, punitive damages, attorney's fees, costs hereby demands trial by jury on all relief as this Court deems just and proper, and issues triable as of right by a jury. COUNT XX Cause of Action Pursuant to 18 USC 42255 March of 2003 — Incident 2 raphs 1 through 19 134. The Plaintiff, C.M.A., adopts and realleges parag above. return ed to JEFFREY 135. For the second time in March of 2003, C.M.A. again JEFFREY EPSTEIN directed EPSTEIN'S residence at his request. On this occasion, age. Defendant, JEFFREY C.M.A to fully undress and to provide him with a mass minor C.M.A. At the conclusion EPSTEIN, fondled the breasts and buttocks of the then elf in C.M.A.'s presence. of the massage, JEFFREY EPSTEIN masturbated hims encounter. JEFFREY EPSTEIN paid C.M.A. In excess of $200 for this 57 EFTA00087909 Document 40 Entered on FLSD Docket 02/09/2009 Page 58 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAIJOHNSON First Amended Complaint EPSTEIN's criminal plea, and 136. As a condition of the Defendant, JEFFREY cuting the Defendant for numerous in exchange for the Federal Government not prose additionally entered into an federal offenses, the Defendant, JEFFREY EPSTEIN, ing: "Any person, who while a agreement with the Federal Government to the follow 18, United States Code, Section minor, was a victim of an offense enumerated in Title n 2255 as she would have had, 2255, will have the same rights to proceed under sectio of an enumerated offense. For if Mr. Epstein had been tried federally and convicted s shall provide Mr. Epstein's purposes of implementing this paragraph, the United State red to name in an indictment as attorneys with a list of individuals whom it was prepa judicial authority interpreting this victims of an enumerated offense by Mr. Epstein. Any burdens if any a Plaintiff must provision, including any authority determining evidentiary these identified victims in meet, shall consider that it is the intent of the parties to place in been convicted at trial. No the same position as they would have been had Mr. Epste more; no less." ses enumerated in 137. The Plaintiff, C.M.A., was a victim of one or more offen ts a cause of action Title 18, United States Code, Section 2255, and as such asser this Section of the United against the Defendant, JEFFREY EPSTEIN, pursuant to REY EPSTEIN, and the States Code and the agreement between the Defendant, JEFF United States Government. 58 EFTA00087910 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 59 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 138. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, 139. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.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 unconventional way of life for a minor. The then minor Plaintiff incurred medical arid psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.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, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 59 EFTA00087911 Document 40 Entered on FLSD Docket 02/09/2009 Page 60 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint hereby demands trial by jury on all relief as this Court deems just and proper, and issues triable as of right by a Jury. COUNT XXI Cause of Action Pursuant to 18 USC 82255 April of 2003 — ncident 1 parag raphs 1 through 19 140. The Plaintiff, C.M.A., adopts and realleges above. REY EPST EIN'S residence 141. In April of 2003, C.M.A. again returned to JEFF directed C.M.A to fully undress at his request. On this occasion, JEFFREY EPSTEIN REY EPSTEIN, fondled the and to provide him with a massage. Defendant, JEFF conclusion of the massage, breasts and buttocks of the then minor C.M.A. At the presence. JEFFREY EPSTEIN JEFFREY EPSTEIN masturbated himself in C.M.A.'s paid C.M.A. in excess of $200 for this encounter. EIN's criminal plea, and 142. As a condition of the Defendant, JEFFREY EPST Defendant for numerous in exchange for the Federal Government not prosecuting the additionally entered into an federal offenses, the Defendant, JEFFREY EPSTEIN, "Any person, who while a agreement with the Federal Government to the following: United States Code, Section minor, was a victim of an offense enumerated in Title 18, as she would have had, 2255, will have the same rights to proceed under section 2255 60 EFTA00087912 Case 9:08-cv-80811-KAM Document 40 Entered on F LSD Docket 02/09/2009 Page 61 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that It is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 143. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 144. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 145. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and 61 EFTA00087913 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 62 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.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, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XXII Cause of Action Pursuant to 18 USC $2255 April of 2003 — Incident 2 146. