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Epstein Release Interview Victim Statements Evidence Maxwell
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Filing E-Filed AM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No JEFFREY EPSTEIN Plaintiff/Counter-Defendant PARTl SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiff PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS APPENDIX OF DOCUMENTS IN SUPPORT OF HIS REVISED OMNIBUS MOTION IN LIMINE Plaintiff/Counter-Defendant Jeffrey Epstein Epstein files this Appendix of Documents in support of his revised Omnibus Motion in Limine No Date Document Epsteins Motion to Amend Complaint D.E Plaintiffs Motion to Strike References to Non-Prosecution Agreement or in the Alternative to Lift Protective Order Barring Jane Does Attorneys from Revealing Provisions in the Agreement D.E Jane Doe Jeffrey Epstein S.D Fla Case No Plaintiffs First Amended Complaint D.E Jane Doe Jeffrey Epstein S.D Fla Case No Jeffrey Epsteins Deposition Transcript Excerpts pp E.W Jeffrey Epstein th Judicial Circuit Case No FILED PALM BEACH COUNTY FL SHARON BOCK CLERK AM No Date Document Plaintiffs Motion for Injunction Restraining Fraudulent Transfer of Asserts Appointment of a Receiver to Take Charge of Property of Epstein and to Post a Million Bond to Secure Potential Judgment D.E Jane Doe Jeffrey Epstein S.D Fla Case No 08-cv-80119-MARRA/JOHNSON Order Denying Plaintiffs Motion for Injunction etc D.E Jane Doe Jeffrey Epstein S.D Fla Case No MARRA/JOHNSON Letters from Edwards re depositions Complaint D.E L.M Jeffrey Epstein S.D Fla Case No NIA Court Docket L.M Jeffrey Epstein S.D Fla Case No Re-Notices of Taking Videotaped Deposition of Donald Trump Jane Doe Jeffrey Epstein S.D Fla Case No Plaintiffs Request for Entry Upon Land D.E E.W Jeffrey Epstein th Judicial Circuit Case No Epsteins Motion for Protective Order Regarding Depositions of Lawrence Visoski and David Hart Rogers D.E L.M Jeffrey Epstein th Judicial Circuit Case No Article South Florida Sun-Sentinel Scott Rothstein investment deals seemed too good to be true Article New Times Broward-Palm Beach Scott Rothstein The Jeffrey Epstein and Bill Clinton Ploy Verified Complaint for Forfeiture In Rem D.E United States of America Scott Rothstein Forfeiture Action S.D Fla Case No Article South Florida Sun-Sentinel FBI doubts Rothstein ran a Ponzi scheme alone No Date Document Complaint without exhibits D.E Razorback Funding LLC Rothstein 17th Jud Cir Case No Amended Verified Complaint for Forfeiture In Rem D.E United States of America Scott Rothstein Forfeiture Action S.D Fla Case No Article South Florida Sun-Sentinel Youre in a town full of thieves Article The Miami Herald Feds Scott Rothstein Ponzi scheme paid salaries at law firm Amended Complaint without exhibits D.E Razorback Funding LLC Rothstein 17th Jud Cir Case No Information D.E United States Rothstein S.D Fla Case No Complaint without exhibits D.E Affidavit of Jeffrey Epstein D.E Bradley Edwards Deposition Transcript Excerpts pp Bradley Edwards Deposition Transcript Excerpts pp Bradley Edwards Deposition Transcript Excerpts pp Email from Pricilla Nascimento to Scott Rothstein Email from Bradley Edwards to Priscilla Nascimento Email from Ken Jenne to Scott Rothstein Scott Rothsteins Deposition Transcript Excerpts pp No Date Document Scott Rothsteins Deposition Transcript Excerpts pp Razorback Funding LLC Rothstein 17th Jud Cir Case No Scott Rothsteins Deposition Transcript Excerpts Razorback Funding LLC Rothstein 17th Jud Cir Case No Jeffrey Epsteins Deposition Transcript Excerpts pp Edwards Amended Exhibit List D.E Epsteins Objections to Edwards Amended Exhibit List D.E Edwards Seventh Amended and Supplemental Witness List D.E Jeffrey Epsteins Deposition Transcript Excerpts pp CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on November through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration Jack Scarola LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Angela Many FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Angela linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Secondary Tanya linkrocklaw.com Secondary Eservice linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Nichole Segal Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL mep searcylaw.com jsx searcylaw.com scarolateam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards West Palm Beach FL njs FLAppellateLaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews Avenue Suite One Broward Boulevard Suite Fort Lauderdale FL Ft Lauderdale FL brad epllc.com marc nuriklaw.com staff.efile pathtojustice.com Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Jack A Goldberger Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein APP.1 JEFFREY EPSTEIN Plaintiff SCOTT ROTHSTEIN individually BMDL YJ EDWJ RDS individually and L.M individually Defendants IN THE CIRCUIT.COURT OF THE FIFTEENTH JUJJICIAL GIR.CUIT IN AND FOR PALM BEA.CH COUNTY FLORIDA Complex Litigation Fla;R Civ Case No AG pursuant to the Florida Rules of Civil Procedure filesHi_i on to Amend the Complaint in part for the reasons set below I On or about December Jaintiff:filed his action in this inatter it is the essence action that the Defendants used actual lawsuits against Epstein or fabricated ot to et investments to third parties for a retom ofinve.stment JV on theEpstein cases I on or 225osition 1e Plaintiff to put into issue whe_ther or not the 225actions alleged am trEpstem by vanous plamt1ffs are true or not Instead the essence of.the complaintis us on the alleged misconduct offiHng legal-me tions and other actions in pursuit ofciv oiu1rirefated to the rne.rits or value ofthe cases brought against the Plaintiff More specific ll Yi See the allegations contained page oJ the colplaint,:paragraphs FOWLER WHITE i Epstein Rothstein et a Case No Phdntiffs Motion to Amend Complaint While the Plaintiff believes his complaint is clear in an abundance of caution so as to removeariy doubt.as to.whetherJhePla.intiff has J:!Utinto issue his alleged resJ:!onsibil ty for the claims brought against him the Plaintiff moves to amend his complaint to elim4liJf fqllowing irngra hS A I The P!aintiff respec fts that additional amendments will be necessary once the 267records 267subpOenaed from.t ve 225been.recelved anddepositions occur relatingto those records F,owever this 7nt is re.quested at this lime for the purpose of clearing up any alleged misapptehension Plaintiff has placed in issue his alleged actual liability in the cases brqught against him stein Rosenfeldt Adler The undersigned counsel certifies hat thiS motign is madein good faith and nolfor theepurpose ofdelay The undersigned counsel certifies that he has and will ntinue to attempUo.resolve this matter without the need of a hearing FOWLE WmTE Epsteinv Rothstein etal Plaintiffs Motion to Amend Complaint CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was i mailed this January,2011.to Jack Scarola Searcy De ey Scarola Barnhart A,ttomeys for Bradley J.Edwards Im Beach Lakes Boulevard West Palm Beac and Marc Nurik;Law Offices of Marc Nurik Attorneys for.Scott Rothstein El Broward Blvd.,:Sfo FortLauderdale;FL30L Respectful lb OS Ackerman Jr c-y FOWLER APP Case Document Entered on FLSD Docket Page of JANE DOE Plaintiff JEFFREY EPSTEIN Defendant UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No MARRA/JOHNSON I MOTION TO STRIKE REFERENCES TO NON-PROSECUTION AGREEMENT OR IN THE ALTERNATIVE TO LIFT PROTECTIVE ORDER BARRING JANE DOES ATTORNEYS FROM REVEALING PROVISIONS IN THE AGREEMENT Plaintiff Jane Doe hereby moves this Court to strike all references to a non prosecution agreement contained in defendant Jeffrey Epsteins Epstein Motion to Stay these proceedings Under the Best Evidence Rule Fed Evid and the principles underlying the rule Epstein is required to produce the written agreement or a copy thereof rather than simply rely on his own summary representations about what the agreement provides In the alternative the Court should lift the protective order it has entered in parallel litigation that precludes Jane Does counsel from revealing in publicly-accessible pleadings the specific language in the non-prosecution agreement In his motion to stay these proceedings defendant Epstein has argued that he must invoke his Fifth Amendment rights lest he be found in violation of a non prosecution agreement with the U.S Attorneys Office Indeed his pleading makes a number of specific representations about the contents of that agreement See e.g Epstein Motion to Stay at the non-prosecution agreement outlines various obligations on the part of Epstein including but not limited to pleading guilty to the Case Document Entered on FLSD Docket Page of Indictment and Information before the 15th Judicial Circuit recommendations for his sentencing before the 15th Judicial Circuit waiver of challenges to the Information filed by the SAO waiver of right to appeal his conviction and the agreement to not prosecute others listed thereon so long as Epstein does not breach and fulfills the requirements of the NPA Epsteins pleading makes further representations about what is not contained in the agreement See e.g id the non-prosecution agreement does not outline or define what constitutes a breach or what act of omission constitutes a breach thereof All references in his motion to the content of the non-prosecution agreement should be stricken The Best Evidence Rule requires Epstein to produce the non prosecution agreement itself to prove what the agreement says not some second hand summary Federal Rule of Evidence directly provides To prove the content of a writing the original writing is required except as otherwise provided in these rules or by Act of Congress The non-prosecution agreement is undoubtedly a writing See Epstein Motion to Stay at conceding this point Moreover it is obvious that Epstein is trying to prove its content in his motion to stay as he is relying on various provisions within the agreement to make his case for a stay As the moving party on his motion for a stay he is therefore obligated to provide the best evidence of the written agreement namely a copy of the agreement itself The rationales underlying the Best Evidence Rule clearly apply here As two leading commentators have explained The continuing existence of the Best Evidence Rule rests upon several considerations First writings occupy a central position in the law The written word has special sanctity justifying more stringent proof Case Document Entered on FLSD Docket Page of requirements Second when the contents of a writing are in issue an evidence other than the writing itself is distinctly inferior Language is complex and the slightest variation in wording can have enormous significance in determining the outcome of a legal dispute Unless a writing is very short it is beyond the power of most human memory to summarize the writing with the precision that is often needed in the courtroom The burden on litigants of requiring them to introduce the writing if available is outweighed by the increased accuracy of the factfinding process Third production of the writing ensures completeness and prevents any segments from being presented out of context CHRISTOPHER MUELLER LAIRD KIRKPATRICK EVIDENCE at 3d ed see also Seiler Lucasfilm Ltd F.2d 9th Cir when the terms are in dispute only the writing itself or a true copy provides reliable evidence Epstein is making some rather remarkable assertions about what the agreement provides or fails to provide and how it operates in practice as Jane Doe explains at greater length in her accompanying response to his motion for a stay To prove those assertions Epstein should not be able to rely on his own inferences from provisions contained in the agreement but rather should be required to provide the specific language supporting those inferences In the alternative if Epstein is allowed to make his own representation about the contents of the agreement then Jane Doe should likewise be allowed to make her own 247presentations about what the document provides Jane Does undersigned attorneys have a copy of what is apparently the non-prosecution agreement They obtained that agreement in parallel litigation under the Crime Victims Rights Act Doe United States No The agreement however was provided to Jane Does counsel subject to a protective order That protective order precludes Jane Does Case Document Entered on FLSD Docket Page of attorneys from revealing the Agreement or its terms to any third party absent further court order Protective Order Doe United States No dkt Aug That Protective Order thus precludes Jane Doe from responding to Epsteins allegations in a publicly-filed motion because her response would necessarily involve disclosing the terms of the agreement Jane Doe therefore requests the alternative relief of having the protective order lifted so that her attorneys can respond directly to Epsteins allegations about what the non-prosecution agreement provides If the protective order is lifted Jane Doe would accordingly request an opportunity to file a supplemental pleading in opposition to the motion to stay to discuss those provisions CONCLUSION For all these reasons all references to the non-prosecution agreement in Epsteins motion for a stay should be stricken In the alternative the Court should lift its protective order and permit Jane Does counsel to file a supplemental response to the motion to stay discussing the specific provisions in the agreement Because the United States may have an interest in this motion a copy of the motion is being served on the U.S Attorneys Office for the Southern District of Florida DATED April Lifting the protective order may be useful for other reasons as well For example Jane Doe intends to question Epstein about the terms of the non-prosecution agreement at his upcoming deposition If the protective order remains in place Jane Doe may be required to proceed cumbersomely by first have Epstein reveal the provisions of the agreement and then asking about the provisions Because only the narrow issue of the motion to stay is currently before the Court Jane Doe has confined her arguments to that issue Jane Doe reserves her right to file an appropriate motion at the appropriate time for release of the non-prosecution agreement on other grounds Case Document Entered on FLSD Docket Page of Respectfully Submitted Plaintiff by One of Her Counsel Bradley Edwards Bradley Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre East Las Olas Blvd Suite Fort Lauderdale Florida Telephone Facsimile Florida Bar No E-mail bedwards rra-law.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April I electronically filed the foregoing document with the Clerk of Court using CM/ECF I also certify that the foregoing is being served this day upon all counsel of record identified on the attached Service List in the manner specified either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing Bradley Edwards Bradley Edwards Case Document Entered on FLSD Docket Page of SERVICE LIST Case No MARRA/JOHNSON Attorneys for Defendant Robert Deweese Critton Jr rcrit bclclaw.com Michael James Pike MPike bclclaw.com Burman Critton Luttier Coleman Flagler Drive Suite West Palm Beach FL fax Lead Counsel Jack Alan Goldberger Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL fax jagesq bellsouth.net Co-Counsel Attorney for United States A Marie Villafana Assistant U.S Attorney U.S Attorneys Office Australian Ave Suite West Palm Beach FL Telephone Facsimile ann.marie.c.villafana usdoj.gov VIA US MAIL Attorneys for Plaintiff Bradley James Edwards Rothstein Rosenfeldt Adler East Las Olas Blvd Suite Ft Lauderdale FL fax bedwards rra-law.com Lead Counsel Paul Cassell South Room Salt Lake City UT fax cassellp law.utah.edu Pro Hae Vice Jay Howell Jay Howell Associates PA Cesery Boulevard Suite Jacksonville FL jay jayhowell.com APP Case Document Entered on FLSD Docket Page of JANE DOE Plaintiff JEFFREY EPSTEIN Defendant UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No MARRA/JOHNSON I PLAINTIFFS FIRST AMENDED COMPLAINT Parties Jurisdiction and Venue Plaintiff Jane Doe hereby brings this First Amended Complaint against Defendant Jeffrey Epstein and states as follows This is an action for damages in an amount in excess of exclusive of interest and costs This First Amended Complaint is brought under a fictitious name in order to protect the identity of Plaintiff Jane Doe because this Complaint makes allegations of sexual assault and child abuse of a then minor At all times material to this cause of action Plaintiff Jane Doe was a resident of Palm Beach County Florida At all times material to this cause of action Defendant Jeffrey Epstein was a resident of the State of New York At all times material to this cause of action Defendant Jeffrey Epstein had a residence located in Palm Beach County Florida Case Document Entered on FLSD Docket Page of At all times material to this cause of action Defendant Jeffrey Epstein was an adult male born in This Court has jurisdiction of this action and the claim set forth herein pursuant to U.S.C a as the matter in controversy exceeds exclusive of interest and costs and is between citizens of different states This Court has venue of this action pursuant to U.S.C a as a substantial part of the events or omissions giving rise to the claim occurred in this district At all times material Defendant Jeffrey Epstein owed a duty unto Plaintiff Jane Doe to treat her in a non-negligent manner and to not commit intentional or tortious or illegal acts against her Factual Allegations Upon information and belief Defendant Jeffrey Epstein has demonstrated a sexual preference and obsession for minor girls He engaged in a plan scheme and enterprise in which he gained access to economically disadvantaged minor girls such as Plaintiff Jane Doe and sexually battered these girls and/or coerced them to engage in prostitution Defendants plan scheme and enterprise included an elaborate system wherein the then minor Plaintiff and other minor girls were contacted by telephone by Defendant Epstein Sarah Kellen or other unknown employees or assistants working for Defendant Epstein and Epsteins assistants would persuade the minor girls including Jane Doe to come over to defendant Epsteins house for the purpose of engaging in prostitution Case Document Entered on FLSD Docket Page of Plaintiff Jane Doe was contacted by Defendant Jeffrey Epstein himself or Sarah Kellen or other unknown employees or assistants of Defendant Epstein on numerous occasions and she was often times brought to Defendant Epsteins residence with the assistance of Defendant Epsteins assistants Sarah Kellen or other employees/assistants of Defendant Epstein would often arrange with the Yellow Cab cab company to take minor girls including Jane Doe to Defendant Epsteins house Once the then minor girl including Plaintiff Jane Doe arrived at Epsteins house the assistants and employees left the then minor Plaintiff and other minor girls alone in a room at the defendants mansion Subsequently Defendant Jeffrey Epstein himself would appear remove his clothing and direct the then minor Plaintiff to remove her clothing He would then perform one or more lewd lascivious and sexual acts including but not limited to masturbation touching of the then minor Plaintiffs sexual organs using vibrators or sexual toys on the then minor Plaintiff and digitally penetrating the then minor Plaintiff Defendant Epstein traveled to his mansion in Palm Beach for the purpose of luring minor girls to his mansion to sexually abuse 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 acts of lewdness in their presence and he conspired with others including his assistants Sarah Kellen and Nadia Marcinkova to further commit these acts and to avoid police detection Case Document Entered on FLSD Docket Page of Plaintiff Jane Doe was first brought to Defendant Epsteins mansion in early when she was a fourteen-year old in middle school Defendant Jeffrey Epstein a wealthy financier with a lavish home significant wealth and a network of assistants and employees used his resources and his influence over a vulnerable minor child to engage in a systematic pattern of sexually exploitive behavior Beginning in approximately February and continuing until approximately June the defendant coerced and enticed the impressionable vulnerable and economically deprived then minor Plaintiff in order to commit various acts of sexual misconduct against her These acts included but were not limited to fondling and inappropriate and illegal sexual touching of the then minor Plaintiff sexual misconduct and masturbation of Defendant Jeffrey Epstein in the presence of the then minor Plaintiff and encouraging and coercing the then minor Plaintiff to become involved in prostitution Defendant Jeffrey Epstein used his money wealth and power to unduly and improperly manipulate and influence the then minor Plaintiff into a deviant and delinquent lifestyle The above-described sexual acts took place in Palm Beach County Florida at the residence of Defendant Jeffrey Epstein Any assertions by Defendant Jeffrey Epstein that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual exploitation sexual battery and abuse of a minor child Case Document Entered on FLSD Docket Page of Defendant Jeffrey Epstein at all times material to this cause of action knew and should have known of the plaintiff Jane Does