Case Document Entered on FLSD Docket Page of Defendant is an adult male born on January This Court has jurisdiction over this action and the claims set forth herein pursuant to U.S.C This Court has venue of this action pursuant to U.S.C as a substantial part of the events giving rise to the claim occurred in this District STATEMENT OF FACTS At all relevant times Defendant was an adult male spanning the ages of and years old Defendant is known as a billionaire financier and money manager with a secret clientele limited exclusively to billionaires He is a man of tremendous wealth power and influence He owns a fleet of aircraft that includes a Gulfstream IV a he1.icopter and a Boeing as well as a fleet of motor vehicles Until his incarceration pursuant to the plea entered and sentencing which occurred on June he maintained his principal place of residence in the largest dwelling in Manhattan a 51,0-square-foot eight-story mansion on the Upper East Side He also owns a million mansion in Palm Beach Florida a million 500-acre ranch in New Mexico he named Zorro a 70-acre private island known as Little St James in the U.S Virgin Islands a mansion in Londons Westminster neighborhood and another residence in the Avenue Foch area of Paris The allegations herein concern Defendants conduct while at his lavish residence in Palm Beach and numerous other locations both nationally and internationally Defendant has a sexual preference for underage minor girls He engaged in a plan scheme or enterprise in which he gained access to countless vulnerable and relatively economically disadvantaged minor girls and sexually assaulted molested and/or exploited these girls and then gave them money Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Beginning in or around through in or around September Defendant used his resources and his influence over vulnerable minor girls to engage in a systematic pattern of sexually exploitative behavior Defendants plan and scheme reflected a particular pattern and method Defendant coerced and enticed impressionable vulnerable and relatively economically less fortunate minor girls to participate in various acts of sexual misconduct that he committed upon them Defendants scheme involved the use of underage girls as well as other individuals to recruit underage girls Defendant and/or an authorized agent would call and alert Defendants assistants shortly before or after he arrived at his Palm Beach residence His assistants would call economically disadvantaged and underage girls from West Palm Beach and surrounding areas who would be enticed by the money being offered and who Defendant and/or his assistants perceived as less likely to complain to authorities or have credibility issues if allegations of improper conduct were made The then minor Plaintiff and other minor girls some as young as years old were transported to Defendants Palm Beach mansion by Defondants employees agents and/or assistants in order to provide Defendant with massages Many of the instances of illegal sexual conduct committed by Defendant were perpetrated with the assistance support and facilitation of at least three assistants who helped him orchestrate this child exploitation enterprise These assistants would arrange times for underage girls to come to Defendants residence transport or cause the transportation of underage girls to Defendants residence escmi the underage girls to the massage room where Defendant would be waiting or would enter shortly thereafter urge the underage girls to remove their clothes deliver cash from Defendant to the underage girls and/or their procurers at the conclusion of each massage appointment and assist Defendant in taking nude photographs Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of and/or videos of the underage girls with and/or without their knowledge Defendant would pay the procurer of each girls appointment hundreds of dollars Defendant designed this scheme to secure a private place in Defendants Palm Beach mansion where only persons employed and invited by Defendant would be present so as to reduce the chance of detection of Defendants sexual abuse and/or exploitation as well as to make it more difficult for the minor girls to flee the premises and/or to credibly report his actions to law enforcement or other authorities The girls were usually transported by his employee agent and/or assistant and/or by taxicab and/or motor vehicle paid for by Defendant which also made it difficult for the girls to flee his mansion Upon her initial arrival at Defendants Palm Beach mans10n each underage victim would generally be introduced to one of Defendants assistants who would gather the girls personal contact information The minor girl would be led up a remote flight of stairs to a room that contained a massage table and a large shower At times if it was the girls first massage appointment another female would be in the room to lead the way Generally the other female would leave or Defendant would dismiss her Often Defendant would start his massage wearing only a small towel which eventually would be removed Defendant and/or the other female would direct the girl to massage him giving the minor girl specific instructions as to where and how he wanted to be touched and then direct her to remove her clothing Defendant would then perform one or more lewd lascivious and sexual acts including masturbation fondling the minors breasts and/or sexual organs touching the minors vulva vagina and/or anus with a vibrator back massager his finger and/or his penis digitally penetrating her vagina performing