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 62 EFTA00087914 Document 40 Entered on FLSD Docket 02/09/2009 Page 63 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint return ed to JEFFREY 147. For the second time in April of 2003, C.M.A. again JEFFREY EPSTEIN directed EPSTEIN'S residence at his request. On this occasion, age. Defendant, JEFFREY C.M.A to fully undress and to provide him with a mass mino r C.M.A. At the conclusion EPSTEIN, fondled the breasts and buttocks of the then ed himself in C.M.A.'s presence. of the massage, JEFFREY EPSTEIN masturbat this encounter. JEFFREY EPSTEIN paid C.M.A. In excess of $200 for EPSTEIN's criminal plea, and 148. As a condition of the Defendant, JEFFREY the Defendant for numerous in exchange for the Federal Government not prosecuting additionally entered into an federal offenses, the Defendant, JEFFREY EPSTEIN, "Any person, who while a agreement with the Federal Government to the following: 18, United States Code, Section minor, was a victim of an offense enumerated in Title as she would have had, 2255, will have the same rights to proceed tinder section 2255 of an enumerated offense. For if Mr. Epstein had been tried federally and convicted provide Mr. Epstein's purposes of Implementing this paragraph, the United States shall to name in an indictment as attorneys with a list of individuals whom it was prepared al authority interpreting this victims of an enumerated offense by Mr. Epstein. Any judici ns if any a Plaintiff must provision, including any authority determining evidentiary burde these identified victims in meet, shall consider that it is the intent of the parties to place in been convicted at trial. No the same position as they would have been had Mr. Epste more; no less." 63 EFTA00087915 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 64 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-Cht-MARFtA/JOHNSON First Amended Complaint 149. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 150. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 151. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.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 unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will In the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., has suffered a loss of income, a loss of the capacity to earn income in the future, and a 64 EFTA00087916 Document 40 Entered on FLSD Docket 02/09/2009 Page 65 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint permanent in nature and the loss of the capacity to enjoy life. These injuries are future. Plaintiff, C.M.A., will continue to suffer these losses in the against the Defendant WHEREFORE, the Plaintiff, C.M.A., demands judgment at least the minimum amount JEFFREY EPSTEIN, for compensatory damages of , and such other and further provided by law, punitive damages, attorney's fees, costs y demands trial by jury on all relief as this Court deems just and proper, and hereb issues triable as of right by a jury. COUNT XXIII Cause of Action Pursuant to 18 USC §2255 May of 2003 — Incident 1 raphs 1 through 19 152. The Plaintiff, C.MA., adopts and realleges parag above. EPST EIN'S residence 153. In May of 2003, C.M.A. again returned to JEFFREY directed C.M.A to fully undress at his request. On this occasion, JEFFREY EPSTEIN REY EPSTEIN, fondled the and to provide him with a massage. Defendant, JEFF the conclusion of the massage, breasts and buttocks of the then minor C.MA. At nce. JEFFREY EPSTEIN JEFFREY EPSTEIN masturbated himself in C.M.A.'s prese paid C.M.A. in excess of $200 for this encounter. 65 EFTA00087917 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 66 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 154. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it Is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 155. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 66 EFTA00087918 Document 40 Entered on FLSD Docket 02/09/2009 Page 67 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint JEFF REY EPSTEIN, is in the 156. Pursuant to the agreement, the Defendant, of the sexual offenses committed same position as if he had been tried and convicted tively admit liability unto the against the Plaintiff, C.M.A., and as such he must effec Plaintiff, C.M_A. enum erated in Title 18, 157. As a direct and proximate result of the offenses against the then minor Plaintiff, United States Code, Section 2255, being committed suffer, physical injury, pain and C.M.A., has in the past suffered, and will in the future mental anguish, humiliation, suffering, emotional distress, psychological trauma, ion of her privacy and other embarrassment, loss of self-esteem, loss of dignity, invas controlling, manipulating and damages associated with Defendant, JEFFREY EPSTEIN, life for a minor. The then minor coercing her into a perverse and unconventional way of and the Plaintiff, C.M.A., will in Plaintiff incurred medical and psychological expenses expenses. The Plaintiff, C.M.A., the future suffer additional medical and psychological e in the future, and a