minority The above-described acts were perpetrated upon the person of the then minor Plaintiff regularly and on dozens of occasions In June in the Fifteenth Judicial Circuit in Palm Beach County Florida Defendant Jeffrey Epstein entered pleas of guilty to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution for which Defendant Epstein was sentenced to months incarceration in Palm Beach County jail to be followed by months community control house arrest COUNTI Sexual Battery upon a Minor The Plaintiff Jane Doe repeats and realleges paragraphs through above On numerous occasions Defendant Epstein did in fact intentionally touch Plaintiff Jane Doe on her person against her will and/or without her legal consent Defendant Epstein battered her sexually in that he touched her in intimate areas of her body and person in an offensive manner while she was a minor child and therefore the touchings were without legal consent Defendant Epstein touched her in intimate areas of her body on dozens of occasions between approximately February and approximately June The conduct described in this count constitutes battery against the person of the then minor Plaintiff Case Document Entered on FLSD Docket Page of As a direct and proximate result of Defendant Jeffrey Epsteins sexual battery on Plaintiff Jane Doe Plaintiff 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 her childhood loss of dignity invasion of her privacy and other damages associated with Defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and unconventional way of life for a minor The then minor Plaintiff incurred medical and psychological expenses and Plaintiff Jane Doe will in the future suffer additional medical and psychological expenses Plaintiff Jane Doe 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 Jane Doe will continue to suffer these losses in the future WHEREFORE Plaintiff Jane Doe demands judgment against Defendant Jeffrey Epstein for compensatory damages punitive damages and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT II Cause of Action Pursuant to USC Plaintiff Jane Doe adopts and realleges paragraphs through above The allegations contained herein in Count II are a separate and distinct legal remedy As a condition of Defendant Jeffrey Epsteins criminal plea and in exchange for the Federal Government not prosecuting the Defendant for numerous Case Document Entered on FLSD Docket Page of federal offenses the Defendant Jeffrey Epstein entered into a Non-Prosecution Agreement with the Federal Government wherein he acknowledged Plaintiff Jane Doe as a victim of certain criminal offenses he committed against Jane Doe The Plaintiff Jane Doe was in fact a victim of one or more offenses enumerated in Title United States Code Section 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 Specifically Defendant Epstein a knowingly conspired with others known and unknown to use a facility or means of interstate commerce to knowingly persuade induce or entice minor females including Plaintiff Jane Doe to engage in prostitution in violation of title United States Code Section knowingly and willfully conspired with others known such as Sarah Kellen and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct with minors including Plaintiff Jane Doe as defined in U.S.C with minor females in violation fo Title United States Code Section all in violation of Title United States Code Section used a facility or means of interstate or foreign commerce to knowingly persuade induce or entice minor females including Plaintiff Jane Doe to engage in prostitution in violation of Title United States Code Section Case Document Entered on FLSD Docket Page of traveled in interstate commerce for the purpose of engaging in illicit sexual conduct as defined in U.S.C with minor females including Plaintiff Jane Doe in violation of Title United States Code Section As a direct and proximate result of the aforementioned criminal offenses enumerated in Title United States Code Section being committed against the then minor Plaintiff the Plaintiff Jane Doe has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with Defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and unconventional way of life for a minor The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff Jane Doe will in the future suffer additional medical and psychological expenses The Plaintiff Jane Doe 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 Jane Doe will continue to suffer these losses in the future WHEREFORE Plaintiff Jane Doe demands judgment against Defendant Jeffrey Epstein for compensatory damages punitive damages attorneys fees 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 Case Document Entered on FLSD Docket Page of COUNT Ill Intentional Infliction of Emotional Distress Plaintiff Jane Doe adopts and realleges paragraphs through above Defendant Jeffrey Epsteins inappropriate sexual conduct towards the then minor Plaintiff was extreme and outrageous under the circumstances his conduct was outrageous and so extreme in degree that it should not be tolerated in a civilized community Defendant Jeffrey Epstein acted with the intent to cause severe emotional distress or with reckless disregard of the high probability of causing severe emotional distress upon the then minor Plaintiff Defendant Jeffrey Epstein was well aware that Plaintiff was a minor child and yet he continued to sexually abuse her intentionally and recklessly causing Plaintiff to suffer extreme emotional distress Defendant Jeffrey Epsteins intentional deliberate and reckless conduct caused severe emotional distress to the Plaintiff Jane Doe Defendant at the time he committed these numerous sexual assaults on Plaintiff Jane Doe had a specific intent to harm the then minor Plaintiff and his conduct did so harm the Plaintiff As a direct and proximate result of Defendant Jeffrey Epsteins intentional and reckless conduct Plaintiff Jane Doe has in the past suffered and in the future will continue to suffer severe emotional distress physical injury pain and suffering 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 Case Document Entered on FLSD Docket Page of unconventional way of life for a minor The then minor Plaintiff incurred medical and psychological expenses and Plaintiff Jane Doe will in the future suffer additional medical and psychological expenses Plaintiff Jane Doe 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 Jane Doe will continue to suffer these losses in the future WHEREFORE Plaintiff Jane Doe demands judgment against Defendant Jeffrey Epstein for compensatory damages punitive damages and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT IV Civil Remedy for Criminal Practices Plaintiff realleges paragraphs through above and for the purposes of this count incorporates and alleges the RICO Statement that has been contemporaneously herewith as Exhibit A The allegations contained herein in Count IV are a separate and distinct legal remedy brought pursuant to Florida Statute and Defendant Jeffrey Epstein was associated with an enterprise a group of individuals associated in fact although not a legal entity which was comprised of at least Defendant Jeffrey Epstein Sarah Kellen and Nadia Marcinkova and likely many other yet unknown persons Defendant Epstein participated in this enterprise or conspired or endeavored to so participate through a pattern of criminal activity in Case Document Entered on FLSD Docket Page of violation of Florida Statutes as further outlined in detail in the RICO statement filed with this court This enterprise was separate and distinct from Epstein himself and had a definite hierarchical structure Epstein served informally but effectively as the leader C.E.O or boss of this organization directing his underlings how to recruit and procure young girls for his sexual activities and when to bring the girls to his mansion Epsteins key lieutenant in the organization was Kellen who served as both his scheduler and a recruiter/procurer of the girls Marcinkova also served as a recruiter and helped Epstein satisfy his criminal sexual desires by on occasion directly participating in sexual abuse and prostitution of the minor girls Epstein also used otherwise-legitimate business activities to help further the purpose of the criminal enterprise These apparently legitimate activities provided cover for Epstein and his associates to commit the crimes Epstein and his associates maintained the appearance of running an upstanding investment business as well as other legitimate businesses with connections to modeling agencies and other powerful business and political people to discourage the minor girls from reporting the abuse to law enforcement Defendant Jeffrey Epstein participated in this enterprise through a pattern of criminal activity in that he engaged in at least two incidents of criminal activity as defined in Florida Statute and as described below that have the same or similar intents results accomplices victims or methods of commission and are not isolated incidents Defendant Jeffrey Epstein engaged in criminal activity by committing attempting to commit conspiring to commit or soliciting coercing or intimidating another Case Document Entered on FLSD Docket Page of person to commit one or more of the following predicate acts as outlined and defined in Florida Statute a Procuring for prostitution or causing to be prostituted any person who is under the age of years in violation of Florida Statutes Chapter Acts of battery in violation of Florida Statutes Chapter Forcing compelling or coercing another to become a prostitute in violation of Florida Statutes Chapter knowingly recruiting enticing harboring transporting providing or otherwise obtaining by any means a person knowing that coercion would be used to cause that person to engage in prostitution in violation of Florida Statutes Chapter tampering with a witness in violation of Florida Statutes Chapter altering destroying removing or concealing records or documents or other evidence with the purpose to impair its verity or availability in violation of Florida Statutes Chapter maintaining a place for the purpose of lewdness or prostitution offering or securing another for the purpose of prostitution or for some other lewd or indecent act receiving persons into his Palm Beach mansion for the purpose of prostitution or lewdness directing taking or transporting or agreeing to direct take or transport persons to his Palm Beach mansion with knowledge or reasonable belief that the purpose of such directing taking or transporting was prostitution or lewdness all in violation of Florida Statutes Chapter Case Document Entered on FLSD Docket Page of The criminal acts of Defendant Epstein occurred repeatedly over a substantial period of time and were not isolated events Under Defendant Jeffrey Epsteins plan scheme and enterprise Defendant Jeffrey Epstein paid employees and underlings including but not limited to Sarah Kellen to bring him minor girls to his Palm Beach mansion in order for the Defendant to solicit induce coerce entice compel or force such girls to engage in acts of prostitution and sexual misconduct with Defendant Epstein and sometimes Nadia Marcinkova and to otherwise commit acts of sexual battery thereon Plaintiff Jane Doe was the victim of Defendant Jeffrey Epsteins plan scheme and enterprise and was so injured by reason of his violations of the provisions of Plaintiff Jane Doe was called on the telephone by Defendant Epstein and other employees of his including Sarah Kellen and transported to the Defendant Jeffrey Epsteins residence where she was placed in a room along with the Defendant enticed to commit acts of prostitution and had acts of sexual battery and sexual exploitation committed against her Defendant Jeffrey Epstein conspired with his assistants and employees in order to accomplish their common motive or intent of seeking out gaining access to and exploiting minor children such as the Plaintiff Jane Doe in the aforementioned ways and he further conspired with his employees assistants and underlings to ensure that the crimes of this criminal enterprise were concealed or undetected by law enforcement After law enforcement began to detect the criminal activities of Defendant Epstein and the other persons involved in the criminal enterprise the enterprise used resources and information to conceal the illegal activities of the enterprise threaten the Case Document Entered on FLSD Docket Page of victims of the crimes of the enterprise if they revealed the full scope of the enterprise to law enforcement and concealed or destroyed documents relevant to the prosecution of the various members of the enterprise The enterprise also made various efforts to discourage the victims from cooperating with law enforcement and from filing civil lawsuits to vindicate their rights Epstein and other members of the enterprise made cash payments and gave gifts to the victims of the enterprise in order to discourage them from reporting crimes to law enforcement and other authorities The evidence clearly and convincingly establishes that Plaintiff Jane Doe was injured by reason of violations of the provisions of and as such is entitled to threefold the actual damages sustained and a minimum of and reasonable attorneys fees and court costs In the alternative and pursuant to Plaintiff Jane Doe was injured due to sex trafficking committed in violation of and is thus entitled to threefold the amount gained from the sex trafficking and to a minimum amount of damages not less than reasonable attorneys fees and court costs WHEREFORE under the provisions of Florida Statutes Chapter Plaintiff Jane Doe demands judgment against Defendant Jeffrey Epstein for any minimum damages authorized by law all actual damages sustained to be trebled as authorized by law court costs and attorneys fees 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 Case Document Entered on FLSD Docket Page of COUNTV Cause of Action Pursuant to Florida Statute Against Defendant Jeffrey Epstein Plaintiff adopts and realleges paragraphs through above The allegations contained herein in Count II are a separate and distinct legal remedy Defendant Jeffrey Epstein was a wealthy and powerful man and Plaintiff was an economically disadvantaged and impressionable minor Defendant Jeffrey Epstein used his vast wealth and power to coerce Plaintiff into prostitution and/or coerced her to remain in prostitution Defendant Jeffrey Epstein coerced Plaintiff into prostitution in one or more of the following ways A Domination of her mind and body through exploitive techniques Inducement Promise of greater financial rewards Exploitation of a condition of developmental disability cognitive limitation affective disorder and/or substance dependency Exploitation of human needs for food shelter or affection Exploitation of underprivileged and vulnerable economic condition or situation Use of a system of recruiting other similarly situated minor girls to further coerce and induce Plaintiff into the lifestyle of prostitution and Case Document Entered on FLSD Docket Page of Exploitation through demonstration of abundant wealth and power to impress a young and vulnerable then minor Plaintiff and to coerce her into prostitution As a direct and proximate result of the offenses committed by Defendant Jeffrey Epstein against Plaintiff pursuant to Florida Statutes the Plaintiff has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with Defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and unconventional way of life for a minor The then minor Plaintiff incurred medical and psychological expenses and Plaintiff will in the future suffer 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 the Plaintiff will continue to suffer these losses in the future WHEREFORE Plaintiff Jane Doe demands judgment against the Defendant Jeffrey Epstein for compensatory damages attorneys fees 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 DATED April Case Document Entered on FLSD Docket Page of Respectfully Submitted Plaintiff by One of Her Counsel Bradley Edwards Bradley Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre East Las Olas Blvd Suite Fort Lauderdale Florida Telephone Facsimile Florida Bar No E-mail bedwards rra-law.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April I electronically filed the foregoing document with the Clerk of Court using CM/ECF I also certify that the foregoing is being served this day upon all counsel of record identified on the attached Service List in the manner specified either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing Bradley Edwards Bradley Edwards Case Document Entered on FLSD Docket Page of SERVICE LIST Case No MARRA/JOHNSON Attorneys for Defendant Robert Deweese Critton Jr rcrit bclclaw.com Michael James Pike MPike bclclaw.com Burman Critton Luttier Coleman Flagler Drive Suite West Palm Beach FL fax Lead Counsel Jack Alan Goldberger Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL fax jagesq bellsouth.net Co-Counsel Attorneys for Plaintiff Bradley James Edwards Rothstein Rosenfeldt Adler East Las Olas Blvd Suite Ft Lauderdale FL fax bedwards rra-law.com Lead Counsel Paul Cassell South Room Salt Lake City UT fax cassellp law.utah.edu Pro Hae Vice Jay Howell Jay Howell Associates PA Cesery Boulevard Suite Jacksonville FL jay jayhowell.com Case Document Entered on FLSD Docket Page of JANE DOE JEFFREY EPSTEIN Case No MARRA/JOHNSON EXHIBIT A Case Document Entered on FLSD Docket Page of CIVIL RICO CASE STATEMENT PURSUANT TO LOCAL RULE Plaintiff Jane Doe alleges a violation of Florida Statutes participation in an enterprise through a criminal activity and conspiracy to do so The following information describes both the claim and the conspiracy claim with the additional note that the conspiracy was between defendant Jeffrey Epstein Sarah Kellen Nadia Marcinkova and numerous other persons whose identity is at this time unknown to Jane Doe Epstein Kellen Marcinkova and others all conspired together to violate the provisions of doing so willfully and with full knowledge of the criminal activities that were planned as part of the criminal enterprise For convenience in this statement Florida Statutes and will be referred to as the Florida Civil RICO provisions While others including Kellen and Marcinkova were involved in the plan scheme and enterprise the sole defendant alleged in this complaint at this time is defendant Jeffrey Epstein Epstein served as the leader and informal C.E.O of the criminal enterprise He also criminally sexually abused and prostituted Jane Doe and other minor girls who were victims of the criminal enterprise He also paid for Kellen and Marcinkova to be a part of the enterprise and conspired with them to commit criminal acts of sexual abuse and prostitution of minors The basis for Epsteins liability is also described in Jane Does complaint The other wrongdoers included Sarah Kellen and Nadia Marcinkova Jane Doe is uncertain as to the precise spelling of their names and their full legal names They assisted defendant Jeffrey Epstein in recruiting and procuring minor girls to satisfy Epsteins criminal sexual purposes and for prostitution For example they Case Document Entered on FLSD Docket Page of contacted the minor girls on the telephone to schedule times for each girl to work for Defendant Epstein at his house and they helped to arrange for minor girls to travel to Epsteins West Palm Beach mansion to satisfy his sexual desires for minor girls Kellen and Marcinkova also conspired with Epstein to commit acts of sexual abuse and prostitution with minor girls and aided and abetted Epstein in the abuse and prostitution Kellen and Marcinkova had full knowledge of the crimes of the enterprise they knew full well that the girls who were coming to Epsteins mansion were minors and that Epstein was sexually abusing and prostituting these minors some of whom were or younger Kellen and Marcinkova willfully and knowingly participated in the activities of the enterprise and intended to make the criminal activities of the enterprise succeed Among other things Kellen helped arrange for recruiters of the minor girls and assisted Epstein in converting minor girls into prostitutes for Epsteins sexual gratification as well as encouraged and coerced these minor girls into recruiting additional minor girls for Epstein and sometimes Marcinkova to sexually batter and exploit all in furtherance of the goal of the criminal enterprise She also spoke personally to the recruiters as well as to the minor girls who were victims of Epstein sexual abuse At Epsteins specific direction Kellen spoke to the recruiters about subjects such as finding more minor girls to satisfy Epsteins criminal sexual appetite Kellen also served as Epsteins scheduler scheduling appointments for the minor girls to ostensibly do work when in fact as she well knew she was scheduling them to be sexually abused and prostituted by Epstein Kellen thus procured minor girls for prostitution and caused them to be prostituted Marcinkova also directly participated in the sexual abuse of the minor girls by participating in unlawful sexual activities and prostitution with the girls Both Kellen and Case Document Entered on FLSD Docket Page of Marcinkova assisted Epstein in attempting to keep Epsteins criminal sexual abuse unknown to law enforcement and other authorities and in discouraging the minor girls from reporting the crimes