EFTA00730882Set 9
2009-07-2773p21,623w
Pursuant to 18 U.S.C. Q 2255
October 2004 — Incident 4
449. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
450. On or about October 2004, the exact date ... April 2005 - Incident 3
through 20 above.
541. Plaintiff, L.M. adopts and realleges paragraphs 1
to L.M., Defendant,
542. On or about April 2005, the exact date being unknown
against ... June 2005 — Incident 2
through 20 above.
569. Plaintiff, L.M. adopts and realleges paragraphs 1
to L.M.,
570. On or about June 2005, the exact date being unknown
offense against
https://www.justice.gov/epstein/files/DataSet%209/EFTA00730882.pdf
EFTA00730803Set 9
2009-07-2779p22,760w
Pursuant to 18 U.S.C. 4 2255
September 2003 — Incident 1
229. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
230. On or about September 2003, the exact date ... Pursuant to 18 U.S.C. 4 2255
September 2003 — Incident 2
233. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
234. On or about September 2003, the exact date ... Docket 07/27/2009 Page 4 of 79
September 2003 - Incident 3
237. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
238. On or about September 2003, the exact date
https://www.justice.gov/epstein/files/DataSet%209/EFTA00730803.pdf
EFTA01109281Set 9
2009-07-2750p14,410w
Action Pursuant to 18 U.S.C. § 2255
March 2003 — Incident 3
141. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
142. On or about March 2003, the exact date ... Pursuant to 18 U.S.C. 4 2255
March 2003 — Incident 4
145. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
146. On or about March 2003, the exact date ... Docket 07/27/2009 Page 54 of 82
April 2003— Incident 1
149. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
150. On or about April 2003, the exact date
https://www.justice.gov/epstein/files/DataSet%209/EFTA01109281.pdf
EFTA01109331Set 9
2009-07-2752p14,953w
Docket 07/27/2009 Page 20 of 79
December 2003 — Incident 2
281. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
282. On or about December 2003, the exact date ... Pursuant to 18 U.S.C. 6 2255
December 2003 — Incident 3
285. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
286. On or about December 2003, the exact date ... Pursuant to 18 U.S.C. 6 2255
pecember 2003 — Incident 4
289. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
Page 104 of 234
IN 01234
EFTA01109334
Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA01109331.pdf
EFTA01109383Set 9
2009-07-2750p14,440w
Pursuant to 18 U.S.C. 4 2255
September 2004 — Incident 3
429. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
430. On or about September 2004, the exact date ... Pursuant to 18 U.S.C. 4 2255
September 2004 — Incident 4
433. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
434. On or about September 2004, the exact date ... Pursuant to 18 U.S.C. Q 2255
October 2004 — Incident 1
437. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
438. On or about October 2004, the exact date
https://www.justice.gov/epstein/files/DataSet%209/EFTA01109383.pdf
EFTA01735094Set 10
2009-07-2450p14,401w
Action Pursuant to 18 U.S.C. § 2255
August 2002 — Incident 1
21. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
22. On or about August 2002, the exact date ... Action Pursuant to 18 U.S.C. & 2255
August 2002 — Incident 2
25. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
Page 8 of 234
II et 231
EFTA ... Pursuant to 18 U.S.C. 4 2255
August 2002 — Incident 3
29. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
30. On or about August 2002, the exact date
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01735094.pdf
EFTA01109465Set 9
2009-07-24234p64,968w
Pursuant to 18 U.S.C. 4 2255
August 2002 — Incident 1
21. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
22. On or about August 2002, the exact date ... Pursuant to 18 U.S.C. 4 2255
August 2002 — Incident 2
25. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
Page 8 of 234
801234
EFTA01109472 ... Pursuant to 18 U.S.C. 4 2255
August 2002 — Incident 3
29. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
30. On or about August 2002, the exact date
https://www.justice.gov/epstein/files/DataSet%209/EFTA01109465.pdf