has suffered a loss of income, a loss of the capacity to earn incom permanent in nature and the loss of the capacity to enjoy life. These injuries are . Plaintiff, C.M.A., will continue to suffer these losses in the future st the Defendant, WHEREFORE, the Plaintiff, C.M.A., demands judgment again least the minimum amount JEFFREY EPSTEIN, for compensatory damages of at , and such other and further provided by law, punitive damages, attorney's fees, costs 67 EFTA00087919 Document 40 Entered on FLSD Docket 02/09/2009 Page 68 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint y demands trial by jury on all relief as this Court deems just and proper, and hereb issues triable as of right by a jury. COUNT XXIV Cause of Action Pursuant to 18 USC 42255 May of 2003 — Incident 2 paragraphs 1 through 19 158. The Plaintiff, C.M.A., adopts and realleges above. again returned to JEFFREY 159. For the second time in May of 2003, C.M.A. JEFFREY EPSTEIN directed EPSTEIN'S residence at his request. On this occasion, age. Defendant, JEFFREY C.M.A to fully undress and to provide him with a mass r C.M.A. At the conclusion EPSTEIN, fondled the breasts and buttocks of the then mino himself in C.M.A.'s presence. of the massage, JEFFREY EPSTEIN masturbated encounter. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this EIN's criminal plea, and 160. As a condition of the Defendant, JEFFREY EPST g the Defendant for numerous in exchange for the Federal Government not prosecutin additionally entered into an federal offenses, the Defendant, JEFFREY EPSTEIN, ing: "Any person, who while a agreement with the Federal Government to the follow 18, United States Code, Section minor, was a victim of an offense enumerated in Title as she would have had, 2255, will have the same rights to proceed under section 2255 68 EFTA00087920 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 69 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint of an enumerated offense. For if Mr. Epstein had been tried federally and convicted s shall provide Mr. Epstein's purposes of implementing this paragraph, the United State red to name in an indictment as attorneys with a list of individuals whom it was prepa judicial authority interpreting this victims of an enumerated offense by Mr. Epstein. Any burde ns if any a Plaintiff must provision, including any authority determining evidentiary these identified victims in meet, shall consider that it is the intent of the parties to place Epstein been convicted at trial. No the same position as they would have been had Mr. more; no less." offen ses enumerated in 161. The Plaintiff, C.M.A., was a victim of one or more asserts a cause of action Title 18, United States Code, Section 2255, and as such this Section of the United against the Defendant, JEFFREY EPSTEIN, pursuant to REY EPSTEIN, and the States Code and the agreement between the Defendant, JEFF United States Government. EPST EIN, is in the 162. Pursuant to the agreement, the Defendant, JEFFREY sexual offenses committed same position as if he had been tried and convicted of the admit liability unto the against the Plaintiff, C.M.A., and as such he must effectively Plaintiff, C.M.A. erate d in Title 18, 163. As a direct and proximate result of the offenses enum the then minor Plaintiff, United States Code, Section 2255, being committed against physical injury, pain and C.M.A., has in the past suffered, and will in the future suffer, 69 EFTA00087921 Document 40 Entered on FLSD Docket 02/09/2009 Page 70 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint mental anguish, humiliation, suffering, emotional distress, psychological trauma, ion of her privacy and other embarrassment, loss of self-esteem, loss of dignity, invas EIN, controlling, manipulating and damages associated with Defendant, JEFFREY EPST life for a minor. The then minor coercing her into a perverse and unconventional way of and the Plaintiff, C.M.A., will in Plaintiff incurred medical and psychological expenses expenses. The Plaintiff, C.M.A., the future suffer additional medical and psychological earn income In the future, and a has suffered a loss of income, a loss of the capacity to permanent in nature and the loss of the capacity to enjoy life. These injuries are . Plaintiff, C.M.A., will continue to suffer these losses in the future st the Defendant, WHEREFORE, the Plaintiff, C.M.A., demands judgment again least the minimum amount JEFFREY EPSTEIN, for compensatory damages of at such other and further provided by law, punitive damages, attorney's fees, costs, and demands trial by jury on all relief as this Court deems just and proper, and hereby issues triable as of right by a jury. COUNT XXV Cause of Action Pursuant to 18 USC 42255 June of 2003 — Incident 1 1 throu gh 19 164. The Plaintiff, C.M.A., adopts and realleges paragraphs above. 