Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 42 of 73
numerous federal criminal statutes condemning the coercion and enticement of a minor
to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual
conduct, sex trafficking of children, sexual exploitation of minor children, transport of
visual depictions of a minor engaging in sexually explicit conduct, child exploitation
enterprises, and other crimes, specifically including, but not limited to, those crimes
designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is
therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as
such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code and the agreement between the Defendant, Jeffrey
Epstein, and the United States Government.
563. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, ■ has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant. Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff incurred medical
and psychological expenses and the plaintiff, will in the future suffer medical and
psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, ■, will continue to suffer these
losses in the future.
Page 204 of 234
203 ot 234
EFTA00594036
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 43 of 73
564. Wherefore, the plaintiff, L.M., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right 137
COUNT 137
Cause of Action Pursuant to 18 U.S.C. d 2255
June 2005 — Incident 1
565. Plaintiff,.. adopts and realleges paragraphs 1 through 20 above.
566. On or about June 2005, the exact date being unknown to..,
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
567. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, ■ has in the past
Page 205 of 234
204 of 234
EFTA00594037
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 44 of 73
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff incurred medical
and psychological expenses and the plaintiff, ■., will in the future suffer medical and
psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, ■, will continue to suffer these
losses in the future.
568. Wherefore, the plaintiff, M., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
COUNT 138
Cause of Action Pursuant to 19 U.S.C. § 2255
June 2005 — Incident 2
569. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
570. On or about June 2005, the exact date being unknown to..,
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
Page 206 of 234
206 of 234
EFTA00594038
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 45 of 73
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
■ is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
571. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, ■ has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff incurred medical
and psychological expenses and the plaintiff. L M , will in the future suffer medical and
psychological expenses. The plaintiff, E., has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, ■, will continue to suffer these
losses in the future.
572. Wherefore, the plaintiff,.., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
Page 207 of 234
206 of IN
EFTA00594039
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 46 of 73
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
COUNT 139
Cause of Action Pursuant to 18 U.S.C. 4 2255
June 2005 — Incident 3
573. Plaintiff, adopts and realleges paragraphs 1 through 20 above.
574. On or about June 2005, the exact date being unknown to..,
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
II . is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant. Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
575. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, L.M. has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
Page 208 of 234
201 0234
EFTA00594040
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 47 of 73
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical
and psychological expenses and the plaintiff, will in the future suffer medical and
psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, ■, will continue to suffer these
losses in the future.
576. Wherefore, the plaintiff, •, demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
COUNT 140
Cause of Action Pursuant to 18 U.S.C. § 2255
June 2005 — Incident 4
577. Plaintiff, L M. adopts and realleges paragraphs 1 through 20 above.
578. On or about June 2005, the exact date being unknown to
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
Page 209 of 234
200 a23+
EFTA00594041
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 48 of 73
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
579. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, ■ has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff a incurred medical
and psychological expenses and the plaintiff, ■, will in the future suffer medical and
psychological expenses. The plaintiff, L.M., has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, ■, will continue to suffer these
losses in the future.
580. Wherefore, the plaintiff, ■., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
Page 210 of 234
1010134
EFTA00594042
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 49 of 73
COUNT 141
Cause of Action Pursuant to 18 U.S.C. 2255
July 2006 — Incident 1
581. Plaintiff, adopts and realleges paragraphs 1 through 20 above.
582. On or about July 2005, the exact date being unknown to
■, Defendant,
Jeffrey Epstein, committed a federal sexual offense against
her, including a violation of
numerous federal criminal statutes condemning the coercion
and enticement of a minor
to engage in prostitution or sexual activity, travel with intent
to engage in illicit sexual
conduct, sex trafficking of children, sexual exploitation of
minor children, transport of
visual depictions of a minor engaging in sexually explicit
conduct, child exploitation
enterprises, and other crimes, specifically including, but
not limited to, those crimes
designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and
§ 2423(e). L.M. is
therefore a victim of one or more offenses enumerated in
18 U.S.C. § 2255 and, as
such, asserts a cause of action against the defendant, Jeffre
y Epstein, pursuant to this
Section of the United States Code and the agreement betwe
en the Defendant, Jeffrey
Epstein, and the United States Government.