EFTA01109231Set 9
2009-07-2450p14,349w
Pursuant to 18 U.S.C. 4 2265
August 2002 — Incident 1
21. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
22. On or about August 2002, the exact date ... Pursuant to 18 U.S.C. 4 2255
August 2002 — Incident 2
25. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
Page 8 of 234
*a 234
EFTA01109238
Case ... Pursuant to 18 U.S.C. 4 2255
August 2002 — Incident 3
29. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
30. On or about August 2002, the exact date
https://www.justice.gov/epstein/files/DataSet%209/EFTA01109231.pdf
EFTA00730721Set 9
2009-07-2482p23,556w
Pursuant to 18 U.S.C. 4 2255
August 2002 — Incident 1
21. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
22. On or about August 2002, the exact date ... Pursuant to 18 U.S.C. 4 2255
August 2002 — Incident 2
25. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
Page 8 of 234
SOS 234
EFTA00730728
Case ... Pursuant to 18 U.S.C. 4 2255
August 2002 — Incident 3
29. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
30. On or about August 2002, the exact date
https://www.justice.gov/epstein/files/DataSet%209/EFTA00730721.pdf
EFTA01109433Set 9
2009-07-2732p9,801w
Pursuant to 18 U.S.C. d 2255
June 2005 — Incident 1
565. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
566. On or about June 2005, the exact date ... 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 ... Pursuant to 18 U.S.C. 4 2255
June 2005 — Incident 3
573. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
574. On or about June 2005, the exact date
https://www.justice.gov/epstein/files/DataSet%209/EFTA01109433.pdf
EFTA00190026Set 9
2009-11-2036p8,414w
allegations against EPSTEIN in
L.M.'s complaint became even more salacious. In paragraph 12 of
L.M.'s Second Amended Complaint, L.M. alleges among other
things, that:
"Jeffrey Epstein coerced, induced ... Plaintiff realleges and incorporates paragraphs 1 through 53 as if fully set forth
herein.
61. RRA, along with ROTHSTEIN, EDWARDS and L.M., each and collectively,
constitute an enterprise pursuant ... Civil Actions against EPSTEIN, the actions of Defendants,
ROTHSTEIN, EDWARDS and L.M. as alleged in paragraphs 9 through 53 herein,
constitute an illegal, improper or perverted use of process
https://www.justice.gov/epstein/files/DataSet%209/EFTA00190026.pdf
EFTA01100909Set 9
16p3,889w
Amended Complaint 1[1[30-33).
For example, Paragraph 30(c) alleges that "Epstein believes that the federal complaint in L.M. v.
Epstein was shown to [Attorney] Legamaro ... long after Edwards filed and served a
state court civil action on behalf of L.M." Paragraph 31 asserts that "[o]n or about October 17,
2009, Edwards, who had filed ... like the one
Edwards had filed in federal court on behalf of L.M." Paragraph 32 then states "Edwards also
made illegal, improper and perverted use of the civil process
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100909.pdf
EFTA00623045Set 9
2009-10-139p2,567w
Corrected Second Amended Complaint. (See Corrected Second Amended Complaint
30-33). For example, Paragraph 30(c) alleges that "Epstein believes that the federal complaint
in LM. v. Epstein was shown ... long after Edwards filed and served a
state court civil action on behalf of L.M." Paragraph 31 asserts that "[o]n or about October 17,
2009, Edwards, who had filed ... like the one
Edwards had filed in federal court on behalf of L.M." Paragraph 32 then states "Edwards also
made illegal, improper and perverted use of the civil process
https://www.justice.gov/epstein/files/DataSet%209/EFTA00623045.pdf
EFTA00795588Set 9
2009-11-20103p23,937w
allegations against EPSTEIN in
complaint became even more salacious. In paragraph 12 of
<SL7 .'s Second Amended Complaint, L.M. alleges among other
things, that:
"Jeffrey Epstein coerced, induced, or enticed ... Civil Actions against EPSTEIN, the actions of Defendants,
ROTHSTEIN, EDWARDS and L.M. as alleged in paragraphs 9 through 53 herein,
constitute an illegal, improper or perverted use of process ... Defendants
76. Plaintiff realleges and incorporates paragraphs 1 through 53, and 7 as if
fully set forth herein.