70 EFTA00087922 Document 40 Entered on FLSD Docket 02/09/2009 Page 71 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint to JEFFREY EPSTEIN'S 165. In June of 2003, C.M.A. again returned EPSTEIN directed C.M.A to fully residence at his request. On this occasion, JEFFREY JEFFREY EPSTEIN, fondled undress and to provide him with a massage. Defendant, At the conclusion of the massage, the breasts and buttocks of the then minor C.M.A. presence. JEFFREY EPSTEIN JEFFREY EPSTEIN masturbated himself in C.M.A.'s paid C.M.A. in excess of $200 for this encounter. EPSTEIN's criminal plea, and 166. As a condition of the Defendant, JEFFREY cuting the Defendant for numerous in exchange for the Federal Government not prose EIN, additionally entered into an federal offenses, the Defendant, JEFFREY EPST ing: 'Any person, who white a agreement with the Federal Government to the follow 18, United States Code, Section minor, was a victim of an offense enumerated in Title n 2255 as she would have had, 2255, will have the same rights to proceed under sectio enumerated offense. For if Mr. Epstein had been tried federally and convicted of an s shall provide Mr. Epstein's purposes of implementing this paragraph, the United State red to name in an indictment as attorneys with a list of individuals whom It was prepa authority interpreting this victims of an enumerated offense by Mr. Epstein. Any judicial ns if any a Plaintiff must provision, including any authority determining evidentiary burde these identified victims In meet, shall consider that it is the intent of the parties to place in been convicted at trial. No the same position as they would have been had Mr. Epste more; no less? 71 EFTA00087923 Document 40 Entered on FLSD Docket 02/09/2009 Page 72 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint more offen ses enumerated in 167. The Plaintiff, C.M.A., was a victim of one or as such asserts a cause of action Title 18, United States Code, Section 2255, and to this Section of the United against the Defendant, JEFFREY EPSTEIN, pursuant ndant, JEFFREY EPSTEIN, and the States Code and the agreement between the Defe United States Government. JEFFREY EPSTEIN, is in the 168. Pursuant to the agreement, the Defendant, of the sexua l offenses committed same position as if he had been tried and convicted tively admit liability unto the against the Plaintiff, C.M.A., and as such he must effec Plaintiff, C.M.A. enum erated in Title 18, 169. As a direct and proximate result of the offenses against the then minor Plaintiff, United States Code, Section 2255, being committed r, physical injury, pain and C.M.A., has in the past suffered, and will In the future suffe mental anguish, humiliation, suffering, emotional distress, psychological trauma, ion of her privacy and other embarrassment, loss of self-esteem, loss of dignity, invas controlling, manipulating and damages associated with Defendant, JEFFREY EPSTEIN, for a minor. The then minor coercing her into a perverse and unconventional way of life the Plaintiff, C.M.A., will in Plaintiff incurred medical and psychological expenses and nses. The Plaintiff, C.M.A., the future suffer additional medical and psychological expe Income in the future, and a has suffered a loss of income, a loss of the capacity to earn 72 EFTA00087924 Document 40 Entered on FLSD Docket 02/09/2009 Page 73 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint permanent in nature and the loss of the capacity to enjoy life. These injuries are in the future. Plaintiff, C.M.A., will continue to suffer these losses ent against the Defendant, WHEREFORE, the Plaintiff, C.M.A., demands judgm of at least the minimum amount JEFFREY EPSTEIN, for compensatory damages , and such other and further provided by law, punitive damages, attorney's fees, costs y demands trial by jury on all relief as this Court deems just and proper, and hereb issues triable as of right by a jury. COUNT XXVI Cause of Action Pursuant to 18 USC §2255 June of 2003 — Incident 2 raphs 1 through 19 170. The Plaintiff, C.M.A., adopts and realleges parag above. return ed to JEFFREY 171. For the second time in June of 2003, C.M.A. again JEFFREY EPSTEIN directed EPSTEIN'S residence at his request. On this occasion, age. Defendant, JEFFREY C.M.A to fully undress and to provide him with a mass r C.M.A. At the conclusion EPSTEIN, fondled the breasts and buttocks of the then mino elf in C.M.A.'s presence. of the massage, JEFFREY EPSTEIN masturbated hims encounter. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this 73 EFTA00087925 Document 40 Entered on FLSD Docket 02/09/2009 Page 74 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAIJOHNSON First Amended Complaint EPSTEIN's criminal plea, and 172. As a condition of the Defendant, JEFFREY cuting the Defendant for numerous in exchange for the Federal Government not prose additionally entered into an federal offenses, the Defendant, JEFFREY EPSTEIN, ing: "Any person, who while a agreement with the Federal Government to the follow 18, United States Code, Section minor, was a victim of an offense enumerated in Title n 2255 as she would have had, 2255, will have the same rights to proceed under sectio of an enumerated offense. For if Mr. Epstein had been tried federally and convicted s shall provide Mr. Epstein's purposes of implementing this paragraph, the United State red to name in an indictment as attorneys with a list of individuals whom it was prepa judicial authority interpreting this victims of an enumerated offense by Mr. Epstein. Any burdens if any a Plaintiff must provision, including any authority determining evidentiary these identified victims in meet, shall consider that it is the intent of the parties to place Epstein been convicted at trial. No the same position as they would have been had Mr. more; no less." offen ses enumerated in 173. The Plaintiff, C.M.A., was a victim of one or more such asserts a cause of action Title 18, United States Code, Section 2255, and as to this Section of the United against the Defendant, JEFFREY EPSTEIN, pursuant JEFFREY EPSTEIN, and the States Code and the agreement between the Defendant, United States Government 74 EFTA00087926 Document 40 Entered on FLSD Docket 02/09/2009 Page 75 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint JEFFREY EPSTEIN, is in the 174. Pursuant to the agreement, the Defendant, of the sexual offenses committed same position as if he had been tried and convicted effectively admit liability unto the against the Plaintiff, C.M.A., and as such he must Plaintiff, C.M.A. erated in Title 18, 175, As a direct and proximate result of the offenses enum against the then minor Plaintiff, United States Code, Section 2255, being committed suffer, physical injury, pain and C.M.A., has in the past suffered, and will in the future mental anguish, humiliation, suffering, emotional distress, psychological trauma, ion of her privacy and other embarrassment, loss of self-esteem, loss of dignity, invas controlling, manipulating and damages associated with Defendant, JEFFREY EPSTEIN, for a minor. The then minor coercing her into a perverse and unconventional way of life the Plaintiff, C.M.A., will in Plaintiff incurred medical and psychological expenses and expenses. The Plaintiff, C.M.A., the future suffer additional medical and psychological e in the future, and a has suffered a loss of income, a loss of the capacity to earn incom anent in nature and the loss of the capacity to enjoy life. These injuries are perm . Plaintiff, C.M.A., will continue to suffer these losses in the future against the Defendant, WHEREFORE, the Plaintiff, C.M.A., demands judgment the minimum amount JEFFREY EPSTEIN, for compensatory damages of at least , and such other and further provided by law, punitive damages, attorneys fees, costs 75 EFTA00087927 Document 40 Entered on FLSD Docket 02/09/2009 Page 76 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et at Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint y demands trial by jury on all relief as this Court deems just and proper, and hereb issues triable as of right by a jury. COUNT XXVII Cause of Action Pursuant to 18 USC §2255 July of 2003 - Incident 1 parag raphs 1 through 19 176. The Plaintiff, C.M.A., adopts and realleges above. EPST EIN'S residence 177. In July of 2003, C.M.A. again returned to JEFFREY ted C.M.A to fully undress at his request. On this occasion, JEFFREY EPSTEIN direc REY EPSTEIN, fondled the and to provide him with a massage. Defendant, JEFF conclusion of the massage, breasts and buttocks of the then minor C.M.A. At the presence. JEFFREY EPSTEIN JEFFREY EPSTEIN masturbated himself in C.M.A.'s paid C.M.A. in excess of $200 for this encounter. EIN's criminal plea, and 178. As a condition of the Defendant, JEFFREY EPST the Defendant for numerous in exchange for the Federal Government not prosecuting additionally entered into an federal offenses, the Defendant, JEFFREY EPSTEIN, person, who while a agreement with the Federal Government to the following: "Any United States Code, Section minor, was a victim of an offense enumerated in Title 18, as she would have had, 2255, will have the same rights to proceed under section 2255 76 EFTA00087928 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 77 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint an enumerated offense. For if Mr. Epstein had been tried federally and convicted of s shall provide Mr. Epstein's purposes of implementing this paragraph, the United State red to name in an indictment as attorneys with a list of individuals whom it was prepa judicial authority interpreting this victims of an enumerated offense by Mr. Epstein. My burdens if any a Plaintiff must provision, including any authority determining evidentiary place these identified victims in meet, shall consider that It is the intent of the parties to in been convicted at trial. No the same position as they would have been had Mr. Epste more; no less." offenses enumerated in 179. The Plaintiff, C.M.A., was a victim of one or more asserts a cause of action Title 18, United States Code, Section 2255, and as such to this Section of the United against the Defendant, JEFFREY EPSTEIN, pursuant JEFFREY EPSTEIN, and the States Code and the agreement between the