to law enforcement and other authorities The names of all of the victims are unknown to the plaintiff at this time However they include Jane Doe herself as well as the victim in E.W Jeffrey Epstein and L.M Jeffrey Epstein A list of more than such minor female victims has previously been provided by the U.S Attorneys Office for the Southern District of Florida to Epstein but not to Jane Doe The injuries to those victims resulted from criminal sexual activity and prostitution with Epstein and Marcinkova The injuries they suffered are like those suffered by Jane Doe in this action as described in paragraph of her complaint For example Jane Doe and the other victims suffered grave emotional distress and financial injury from being forced to engage in unlawful sexual activities with him to which as minors they could not lawfully consent They also suffered distress and financial injury from being prostituted by him The pattern of racketeering and/or criminal activity is also described in the complaint which Jane Doe incorporates by reference into this statement here and at all other points in the statement The criminal activity included Epstein using paid employees and underlings including Kellen and Marcinkova to repeatedly find procure and bring to him minor girls in order for Epstein to solicit induce coerce entice compel or force these minor girls to engage in unlawful sexual activity and acts of prostitution The criminal activity and specific statutes violated that are relevant to the RICO count include but are not necessarily limited to Procuring for prostitution or causing to Case Document Entered on FLSD Docket Page of be prostituted any person who is under the age of years in violation of Florida Statutes Chapter Acts of battery in violation of Florida Statutes Chapter Forcing compelling or coercing another to become a prostitute in violation of Florida Statutes Chapter knowingly recruiting enticing harboring transporting providing or otherwise obtaining by any means a person knowing that coercion would be used to cause that person to engage in prostitution in violation of Florida Statutes Chapter tampering with a witness in violation of Florida Statutes Chapter altering destroying removing or concealing records or documents or other evidence with the purpose to impair its verity or availability in violation of Florida Statutes Chapter maintaining a place for the purpose of lewdness or prostitution offering or securing another for the purpose of prostitution or for some other lewd or indecent act receiving persons into his Palm Beach mansion for the purpose of prostitution or lewdness directing taking or transporting or agreeing to direct take or transport persons to his Palm Beach mansion with knowledge or reasonable belief that the purpose of such directing taking or transporting was prostitution or lewdness all in violation of Florida Statutes Chapter Numerous other crimes were committed by the criminal enterprise against the minor victims however those numerous other crimes are not crimes enumerated in the criminal activity section of the civil RICO section a The dates of the events are not fully known to Jane Doe at this time However at a minimum Epstein obtained minor girls including Jane Doe for sexual purposes of the period of approximately June through November Epstein could better determine than Jane Doe the precise dates of his abuse of her by reviewing Case Document Entered on FLSD Docket Page of his schedule for this period of time and looking for notations of days on which she performed work for him Epstein has pied guilty to two such criminal offenses against minor girls although the total number of indictable or chargeable offenses would easily number more than On each of these occasions as described in the complaint Epstein would have his underlings including Kellen procure a minor girl to satisfy his sexual desires and then would satisfy his sexual desires through criminal sexual contact and conduct with the minor girls Epstein would also watch Marcinkova sexually abuse the minor girls to satisfy his sexual desires Epstein had a particular interest in minor girls including girls as young as or younger On occasion he would turn away girls who were or over because of perverse and unlawful sexual interest in young girls Epstein recruited and paid the girls for the sexual activities In doing so he procured for prostitution and caused to be prostituted many young girls under the age of in violation of among other statutes Florida Statute The pattern of criminal and unlawful sexual activity extended from at least June through November Epstein committed unlawful sexual abuse against Jane Doe at least times between February to June while she was a minor Other criminal activities involving tampering with and harassing witnesses occurred from June through early and perhaps later On many of the occasions the exact dates of which are not as yet determined by the Jane Doe Epstein would represent that he was interested in a massage or legitimate work when in fact he was interested in unlawful sexual activity with the minor girls including fondling the girls masturbating in their presence and vaginally penetrating them or causing them to be penetrated Epstein and others acting Case Document Entered on FLSD Docket Page of under his direction falsely represented to the minor girls that he was interested in a massage or work when in fact he was interested in procuring the girls for unlawful sexual activity and acts of prostitution Epstein and others acting under his direction used means of interstate communications to make these false representations including cellular telephones Epstein has pied guilty to two Florida criminal offenses against minor girls The relationship of the criminal activity to the enterprise is also described in the complaint The Florida offenses to which Epstein pied guilty are but a few of the many instances of his plan succeeding The acts are all related to each other are arranged and are part of a common plan for these reasons they have the same intent to gratify Epsteins unlawful sexual interest in minor girls the same results the unlawful sexual abuse and prostitution of minor girls the same accomplices including Kellen and frequently Marcinkova the same victims Jane Doe was herself victimized more than times and many other girls were also victimized repeatedly the same means there was a standard payment of several hundred dollars for going to the mansion and standard escalation feature depending on the nature of the sexual acts that Epstein performed and the same methods of commission Epstein obtained young skinny and attractive girls to satisfy his sexual desires while they were economically disadvantaged and lacked a stable family life and therefore he perceived would be interested in obtaining money and unlikely to report his crimes to law enforcement The acts were also interrelated by common characteristics namely the identity of the perpetrator Epstein and often Marcinkova and the common results of his crimes sexual abuse and acts of prostitution with minor girls The acts also constituted Case Document Entered on FLSD Docket Page of a clear pattern of criminal activity The criminal acts of Epstein occurred repeatedly over a substantial period of time and were not isolated events In particular Epstein committed repeated more than criminal acts of sexual abuse against Jane Doe from approximately February to June He committed similar criminal acts of unlawful sexual activity and prostitution against other minor girls for a period of time exceeding more than three years from approximately June through November The acts occurred frequently during this time easily exceeding more than instances of criminal sexual abuse Jane Doe does not know the exact number of acts but intends to determine this during the discovery process It is possible that the total number of acts could be several hundred or thousand The acts were part of Epsteins regular way of doing business e.g obtaining sexual gratification during this period of time Epstein and others acting at his direction including Kellen made hundreds of telephone calls in furtherance of these illegal activities It is common belief that the sexual acts ag minors temporarily ceased in approximately November when Epstein learned that law enforcement authorities were investig his crimes If however Epstein througli his criminal enterprise is given the opportunity to commit similar acts in the future upon his release from jail the enterprise will likely continue this illegal activity In addition pstein committed criminal acts of tampering with witnesses in violation of Florida Statutes For example Epstein paid the minor girls money not only with the intent to prostitute them but also with the specific intent of causing the minor girls not to communicate to law enforcement officers information about the sexual abuse committed igainst them pstein made big_ger payments to the minor girls depending on the Case Document Entered on FLSD Docket Page of igree of force he used towards them making ger payments when he was more concerned about the fact they might report the crimes committed against them These payments pose a continuing threat of misconduct as they may interfere with the ability of law enforcement to discover and prosecute all of Epsteins crimes Epstein or other members of his enterprise paid for attorneys to represent several of his minor victims while he and his employees or assistants were being criminally investigated in an effort to influence the testimony of persons that had information otherwise valuable to law enforcement Epstein and his enterprise may likewise interfere with the ability of Jane Doe to discover all of the information supporting her claim pstein also selected 247poverished girls for his crimes believing that the payments would be more effective in obtaining their silence and that their economic circumstances might make them less likely to report to law enforcement If all else failed after having unlawful sex with the minor girls Epstein would tell them not to tell anyone about their unlawful encounter or bad things would happen In addition since November and through the early part of and perhaps later Epstein and others acting at his direction have attempted to discourage the victims of his crimes from reporting his crimes and cooperating with law enforcement For example persons acting at the direction of pstein have ag_gressively attempted to interview the victims or to tail the victims in their cars They also harassed a victim shortly before she was to testify at a grand jury investig Epstein These efforts have been made not for legitimate investig reasons but rather for the purpose of discouragl!!_g the victims from cooperating with law enforcement and in at least one case the investigating_grand jury and from filingi I lawsuits to vindicate their rig Case Document Entered on FLSD Docket Page of The enterprise included at a minimum a group of individuals associated in fact to assist Epstein in recruiting and procuring minor girls and obtaining criminal gratification of his illegal sexual interest in minor girls a The persons constituting the enterprise included a group of individuals associated in fact These individuals include Epstein Sarah Kellen and Nadia Marcinkova as well as other persons whose names Jane Doe intends to identify during the discovery phase of this case The criminal enterprise had a definite structure similar to a mafia-type family although all the details of that structure are not currently known to Jane Doe Through discovery Jane Doe intends to ascertain the precise structure of the enterprise that enabled Epstein to commit sexual crimes against her While Jane Doe does not currently know all of the details of the structure she does know that the enterprise operated together on a continuing basis with largely the same personnel for a common purpose The shared purpose of the enterprise was to satisfy Epsteins illegal interest in having sexual activities with minor girls The enterprise was not a mere informal conspiracy but had a definite hierarchical structure Epstein served informally but effectively as the leader C.E.O or boss of this organization directing his underlings how to recruit and procure young girls for his sexual activities and when to bring the girls to his mansion Epsteins key lieutenant in the organization was Kellen who served as both his scheduler and a recruiter/procurer of the girls This was an important function as the recruiting was necessary to satisfy Epsteins desire to abuse a large number of different minor girls with different albeit similar physical attributes and the scheduling was necessary to insure that the minor girls would be brought to Epsteins Case Document Entered on FLSD Docket Page of mansion to be sexually abused and prostituted at a time when Epstein was there but not at the same time when they might learn of other girls identities and possibly become emboldened to report his activities to law enforcement Scheduling was also necessary to ensure secrecy so that as few persons as possible were aware that minor girls were coming at unusual hours to Epsteins mansion Kellen also needed directly or indirectly to make transportation arrangements for many of the girls as they were often too young to drive themselves to and from the mansion Marcinkova also served as a recruiter and helped Epstein satisfy his criminal sexual desires by on occasion directly participating in sexual abuse and prostitution of the minor girls Epstein Kellen and Marcinkova all took steps to conceal the existence of the enterprise and to discourage the girls from reporting the sexual abuse and prostitution to law enforcement or other authority figures Epstein also used otherwise-legitimate business activities to help further the purpose of the criminal enterprise These apparently legitimate activities provided cover for Epstein and his associates to commit the crimes Epstein also maintained the appearance of an upstanding and prominent banker and investor to discourage the minor girls from reporting the abuse to law enforcement By projecting an image of financial power and strong political connections to prominent politicians and current and former government officials and personal connections to prominent scientists Epstein hoped to discourage the minor girls from reporting what he was doing to them by making it appear that they would not be believed These business activities helped Epstein secure the financial resources to commit the crimes against the minor girls and to pay for prostituting them For example the activities paid for maintaining the mansion where the girls were abused and paid for the cellular Case Document Entered on FLSD Docket Page of telephones and other means of communications that were used to recruit and procure the girls The business activities also helped to provide the funds to pay Kellen and Marcinkova large sums of money to participate in the illegal enterprise and make payments to the girls for performing sexual acts In sum Epstein and the persons under his direction associated in fact and functioned as a continuing unit This enterprise produced a course of conduct that lead to a pattern of criminal activity involving hundreds of instances of sexual abuse and prostitution of minor girls This enterprise was the vehicle for Epstein to commit his crimes against Jane Doe and other minor girls and operated on a continuing basis from June to November and in regard to witness tampering and harassment through at least early The enterprise enabled Epstein to sexually abuse and prostitute Jane Doe in particular on more than occasions from February through June Epstein served as the informal but effective leader or C.E.O of the enterprise Epstein was associated with the enterprise as its informal but effective leader or C.E.O Epstein directed the affairs of the enterprise and the others in the enterprise responded to his commands Based on the facts that she currently possesses Jane Doe specifically alleges and intends to prove both that i Epstein was an individual separate from the enterprise and ii the defendant was a member of the enterprise namely that he served as the effective leader of the enterprise With regard to point i the illegal enterprise had a definite structure and operational function apart from Epstein The structure is Case Document Entered on FLSD Docket Page of described in greater detail in this statement in answer above With regard to point ii the defendant was a member of the enterprise and served to execute many of the decisions and activities of the enterprise and to command the execution of others Epstein personally engaged in sexual abuse of minor girls including Jane Doe Epstein also directed others to engage in sexual abuse of minor girls including Marcinkova Epstein also procured girls for prostitution and caused these girls to be prostituted Epstein also served as the leader of the enterprise Epstein was a direct perpetrator of the racketeering activity In particular Epstein engaged in criminal acts of sexual abuse and prostitution with minor girls as well as procuring girls for prostitution He also directed others i.e Marcinkova to engage in such criminal acts and served as the leader of the criminal enterprise The relationship between the pattern of criminal activity and the enterprise is not completely known to Jane Doe at this time There was a criminal entity separate and apart from the pattern of activity in which it eng ged The pattern of criminal activity was the series of crimes committed by Epstein and others and includes the specific crimes identified in part above These offenses were closely related and formed a clear pattern as described in part above These acts included acts of sexual abuse and procuring the prostitution of minors by Epstein personally and by Marcinkova acting at Epsteins direction In contrast the enterprise was the group of persons who associated together for the common purpose of eng in the criminal course of conduct described at greater length elsewhere in this statement including part above The group of persons included Epstein Kellen and Marcinkova and numerous others whose identity is at this time unknown to Jane Doe Case Document Entered on FLSD Docket Page of In this part of the statement Jane Doe will provide a description of the relationship between the otherwise-lawful activities of the enterprise and the criminal activities of the enterprise The lawful and unlawful activities of the enterprise have been described in addition in the complaint and previous answers found in parts and above which Jane Doe expressly incorporates into her answer here The usual and daily activities of the criminal enterprise included scheduling meetings activities and other events for Epstein including scheduling private time in his mansion for Epstein to commit sexual crimes against minor girls Kellen served as Epsteins scheduler scheduling both otherwise-lawful activities to provide cover for Epstein as well as the illegal sexual activities The exact frequency with which the sexual crimes took place varied and is not known at this time to Jane Doe However when Epstein was in West Palm Beach it often occurred on a weekly or daily basis and in some instances took place on several times during a single day The scheduling was designed to secure a private place in Epsteins mansion when few other persons would be present at the mansion so as to reduce the chance of detection of Epsteins sexual abuse and prostitution as well as to make it more difficult for the minor girls to report his actions to law enforcement or other authorities The usual activities of the enterprise also included maintaining the mansion and securing means of communication i.e cellular telephones to recruit minor girls and procure them for prostitution The activities further included arranging transportation for the girls to and from the mansion if it was necessary The enterprise also attempted to make Epstein appear to be an upstanding and law-abiding member of community and a successful businessperson for reasons described in paragraph above The enterprise served as the usual way Case Document Entered on FLSD Docket Page of in which Epstein would obtain sexual gratification Through his criminal enterprise Epstein received perverse and unlawful sexual gratification from sexually abusing minor girls and eng_ in acts of prostitution with them He also received perverse sexual gratification from directing others e.gJ Marcinkova to sexually abuse and prostitute minor girls He could not have gained access to the great number of minor girls without a structured and organized enterprise promoting the same agenda and plan While Jane Does civil action alleges violations of the Florida Civil RICO statute rather than violations of the federal civil RICO statute it should be noted that means of interstate communications were used to perpetrate the crimes against minor girls including Jane Doe including cellular and other telephones that Epstein used or caused to be used to arrange his illegal sexual activities and to recruit additional minor girls to participate in these activities Through his recruitment and procuring of young girls Epsteins activities directly affected interstate commerce Based on the information currently known to her Jane Doe does not allege that Epstein who is a billionaire banker