583. As a direct and proximate result of the offenses
enum erated in Title 18,
United States Code, Section 2255, being committed again
st her, has in the past
suffered, and will in the future suffer, physical injury pain
and suffering, emotional
distress, psychological trauma, mental anguish, humiliation
, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and
other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and
coercing her into a perverse
Page 211 of 234
210 0334
EFTA00594043
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 50 of 73
and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical
and psychological expenses and the plaintiff, L.M., will in the future suffer medical and
psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, E, will continue to suffer these
losses in the future.
584. Wherefore, the plaintiff, E. demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
COUNT 142
Cause of Action Pursuant to 18 U.S.C. 6 2255
July 2005 — Incident 2
585. Plaintiff, in . adopts and realleges paragraphs 1 through 20 above.
586. On or about July 2005, the exact date being unknown to.., Defendant,
Jeffrey Epstein, committed a federal sexual offense against her, including a violation of
numerous federal criminal statutes condemning the coercion and enticement of a minor
to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual
conduct, sex trafficking of children, sexual exploitation of minor children, transport of
visual depictions of a minor engaging in sexually explicit conduct, child exploitation
enterprises, and other crimes, specifically including, but not limited to, those crimes
designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is
Page 212 of 234
2110234
EFTA00594044
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 51 of 73
therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as
such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code and the agreement between the Defendant, Jeffrey
Epstein, and the United States Government.
587. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, L.M. has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical
and psychological expenses and the plaintiff, L.M., will in the future suffer medical and
psychological expenses. The plaintiff, L.M., has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, •, will continue to suffer these
losses in the future
588. Wherefore, the plaintiff,.., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
COUNT 143
Cause of Action Pursuant to 18 U.S.C. 4 2255
Page 213 of 234
212 of231
EFTA00594045
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 52 of 73
July 2005 — Incident 3
589. Plaintiff, adopts and realleges paragraphs 1 through 20 above.
590. On or about July 2005, the exact date being unknown to E, Defendant,
Jeffrey Epstein, committed a federal sexual offense against her, including a violation of
numerous federal criminal statutes condemning the coercion and enticement of a minor
to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual
conduct, sex trafficking of children, sexual exploitation of minor children, transport of
visual depictions of a minor engaging in sexually explicit conduct, child exploitation
enterprises, and other crimes, specifically including, but not limited to, those crimes
designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is
therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as
such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code and the agreement between the Defendant, Jeffrey
Epstein, and the United States Government.
591. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255. being committed against her, ■ has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff ■ incurred medical
and psychological expenses and the plaintiff, ■., will in the future suffer medical and
Page 214 of 234
213.1231
EFTA00594046
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 53 of 73
psychological expenses. The plaintiff, I., has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, will continue to suffer these
■,
losses in the future.
592. Wherefore, the plaintiff, L.M., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
COUNT 144
Cause of Action Pursuant to 18 U.S.C. § 2255
July 2005 — Incident 4
593. Plaintiff, adopts and realleges paragraphs 1 through 20 above.
594. On or about July 2005, the exact date being unknown to in, Defendant,
Jeffrey Epstein, committed a federal sexual offense against her, including a violation of
numerous federal criminal statutes condemning the coercion and enticement of a minor
to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual
conduct, sex trafficking of children, sexual exploitation of minor children, transport of
visual depictions of a minor engaging in sexually explicit conduct, child exploitation
enterprises, and other crimes, specifically including, but not limited to, those crimes
designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e) is
therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as
such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this
Page 215 of 234
214 0134
EFTA00594047
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 54 of 73
Section of the United States Code and the agreement between the Defendant, Jeffrey
Epstein, and the United States Government.
595. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, • has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff incurred medical
and psychological expenses and the plaintiff, L.M., will in the future suffer medical and
psychological expenses. The plaintiff, •, has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, ■, will continue to suffer these
losses in the future.
596. Wherefore, the plaintiff, demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
COUNT 145
Cause of Action Pursuant to 18 U.S.C. 6 2255
August 2005 — Incident 1
597. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above.