Defendant, United States Government REY EPSTEIN, is in the 180. Pursuant to the agreement, the Defendant, JEFF the sexual offenses committed same position as if he had been tried and convicted of tively admit liability unto the against the Plaintiff, C.M.A., and as such he must effec Plaintiff, C.M.A. erate d in Title 18, 181. As a direct and proximate result of the offenses enum st the then minor Plaintiff, United States Code, Section 2255, being committed again physical injury, pain and C.M.A., has in the past suffered, and will in the future suffer, 77 EFTA00087929 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 78 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARR/VJOHNSON First Amended Complaint mental anguish, humiliation, suffering, emotional distress, psychological trauma, y, invasion of her privacy and other embarrassment, loss of self-esteem, loss of dignit controlling, manipulating and damages associated with Defendant, JEFFREY EPSTEIN, of life for a minor. The then minor coercing her into a perverse and unconventional way and the Plaintiff, C.M,A., will in Plaintiff incurred medical and psychological expenses al expenses. The Plaintiff, C.M.A., the future suffer additional medical and psychologic income in the future, and a has suffered a loss of income, a loss of the capacity to earn permanent in nature and the loss of the capacity to enjoy life. These injuries are . Plaintiff, C.M.A., will continue to suffer these losses in the future against the Defendant, WHEREFORE, the Plaintiff, C.M.A., demands judgment at least the minimum amount JEFFREY EPSTEIN, for compensatory damages of , and such other and further provided by law, punitive damages, attorney's fees, costs demands trial by jury on all relief as this Court deems just and proper, and hereby Issues triable as of right by a jury. COUNT XXVIII Cause of Action Pursuant to 18 USC §2255 July of 2003 — Incident 2 raphs 1 through 19 182. The Plaintiff, C.M.A., adopts and realleges parag above. 78 EFTA00087930 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 79 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint returned to JEFFREY 183. For the second time in July of 2003, C.M.A. again JEFFREY EPSTEIN directed EPSTEIN'S residence at his request. On this occasion, age. Defendant, JEFFREY C.M.A to fully undress and to provide him with a mass then minor C.M.A. At the conclusion EPSTEIN, fondled the breasts and buttocks of the himself in C.MA.'s presence. of the massage, JEFFREY EPSTEIN masturbated this encounter. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for EPSTEIN's criminal plea, and 184. As a condition of the Defendant, JEFFREY the Defendant for numerous in exchange for the Federal Government not prosecuting additionally entered into an federal offenses, the Defendant, JEFFREY EPSTEIN, ing: °Any person, who while a agreement with the Federal Government to the follow United States Code, Section minor, was a victim of an offense enumerated in Title 18, n 2255 as she would have had, 2255, will have the same rights to proceed under sectio of an enumerated offense. For if Mr. Epstein had been tried federally and convicted s shall provide Mr. Epstein's purposes of implementing this paragraph, the United State red to name in an indictment as attorneys with a list of individuals whom it was prepa al authority interpreting this victims of an enumerated offense by Mr. Epstein. Any judici ns if any a Plaintiff must provision, including any authority determining evidentiary burde these identified victims in meet, shall consider that it is the intent of the parties to place in been convicted at trial. No the same position as they would have been had Mr. Epste more; no less." 79 EFTA00087931 Document 40 Entered on FLSD Docket 02/09/2009 Page 80 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et at Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint or more offenses enumerated in 185. The Plaintiff, C.M.A., was a victim of one as such asserts a cause of action Title 18, United States Code, Section 2255, and to this Section of the United against the Defendant, JEFFREY EPSTEIN, pursuant ndant, JEFFREY EPSTEIN, and the States Code and the agreement between the Defe United States Government. t, JEFF REY EPSTEIN, is in the 186. Pursuant to the agreement the Defendan the sexual offenses committed same position as if he had been tried and convicted of effectively admit liability unto the against the Plaintiff, C.M.A., and as such he must Plaintiff, C.M.A. ses enum erated in Title 18, 187. As a direct and proximate result of the offen against the then minor Plaintiff, United States Code, Section 2255, being committed suffer, physical injury, pain and C.M.A., has in the past suffered, and will in the future mental anguish, humiliation, suffering, emotional distress, psychological trauma, ion of her privacy and other embarrassment, loss of self-esteem, loss of dignity, invas controlling, manipulating and damages associated with Defendant JEFFREY EPSTEIN, life for a minor. The