used the enterprise to personally make a financial profit or to obtain the collection of an unlawful debt That being said Plaintiff Jane Doe does not concede that the enterprise did not turn a profit Discovery will reveal this information regarding profits appreciated by the criminal enterprise through various criminal activities of the enterprise Epstein did however make payments to and prostitute the minor girls for the sexual gratification that he obtained from them and to discourage them from reporting his crimes to law enforcement and other authorities Based on the information currently known to her Jane Doe does not Case Document Entered on FLSD Docket Page of allege that Epstein who is a billionaire banker used the enterprise to obtain or maintain control of a business enterprise or real property Epstein did however use his West Palm Beach mansion to perpetrate the crimes against the then-minor girls He also used his financial success to provide cover for his crimes as described in part above The criminal enterprise is described in the complaint and part of this statement above which description Jane Doe incorporates here a The enterprise included persons unknown to Jane Doe but at least included Epstein and his paid assistants Sarah Kellen and Nadia Marcinkova Under the direction of Epstein Kellen Marcinkova and others whose names are unknown to Jane Doe arranged for minor girls to come to Epsteins mansion where he could sexual abuse them and prostitute them to satisfy his perverse sexual desires Kellen and Marcinkova were responsible for recruiting the girls and procuring them for prostitution Kellen was also responsible for scheduling a time when both Epstein and the minor girl could meet together at Epsteins mansion for the sexual abuse and for making travel arrangements if necessary for the girls Kellen was also responsible for ensuring the privacy of the room in Epsteins mansion where Epstein would sexually abuse the girls Marcinkova would participate in abusing and prostituting the girls for Epsteins sexual gratification Kellen and Marcinkova received payments and other forms of compensation from Epstein for performing these illegal activities and for participating in the enterprise Epstein Kellen and Marcinkova also all took steps to discourage the girls from reporting these crimes to law enforcement including making cash payments to the girls Case Document Entered on FLSD Docket Page of As a result of the criminal enterprise Jane Doe then a minor suffered criminal sexual abuse at the hands of Epstein As alleged in greater detail in the complaint this abuse primarily lead to actual damages namely loss of personal property for which she is statutorily entitled to no less than The property lost in the form of lost income loss of ability to earn income and monies expended by her for medical and psychological treatment Stated simply she lost money property as a result of this sexual abuse she suffered at the hands of Epsteins criminal enterprise The abuse also lead to significant past and future physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of privacy and other damages including consequential damages from Epstein controlling manipulating and coercing her into a perverse and unconventional way of life for a minor In addition the time involved in the abuse created lost opportunities to pursue other activities including economic activities and lead to past and future financial and proprietary losses to Jane Doe as well as the need for psychiatric services Jane Doe has also suffered a loss of income a loss of capacity to earn income in the future and a loss of the capacity to enjoy life It has also lead to the need to file this civil suit with consequent attorneys fees All of these damages were caused by and proximately caused by the criminal enterprise and its criminal acts All of these injuries were inflicted directly on Jane Doe and occurred by reason of the criminal acts of the enterprise including the acts of sexual abuse by Epstein The defendant person in the Florida Civil RICO action is at this time only defendant Epstein Defendant Epstein is associated with a criminal Case Document Entered on FLSD Docket Page of enterprise that conducted and participated both directly and indirectly in a pattern of criminal activity in violation of both Florida and federal criminal law The exact relationship between Epstein and the criminal enterprise is described in greater detail in parts and above The criminal conspiracy involving the enterprise is described above Jane Doe expressly incorporates that information into her statement here The conspiracy was formed of Epstein Kellen Marcinkova and others who agreed to arrange for illegal sexual gratification by Epstein through the sexual abuse and prostitution of minor girls both by Epstein personally and by others i.e Marcinkova while he watched The object and substance of the conspiracy was to obtain minor girls for Epstein so that he could satisfy his perverse sexual interest in minor girls to recruit minor girls to be abused and prostituted for his gratification to keep the existence of the sexual abuse from being learned by law enforcement and other authorities and to discourage the victims from reporting the abuse to authorities The conspiracy started no later than approximately June in West Palm Beach Florida and other locations The sexual abuse of the minor girls appears to have at least temporarily ceased in approximately The conspiracy extended beyond November to early and perhaps later in its efforts to keep the criminal conspiracy unknown as described in part above The conspiracy committed numerous overt acts For example Kellen and Marcinkova arranged for minor girls to be brought to Epsteins West Palm Beach mansion so that he could sexually abuse the girls and obtain sexual gratification Epstein sexually abused minor girls at his mansion and made payments to them and otherwise prostituted them there Case Document Entered on FLSD Docket Page of Jane Doe suffered actual damages including financial and proprietary injuries as described in part above The enterprise injured Jane Doe and the other minor girls by enabling Epstein to sexually abuse and prostitute the girls Defendant Epstein is liable for all the damages for his criminal activity and the activity of his criminal enterprise If additional defendants are added to the complaint these other defendants may also be jointly and severable liable for the damages The damages for which Epstein is liable include compensatory damages including damages for emotional distress as well as damages for financial and proprietary losses attorneys fees and such further relief as the Court deems just and proper The amount of these damages is in excess of These damages recoverable under the Civil RICO count are trebled by operation of Florida Statutes Jane Doe is aware of the provision in Florida Statutes In no event shall punitive damages be awarded under this section but is nonetheless entitled to punitive damages by virtue of her complaint She is seeking punitive damages for Epsteins outrageous and egregious conduct and crimes under other provisions of law in this lawsuit All of the above answers must be read in light of the complaint that has been filed in this case Jane Doe expressly incorporates by reference her complaint as part of the answer to each of the above questions Whenever the word include or its variations appears in this statement the information that follows is not intended to be an exclusive listing APP IN THE CIRCUIT COURT OF THE FIFT ENTH JUI CIAL CIRCUIT IN AND FQR PALMBEACHCOUNTY FLQRIDA E.W I ii Plaintiff JEFFREY EPST,EINand SARAH KELLEN Defendants No BCAO SBXMBAD West Palm.Beach Florida VIDEOTI PED.DEPOSITION OF JEFFREY EPSTEIN Paim Beach Reporting Service Inc Thereupon a lunch break was taken from to THE VIDEOGRAPHER we back on record at MR EDWARDS Ready MR GOLDBERGER Sure By Mr Edllards r-.-Epstein,-did_youJ girls-that-you were-engaging-in-sex-with MR BURMAN Object to the form THE WITNESS intend to respond to all relevant questions regarding this lawsuit However at the.present time my attorneys have counseled me that I cannot provide answers to any questions relevant to this lawsuit at this tiine so mllst accept their advice or I lose potential I risk losing my Sixth Amendment right to effective representation And accordingly I have to assert my Federal Constitutional rights as guaranteed by the Fifth sixth and Fourteenth Amendment to the United States Constitution By Mr Edwards Did it ever occur to you that any of these girls were somebodys daught MR BURMAN Object to the form Palm Beach Reporting Serv:i.ce Inc a is 1B 2i By Mr Edwards Isi:it ii true that at the time that you were sexually battering these minor girls you didnt care what happened to them and only ca:red about.your only personal sexual grat:i.ficat:i.on MR BURMAN Object to the form We need to talk outside THE WITNESS too THE VIDEOGRAPHER We re off the record af There11pon a brief break wa:s taken THE VIDEOGRAPHER We re back on the record at MR BURMAN For 267the purposes of the record I wfil tell you tllat this line.of questioning I in my view I is way beyond the bounds or permissible discovery-type questions arid nothing but pure argument and if you continue in this vein I will stop the deposition and we will seek instruction from Judge Raf ele about what I permis_sible and whats not By Mr Edwards Isn it true that atj the time you were inserting your fingers into _gina of these little 243ias all you caredanout was Palm ach Rep9rting Service Inc your own sexual gratification MR BURMAN The deposition is over THE:VIDEOGRAPHER Conclud at erid of tape of MR BERGER Were go,ing to order instant copy and we want the tape also Mr Vi leogr,apller MR BURMAN We 267want this as soon as they get theirs we want 267ou:ts Thereupon the deposition wa:s adjourned at p.m Palm Beach Reporting Service Inc APP Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant I JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant I JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant I CASE NO 08-CV-80119-MARRA/JOHNSON CASE NO 08-CV-80232-MARRA/JOHNSON CASE NO 08-CV-80380-MARRA/JOHNSON Case Document Entered on FLSD Docket Page of JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant I JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant I JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant __ CASE NO 08-CV-80119-MARRA/JOHNSON CASE NO 08-CV-80381-MARRA/JOHNSON CASE NO 08-CV-80994-MARRA/JOHNSON CASE NO 08-CV-80993-MARRA/JOHNSON Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON CASE NO 08-CV-80811-MARRA/JOHNSON C.M.A Plaintiff vs JEFFREY EPSTEIN Defendant I JANE DOE Plaintiff Vs CASE NO 08-CV-80893-CIV-MARRA/JOHNSON JEFFREY EPSTEIN et al Defendant I DOEii CASE NO 09-CV-80469-MARRA/JOHNSON Plaintiff vs JEFFREY EPSTEIN et al Defendants I Case Document Entered on FLSD Docket Page of JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant I CASE NO 08-CV-80119-MARRA/JOHNSON CASE NO 09-CV-80591-MARRA/JOHNSON CASE NO 09-CV-80656-MARRA/JOHNSON PLAINTIFF JANE DOES MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON Epsteins property and to post a million bond to secure any potential judgment in this case Epstein is a billionaire who recently has been fraudulently transferring his assets overseas and elsewhere with the intent to prevent Jane Doe and possibly numerous other victims of his sexual abuse from satisfying any judgment they might obtain against him Federal Rule of Civil Procedure guarantees Jane Doe all available state law pre-judgment remedies to respond to these fraudulent transfers Florida has adopted the Florida Uniform Fraudulent Transfer Act FUFTA Fla Stat Ann et seq which gives the Court power to appoint a receiver to take charge of assets that are being fraudulently transferred Given the serious allegations of sexual abuse against Jane Doe when she was a minor this Court should appoint a receiver to control and account for Epsteins assets and direct the receiver to post a million bond with this Court on behalf of Epstein to satisfy any judgment that Jane Doe might obtain STATEMENT OF MATERIAL FACTS Defendant Jeffrey Epstein is the defendant in this action which involves claims by Jane Doe that Epstein repeatedly sexually abused her when she was a minor Because of the egregious and repeated acts of sexual abuse committed by Epstein her complaint seeks damages in excess of million including punitive damages See Amended Complaint Defendant Jeffrey Epstein is extremely wealthy According to reputable press reports in the New York Times and elsewhere he is a billionaire He is also the owner Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON of a Caribbean island in the Virgin Islands Little St James Island where he serves as a financial advisor to other billionaires He was previously a financial trader at Bear Stearns It is therefore reasonable to infer that he has a great deal of financial sophistication See Affidavit of Paul Cassell at Attachment A to this Pleading According to reputable press reports before his recent incarceration discussed below he frequently traveled around the globe in the company of such famous persons as President Bill Clinton Prince Andrew and Donald Trump It is therefore reasonable to infer that he has international contacts including international financial contacts See Affidavit of Paul Cassell at Over the past year approximately civil suits have been filed in Florida state courts and Florida federal courts raising similar allegations of sexual abuse by Jeffrey Epstein against minor girls These complaints seek damages comparable to those sought by Jane Doe in this case See Affidavit of Paul Cassell at Accordingly Epstein has currently pending against him lawsuits seeking more than billion in damages He thus faces financial ruin Id On June Jeffrey Epstein pied guilty to one count of procuring a person under for prostitution and one count of felony solicitation to prostitution before the Circuit Court of the Fifteenth Judicial circuit in and for Palm Beach County Florida He was sentenced to months in jail Since those guilty pleas he has been incarcerated in the Palm Beach County Detention facility However he has also been allowed out on a work release program where he works at managing his financial interests Affidavit of Paul Cassell at Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON Given the substantial claims against him his international connections and other information Jane Does counsel has been gravely concerned that Epstein will fraudulently transfer all of his assets to overseas locations to defeat collection of any judgment that she might obtain against him Accordingly as part of discovery in this case Jane Doe propounded requests for admissions by Epstein regarding whether he was fraudulently transferring assets Rather than answering these requests for admission about on-going fraudulent transfers of his property Jeffrey Epstein asserted his Fifth Amendment right against self-incrimination Affidavit of Paul Cassell at Jeffrey Epsteins net worth is greater than billion Jane Does First Request for Admissions RFAs Attachment to this Pleading Epsteins Resp to RFAs Attachment to this Pleading Since he was incarcerated Jeffrey Epstein has directly or indirectly through the services or assistance of other persons conveyed money and assets in an attempt to insulate and protect his money and assets from being captures in civil lawsuits filed against him Epsteins Resp to RFAs Epstein owns and controls real estate property in foreign countries including the Caribbean Epsteins Resp to RFAs and Epstein is currently moving significant financial assets overseas outside of the direct territorial reach of federal and Florida courts Epsteins Resp to RFA Epstein is transferring these assets with the intent to defeat any judgment that might be entered against him in this and other similar cases Epsteins Resp to RFA Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON Epstein could currently post a million bond to satisfy a judgment in this case without financial or other difficulty Epsteins Resp to RFA Epstein has blocked all discovery in this and other related cases regarding his assets Affidavit of Paul Cassell at r,r ARGUMENT I EPSTEIN IS FRAUDULENTLY TRANSFERRING HIS Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON Conjurers Circle The Fiffh Amendment Privilege in Civil Cases YALE L.J As a result where a witness refuses to testify in a civil case on Fifth Amendment grounds the permissible inference is that the witnes testimony had it been given would not have been favorable to the claim United States A Single Family Residence F.2d 11th Cir Of course the Fifth Amendment is not violated by such an inference The concerns animating the Fifth Amendment right against self-incrimination are not in play in a civil suit involving only private parties because no party brings to the battle the awesome powers of the government and therefore to permit an adverse inference to be drawn from exercise of the privilege does not implicate the policy considerations underlying the privilege Baxter Palmigiano An adverse inference is entirely justified in this case Epstein has remained silent when asked such straightforward requests for admissions Since being incarcerated you have directly or indirectly through the services or assistance of other persons conveyed money or assets in an attempt to insulate or protect your money or assets from being captured in any civil lawsuits filed against you RFAs You are moving significant financial assets overseas outside of the direct territorial reach of the U.S and Florida Courts RFAs You are making asset transfers with the intent to defeat any judgment that might be entered against you in this or similar cases RFAs Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON The silence in the face of these questions speaks far louder than words As Justice Brandeis recognized long ago silence is often evidence of the most persuasive character Baxter Palmigiano U.S quoting U.S ex rel Bilokumsky Tod U.S This is plainly one of those situations In a civil case drawing an adverse inference is the proper action for a court to take when a litigant blocks legitimate discovery through exercise of a Fifth Amendment invocation While there is no doubt that a witness is entitled to assert the privilege in a civil case it is also clear that an adverse inference based on a refusal to answer in a civil case is an appropriate remedy as it provides some relief for the civil litigant whose case is unfairly prejudiced by a witness assertion of the Fifth Amendment privilege without placing the witness in the cruel trilemma of choosing among incrimination perjury or contempt United States ex rel DRC Inc Custer Battles LLC F.Supp.2d E.D Va The Eleventh Circuit has not hesitated to support district courts that draw an adverse inference from silence For example in United States Two Parcels of Real Property F.3d 11th Cir the district court drew an adverse inference when claimants to real property refused to answer questions regarding the property The Eleventh Circuit affirmed that decision explaining that this Court has held that the trier of fact may take an adverse inference against parties to a civil action refusing to testify on Fifth Amendment grounds Id at citing United States A Single Family Residence F.2d 11th Cir Similarly in Arango U.S Dept of the Treasury F.3d 11th Cir the Eleventh Circuit explained that the First Amendment Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON does not forbid adverse inferences against civil litigants who assert the privilege against self-incrimination Here an adverse inference is entirely appropriate In addition to Epsteins refusal to answer questions there are strong circumstantial reasons for believing he is hiding his assets As explained above see Statement of Material Facts through Epstein clearly has the means to hide his assets he is a sophisticated financial advisor And given that the sexual abuse lawsuits brought against Epstein threaten him with financial ruin he has a clear motive for hiding his substantial assets Finally Epstein is currently on work release running his financial affairs from his office giving him the clear opportunity to make the necessary arrangements to move his assets to overseas or other unreachable locations Thus there is a perfect circumstantial evidence case that Epstein has means motive and opportunity to fraudulently transfer assets See United States Sparks F.3d 9th Cir finding probable cause for an arrest based solely on a showing of means motive and opportunity The fact that this evidence is circumstantial rather than direct proof of the transfers is irrelevant because circumstantial evidence is not less probative than direct evidence and in some cases is even more reliable United States Ranum F.3d 7th Cir quoting United States Hatchett F.3d 7th Cir For all these reasons the Court should conclude that Epstein is fraudulently transferring assets Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON II JANE DOE IS ENTITELD TO THE PROTECTIONS OF THE UNIFORM FRAUDULENT TRANSFER ACT AS ADOPTED BY FLORIDA In light of Epsteins fraudulent asset transfers Jane Doe is entitled to pre judgment remedies to protect her against Epsteins efforts to block her from satisfying the judgment she is likely to ultimately obtain in this case Federal Rule of Civil