intercourse oral sex and/or anal sex and/or coercing or attempting to coerce the girl to engage in lewd acts and/or Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of prostitution and/or enticing the then minor girl to engage in sexual acts with another female in Defendants presence The exact degree of molestation and frequency with which the sexual exploitations took place varied and is not yet completely known however Defendant committed such acts regularly on a daily basis and in most instances several times a day In order to facilitate the daily exchanges of money for sexual assault and abuse Defendant kept U.S currency readily available Defendant traveled out of Florida to Palm Beach for the purpose of luring minor girls to his mansion to sexually abuse and/or batter them He used the telephone to contact these minor girls for the purpose of coercing them into acts of prostitution and to enable himself to commit sexual battery against them and/or acts of lewdness in their presence and he conspired with others including his employee assistant driver pilot and/or agent to facilitate these acts and to avoid police detection Defendants systematic pattern of sexually exploitative behavior described above also occurred in Defendants other domestic and/or international residences places oflodging and/or modes of transportation Consistent with the foregoing plan and scheme Defend.ant used his money wealth and power to unduly and improperly manipulate and influence the then minor Plaintiff A vulnerable young girl Plaintiff was merely a seventeen year old high school student when she was first lured into Defendants sexually exploitative world in or about January Plaintiff was recruited while at work by a co-worker one of the minor victims Defendant paid to procure underage females Plaintiff went to Defendants Palm Beach mansion accompanied by this co worker Upon arriving Plaintiff was led by one of Defendants assistants up a flight of stairs to a spa room with a shower and a massage table Defendant entered this room wearing only a towel Defendant suddenly removed his towel exposing his naked body and then lay on the massage Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of table Defendant told Plaintiff to massage his back and take off her clothing which she refused to do Defendant then began to try to touch the minor Plaintiff and/or take off her clothing After Defendants relentless pawing she reluctantly removed some of her clothing During this encounter Defendant turned over on his back and fondled Plaintiffs breasts despite her repeatedly telling him not to do so As Plaintiff massaged Defendant Defendant proceeded to masturbate until ejaculation Defendant then paid Plaintiff two hundred dollars and Plaintiff was escorted out of Defendants mansion and left Defendants property A similar pattern of grooming continued and the sexual exploitation progressively escalated over the course of approximately seventeen months during which Defendant would often travel to Palm Beach Prior to arriving and wf in Palm Beach Defendant and/or his agent would frequently call Plaintiff at her home telephone number and/or other telephone numbers arranging for encounters with her for Defendant sometimes twice daily While usually such contacts were made by his assistants Defendant personally called Plaintiff repeatedly despite being told to leave Plaintiff alone After the first few encounters Defendant coerced Plaintiff to remove all her clothing and Defendant penetrated the minor Plaintiffs vagina digitally Defendant sexually abused and/or battered and/or exploited Plaintiff at least a hundred times between approximately January and May Such exploitation included but was not limited to Defendants sexual abuse and battery of Plaintiff with vibrator back massager his finger and his penis At times Defendant manipulated Plaintiff to interact sexually with another female During one encounter Dt!fendant penetrated the minor Plaintiffs vagina with his penis all the while narrating and demonstrating his sexual battery of Plaintiff to another female present in the room While some of the precise dates that Defendants acts of sexual exploitation occurred are unknown to Plaintiff these dates are known Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of to Defendant as he and/or his assistants kept written records some of which are in the custody of law enforcement of each instance in which he committed lewd acts upon minor girls including the then minor Plaintiff Defendants preference for underage girls was well-known to those who regularly procured them for him The above-described acts of abuse began to occur during a time when Defendant knew that Plaintiff was a minor Defendant at all times material to this cause of action knew and/or should have known of Plaintiffs age of minority In fact Defendant repeatedly urged the minor Plaintiff to become legally emancipated in order to accompany him as he traveled both nationally and internationally Additionally Defendant knowing that Plaintiff was merely seventeen years old lured her by inviting her to stay with him at his mansion in Manhattan and arranging and/or paying for airplane tickets theater tickets and a personal chauffeur as gifts for her upcoming birthday As part of Defendants persistent process of grooming Plaintiff and immersing her in his lewd and abusive lifestyle Defendant regularly showered the adoL 3cent Plaintiff with gifts including but not limited to lingerie flowers bikini bathing suit art book purse envelopes of U.S currency use of a car and/or other accoutrements