Page 216 of 234
2150234
EFTA00594048
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 55 of 73
598. On or about August 2005, the exact date being unknown to..,
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
599. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, L.M. has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress. psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical
and psychological expenses and the plaintiff, ■., will in the future suffer medical and
psychological expenses. The plaintiff, ■, has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
Page 217 of 234
11101334
EFTA00594049
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 56 of 73
injuries are permanent in nature and the plaintiff, will continue to suffer these
losses in the future.
600. Wherefore, the plaintiff, ■, demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
COUNT 146
Cause of Action Pursuant to 18 U.S.C. L2255
August 2005 — Incident 2
601. Plaintiff,.. adopts and realleges paragraphs 1 through 20 above.
602. On or about August 2005, the exact date being unknown to..,
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
Page 218 of 234
2'? of 234
EFTA00594050
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 57 of 73
603. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical
and psychological expenses and the plaintiff, ■, will in the future suffer medical and
psychological expenses. The plaintiff, ■, has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, ■, will continue to suffer these
losses in the future.
604. Wherefore, the plaintiff,.., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper. and hereby demands trial by jury on all issues triable as of right by a jury
COUNT 147
Cause of Action Pursuant to 18 U.S.C. § 2255
August 2005 — Incident 3
605. Plaintiff,.. adopts and realleges paragraphs 1 through 20 above.
606. On or about August 2005, the exact date being unknown to..,
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
Page 219 of 234
21101234
EFTA00594051
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 58 of 73
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
607. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, ■ has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein. controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical
and psychological expenses and the plaintiff, L.M., will in the future suffer medical and
psychological expenses. The plaintiff, L.M., has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, will continue to suffer these
■,
losses in the future.
Page 220 of 234
119 of 134
EFTA00594052
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 59 of 73
608. Wherefore, the plaintiff,
•, demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
COUNT 148
Cause of Action Pursuant to 18 U.S.C. 4 2255
August 2005 — Incident 4
609. Plaintiff, adopts and realleges paragraphs 1 through 20 above.
610. On or about August 2005, the exact date being unknown to
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
El is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
611. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, L.M. has in the past
Page 221 of 234
220.0124
EFTA00594053
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 60 of 73
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical
and psychological expenses and the plaintiff, L.M., will in the future suffer medical and
psychological expenses. The plaintiff, a, has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, ■, will continue to suffer these
losses in the future.
612. Wherefore, the plaintiff, L.M., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
COUNT 149
Cause of Action Pursuant to 18 U.S.C. 6 2255
September 2005 — Incident 1
613. Plaintiff, ■ adopts and realleges paragraphs 1 through 20 above.
614. On or about September 2005, the exact date being unknown to..,
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
Page 222 of 234
111 a114
EFTA00594054
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 61 of 73
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
■ is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
615. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, L.M. has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical
and psychological expenses and the plaintiff, L M . will in the future suffer medical and
psychological expenses. The plaintiff, M., has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, ■, will continue to suffer these
losses in the future.
616. Wherefore, the plaintiff, •, demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
Page 223 of 234
222 of 234
EFTA00594055
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 62 of 73
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
COUNT 10
Cause of Action Pursuant to 18 U.S.C. 4 2255
September 2005 - Incident 2
617. Plaintiff,.. adopts and realleges paragraphs 1 through 20 above.
618. On or about September 2005, the exact date being unknown to L.M.,
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
619. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, ■ has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
Page 224 of 234
223 0234
EFTA00594056
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 63 of 73
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical
and psychological expenses and the plaintiff,.., will in the future suffer medical and
psychological expenses. The plaintiff, L.M., has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, MI, will continue to suffer these
losses in the future.
620. Wherefore, the plaintiff, L.M., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
COUNT 151
Cause of Action Pursuant to 18 U.S.C. i 2255
September 2006 — Incident 3
621. Plaintiff... adopts and realleges paragraphs 1 through 20 above
622. On or about September 2005, the exact date being unknown to..,
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
Page 225 of 234
224 0 224
EFTA00594057
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 64 of 73
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
623. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, ■ has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff ■ incurred medical
and psychological expenses and the plaintiff, will in the future suffer medical and
psychological expenses. The plaintiff, •, has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, L.M., will continue to suffer these
losses in the future.