Procedure guarantees Jane Doe during the course of this suit all remedies providing for seizure of person or property for the purpose of securing satisfaction of the judgment ultimately to be entered in the action that are available under the circumstances and in the manner provided by the law of the state in which the court is held The Rule goes on to provide that the remedies thus available include arrest attachment garnishment replevin sequestration and other corresponding or equivalent remedies however designated and regardless of whether by state procedure the remedy is ancillary to an action or must be obtained by an independent action This long-settled federal law provides that in all cases in federal court state law is incorporated to determine the availability of prejudgment remedies for the seizure of person or property to secure satisfaction of the judgment ultimately entered Rosen Cascade Intern Inc F.3d 11th Cir Accordingly under this Rule this Court looks to Florida law to determine Jane Does rights to pre-judgment relief To prevent fraudulent transfers of assets before judgment Florida has adopted the Uniform Fraudulent Transfer Act Fla Stat Ann et seq Under the Floridas Uniform Transfer Act FUFTA courts are broadly empowered to take action to block certain fraudulent transfers of assets Jane Doe is accordingly entitled to invoke the remedies under this Act if Epstein is making fraudulent transfers of his assets Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON The Act defines a fraudulent transfer of assets as one made with actual intent to hinder delay or defraud any creditor of the debtor Fla Stat Ann a The FUFTA also contains a quite broad definition of transfer Nationsbank N.A Coastal Utilities Inc So.2d Fla Ct Apps It extends to every mode direct or indict absolute or conditional voluntary or involuntary of disposing of or parting with an asset or an interest in an asset and includes payment of money release lease and creation of a lien or other encumbrance Fla Stat Ann This broad definition includes every mode of disposing of an asset and does not limit the statute to direct transactions made by the debtor him/herself Nationsbank N.A Coastal Utilities Inc So.2d As noted above Epstein is transferring his assets with the intent to defeat any judgment that might be entered against him in this and other similar cases see Statement of Material Facts and therefore is plainly covered by the Act The FUFTA extends is protections to creditors such as Jane Doe who is a creditor of Epsteins within the meaning of the Act The FUFTA extends its protections not merely to judgment creditors but more widely to future creditors who have a claim including a claim that has not yet been reduced to judgment See Fla Stat Ann defining a claim as a right to payment whether or not the right is reduced to judgment liquidated unliquidated fixed contingent matured unmatured disputed undisputed legal equitable secured or unsecured Fla Stat Ann defining creditor protected by the act as a person who has a claim See generally Freeman First Union Nat Bank So.2d Fla noting that the definition of Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON claim is broadly constructed under the FUFTA This means that as is universally accepted as well as settled in Florida a claim under the Act may be maintained even though contingent and not yet reduced to judgment Freeman at internal quotations omitted In Florida then tort claimants are as fully protected against fraudulent transfers as holders of absolute claims Id at quoting Money Powell So.2d Fla Ct Apps Jane Doe is of course a tort claimant against Epstein For all these reasons Jane is entitled to the full protections of the Florida Uniform Fraudulent Transfer Act Ill UNDER THE UNIFORM FRAUDULENT TRANSFER ACT JANE DOE IS ENTITLED TO THE REMEDIES OF APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF EPSTEINS Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON Jane Doe seeks one of these specifically provided remedies namely appointment of a receiver to take charge of Epsteins assets Appointment of a receiver will serve three important goals first if a receiver has control of Epsteins assets Epsteins ability to further transfer those assets will be blocked second the receiver can provide an accounting of Epsteins assets allowing Jane Doe and the Court to take whatever other action may be appropriate and third the receiver can post a bond of million with the Court so that Jane Doe will have funds to satisfy any judgment that she might obtain The Court should appoint a receiver to account for Epsteins assets The appointment of a receiver is directly authorized by the FUFTA Fla Stat Ann see Freeman First Union Nat Bank So.2d Fla noting that appointment of a receiver is remedy provided by the FUFTA A receiver is the only way to start to block further dissipation of assets by first gaining control over Epsteins assets and then second making an accounting of what assets of Epsteins remain in this country or are otherwise subject to control by this Court Given Epsteins Fifth Amendment invocations and other obstructions regarding any discovery concerning his assets see Statement of Material Facts it is currently impossible for Jane Doe to protect her interests in blocking Epsteins fraudulent transfers Indeed one of the other remedies specifically specified in the Act an injunction against further disposition by the debtor of the asset transferred is presumably unworkable given that there is no way to know what assets Epstein possesses much less where he is transferring them to Cf Special Purpose Accounts Receivable Co-op Corp Prime One Capital Co L.L.C WL S.D Fla Marra refusing to Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON apply any heightened pleading requirements to UFTA claims given this lack of access to information on the part of a plaintiff in a fraudulent transfer case Jane Doe therefore needs a receiver to account for Epsteins assets to the Court The receiver should make a report to the Court regarding Epsteins assets so that Jane Doe can determine what additional further action is required For example Jane Doe might need to take action to set aside various transfers But even now it is clear that the receiver should take one additional step Once a receiver is appointed and accounts for Epsteins assets the receiver should post a million bond on behalf of Epstein with the Clerk of the Court in order to satisfy any judgment that Jane Doe might obtain in this case A million bond is reasonable First given Epsteins tremendous net worth he can post a million bond without any financial or other difficulty See Statement of Material Facts Second given the egregious acts of sexual abuse Epstein committed against Jane Doe who was a minor at the time and the punitive damages claim present in this case million is a reasonable bond amount given the nature of the judgment that Jane Doe is likely to obtain at trial Jane Doe seeks more than million damages See First Amended Complaint Her complaint alleges that Jeffrey Epstein had a sexual obsession for minor girls Id at To satisfy that obsession Epstein engaged in an elaborate scheme whereby his assistants recruited minor girls for the purpose of engaging in prostitution Id at Her complaint explains that Beginning in approximately February and continuing until approximately June the defendant coerced and enticed the impressionable vulnerable and economically deprived then minor Jane Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON Doe in order to commit various acts of sexual misconduct against her These acts included but were not limited to fondling and inappropriate and illegal sexual touching of the then minor Jane Doe sexual misconduct and masturbation of Defendant Jeffrey Epstein in the presence of the then minor Plaintiff and encouraging and coercing the then minor Plaintiff to become involved in prostitution Id at Jane Doe finally notes that in June Epstein entered pleas of guilty to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution for which Defendant Epstein was sentenced to months incarceration in Palm Beach County jail to be followed by months community control house arrest Id at Jane Doe has propounded various discovery requests regarding these allegations to Jeffrey Epstein It is noteworthy that Epstein has asserted a Fifth Amendment self-incrimination privilege to these requests rather than provide answers For example Jane Doe has asked Epstein to admit that he committed sexual assault against Jane Doe when she was minor Plaintiffs First Request for Admissions to Defendant Epstein In response Epstein asserted his Fifth Amendment privilege not to incriminate himself For all these reasons directing the receiver to post a million bond on behalf of Epstein is reasonable under the circumstances The UFTA also grants the court equity powers to remedy fraud lnvo Florida Inc Somerset Venturer Inc So.2d Fla Ct Apps The FUFTAs provisions are supplemented by the principles of law and equity Fla Stat Ann It is well-settled that an equitable action requires equitable relief Prince Tyler So.2d Fla and equity will do what ought to Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON be done Sterling Brevard County So.2d Fla Ct Apps The Court should therefore also exercise its equitable powers to impose the same remedies that Jane Doe requests Of course in equity the Court considers the relative positions of the two claimants Here Jane Doe has presented substantial claims of sexual abuse against her while a minor while Epstein who pied guilty to felony charges involving such conduct has taken the Fifth Amendment rather than answer questions about his sexual abuse of Jane Doe If Jane Doe does not obtain the remedy that she is requesting then Epstein may well be able to move all of his assets to unreachable locations leaving her with a substantial tort claim and no possible way to satisfy it On the other hand appointing a receiver will not interfere with any legitimate interest of Epstein particularly given his phenomenal wealth When this Court proceeds in equity it will not suffer a wrong to be without a remedy Connell Mittendorf So.2d Fla Ct Apps This case cries out for the Court to intercede and take action to avoid allowing a confessed and wealthy sex offender from concealing his assets and depriving his victims including Jane Doe from satisfying any judgment that they may well obtain against him A receiver with control over Epsteins assets is a modest and entirely appropriate step to take given Epsteins actions For the consideration of the Court a proposed order adopting these remedies is attached to this pleading Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON CONCLUSION WHEREFORE in view of the fraudulent transfers being made by Jeffrey Epstein to prevent Jane Doe from satisfying any judgment she might obtain in this case the Court should appoint a receiver to take charge of Epsteins property and direct the receiver to provide the Court with an accounting of Epsteins assets and post a million bond to secure any potential judgment that Jane Doe might obtain in this case DATED this th day of June Respectfully Submitted Bradley Edwards Bradley Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre East Las Olas Blvd Suite Fort Lauderdale Florida Telephone Facsimile Florida Bar No E-mail bedwards rra-law.com And Paul Cassell Pro Hae Vice Salt Lake City UT Telephone Facsimile E-Mail cassellp law.utah.edu Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June I electronically filed the foregoing document with the Clerk of the Court using CM/ECF I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically filed Notices of Electronic Filing Bradley Edwards Bradley Edwards Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON SERVICE LIST Jane Doe Jeffrey Epstein United States District Court Southern District of Florida Jack Alan Goldberger Esq Jgoldberger agwpa.com Robert Critton Esq rcritton bclclaw.com Isidro Manual Garcia isid rogarcia bellsouth.net Jack Patrick Hill iph searcylaw.com Katherine Warthen Ezell KEzell podhurst.com Michael James Pike MPike bclclaw.com Paul Cassell cassellp bclclaw.com Richard Horace Willits lawyerswillits aol.com Robert Josefsberg rjosefsberg podhurst.com Adam Horowitz ahorowitz sexabuseattorney.com Stuart Mermelstein ssm sexabuseattorney.com William Berger wberger rra-law.com Case Document Entered on FLSD Docket Page of AFFIDAVIT OF PAUL CASSELL ESQUIRE I Paul Cassell have person lmowledge of the matters set forth herein I am an attorney licensed to practice in the State of Utah since My office is located at the University of Utah College of Law where I am a law professor Along with other attorneys I represent plaintiff Jane Doe in this matter It appears that defendant Jeffrey Epstein is an extremely wealthy individual According to reputable press reports his net worth is in the hundreds of millions of dollars if not indeed a billion dollars See e.g New York Time July at A2 Over the weekend Jeffrey Epstein who after years of advising billionaires became a billionaire himself left his estate on Little St James Island with its staff of and its flamingo-stocked lagoon boarded a private helicopter and flew to Florida There he turned himself in at the Palm Beach County jail and began serving months for soliciting prostitution According to the Wikipedia entry about Jeffrey Epstein he is a billionaire and owner of a private island in the Virgin Island Little St James Island and was a financial trader at Bear Steams He then founded his own financial management firm EXHIB Case Document Entered on FLSD Docket Page of Epstein and Col later called Financial Trust Co located on his private island in the U.S Virgin Island He reportedly only took billionaire clients Other attorneys and I have made repeated efforts to find published information about defendant Jeffrey Epstein in general and his financial dealings in particular The most detailed published source of information about defendant Jeffrey Epstein that I have been able to locate is an article that was published in Vanity Fair by Vicky Ward Vicky Ward is a contributing editor to Vanity Fair a contributor to CNBC and a weekly columnist for the London Evening Standard The article can be found in the internet at http vickyward.com/wordpress archives/3 According to the Vanity Fair article defendant Jeffrey Epstein became wealthy by managing the financial assets of other billionaires He reportedly limited his clients to those whose net worth was more than billion Unlike other fund managers however Epstein kept all his deals and clients secret with one exception billionaire Leslie Wexner-who Epstein claims was his mentor He has great skills in trading in international currency markets which helped him make money for himself and his clients As a result it is reasonable to infer that he Case Document Entered on FLSD Docket Page of has significant financial sophistication including sophistication about the international transfer of financial instruments and other assets According to the Vanity Fair article defendant Jeffrey Epsteins real mentor was not Leslie Wexner but Steven Jude Hoffenberg who was sent to federal prison for twenty years for bilking investors out of more than million in one of the largest Ponzi schemes in American history Epstein assisted Hoffenberg with failed takeover bids of Pan American World Airways and Emery Air Freight According to the Vanity Fair article before working with Wexner and Hoffenberg defendant Jeffrey Epstein worked with Beam Stearns He left the firm very suddenly in after being questioned by S.E.C investigators in an insider trading scandal involving several Italian and Swiss investors According to the Vanity Fair article Epstein recently owned and thus may still own a Boeing with a trading room Vicky Ward published a follow-up note to her earlier article in May It can be found at http Case Document Entered on FLSD Docket Page of ward-you.html According to this note rumors were circulating to celebrities such as Dustin Hoffman Alec Baldwin and filmmaker Michael Mailer that Epstein was moving all of his considerable assets to Israel The note also indicated that having written the earlier detailed article about Epstein Ward was now frequently viewed as an expert on Epstein According to reputable press reports Jeffrey Epstein has travelled internationally with Donald Trump former President Bill Clinton and Prince Andrew See e.g The Daily Mail Prince Andrews Billionaire Friend is Accused of Preying on Girl of Apr One of Prince Andrews closest friends Jeffrey Epstein is being investigated by the FBI for allegedly paying under-age girls for tawdry sexual encounters It is therefore reasonable to infer that he has international contacts including international financial contacts Approximately civil suits have been filed in Florida state courts and Florida federal courts raising similar allegations against ef:frey Epstein These complaints seek damages comparable to those sought by Jane Doe in this case Accordingly Epstein has currently pending against him lawsuits seeking more than Case Document Entered on FLSD Docket Page of billion in damages Even given his great wealth it appears that the lawsuits against him could well lead to his financial ruin unless he is able to conceal his assets so that the plaintiffs in these cases are unable to reach them Since his guilty plea in state court he has been incarcerated in the Palm Beach County Detention facility I have been advised however that he has currently been allowed out on a work release program where he works at managing his financial interests Because of his overseas contacts other plaintiff attorneys and I have been greatly concerned that Epstein might attempt to transfer many of his assets overseas with the intent to defeat any judgment that might be entered against him I have also received reports that I am attempting to substantiate that Epstein is transferring his assets out of the country at this time with the intent to make it impossible for Jane Doe and other plaintiffs to satisfy any significant judgment that they might obtain against him In light of these reports other attorneys and I have propounded the requests for admission regarding fraudulent asset transfers discussed in the pending motion Case Document Entered on FLSD Docket Page of In this case Epstein has blocked all discovery regarding the current location of his assets and recent fraudulent transfers of his assets by asserting a Fifth Amendment privilege against self-incrimination With other attorneys working on this case and related cases I have wanted to obtain direct first hand information regarding Epsteins financial dealings but have been blocked for doing so by Epstein Therefore I have been forced to rely on reputable press reports for information about these dealings In the similar sexual abuse lawsuits filed against Epstein other plaintiffs attorneys have advised that Epstein has likewise blocked all discovery regarding his finances with Fifth Amendment invocations or other interposed obstructions Case Document Entered on FLSD Docket Page of __ I swear the foregoing to be truthful under the penalty of rjury FURTHER THEAFFIANT Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CV-80893-MARRA/JOHNSON JANE DOE Plaintiff vs JEFFREY EPSTEIN Defendant PLAINTIFFS FIRST REQUEST FOR ADMISSIONS TO DEFENDANT COMES NOW the Plaintiff Jane Doe by and through her undersigned counsel and files this her First Request for Admissions to the Defendant JEFFREY EPSTEIN and requests said Defendant admit or deny the following facts in accordance with Federal Rules of Civil Procedure DEFINITIONS The term you means and refers to the Defendant JEFFREY EPSTEIN ADMISSIONS Your net worth is greater than million Your net worth is greater than million Your net worth is greater than million Your net worth is greater than million EXHIBIT Case Document Entered on FLSD Docket Page of Your net worth is greater than billion Since being incarcerated you have directly or indirectly through the services or assistance of other persons conveyed money or assets in an attempt to insulate or protect your money or assets from being captured in any civil lawsuits filed against you You own or control directly or indirectly real estate property in the Caribbean You own or control directly or indirectly real estate property in foreign countries In the last years you have transferred assets and/or money and/or financial instruments to countries outside the United States You have provided financial support to the modeling agency MC2 You committed sexual assault against Plaintiff a minor You committed battery against Plaintiff You digitally penetrated Plaintiff when she was a minor You offered Plaintiff more money contingent upon her having sex with you or giving you oral sex You intended to harm Plaintiff when you committed these sexual acts against her You knew Plaintiff was under the age of when you sexually touched and fondled her You intend to hire investigators to intimidate and harass Plaintiff during this litigation You were engaged in the act of trafficking minors across state or country borders for the purposes of sex or prostitution between and the present You coerced Plaintiff into being a prostitute and remaining in prostitution Case Document Entered on FLSD Docket Page of You are guilty of the following offenses against Jane Doe A Procuring a minor for