77. ROTHSTEIN, EDWARDS and L.M. conspired to commit t i on EPSTEIN
https://www.justice.gov/epstein/files/DataSet%209/EFTA00795588.pdf
EFTA00587914Set 9
2009-11-2030p7,249w
EPSTEIN, the actions of Defendants,
ROTHSTEIN, FISTEN, JENNE, the Litigation Team and L.M. as alleged in paragraphs
through herein, constitute an illegal, improper or perverted use of process.
79. ROTHSTEIN ... Defendants
81. Plaintiff realleges and incorporates paragraphs 1 through as if fully set forth
herein.
82. ROTHSTEIN, ROSENFELDT, FISTEN, JENNE and L.M. by and through
Defendants EDWARDS, BERGER and ADLER ... Defendants
84. Plaintiff realleges and incorporates paragraphs 1 through as if fully set forth
herein.
85. ROTHSTEIN, FISTEN, JENNE and L.M. and the Litigation Team conspired to
commit a fraud
https://www.justice.gov/epstein/files/DataSet%209/EFTA00587914.pdf
EFTA00725289Set 9
2009-11-2030p7,253w
EPSTEIN, the actions of Defendants,
ROTHSTEIN, FISTEN, JENNE, the Litigation Team and L.M. as alleged in paragraphs
through herein, constitute an illegal, improper or perverted use of process.
79. ROTHSTEIN ... Defendants
81. Plaintiff realleges and incorporates paragraphs 1 through as if fully set forth
herein.
82. ROTHSTEIN, ROSENFELDT, FISTEN, JENNE and L.M. by and through
Defendants EDWARDS, BERGER and ADLER ... Defendants
84. Plaintiff realleges and incorporates paragraphs 1 through as if fully set forth
herein.
85. ROTHSTEIN, FISTEN, JENNE and L.M. and the Litigation Team conspired to
commit a fraud
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725289.pdf
EFTA00607531Set 9
2009-11-2036p8,599w
allegations against EPSTEIN in
•'s complaint became even more salacious. In paragraph 12 of
L.M.'s Second Amended Complaint, • alleges among other
things, that:
"Jeffrey Epstein coerced, Induced, or enticed ... Plaintiff realleges and incorporates paragraphs 1 through 53 as if fully set forth
herein.
61. RRA, along with ROTHSTEIN, EDWARDS and L.M., each and collectively,
constitute an enterprise pursuant ... Plaintiff realleges and Incorporates paragraphs 1 through 53 as If fully set forth
herein.
74. ROTHSTEIN, by and through Defendant EDWARDS and L.M. made false
statements of fact to EPSTEIN
https://www.justice.gov/epstein/files/DataSet%209/EFTA00607531.pdf
EFTA00594036Set 9
2009-07-2732p9,748w
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 ... 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 ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00594036.pdf
EFTA00182658Set 9
2008-06-3090p21,515w
then minor.
3. At all times material to this cause of action, the Plaintiff, L.M. (hereinafter
referred to as "Plaintiff"), was a resident of Palm Beach County, Florida ... school aged child and into a delinquent lifestyle.
15. The acts referenced above in paragraphs 10 through 14, committed by Defendant,
Jeffrey Epstein, against the then minor Plaintiff were committed ... XXXXMB AB
COUNT IV
Battery
40. The plaintiff, L.M., repeats and realleges paragraphs 1 through 15 above.
41. On numerous occasions, Defendant Epstein did in fact intentionally touch
Plaintiff, L.M
https://www.justice.gov/epstein/files/DataSet%209/EFTA00182658.pdf
EFTA00614572Set 9
16p3,578w
sexual
nature.
3. At all times material to this cause of action, the plaintiff, L.M. (hereinafter
referred to as "Plaintiff"), was a resident of Palm Beach County, Florida ... Negligence Per Se, violation of criminal statutes
16. The plaintiff adopts and realleges paragraphs 1 through 15 above.
17. Defendant, Jeffrey Epstein, negligently injured Plaintiff, and/or failed to
understand ... XXXXMB AB
COUNT IV
Battery
40. The plaintiff, L.M., repeats and realleges paragraphs 1 through 15 above.
41. On numerous occasions, Defendant Epstein did in fact intentionally touch
Plaintiff, L.M
https://www.justice.gov/epstein/files/DataSet%209/EFTA00614572.pdf