624. Wherefore, the plaintiff, L.M., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
Page 226 of 234
226 a2s4
EFTA00594058
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 65 of 73
COUNT 152
Cause of Action Pursuant to 18 U.S.C. 4 2255
September 2005 — Incident 4
625. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above.
626. On or about September 2005, the exact date being unknown to..,
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
627. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, L.M. has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
Page 227 of 234
221of 234
EFTA00594059
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 66 of 73
and conventional way of life for a minor. The then-minor plaintiff 5 incurred medical
and psychological expenses and the plaintiff, ■, will in the future suffer medical and
psychological expenses. The plaintiff, ■, has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, ■, will continue to suffer these
losses in the future.
628. Wherefore, the plaintiff, ■, demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
COUNT 153
Cause of Action Pursuant to 18 U.S.C. 4 2256
October 2005 — Incident 1
629. Plaintiff, 5 adopts and realleges paragraphs 1 through 20 above.
630. On or about October 2005, the exact date being unknown to 5.,
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
Page 228 of 234
227 el 234
EFTA00594060
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 67 of 73
M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
631. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, ■ has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiffs incurred medical
and psychological expenses and the plaintiff, ■., will in the future suffer medical and
psychological expenses. The plaintiff, has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, ■, will continue to suffer these
losses in the future.
632. Wherefore, the plaintiff, ■, demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
COUNT 154
Cause of Action Pursuant to 18 U.S.C. 4 2255
Page 229 of 234
2at of 2II
EFTA00594061
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 68 of 73
October 2005 — Incident 2
633. Plaintiff, adopts and realleges paragraphs 1 through 20 above.
634. On or about October 2005, the exact date being unknown to
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
■ is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
635. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, L M has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff incurred medical
and psychological expenses and the plaintiff, ■., will in the future suffer medical and
Page 230 of 234
mane
EFTA00594062
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 69 of 73
psychological expenses. The plaintiff, E, has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
are permanent in nature and the plaintiff, ■, will continue to suffer these
losses in the future.
636. Wherefore, the plaintiff, E, demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
COUNT 165
Cause of Action Pursuant to 18 U.S.C. 4 2255
October 2005 — Incident 3
637. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above.
638. On or about October 2005, the exact date being unknown to..,
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
Page 231 of 234
2300234
EFTA00594063
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 70 of 73
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
639. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, ■ has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical
and psychological expenses and the plaintiff, •, will in the future suffer medical and
psychological expenses. The plaintiff, L.M., has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
injuries are permanent in nature and the plaintiff, ■, will continue to suffer these
losses in the future.
640. Wherefore, the plaintiff, L.M., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper, and hereby demands trial by jury on all issues triable as of right by a jury.
COUNT 156
Cause of Action Pursuant to 18 U.S.C. § 2255
October 2006 — Incident 4
641. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above.
Page 232 of 234
231 at 234
EFTA00594064
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 71 of 73
642. On or about October 2005, the exact date being unknown to L.M.,
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
643. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, ■ has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff incurred medical
and psychological expenses and the plaintiff, will in the future suffer medical and
psychological expenses. The plaintiff, ■., has suffered a loss of income, a loss of the
capacity to earn income in the future, and a loss of the capacity to enjoy life. These
Page 233 of 234
2320132+
EFTA00594065
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 72 of 73
injuries are permanent in nature and the plaintiff, will continue to suffer these
losses in the future.
644. Wherefore, the plaintiff, 5, demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper.
DEMAND FOR JURY TRIAL
Plaintiff hereby demands trial by jury on all issues triable as of right by a jury.