the purpose of prostitution as defined in F.S Battery as defined by Florida Statutes Sexual Battery You are moving significant financial assets overseas outside of the direct territorial reach of the U.S and Florida Courts You are making asset transfers with the intent to defeat any judgment that might be entered against you in this or similar cases You currently have the ability to post a bond of million to satisfy a judgment in this case without financial or other difficulty CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided via United States mail to the following addressees this 7.3day of March Robert Critton Jr Esquire Michael Pike Esquire Burman Critton Luttier Coleman LLP North Flagler Drive Suite West Palm Beach Florida rcrit bclclaw.com mpike bclclaw.com Jack Alan Goldberger Esquire Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach Florida jagesq bellsouth.net Case Document Entered on FLSD Docket Page of Michael Tein Esquire Lewis Tein P.L Grand A venue Suite Coconut Grove Florida tein lewistein.com By Respectfully Submitted THE LAW OFFICE OF BRAD EDWARDS AS SOCIA TES LLC Brad Edwards Esquire Attorney for Plaintiff Florida Bar No Harrison Street Suite Hollywood Florida Telephone Facsimile E-Mail be bradedwardslaw.com Paul Cassell Attorney for Plaintiff Pro Hae Vice Salt Lake City UT Telephone Facsimile E-Mail cassellp law.utah.edu FAX BURMAN CRITTON LUTTIER Case Document Entered on FLSD Docket Page oi UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV MARRA/JOHNSON JANE DOE Plaintiff JEFFREY EPSTEIN Defendant DEFENDANT EPSTEINS RESPONSE TO PLAINTIFF JANE DOES FIRST REQUEST FOR ADMISSIONS dated Defendant JEFFREY EPSTEIN EPSTEIN by and through his undersigned attorneys serves his response to Plaintiffs First Request for Admission dated March In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my EXHIBIT FAX BURMAN CRITTO LUTTIER Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Page2 attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to FA A IT TON Li TI ER la Case Document Entered on FLSD Docket Page oi Jane Doe Epstein et al Page3 effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In respon5e Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States FAX BURMAN CRITTON LUTTIER Case Document Entered on FLSD Docket Page ol Jane Doe Epstein et al Page4 Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse lnference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept thi advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Arru ndment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would FAX BURMAN CRITTON LUTTIER Case Document Entered on FLSD Docket Page ol Jane Doe Epstein et al Page unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitutron Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution FAX BURMAN CRITTON LUTHER Case Document Entered on FLSD Docket Page or Jane Doe Epstein et al Page6 In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my FA A IT TO UT TI ER Id case Document Entered on FLSD Docket Page ol Jane Doe Epstein et al Page attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response to A and Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to FAX BURMAN CRITTON LIJTTIER Case Document Entered on FLSD Docket Page of Jane Doe Epstein et al Pages effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however rny attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the United States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution In response Defendant asserts his U.S constitutional privileges as specified herein I intend to respond to all relevant discovery regarding this lawsuit however my attorneys have counseled me that I cannot provide answers to any discovery relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation Accordingly I assert my federal constitutional rights under the Fifth Sixth and Fourteenth Amendments as guaranteed by the Unrted States Constitution Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights would be unreasonable and would therefore violate the Constitution Certificate of Service WE HEREBY CERTIFY that a true copy of the Jregoing has been sent via U.S Mail and facsimile to the following addressees this J.i fay of May Jane Doe Epstein et al Page Brad Edwards Esq Rothstein Rosenfeldt Adler East Las Olas Boulevard Suite Fort Lauderdale FL Phone Fax bedwards rra-law.com Counsel for Plaintiff Paul Cassell Esq Pro Hae Vice South Room Salt Lake City UT Fax cassellp law.utah.edu Go-counsel for Plaintiff Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Fax jagesg bellsouth.net Co-Counsel for Defendant Jeffrey Epstein Respectfully sub By __ ROBERT CRITTON JR ESQ Florida Ba No rcrit bclclaw.com BURMAN CRITTON LUTTIER COLEMAN Flagler Drive Suite West Palm Beach FL Phone Fax Counsel for Defendant Jeffrey Epstein Case Document Entered on FLSD Docket Page of JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 08-CV-80232-MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 08-CV-80380-MARRA/JOHNSON I Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 08-CV-80381-MARRA/JOHNSON I JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 08-CV-80994-MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 08-CV-80993-MARRA/JOHNSON I Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON C.M.A Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 08-CV-80811-MARRA/JOHNSON JANE DOE Plaintiff Vs JEFFREY EPSTEIN et al Defendant CASE NO 8-CV-80893-MARRA/JOHNSON I DOE II CASE NO 09-CV-80469-MARRA/JOHNSON Plaintiff vs JEFFREY EPSTEIN et al Defendants I Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 09-CV-80591-MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant CASE NO 09-CV-80656-MARRA/JOHNSON I ORDER APPOINTING RECEIVER AND DIRECTING RECEIVER TO SECURE Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON is appointed as receiver of all the real property good chattels moneys financial instruments stocks or other assets of any type of defendant Jeffrey Epstein and all the rents income interest and profits from them all called the property in this order and the receiver is directed to immediately enter upon receive and take complete possession of all of the property and the rents income and profits Defendant Jeffrey Epstein and his servants agents and employees are ordered to deliver immediately to the receiver all of the property and they and each of them are enjoined from interfering in any way with the receiver or with any of the property until the further order of this court Defendant Jeffrey Epstein and his servants agents and employees are further ordered to deliver to the receiver or his representative all keys or combinations to locks required to open or gain access to any of the property and all money deposited in any bank to the credit of the defendant and any other money financial instruments or things of value of the defendant wherever they may be The receiver is granted all the usual necessary and incidental powers for the purpose of managing and maintain the property including the power to appoint such agents as the receiver considers necessary to enable the receive to perform the receivers duties The receiver shall within days of this order if sufficient assets are available post a million bond on behalf of Jeffrey Epstein with the Clerk of the Court to secure any potential judgment the plaintiff might obtain The Case Document Entered on FLSD Docket Page of CASE NO 08-CV-80119-MARRA/JOHNSON receiver shall also by that time file an accounting of all significant assets of Jeffrey Epstein with the Court The receiver shall be entitled to reasonable compensation and coverage of expenses as approved by the Court DONE AND ORDERED in Chambers at West Palm Beach Palm Beach County Florida this_ day of Copies furnished to All counsel of record APP Case Document Entered on FLSD Docket Page of JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV-80119-MARRA/JOHNSON I Related cases I ORDER This cause is before the Court upon Plaintiff Jane Does Motion for Injunction Restraining Fraudulent Transfer of Assets Appointment of a Receiver to Take Charge of Property of Epstein and to Post a Million Bond to Secure Potential Judgment DE Defendant Jeffrey Epstein filed a response in opposition to the motion DE and Plaintiff filed a reply DE The motion is now fully briefed and ripe for review Plaintiffs motion argues that Defendant is fraudulently transferring his assets with the specific intent to defeat any judgment that might be entered against him in this and other similar cases Plaintiff therefore seeks an order enjoining Defendant from fraudulent transfers of his assets appointing a receiver to take charge of Defendants property and requiring Defendant to post a million dollar bond against any potential judgment in this case Case Document Entered on FLSD Docket Page of The relief sought by Plaintiff is injunctive and essentially amounts to a prejudgment writ of attachment Rosen Cascade Intern Inc F.3d th Cir vacating district courts preliminary injunction freezing defendants assets No relief of this character has been thought justified in the long history of equity jurisprudence De Beers Consol Mines Ltd United States U.S Preliminary injunctive relief freezing a defendants assets in order to establish a fund with which to satisfy a potential judgment for money damages is simply not an appropriate exercise of a federal district courts authority Rosen F.3d at Indeed it is entirely settled by a long and unbroken line of Florida cases that in an action at law for money damages there is simply no judicial authority for an order requiring the deposit of the amount in controversy into the registry of the court or indeed for any restraint upon the use of a defendants unrestricted assets prior to the entry of judgment Id at quoting Konover Realty Assoc Ltd Mladen So.2d Fla 3d DCA In Florida an injunction cannot be entered to prevent a party from using or disposing of his assets prior to the conclusion of a legal action Briceno Bryden Investments Ltd So.2d Fla 3d DCA See also SME Racks Inc Sistemas Mecanicos Para Electronica S.A Fed.Appx th Cir affirming districts courts denial of preliminary injunction to freeze defendants assets Proctor Eason,651 So.2d Fla 2d DCA Defendant not required to deposit funds in court registry prior to final judgment where Plaintiff failed to show unavailability of an adequate remedy at law and the likelihood of irreparable harm two elements essential to entry of an injunction Lawhon Mason So.2d Fla 2d DCA quashing trial court order requiring defendant to Case Document Entered on FLSD Docket Page of give plaintiffs ten days notice prior to the transfer of any assets in excess of Additionally as the Eleventh Circuit explained in Rosen In actions at law plaintiffs in Florida possess an adequate exclusive prejudgment remedy for the sequestration of assets under the attachment statute Fla.Stat.Ann West provided that they can satisfy the enumerated statutory grounds for relief Accordingly the use of injunctive relief as a substitute for the remedy of prejudgment attachment with its attendant safeguards is improper F.3d at emphasis added Here Plaintiff did not move to amend her complaint to allege a claim under the Florida Uniform Fraudulent Transfers Act FUFTA Fla Stat et seq Rather she filed the present motion for injunctive relief Even if she had moved to amend her complaint it is certainly not clear that she could meet the required statutory elements Plaintiffs motion is premised on the contention that Defendant is fraudulently transferring assets However Plaintiffs motion is entirely devoid of evidence of Defendants alleg fraudulent transfers The Court declines to conclude that Defendant is fraudulently transferring assets based upon the adverse inferences relied upon by Plaintiff Plaintiffs su_Qplemental filing i Q!g the titles of a_Qproximately five of Defendants vehicles is clearly de minimisJ particularly in light of Plaintiffs repeated characterization of Defendant as a billionaire Based upon the foregoing it is hereby ORDERED AND ADJUDGED that Fraudulent transfer claims under Florida law arise under the Florida Uniform Fraudulent Transfers Act FUFTA Fla Stat et seq FUFTA as set forth in Florida Statute provides the substantive requirements that must be pied to state a valid fraudulent transfer claim Nationsbank N.A Coastal Utilities Inc So.2d Fla Dist Ct App The plaintiff must show that there was a creditor to be defrauded a debtor intending fraud and a conveyance of property which could have been applicable to the payment of the debt due Id Case Document Entered on FLSD Docket Page of Plaintiff Jane Does Motion for leave to Provide Recently-obtained Deposition Testimony and Affidavit DE in is GRANTED Plaintiff Jane Does Motion for Injunction Restraining Fraudulent Transfer of Assets _gpointment of a Receiver to Take Charge of Propei:t of Epstein and to Post a Million Bond to Secure Potential Judgment DE in is DENIED DONE AND ORDERED in Chambers at West Palm Beach Palm Beach County Florida this th day of November Copies to all counsel of record APP FAX Rothstein Rosenfeldt Adler Attorneys at Law July Via Fa mile ROTHSTEIN ROSBNFELT ADLE Adam Horowitz Esquire Stuart Mennelstein Esquire lsidro Manuel Garcia Esquire Jeffrey Mate Herm Esquke Katherine Earthen Ezell Esquire Robert Josefsberg Esquire Jaok Hill Esquire Dear Counsel Bradley Ed,vards Dir.ect Diol bedwardsif!;rraul.aw com We have recently reoe:ived Notice for Depositions from Adam Horowitz for several witnesses and the lever from Jack Hill indfoatlng an intent to take others We intend to Cross-Notice each deposition Additionally we intend to set the following other individuals for video deposition I Donald Trump West Palm Beach Olen Dubin West Palm Beach Gblslain Maxwell New York Sara Keller New Yorl Leslie Wexner Ohio Bill Clinton D.C Paula-Heil New York Jean Luc Bruhel New York Li Ji EXHIBIT Deponentffltf uJ5 Date Rptr t;Srj Pl!lOllOOI ply To Las Oily Canlr East Olas 601Jlavatd Ulte Fort L:s.utl rdale lorfda Telepnone Fax BOCA RATON FORT LAUDERDALE JVIIAMI NaW YORK CITY TALLAHASSEE WASHtNGi0N D,C WEST fALM BEACH EXHIBITM PAX ROTHSTEIN ROSBNFBLT ADLE July Page of We will choose dates that have not already been occupied by other depositions already set in this case If you would like to be included in the scheduling of these depositions please provide me with your scheduling secretaries names and e-mail addresses ff any of you do not need to be consulted regarding the scheduling of these depositions please advise me of that as Wells Very truly yoUrS ROTHSTEIN ROSENFELDT ADLER Bradley Edwards Esqmre Partner Fort the Fhm BJE/mgl APP Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA L.M CASE NO 09-CV-81092-Cohn-Seltzer Plaintiff vs JEFFREY EPSTEIN Defendant I COMPLAINT AND DEMAND FOR JURY TRIAL FILED by VT D.C ELECTRONIC July STEVEN LARIMORE CLERK U.S DIST CT OF FLA MIAMI Plaintiff L.M hereby sues the Defendant Jeffrey Epstein and states as follows At all times material to this cause of action L.M was a resident of Palm Beach County Florida This Complaint is brought under a fictitious name to protect the identity of L.M because this Complaint makes sensitive allegations of sexual assault and abuse of a then-minor At all times material to this cause of action Defendant Jeffrey Epstein had a mansion located at El Brillo Way Palm Beach Palm Beach County Florida At all times materials to this cause of action Defendant Jeffrey Epstein was an adult male born in Defendant Jeffrey Epstein is currently a citizen of the State of Florida This is substantiated by the residence that he maintains at El Brillo Way West Palm Beach Florida where he spends the majority of his time and intentions to remain at that address permanently are further evidenced by his statements to the Court during Page of Case Document Entered on FLSD Docket Page of his State Plea colloquy on June case number taken before the Honorable Judge Dale Pucillo wherein he indicated that after his release from the Palm Beach County Jail he intends to reside permanently at his home at El Brillo Way West Palm Beach Florida and he plans to work in West Palm Beach Florida as well This Court has jurisdiction of this action and the claims set forth herein pursuant to U.S.C L.M seeks damages in excess of million dollars This Court has venue of this action pursuant to U.S.C as a substantial part of the events giving rise to the claims occurred in this District STATEMENT OF FACTS Upon information and belief the Defendant Jeffrey Epstein has demonstrated a sexual preference and obsession for minor girls The Defendant Jeffrey Epstein developed a plan scheme and criminal enterprise that included an elaborate system wherein the then-minor L.M was brought to the Defendant Jeffrey Epsteins residence by the Defendants employees recruiters and assistants When the assistants and employees left the then-minor L.M and on some occasions other minor girls alone in a room at the Defendants mansion the Defendant Jeffrey Epstein himself would appear remove his clothing and direct the then-minor L.M to remove her clothing He would then perform one or more lewd lascivious and sexual acts including but not limited to masturbation touching of the then minor Plaintiffs sexual organs coercing or forcing the then-minor L.M to perform oral sex on him using vibrators or sexual toys on the then-minor L.M coercing the Page of Case Document Entered on FLSD Docket Page of then-minor L.M into sexual acts with himself or others and digitally penetrating the then-minor L.M He would then pay L.M for engaging in this sexual activity L.M was first brought to the Defendant Jeffrey Epsteins mansion in when she was a fourteen-year old in middle school The then-minor L.M was a vulnerable child without adequate parental support at all times material to this Complaint The Defendant Jeffrey Epstein a wealthy financier with a lavish home significant wealth and a network of assistants and employees used his resources and his influence over a vulnerable minor child to engage in a systematic pattern of sexually exploitive behavior Beginning in approximately August and continuing until approximately the end of October the Defendant Jeffrey Epstein repeatedly coerced induced and/or enticed the impressionable vulnerable and economically deprived then-minor L.M to commit various acts of sexual misconduct and sexually abused L.M These acts included but were not limited to fondling and inappropriate and illegal sexual touching of the then-minor L.M fuigfug the then-minor L.M into oral sex sexual misconduct and masturbation of the Defendant Jeffrey Epstein in the presence of the then-minor L.M handling and fondling of the then-minor L.M.s sexual organs for the purpose of masturbation and encouraging the then-minor L.M to become involved in prostitution Defendant Jeffrey Epstein committed and conspired with others to commit numerous criminal sexual offenses against the then minor Plaintiff including but not limited to sexual battery solicitation of prostitution coercing a minor into a life of prostitution and lewd and lascivious assaults upon the person of the then-minor L.M Defendant Jeffrey Page of Case Document Entered on FLSD Docket Page of Epstein knowingly transported L.M and other minors in interstate commerce with the intent that the L.M engage in prostitution and in other sexual activity for which he and others could be charged with criminal offenses Defendant Jeffrey Epstein also knowingly used means of interstate commerce to knowing persuade and induce minors including L.M to engage in prostitution and other sexual activity for which he and others could be charged with criminal offenses In addition to the direct sexual abuse and molestation of the then-minor L.M Defendant Jeffrey Epstein instructed coerced and otherwise induced the then minor L.M to bring him numerous other minor girls some as young at years old for the purposes of further satisfying his deviant sexual attraction to minors and for purposes of prostitution On information and belief Epstein sexually abused hundreds of minor girls through his recruiting system Defendant Jeffrey Epstein used his money wealth and power to unduly and improperly manipulate and influence the then minor L.M to bring him these other minor girls for purposes of prostitution and in exchange for money This influence led the then-minor L.M away from the life of a middle school aged child and into a delinquent lifestyle This conduct also involved transporting L.M and other minors in interstate commerce and using means of interstate commerce to persuade and induce L.M and others to engage in prostitution and in other sexual activity for which he and others could be charged with criminal offenses The Defendant Jeffrey Epstein at all times material to this Complaint knew and should have known of L.M.s minority The Defendant Jeffrey Epstein at all times Page of Case Document Entered on FLSD Docket Page of material to this Complaint knew and should have know of the minority of the other girls he was sexually abusing The acts referenced above in paragraphs through committed by Defendant Jeffrey Epstein against the then-minor Plaintiff L.M were committed in violation of numerous State criminal statutes condemning the sexual exploitation of minor children prostitution and prostitution-related offenses sexual performances by a child lewd and lascivious assaults sexual battery contributing to the delinquency of a minor and