Defendant possessed photographs of nude underage girls some of which may have been taken with hidden cameras set up in his residence in Palm Beach On the day of Defendants arrest police found two hidden cameras and photographs of underage girls in Defendants mansion Defendant took lewd photographs of Plaintiff with his hidden cameras and transported lewd photographs of Plaintiff and other victims elsewhere using a facility or means of interstate and/or foreign commerce On one occasion Defendant manipulated the minor Plaintiff to pose nude for him and photographed her using several rolls of film One or Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of more of those nude photographs of Plaintiff that were taken by the Defendant when she was a minor were confiscated by the Palm Beach Police Department during its execution of a search warrant of Defendants Palm Beach mansion on October Defendant was particularly skillful at discerning his minor victims respective hopes dreams and ambitions As he did with many of his victims Defendant lured Plaintiff early-on with modeling opportunities impressing her with his modeling business and contacts with supermodels indicating that he could help her with a modeling career Knowing that the minor Plaintiff was an excellent student and desired to attend New York University or Columbia University Defendant pretended to show great interest in her college admission and offered to help her with her applications and to assist her with her tuition Defendant had told Plaintiff of his substantial connections within the academic community a matter about which he often bragged Defendant took it upon himself to take control of Plaintiffs college application process and led Plaintiff to believe that he was sincere about helping her Even though she had earned a Bright Futures Scholarship to the Florida college of her choice Defendant insisted that she would not need it and that with his involvement she would be admitted into one or both of the universities in New York As a result of Defendants manipulation Plaintiff did not apply timely for the Bright Futures Scholarship or to any college and therefore missed the fall semester of her freshman year When the Palm Beach Police Department executed the search warrant on Defend.m1ts mansion among the artifacts found and confiscated were Plaintiffs high school transcript In June after an investigation by the Palm Beach Police Department the State Attorneys Office the Federal Bureau of Investigation and the United States Attorneys Office Defendant entered pleas of guilty to one count of solicitation of prostitution in Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurslcom Case Document Entered on FLSD Docket Page of violation of Fla Stat and one count of solicitation of a minor to engage in prostitution in violation of Fla Stat in the Fifteenth Judicial Circuit in Palm Beach County Florida As a condition of that plea Defendant entered into a Non-Prosecution Agreement Addendum and Affirmation collectively the NPA with the United States Attorneys Office for the Southern District of Florida on September October and December respectively In so doing Defendant acknowledged that Plaintiff was one of his victims and agreed to the following provisions of the NP A If any of the acknowledged victims elects to file suit pursuant to U.S.C Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter and Epstein waives his right to contest liability and also waives his right to contest damages up to an amount agreed to between the identified individual and Epstein so long as the identified individual elects to proceed exclusively under U.S.C and agrees to waive any other claim for damages whether pursuant to state federal or common law Except as to those individuals who elect to proceed exclusively under US.C as set forth in paragraph supra neither Epsteins signature on this agreement nor its terms nor any resulting waivers or settlements by Epstein are to be construed as admissions of evidence or evidence of civil or criminal liability or a waive of any jurisdictional or other defense as to any person whether or not her name appears on the list provided by the United States emphasis added Plaintiff was among the individuals identified by the United States Attorneys Office as victims of Defendant upon whose testimony it intended to base its federal prosecution of Defendant for his illegal conduct Consequently Defendant is estopped by his state court plea and the Non-Prosecution Agreement from denying the acts alleged in this Complaint and must effectively admit liability to Plaintiff Jane Doe No COUNT ONE Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Cause of Action for Coercion and Enticement of Minor to Engag in Prostitution or Sexual Activity pursuant to U.S.C in Violation of S.C Plaintiff hereby adopts repeats realleges and incorporates by reference the allegations contained in paragraphs through above Defendant used a facility or means of interstate and/or foreign commerce to knowingly persuade induce entice or coerce Plaintiff when she was under the age of years to engage in prostitution and/or sexual activity for which any person can be charged with a criminal offense or attempted to do so pursuant to U.S.C in violation of U.S.C Plaintiff was a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against Defendant pursuant to this Section of the United States Code As a direct and proximate result of the offenses enumerated in U.S.C being committed against the then minor Plaintiff by Defendant Plaintiff has in the past suffered and will in the