then minor coercing her into a perverse and unconventional way of and the Plaintiff, C.M.A., will in Plaintiff incurred medical and psychological expenses The Plaintiff, C.M.A., the future suffer additional medical and psychological expenses. earn income in the future, and a has suffered a loss of income, a loss of the capacity to 80 EFTA00087932 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 81 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRPJJOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, C.MA., will continue to suffer these losses in the future. t, WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendan JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XXIX Cause of Action Pursuant to 18 USC §2255 August of 2003 — Incident 1 188. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 above. 189. In August of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 81 EFTA00087933 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 82 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint EPSTEIN's criminal plea, and 190. As a condition of the Defendant, JEFFREY the Defendant for numerous in exchange for the Federal Government not prosecuting additionally entered into an federal offenses, the Defendant, JEFFREY EPSTEIN, ing: "Any person, who while a agreement with the Federal Government to the follow 18, United States Code, Section minor, was a victim of an offense enumerated in Title 2255 as she would have had, 2255, will have the same rights to proceed under section of an enumerated offense. For if Mr. Epstein had been tried federally and convicted s shall provide Mr. Epstein's purposes of implementing this paragraph, the United State red to name in an indictment as attorneys with a list of individuals whom it was prepa al authority interpreting this victims of an enumerated offense by Mr. Epstein. Any judici burdens If any a Plaintiff must provision, including any authority determining evidentiary these identified victims in meet, shall consider that it is the intent of the parties to place in been convicted at trial. No the same position as they would have been had Mr. Epste more; no less." offen ses enumerated in 191. The Plaintiff, C.M.A., was a victim of one or more asserts a cause of action Title 18, United States Code, Section 2255, and as such this Section of the United against the Defendant, JEFFREY EPSTEIN, pursuant to JEFFREY EPSTEIN, and the States Code and the agreement between the Defendant, United States Government. 82 EFTA00087934 Document 40 Entered on FLSD Docket 02/09/2009 Page 83 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAMOHNSON First Amended Complaint REY EPSTEIN, is in the 192. Pursuant to the agreement, the Defendant, JEFF of the sexual offenses committed same position as if he had been tried and convicted effectively admit liability unto the against the Plaintiff, C.M.A., and as such he must Plaintiff, C.M.A. enum erated in Title 18, 193. As a direct and proximate result of the offenses against the then minor Plaintiff, United States Code, Section 2255, being committed suffer, physical injury, pain and C.M.A., has in the past suffered, and will in the future a, mental anguish, humiliation, suffering, emotional distress, psychological traum ion of her privacy and other embarrassment, loss of self-esteem, loss of dignity, invas controlling, manipulating and damages associated with Defendant, JEFFREY EPSTEIN, life for a minor. The then minor coercing her into a perverse and unconventional way of and the Plaintiff, C.M.A., will in Plaintiff incurred medical and psychological expenses expenses. The Plaintiff, C.M.A., the future suffer additional medical and psychological income in the future, and a has suffered a loss of income, a loss of the capacity to earn anent in nature and the loss of the capacity to enjoy life. These injuries are perm future. Plaintiff, C.M.A., will continue to suffer these losses in the against the Defendant, WHEREFORE, the Plaintiff, C.MA, demands judgment the minimum amount JEFFREY EPSTEIN, for compensatory damages of at least , and such other and further provided by law, punitive damages, attorney's fees, costs 83 EFTA00087935 Document 40 Entered on FLSD Docket 02/09/2009 Page 84 of 91 Case 9:08-cv-80811-KAM C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRNJOHNSON First Amended Complaint y demands trial by jury on all relief as this Court deems just and proper, and hereb issues triable as of right by a jury. COUNT XXX Cause of Action Pursuant to 18 USC §2255 August of 2003 — Incident 2 paragraphs 1 through 19 194. The Plaintiff, C.M.A., adopts and realleges above. . again returned to 195. For the second time in August of 2003, C.M.A ion, JEFFREY EPSTEIN JEFFREY EPSTEIN'S residence at his request. On this occas with a massage. Defendant, directed C.M.A to fully undress and to provide him the then minor C.M.A. At the JEFFREY EPSTEIN, fondled the breasts and buttocks of urbated himself in C.M.A.'s conclusion of the massage, JEFFREY EPSTEIN mast for this encounter. presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 criminal plea, and 196. As a condition of the Defendant, JEFFREY EPSTEIN's Defendant for numerous in exchange for the Federal Government not prosecuting the additionally entered into an federal offenses, the Defendant, JEFFREY EPSTEIN, person, who while a agreement with the Federal Government to the following: 'Any United States Code, Section minor, was a victim of an offense enumerated in Title 18, she would have had, 2255, will have the same rights to proceed under section 2255 as 84 EFTA00087936 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 85 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 197. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 198. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the Plaintiff, C.M.A. 199. As a direct and proximate. result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and 85 EFTA00087937 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02109/2009 Page 86 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.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, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XXXI Sexual Battery 200. The Plaintiff, C.MA., adopts and realleges paragraphs 1 through 199 above. 86 EFTA00087938 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 87 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 201. Between late May or early June of 2002 and August of 2003, Defendant, JEFFERY EPSTEIN, engaged in dozens of illegal and depraved sexual acts against Plaintiff, C.M.A. 202. As described more fully in the above paragraphs, Defendant, JEFFERY EPSTEIN, intentionally inflicted harmful and/or offensive sexual contact on the person of C.M.A. 203. Defendant, JEFFREY EPSTEIN'S, tortuous commission of sexual battery upon C.M.A. were done willfully and maliciously. 204. As a direct and proximate result of JEFFREY EPSTEIN'S battery on C.M.A., she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XXXII Conspiracy to Commit Tortious Assault Against Defendant 205. Plaintiff incorporates into this count the allegations of paragraphs 1 through 19. 87 EFTA00087939 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 88 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 206. Defendant is one of Defendant, JEFFREY EPSTEIN'S, referenced in paragraph 12 above. Defendant, JEFFREY EPSTEIN, Defendant, and others reached an agreement between themselves for the purpose of allowing Defendant, JEFFREY EPSTEIN, to commit the illegal acts described above upon Plaintiff, C.M.A. 207. Many of the instances of illegal sexual conduct committed by Defendant, JEFFREY EPSTEIN, described above were perpetrated with the assistance, support, and facilitation by Defendant, In fact, Defendant, aided, assisted, and/or abetted Defendant, JEFFREY EPSTEIN, in his organized scheme and plan to sexually assault, and/or coerce Plaintiff, C.M.A., to engage in prostitution. 208. Defendant, would often arrange times for C.M.A. to come to Defendant, JEFFREY EPSTEIN'S, residence, would escort C.M.A. to the room where Defendant, JEFFREY EPSTEIN, was waiting, would deliver cash from Defendant, JEFFREY EPSTEIN, at the conclusion of a session, and took nude photographs of Plaintiffs, C.M.A., for Defendant, JEFFREY EPSTEIN. 209. As a direct and proximate result of Defendant, participation in the aforementioned conspiracy, Plaintiff, C.M.A, has suffered and will continue to suffer damages, including, but not limited to, pain, suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of 88 EFTA00087940 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 89 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint self-esteem, loss of dignity, invasion of personal privacy and other damages associated with JEFFREY EPSTEIN'S controlling , manipulating, and coercing C.M.A. into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, C.MA., will in the future suffer additional medical and psychological expenses. The Plaintiff, C.M.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, C.M.A., will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, ....or compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 9th day of February, 2009, I electronically filed the foregoing with the Clerk of the Court by using CM/ECF system, which will send a notice of electronic filing to all counsel of record on the attached service list. 89 EFTA00087941 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 90 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint Page 90 of 91 /s/Jack P Hill Jack Scarola Florida Bar No.: 169440 Jack P. Hill Florida Bar No.: 0547808 Shipley, P.A. Attorneys for s 90 EFTA00087942 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 91 of 91 C.M.A. vs. Epstein, et al. case No.: 08-CV-80811-CIV-MARRNJOHNSON First Amended Complaint Page 91 of 91 COUNSEL LIST Richard H. Willits, Esquire Richard H. Willits, PA. Robert Critton, Esquire Burman Critton Luther & Coleman LLP Jack A. Goldberger, Esquire Bruce E. Reinhart, Esquire 11 . 91 EFTA00087943