other crimes specifically including but not limited to those criminal offenses outlined in Chapters and of the Florida Statutes as well as those designated in Florida Statutes and The acts reference above in paragraphs through committed by Defendant Jeffrey Epstein against the then-Minor Plaintiff L.M were committed in violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C and The crimes committed against L.M by Epstein were committed on average four times per month from the beginning of August through the end of October the exact dates being unknown to L.M Page of Case Document Entered on FLSD Docket Page of In June after investigations by the Palm Beach Police Department the Palm Beach State Attorneys Office the Federal Bureau of Investigation and the United States Attorneys Office for the Southern District of Florida Defendant Jeffrey Epstein entered pleas of guilty to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution in the Fifteenth Judicial Circuit in the Palm Beach County Florida Defendant Jeffrey Epstein is in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and as such must admit liability unto Plaintiff Jane Doe No In this action Plaintiff hereby exclusively seeks civil remedies pursuant to U.S.C As a condition of his plea and in exchange for the Federal Government not prosecuting the Defendant Jeffrey Epstein for numerous federal offenses Defendant Jeffrey Epstein additionally entered into an agreement with the Federal Government to the following Any person who while a minor was a victim of an offense enumerated in Title United States Code Section will have the same rights to proceed under section as she would have had if Mr Epstein had been tried federally and convicted of an enumerated offense For purposes of implementing this paragraph the United States shall provide Mr Epsteins attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr Epstein Any judicial authority interpreting this provision including any authority determining evidentiary burdens if any a Plaintiff must meet shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been Page of Case Document Entered on FLSD Docket Page of had Mr Epstein been convicted at trial No more no less Plaintiff L.M is covered by this paragraph and entitled to rights under this paragraph The defendant Jeffrey Epstein is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged in this Complaint and must effectively admit liability to the Plaintiff L.M including admitting liability for all counts enumerated in this Complaint Plaintiff L.M is entitled to damages as further alleged below including damages as provided in U.S.C as amended by Pub Title VII and Stat COUNT1 Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to Page of Case Document Entered on FLSD Docket Page of this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above Page of Case Document Entered on FLSD Docket Page of On or about August 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 Page of Case Document Entered on FLSD Docket Page of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 of Case Document Entered on FLSD Docket Page of As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a Page of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Page of Case Document Entered on FLSD Docket Page of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNTS Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September 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 Page of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of Case Document Entered on FLSD Docket Page of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of Case Document Entered on FLSD Docket Page 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September 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 inicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct Page of Case Document Entered on FLSD Docket Page of child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of Case Document Entered on FLSD Docket Page of COUNT Cause of Action Pursuant to U.S.C October Incident Plaintiff L.M adopts and realleges paragraphs through above On or about October 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT10 Cause of Action Pursuant to U.S.C October Incident Plaintiff L.M adopts and realleges paragraphs through above On or about October 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 U.S.C a and Page of Case Document Entered on FLSD Docket Page of L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of Case Document Entered on FLSD Docket Page of October Incident Plaintiff L.M adopts and realleges paragraphs through above On or about October 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 Page of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT12 Cause of Action Pursuant to U.S.C October Incident Plaintiff L.M adopts and realleges paragraphs through above On or about October 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to Page of Case Document Entered on FLSD Docket Page of this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT13 Cause of Action Pursuant to U.S.C November Incident Plaintiff L.M adopts and realleges paragraphs through above Page of Case Document Entered on FLSD Docket Page of On or about November 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 Page of Case Document Entered on FLSD Docket Page of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT14 Cause of Action Pursuant to U.S.C November Incident Plaintiff L.M adopts and realleges paragraphs through above On or about November 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 of Case Document Entered on FLSD Docket Page of As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT15 Cause of Action Pursuant to U.S.C November Incident Plaintiff L.M adopts and realleges paragraphs through above On or about November the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a Page of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Page of Case Document Entered on FLSD Docket Page of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT16 Cause of Action Pursuant to U.S.C November Incident Plaintiff L.M adopts and realleges paragraphs through above On or about November 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT17 Cause of Action Pursuant to U.S.C December Incident Plaintiff L.M adopts and realleges paragraphs through above On or about December 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 Page of of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of Case Document Entered on FLSD Docket Page of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT18 Cause of Action Pursuant to U.S.C December Incident Plaintiff L.M adopts and realleges paragraphs through above On or about December 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of of Case Document Entered on FLSD Docket Page 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT19 Cause of Action Pursuant to U.S.C December Incident Plaintiff L.M adopts and realleges paragraphs through above On or about December 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 Page of Case Document Entered on FLSD Docket Page of child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of of Case Document Entered on FLSD Docket Page of COUNT Cause of Action Pursuant to U.S.C December Incident Plaintiff L.M adopts and realleges paragraphs through above On or about December 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C January Incident Plaintiff L.M adopts and realleges paragraphs through above On or about January 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 U.S.C a and Page of of Case Document Entered on FLSD Docket Page of L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of of Case Document Entered on FLSD Docket Page of January Incident Plaintiff L.M adopts and realleges paragraphs through above On or about January 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 Page of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C January Incident Plaintiff L.M adopts and realleges paragraphs through above On or about January 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to Page of Case Document Entered on FLSD Docket Page of this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C January Incident Plaintiff L.M adopts and realleges paragraphs through above Page of Case Document Entered on FLSD Docket Page of On or about January 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 Page of Case Document Entered on FLSD Docket Page of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C February Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 of Case Document Entered on FLSD Docket Page of As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C February Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a Page of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Page of Case Document Entered on FLSD Docket Page of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C February Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C February Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February 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 Page of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of Case Document Entered on FLSD Docket Page of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of Case Document Entered on FLSD Docket Page 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March 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 Page of of Case Document Entered on FLSD Docket Page of child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of of Case Document Entered on FLSD Docket Page of COUNT Cause of Action Pursuant to U.S.C March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March 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 U.S.C a and Page of of Case Document Entered on FLSD Dock Page of L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of Case Document Entered on FLSD Docket Page of April Incident Plaintiff L.M adopts and realleges paragraphs through above On or about April 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 Page of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C April Incident Plaintiff L.M adopts and realleges paragraphs through above On or about April 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Page of of Case Document Entered on FLSD Docket Page of Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C April Incident Plaintiff L.M adopts and realleges paragraphs through above Page of of Case Document Entered on FLSD Docket Page of On or about April 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 Page of of case Document Entered on FLSD Docket Page of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C April Incident Plaintiff L.M adopts and realleges paragraphs through above On or about April 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 wtth 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 of of Case Document Entered on FLSD Docket Page of As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C May Incident Plaintiff L.M adopts and realleges paragraphs through above On or about May the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of Page of of Case Document Entered on FLSD Docket Page 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Page of of Case Document Entered on FLSD Docket Page of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C May Incident Plaintiff L.M adopts and realleges paragraphs through above On or about Mayl 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C May Incident Plaintiff L.M adopts and realleges paragraphs through above On or about May 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 Page of of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of case Document Entered on FLSD Docket Page of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C May Incident Plaintiff L.M adopts and realleges paragraphs through above On or about May 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of of Case Document Entered on FLSD Docket Page 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C June Incident Plaintiff L.M adopts and realleges paragraphs through above On or about June 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 Page of of Case Document Entered on FLSD Docket Page of child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of of Case Document Entered on FLSD Docket Page of COUNT42 Cause of Action Pursuant to U.S.C June Incident Plaintiff L.M adopts and realleges paragraphs through above On or about June 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C June Incident of Plaintiff L.M adopts and realleges paragraphs through above On or about June 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 U.S.C a and Page of of Case Document Entered on FLSD Docket Page of L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of case Document Entered on FLSD Docket Page of June Incident Plaintiff L.M adopts and realleges paragraphs through above On or about June the exact date being unknown to L.M of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 Page of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C July Incident Plaintiff L.M adopts and realleges paragraphs through above On or about July 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Page of Case Document Entered on FLSD Docket Page of Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C July Incident Plaintiff L.M adopts and realleges paragraphs through above Page of of Case Document Entered on FLSD Docket Page of On or about July 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 Page of Case Document Entered on FLSD Docket Page of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT47 Cause of Action Pursuant to U.S.C July Incident Plaintiff L.M adopts and realleges paragraphs through above On or about July 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 of of case Document Entered on FLSD Docket Page of As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C July Incident Plaintiff L.M adopts and realleges paragraphs through above On or about July the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of Page of of Case Document Entered on FLSD Docket Page 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Page of Case Document Entered on FLSD Docket Page of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August 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 Page of of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of of Case Document Entered on FLSD Docket Page of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of of Case Document Entered on FLSD Docket Page 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August 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 Page of Case Document Entered on FLSD Docket Page of child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of of Case Document Entered on FLSD Docket Page of COUNT53 Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September 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 U.S.C a and Page of of Case Document Entered on FLSD Docket Page of L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of of Case Document Entered on FLSD Docket Page of September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 Page of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to Page of of Case Document Entered on FLSD Docket Page of this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C October Incident Plaintiff L.M adopts and realleges paragraphs through above Page of of Case Document Entered on FLSD Docket Page of On or about October 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 Page of Case Document Entered on FLSD Docket Page of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C October Incident Plaintiff L.M adopts and realleges paragraphs through above On or about October 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 of Case Document Entered on FLSD Docket Page of As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C October Incident Plaintiff L.M adopts and realleges paragraphs through above On or about October the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a Page of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Page of Case Document Entered on FLSD Docket Page of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT60 Cause of Action Pursuant to U.S.C October Incident Plaintiff L.M adopts and realleges paragraphs through above On or about October 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C November Incident Plaintiff L.M adopts and realleges paragraphs through above On or about November 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 Page of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of Case Document Entered on FLSD Docket Page of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C November Incident Plaintiff L.M adopts and realleges paragraphs through above On or about November 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of Case Document Entered on FLSD Docket Page 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C November Incident Plaintiff L.M adopts and realleges paragraphs through above On or about November 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 Page of Case Document Entered on FLSD Docket Page of child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of Case Document Entered on FLSD Docket Page of COUNT Cause of Action Pursuant to U.S.C November Incident Plaintiff L.M adopts and realleges paragraphs through above On or about November 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of Case Document Entered on FLSD Docket Page of of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT65 Cause of Action Pursuant to U.S.C December Incident Plaintiff L.M adopts and realleges paragraphs through above On or about December 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 U.S.C a and Page of of Case Document Entered on FLSD Docket Page of L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of of Case Document Entered on FLSD Docket Page of December Incident Plaintiff L.M adopts and realleges paragraphs through above On or about December 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 Page of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C December Incident Plaintiff L.M adopts and realleges paragraphs through above On or about December 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to Page of of Case Document Entered on FLSD Docket Page of this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT68 Cause of Action Pursuant to U.S.C December Incident Plaintiff L.M adopts and realleges paragraphs through above Page of of Case Document Entered on FLSD Docket Page of On or about December 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 Page of of Case Document Entered on FLSD Docket Page of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C January Incident Plaintiff L.M adopts and realleges paragraphs through above On or about January 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 of of Case Document Entered on FLSD Docket Page of As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT70 Cause of Action Pursuant to U.S.C January Incident Plaintiff L.M adopts and realleges paragraphs through above On or about January the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a Page of of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Page of Case Document Entered on FLSD Docket Page of of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C January Incident Plaintiff L.M adopts and realleges paragraphs through above On or about January 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C January Incident Plaintiff L.M adopts and realleges paragraphs through above On or about January 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 Page of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of Case Document Entered on FLSD Docket Page of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C February Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of Case Document Entered on FLSD Docket Page 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C February Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February 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 Page of of Case Document Entered on FLSD Docket Page of child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of Case Document Entered on FLSD Docket Page of COUNT75 Cause of Action Pursuant to U.S.C February Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT76 Cause of Action Pursuant to U.S.C February Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February 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 U.S.C a and Page of Case Document Entered on FLSD Docket Page of L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of Case Document Entered on FLSD Docket Page of March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 Page of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to Page of of Case Document Entered on FLSD Docket Page of this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C March Incident Plaintiff L.M adopts and realleges paragraphs through above Page of of Case Document Entered on FLSD Docket Page of On or about March 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 Page of Case Document Entered on FLSD Docket Page of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 of of Case Document Entered on FLSD Docket Page of As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C April Incident