future continue to suffer physical injury pain and suffering emotional distress psychological and/or psychiatric trauma mental anguish humiliation confusion embarrassment loss of educational opportunities loss of self-esteem loss of dignity invasion of her privacy separation from her family and other damages associated with Defendants manipulating and luring her into a perverse and unhealthy way of life The then minor Plaintiff incurred medical and psychological expenses and Plaintiff will in the future incur additional medical and psychological expenses Plaintiff has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and Plaintiff will continue to suffer these losses in the future Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of WHEREFORE Plaintiff demands judgment against Defendant for all damages available under U.S.C including without limitation actual and compensatory damages attorneys fees costs of suit and such other 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 TWO Cause of Action for Travel with Intent to Engage in Illicit Sexual Conduct pursuant to U.S.C in Violation of U.S.C bJl Plaintiff hereby adopts repeats realleges and incorporates by reference the allegations contained in paragraphs through above Defendant traveled in interstate and/or foreign commerce for the purpose of engaging in illicit sexual conduct as defined in U.S.C with minor females including the then minor Plaintiff in violation of S.C Plaintiff was a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against Defendant pursuant to this Section of the United States Code As a direct and proximate result of the offenses enumerated in S.C being committed against the then minor Plaintiff by Defendant Plaintiff ha in the past suffered and will in the future continue to suffer physical injury pain and suffering emotional distress psychological and/or psychiatric trauma mental anguish humiliation confusion embarrassment loss of educational opportunities loss of self-esteem loss of dignity invasion of her privacy separation from her family and other damages associated with Defendants manipulating and luring her into a perverse and unhealthy way of life The then minor Plaintiff incurred medical and psychological expenses and Plaintiff will in the future incur additional medical and psychological expenses Plaintiff has suffered a loss of income a loss of the capacity to earn Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of income in the future and a loss of the capacity to enjoy life These injrn es are permanent in nature and Plaintiff will continue to suffer these losses in the future WHEREFORE Plaintiff demands judgment against Defendant for all damages available under U.S.C including without limitation actual and compensatory damages attorneys fees costs of suit and such other 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 THREE Cause of Action for Sexual Exploitation of Children pursuant to U.S.C in Violation of U.S.C Plaintiff hereby adopts repeats realleges and incorporates by reference the allegations contained in paragraphs through above Defendant knowingly persuaded induced enticed or coeH:ed the then minor Plaintiff to engage in sexually explicit conduct for the purpose of producing a visual depiction of such conduct in violation of S.C Plaintiff was a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against Defendant pursuant to this Section of the United States Code As a direct and proximate result of the offenses enumerated in U.S.C being committed against the then minor Plaintiff by Defendant Plaintiff has in the past suffered and will in the future continue to suffer physical injury pain and suffering emotional distress psychological and/or psychiatric trauma mental anguish humiliation confusion embarrassment loss of educational opportunities loss of self-esteem loss of dignity invaswn of her privacy separation from her family and other damages associated with Defendants manipulating and luring her into a perverse and unhealthy way of life The then minor Plaintiff incurred medical Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of and psychological expenses and Plaintiff will in the future incur additional medical and psychological expenses Plaintiff has suffered a loss of income a loss of the capacity to eam income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and Plaintiff will continue to suffer these losses in the future WHEREFORE Plaintiff demands judgment against Defendant for all damages available under U.S.C including without limitation actual and corr,pensatory damages attorneys fees costs of suit and such other further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as ofright by a jury COUNT FOUR Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit Conduct pursuant to U.S.C in Violation of U.S.C a Plaintiff hereby adopts repeats realleges and incorporates by reference the allegations contained in paragraphs through above Defendant knowingly mailed transported shipped or sent via computer and/or facsimile in or affecting interstate and/or foreign commerce at least one visual depiction of the minor Plaintiff engaging in sexually explicit conduct in violation of U.S.C a Defendant transported lewd photographs of Plaintiff and oth victims elsewhere using a facility or means of interstate and/or foreign commerce Plaintiff was a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against Defendant pursuant to this Section of the United States Code As a direct and proximate result of the offenses enumerated in U.S.C being committed against the then minor Plaintiff by Defendant