DATED July 24, 2009
ectfully Submitted,
radl y J. Edwards
ROTHSTEIN ROSENFELDT ADLER
Las Olas City Centre
401 East Las Olas Blvd., Suite 1650
Fort Lauderdale, Florida 33301
Telephone (954) 522-3456
Facsimile (954) 527-8663
Florida Bar No.: 542075
E-mail• bedwardsnrr rra-law corn
Page 234 of 234
233 of 234
EFTA00594066
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 73 of 73
%IS 44 (Et.. 2T1) CIVIL COVER SHEET
papers as required by law, except as provided
The JS44 civil cover shoat and the infortnation contained herein neither tivtace nor suppkment the filing and smite ofpkadinv samba
for the use ofIlseClerk of Court for the putposc of initiating
by local rules ofcourt. This form, approved by the Judicial Conference of the Unikd Swain September 1974, is requiscd
the civil docket sheet (SEE ininner:OHS ON THE REVERSE OF THE FORM) NOTICE: Attorneys MUST.J.DKIcale AllRfratdalistpdow•
1. (a) PLAINTIFFS DEFENDANTS
JEFFREY EPSTEIN
(b) County o(Residerne of First lined Plaintiff Palm Beach County of Residence of Fine Listed Deketent Palm Beach
(EXCEPT IN U.S. PLAINTIFF CASES) ID4 V.S. ILA Dann CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES. USE THE LOCATION OF THE TRACT
(C) Alt/411CP (MN Name. neatest. ss4 Tiltpains Mamba°
LAND INVOLVED
Rothstein Rosenfeldt Adler
ABOIIICKI (if Rem)
401 East Las Olas Blvd., Suite 1650
Fort Lauderdale, FL 33301 - Phone 954-522-3456 Bradley 1. Edwards
0 MIAMI. DADE 0 MONROE 0 IROWARD 4 PALM 'EACH 3 MARTIN 0 ET. LUCIE 0 INDIAN RIVER 0 OKEECHOBEE
(10 Check County Where Mho° Arose
HIOHLANDS
II. BASIS OF JURISDICTION (19.e. la 'X' M Om an OWN III. CITIZENSHIP OF PRINCIPAL PARTIEStru« -x- In OO. en for PAMIR
Poe Oremlly Coos Ilaly) and 044 Bo. ill Elaleadasi)
O I US. OsIIIMAI vb Fultr)gslloe PIT OBI
1 0 I horporawl or Inn p.' Plso 0
PTV
4
OCT
0 4
ANNA (U S. Orson's NMI WO) Chins of TIM Sob 0
•f BOAS I. Tki4 Soo
Dives, Cain •f Asks Sis 3 2 0 1 lacomparsl sad PriocloalPlor 0 $ 0
O 2 U.S00Venal•At 0 4
Defends 011usisass b Asoilto Sista
Nodes Cs of PAtIti la Ise III)
O 6 0 4
q ie rge V V/ i qfP" C~tnn-.)1i2
_ _
Cabo or SuNrst ors
Iona...Coos
0 1 0 ) inform Nano.
... .,.......„ —. ..... 4 .....—
contact ARTA FORPRITURIOPENALTV namenuercy OTHER STATUTES II
a WI Inesoct PERSONAL INJURY PERSONAL INJURY 0 610 AptIt•fruit 0 422 Ars' 20 USC I SS 400 Sills Reepp011i00000I
0120 Mom 0 310AM 0 362 04.104iil Isjury • 0 620 CAS he/ • Os 0 41) Withdrawal 410 Aeliimi
0 130 MIEn Ac' 0 313 Moho Pods.. ■Malsociie• 0 613 Deas It OHO Saws II USC 137 430 Inks and Ilszlanp
30 PlIrS9nII tajufy • of Press 21 U10111 430 Cesar«
O 140 Negotiable Issaumani LIalmitity 0
O Ise amen., of 0 ..... yams 0 324 ANNA. Lib& a Frahm Lai 0 610 Liquor Leal PRO 460 Dtpotuars
A lielercesal other's Moiler 3 361 aaaaaNs I 0 640 R R. A Trick 0 010 Cowl/MR 470 Rotuma. tafimme4 tad
0 lit Silts Ati 0 330 isisaal trepLyS bran Prods 0 630 ANIS Reµ 0 SIG Psis Coins CarioN9INal
CI 132 Romeo of Defoltal LIM% Lilbllity 0 661 04supiiImal 0 040 1 as 410 Conan Credit
Ste,44sl Los 0 140 Miami PERSONAL PROPERTY Satcy41•4160 490 CableSsi TV
0 345 USN Potosi 3 370 Othior Fowl 0 OM Oilior 110 Salsolve Sinks
MS Swan)
0 IS) Ross of Ovens's, Liabitliy 0 331 Thoth le USN LAROA SOCIAL SECURITY ISO Ssridta/Cenanothusn'
of Veleta'. 00401.1 0 110 4.04•4 Ve blcle 0 31000.' Nasal 0 MOM. Lobel Sisisrds 0161 NIA (I 39 30) Stamm.