Plaintiff has in the past suffered and will in the future continue to suffer physical injury pain and suffering emotional distress psychological and/or psychiatric trauma mental anguish humiliation confusion embarrassment Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale podhurst.corn Case Document Entered on FLSD Docket Page of loss of educational opportunities loss of self-esteem loss of dignity invasion of her privacy separation from her family and other damages associated with Defendants manipulating and luring her into a perverse and unhealthy way of life The then minor Plaintiff incurred medical and psychological expenses and Plaintiff will in the future incur additional medical and psychological expenses Plaintiff has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and Plaintiff will continue to suffer these losses in the future WHEREFORE Plaintiff demands judgment against Defendant for all damages available under U.S.C including without limitation actual and compensatory damages attorneys fees costs of suit and such other 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 FIVE Cause of Action for Transport of Child Pornography pursuant to U.S.C in Violation of U.S.C a Plaintiff hereby adopts repeats realleges and incorporates by reference the allegations contained in paragraphs through above Defendant knowingly mailed transported shipped or sent via computer and/or facsimile in or affecting interstate and/or foreign commerce child pornography in violation of U.S.C a Defendant transported lewd photographs of Plaintiff and other victims elsewhere using a facility or means of interstate and/or foreign commerce Plaintiff was a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against Defendant pursuant to this Section of the United States Code Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of As a direct and proximate result of the offenses enumerated in U.S.C being committed against the then minor Plaintiff by Defendant Plaintiff has in the past suffered and will in the future continue to suffer physical injury pain and suffering emotional distress psychological and/or psychiatric trauma mental anguish humiliation confusion embarrassment loss of educational opportunities loss of self-esteem loss of dignity invasion of her privacy separation from her family and other damages associated with Defendants manipulating and luring her into a perverse and unhealthy way of life The then minor Plaintiff incurred medical and psychological expenses and Plaintiff will in the future incur additional medical and psychological expenses Plaintiff has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and Plaintiff will continue to suffer these losses in the future WHEREFORE Plaintiff demands judgment against Defendant for all damages available under U.S.C including without limitation actual and compensatory damages attorneys fees costs of suit and such other 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 SIX Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to U.S.C in Violation of U.S.C Plaintiff hereby adopts repeats realleges and incorporates by reference the allegations contained in paragraphs through above and Counts One through Five above Defendant knowingly engaged in a child exploitation enterprise as defined in U.S.C in violation of U.S.C As more fully set forth above Defendant engaged in actions that constitute countless violations of U.S.C sex trafficking of children Chapter sexual exploitation of children in violation of U.S.C Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of a and A a and Chapter transportation for illegal sexual activity in violation of U.S.C and As more fully set forth above in paragraphs through Defendants actions involved countless victims and countless separate incidents of sexual abuse which he committed against minors including Plaintiff in concert with at least three other persons Plaintiff was a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against Defendant pursuant to this Section of the United States Code As a direct and proximate result of the offenses enumerated in U.S.C being committed against the then minor Plaintiff by Defendant Plaintiff has in the past suffered and will in the future continue to suffer physical injury pain and suffering emotional distress psychological and/or psychiatric trauma mental anguish humiliation confuswn embarrassment loss of educational opportunities loss of self-esteem loss of dignity invasion of her privacy separation from her family and other damages associated with Defendants manipulating and luring her into a perverse and unhealthy way of life The then minor Plaintiff incurred medical and psychological expenses and Plaintiff will in the future incur additional medical and psychological expenses Plaintiff has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and Plaintiff will continue to suffer these losses in the future WHEREFORE Plaintiff demands judgment against Defendant for all damages available under U.S.C including without limitation actual and compensatory damages Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of attorneys fees costs of suit and such other 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 Date By Podhurst Orseck P.A Respectfully Submitted Bar No Katherine Ezell BarNo Podhurst Orseck P.A West Flagler St Suite Miami Florida Telephone Fax rjosefsberg podhurst.com kezel podhurst.com Attorneys for Plaintiff West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of 4c rlev CIVIL COVER Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION ATTACHMENT TO CIVIL COVER