0 111 Mew Volta An 0 141 aka Leos (92)1 175 Colossi Challenge
o 160 Siokbeldati Sup4. Poona CoNOT
1900Sr Ce Produsi Liabifity 3 OE Pommy Daman 3 7111 LaiMMEmi Realms 0 SO DIWC/DIWW MO HEN II USC 3410
0
3 195 Como Ili LIalollsy 0 34001k,. toms' Prato L Silliy 5 330 LolsorMont Pennies 0 1164 SSII1Tio XVI 190 Olbo Sissy Actions
Alm • Ditclosere Alt 0463151(403W) 491 Appicuharsl Adis
O 196 tomb's',
( REAL PROPERTY CIVIL MONTE PRISONER PETITIONS 1 740 Ile Sway Lebo. Art IIDIRAL TAX MTh 192 Eon OM SIC:Malin AM
3 441 Troin 0 110 Mors a Versa 3 116 Oilat Labor Lkiphos 0 070 TIM 0I.S Plehauff 093 En•konosnasl Mails
0 Ile Lad Corallosiis
0 220 Fends° 0 441 Esoliailoo Solon 0 191 tapl. Kin In. Usual' or OS'S. 494 Meru A MY inas Act
0 210 Rani Least a ESNs' 0 40 HOMO? Hato C oo 000i AO 0 1' 1 IR S. l'on1 $93 eeeee ern col Weiss ma
O NC 7 s::. ra t.:-0 As, re sac•— • ". ;1. 4., 4„,1 .1. Ott aloe
3 3 4: T on !reruni 1 sae) 7a. Menu :I 111 Onin hue. I 1 T90 APP.Ii of 44. Den muse*.
441 A oamu abilso c Undo East Mtn. ii• lona
CI 290 All Olhait Rol Promo .__-
0 Em 0 340 M lookout A Oast 0 4" " ' tante"
bY Appless
0 .46 Asa. WOISallelot - 0 461 llotiot Csua.P.11r.
O 350 CS Melo Dans
Oilier
4A62 en.
Olbut 'signs 0 930 Cslevisellly of Sion
0 oft Mbar COB RItly 3 Mt Prls Coedits fl Status
Appal CO DittrICI
V. ORIGIN (Plaec • 'X' le 0 se So. Only) Trans erred from Judge from
,p i Original 0 2 Removed from 0 3 Re-filed- 0 4 Reasoned« 0 5 soother district 0 6 Lltitiligtuttuc
n i Et 7 Maps straw
Proceeding State Court (see VI below) Reopened
OPecifY) ludameni
a) Re•filed Case 0 YES O NO b) Related Cases GIVES° NO
VI. RELATED/RE-FILED (S.. lastniclien•
CASE(S). (Mass 'or): JUDGE DOCKET NUMBER 9:08-cv-80119
me the U.S. OW Statute under which you are films and Wnto • Bnef Statement of Cause (Do not cite Jurisdictional statutes unless
diversity).
VII. CAUSE OF ACTION USC Section 2255
O
LENGTH OF TRIAL via ys estimated (for both tides to try mire cue)
VIII. REQUESTED IN 0 (ECK IT nits is AC ON DEMAND S /A/ErteS..5 CHECK YES only if demanded in complaint:
COMPLAINT: . 23 1,000,000.00 JURY DEMAND: 0 Yea O No
ABOVE INFORMATION IS TRUE & CORRECT TO si OF ATTORNEY OF OATS
THE BEST OF MY KNOWLEDGE
FOR evert LY
AMOUNT RECEIPT • IF?
234012M
546n7
EFTA00594067