Plaintiff L.M adopts and realleges paragraphs through above On or about April the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of Page of of Case Document Entered on FLSD Docket Page 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Page of of Case Document Entered on FLSD Docket Page of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C April Incident Plaintiff L.M adopts and realleges paragraphs through above On or about April 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C April Incident Plaintiff L.M adopts and realleges paragraphs through above On or about April 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 Page of of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of Case Document Entered on FLSD Docket Page of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C April Incident Plaintiff L.M adopts and realleges paragraphs through above of On or about April 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of of Case Document Entered on FLSD Docket Page 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C May Incident Plaintiff L.M adopts and realleges paragraphs through above On or about May the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation Page of of Case Document Entered on FLSD Docket Page of enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of of Case Document Entered on FLSD Docket Page of COUNT Cause of Action Pursuant to U.S.C May Incident Plaintiff L.M adopts and realleges paragraphs through above On or about May 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C May Incident Plaintiff L.M adopts and realleges paragraphs through above On or about May 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 U.S.C a and L.M is Page of of Case Document Entered on FLSD Docket Page of therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of Case Document Entered on FLSD Docket Page of of May Incident Plaintiff L.M adopts and realleges paragraphs through above On or about May 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 Page of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to June Incident Plaintiff L.M adopts and realleges paragraphs through above On or about June 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to Page of of Case Document Entered on FLSD Docket Page of this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C June Incident Plaintiff L.M adopts and realleges paragraphs through above Page of of Case Document Entered on FLSD Docket Page of On or about June 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 Page of Case Document Entered on FLSD Docket Page of of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C June Incident Plaintiff L.M adopts and realleges paragraphs through above On or about June 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 of of Case Document Entered on FLSD Docket Page of As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C June Incident Plaintiff L.M adopts and realleges paragraphs through above On or about June the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a Page of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Page of of of Case Document Entered on FLSD Docket Page of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C July Incident Plaintiff L.M adopts and realleges paragraphs through above On or about July 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of Case Document Entered on FLSD Docket Page of of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT94 Cause of Action Pursuant to U.S.C July Incident Plaintiff L.M adopts and realleges paragraphs through above On or about July 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 Page of of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of of Case Document Entered on FLSD Docket Page of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C July Incident Plaintiff L.M adopts and realleges paragraphs through above On or about July 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT96 Cause of Action Pursuant to U.S.C July Incident Plaintiff L.M adopts and realleges paragraphs through above On or about July the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation Page of Case Document Entered on FLSD Docket Page of enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of of Case Document Entered on FLSD Docket Page of COUNT Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August 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 U.S.C a and Page of Case Document Entered on FLSD Docket Page of of L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of Case Document Entered on FLSD Docket Page of August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 of As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 Page of Case Document Entered on FLSD Docket Page of of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to Page of Case Document Entered on FLSD Docket Page of of this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above Page of Case Document Entered on FLSD Docket Page of of On or about September 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 Page of Case Document Entered on FLSD Docket Page of of As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a Page of Case Document Entered on FLSD Docket Page of of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Page of of Case Document Entered on FLSD Docket Page of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C October Incident Plaintiff L.M adopts and realleges paragraphs through above On or about October 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 Page of Case Document Entered on FLSD Docket Page of of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of case Document Entered on FLSD Docket Page of of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C October Incident Plaintiff L.M adopts and realleges paragraphs through above On or about October 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of of Case Document Entered on FLSD Docket Page 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C October Incident Plaintiff L.M adopts and realleges paragraphs through above On or about October 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 Page of of Case Document Entered on FLSD Docket Page of child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of of Case Document Entered on FLSD Docket Page of COUNT Cause of Action Pursuant to U.S.C October Incident Plaintiff L.M adopts and realleges paragraphs through above On or about October 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to November Incident Plaintiff L.M adopts and realleges paragraphs through above On or about November 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 U.S.C a and Page of case Document Entered on FLSD Docket Page of of L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of of Case Document Entered on FLSD Docket Page of November Incident Plaintiff L.M adopts and realleges paragraphs through above On or about November 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 Page of Case Document Entered on FLSD Docket Page of of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C November Incident Plaintiff L.M adopts and realleges paragraphs through above On or about November 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to Page of of Case Document Entered on FLSD Docket Page of this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C November Incident Plaintiff L.M adopts and realleges paragraphs through above Page of Case Document Entered on FLSD Docket Page of of On or about November 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 Page of Case Document Entered on FLSD Docket Page of of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C December Incident Plaintiff L.M adopts and realleges paragraphs through above On or about December 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 of Case Document Entered on FLSD Docket Page of of As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C December Incident Plaintiff L.M adopts and realleges paragraphs through above On or about December the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a Page of Case Document Entered on FLSD Docket Page of of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Page of of Case Document Entered on FLSD Docket Page of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C December Incident Plaintiff L.M adopts and realleges paragraphs through above On or about December 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of of Case Document Entered on FLSD Docket Page of 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 psychologic I 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C December Incident Plaintiff L.M adopts and realleges paragraphs through above On or about December 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 Page of case Document Entered on FLSD Docket Page of of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of Case Document Entered on FLSD Docket Page of of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C January Incident Plaintiff L.M adopts and realleges paragraphs through above On or about January 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C January Incident Plaintiff L.M adopts and realleges paragraphs through above On or about January 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 Page of of Case Document Entered on FLSD Docket Page of child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of of Case Document Entered on FLSD Docket Page of COUNT Cause of Action Pursuant to U.S.C January Incident Plaintiff L.M adopts and realleges paragraphs through above On or about January 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of Case Document Entered on FLSD Docket Page of of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C January Incident Plaintiff L.M adopts and realleges paragraphs through above On or about January 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 U.S.C a and Page of Case Document Entered on FLSD Docket Page of of L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to Page of Case Document Entered on FLSD Docket Page of of February Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 Page of Case Document Entered on FLSD Docket Page of of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C February Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to Page of of Case Document Entered on FLSD Docket Page of this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C February Incident Plaintiff L.M adopts and realleges paragraphs through above Page of Case Document Entered on FLSD Docket Page of of On or about February 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 Page of of Case Document Entered on FLSD Docket Page of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C February Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 of of Case Document Entered on FLSD Docket Page of As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a Page of of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Page of of Case Document Entered on FLSD Docket Page of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March 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 Page of of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of of Case Document Entered on FLSD Docket Page of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of of Case Document Entered on FLSD Docket Page 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C April Incident Plaintiff L.M adopts and realleges paragraphs through above On or about April the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation Page of of Case Document Entered on FLSD Docket Page of enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of of Case Document Entered on FLSD Docket Page of COUNT Cause of Action Pursuant to U.S.C Aprl Incident Plaintiff L.M adopts and realleges paragraphs through above On or about April 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C April Incident Plaintiff L.M adopts and realleges paragraphs through above On or about April 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 U.S.C a and L.M is Page of Case Document Entered on FLSD Docket Page of therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of of Case Document Entered on FLSD Docket Page of of April Incident Plaintiff L.M adopts and realleges paragraphs through above On or about April 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 Page of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C May Incident Plaintiff L.M adopts and realleges paragraphs through above On or about May 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Page of of Case Document Entered on FLSD Docket Page of Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursu 267ant to U.S.C May Incident Plaintiff L.M adopts and realleges paragraphs through above Page of Case Document Entered on FLSD Docket Page of of On or about May 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 Page of of Case Document Entered on FLSD Docket Page of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C May Incident Plaintiff L.M adopts and realleges paragraphs through above On or about May 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 of Case Document Entered on FLSD Docket Page of of As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C May Incident Plaintiff L.M adopts and realleges paragraphs through above On or about May the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of Page of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Page of case Document Entered on FLSD Docket Page of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right COUNT Cause of Action Pursuant to U.S.C June Incident Plaintiff L.M adopts and realleges paragraphs through above On or about June 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C June Incident Plaintiff L.M adopts and realleges paragraphs through above On or about June 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 Page of Case Document Entered on FLSD Docket Page of of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of Case Document Entered on FLSD Docket Page of of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C June Incident Plaintiff L.M adopts and realleges paragraphs through above On or about June 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of Case Document Entered on FLSD Docket Page 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C June Incident of Plaintiff L.M adopts and realleges paragraphs through above On or about June 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 Page of of Case Document Entered on FLSD Docket Page of child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of case Document Entered on FLSD Docket Page of of COUNT Cause of Action Pursuant to U.S.C July Incident Plaintiff L.M adopts and realleges paragraphs through above On or about July 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C July Incident Plaintiff L.M adopts and realleges paragraphs through above On or about July 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 U.S.C a and L.M is Page of of Case Document Entered on FLSD Docket Page of therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of Case Document Entered on FLSD Docket Page of of July Incident Plaintiff L.M adopts and realleges paragraphs through above On or about July 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 Page of case Document Entered on FLSD Docket Page of of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C July Incident Plaintiff L.M adopts and realleges paragraphs through above On or about July 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Page of Case Document Entered on FLSD Docket Page of Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT of Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above Page of Case Document Entered on FLSD Docket Page of of On or about August 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 Page of of Case Document Entered on FLSD Docket Page of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 of case Document Entered on FLSD Docket Page of of As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a Page of case Document Entered on FLSD Docket Page of of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Page of Case Document Entered on FLSD Docket Page of of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September 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 Page of Case Document Entered on FLSD Docket Page of 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of Case Document Entered on FLSD Docket Page of of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT10 Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of Case Document Entered on FLSD Docket Page 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September 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 Page of Case Document Entered on FLSD Docket Page of child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of of Case Document Entered on FLSD Docket Page of COUNT Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 of 5F?k?D r??gz rh?i?K I 1M w?ϩ CT0 mS Gv Q?E:?Ef z:yd K?dA iR D?S I v?y po?f Mg?F?n?WJ 3L?a?Σ hE"??a?/s?sC L??t DLoP?Ć??l??i V?փ?h RTGv?y wٮ P??H mk ORg 9Pށ A??i PJuf a6 QG?ν J6Jl?A a 9Yl i H?O?ۦ?C?qcM?4et?:c B?C Z??ZI?i?hp m?d?A Jc??c 9㺏(ʩ a 1b?q aL?8 l?X?ǛI?ie F?l dCP B_ Lo f??ͻT"?Wv?r?E cǦ e1 aM?N H?I ʽ?KPoiy yoc V?S?M"?Ԥ 4Z t?d CH?"E Ii DFnT?H??z F7 iT u?ʢL?y??M 1B V?Q7 w7m?GK ĊUu?:d?,?p J!??mP??cnI?f?!f c?P?Qa??V OsF?3 P1/H?c lݪ4n?G??ݟu exÚD i j?v i s?a Yu C??Yk c?a?ʻ?UM IG K?m B9 5v gr H?r x?E?J DK?Dƀ D??r2ˤy?H oD9Ӟ?p?Pi??7?ȑ w?U?h0 4X?uE?Q Ֆ?O S!?i?т?S 3?wV,Ŀ y?q K1 Ag M?/?Usr 7U l?c cz װ??C T?i?j?I?V zC 6tu SÂq hذ/V?l v?Uı?j??q?絓?D?q qm A Oq?4H??b Bއ?7 7q RBqQ I j?b i ѯ?TE?ďQ??鲄?e?Fk nq??B??Y?b Ab?O x??l s?lD gQ?8?хF?C?O EZ?9 I 7n?Vd?N z?A?W?0t?v B?sK FA0??g Ȉ?C QPi7 w?C XZ?UY?G eYiD?b?o?տ O?x ݩGl J?좯 k?C??Ҡ?A T?f lŠ A 4b p??N q?W b?f??T Ĭr A 4?RP?aU?R Kk"??q RM p_?Wz V?nJ N?Lm O?p?l у?zݕ 6CK kF i g?D Jĥ Ɵ??y n?O gb??S JfD cb??K?J חklƕ G?Ȕ:.B X6R?Oi HZ?E Ba SE l!?Q x??h Re??q rE?R NqwD of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C October Incident Plaintiff L.M adopts and realleges paragraphs through above On or about October 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 U.S.C a and Page of Case Document Entered on FLSD Docket Page of of L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of of Case Document Entered on FLSD Docket Page of October Incident Plaintiff L.M adopts and realleges paragraphs through above On or about October 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 Page of of Case Document Entered on FLSD Docket Page of 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to October Incident Plaintiff L.M adopts and realleges paragraphs through above On or about October 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to Page of of Case Document Entered on FLSD Docket Page of this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C October Incident Plaintiff L.M adopts and realleges paragraphs through above Page of of Case Document Entered on FLSD Docket Page of On or about October 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 U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C 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 As a direct and proximate result of the offenses enumerated in Title United States Code Section 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 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 Page of of Case Document Entered on FLSD Docket Page of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper DEMAND FOR JURY TRIAL Plaintiff hereby demands trial by jury on all issues triable as of right by a jury DATED July radl Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre East Las Olas Blvd Suite Fort Lauderdale Florida Telephone Facsimile Florida Bar No E-mail bedwards rra-law.com Page of Case Document Entered on FLSD Docket Page of JS Rev CIVIL COVER Racketeer Influenced and Patent Corrupt Organizations Trademark Consumer Credit Cable/Sat TV Selective Service SOCIAL SECURITY Securities/Commodities HIA Exchange Black Lung Customer Challenge DIWC/DIWW use SSID Title XVI Other Statutory Actions RSI Agricultural Acts FEDERAL TAX SUITS Economic Stabilization Act Taxes U.S Plaintiff Environmental Matters or Defendant Energy Allocation Act IRS-Third Party Freedom of Information Act USC Appeal of Fee Determination Under Equal Access to Justice Constitutionality of State Statutes ORIGIN fl I Original Proceeding Place an in One Box Only Removed from State Court Re-filed see VI below Reinstated or Reopened Transferred from another district specify Multidistrict Litigation Appeal to District Judge from Magistrate Jud ment VI RELATED/RE-FILED CASE VII CAUSE OF ACTIO VI REQUESTED IN COMPLAINT Related Cases YES ONO See instructions second page a Re-filed Case YES fJ NO JUDGE A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 10Cy n??m?n k?o?h I A I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R h?H?T3P K?z X?K H?o I Idc rM?M rM 10Cy f헊?f?Tz e?e:Aa I v"x i X5 EO5 5a r?q CX 9r Cy rq rqC M3 ş?:c p/p0 5H V)V 6T Y2 G5 qrM?r?qr?r9 q?10Cy rCX qr l1 X?l 3K fm?Q Z2f CX CX gT L??T 2E Cy 3P EM3 J4T L?h??M q?ᡚ?Y r??O?rJt CTX i P!e i I CTX rC YY I 1e 2j CTX X0T1i k3v Jh/e0h1 H(K W/Q0 CTX j?!k 5B r2 CTX A A A 4v z"p A A A0A?A AK CTX A A?!k CX qCX YCX i!d A fi8 l8 yuZ 6L pH m?c sP;0 6ZR Ni P0 0Q X(P0s s(s p0 Pp CTX qq dR B/J Va A y!k N?M??N rC f?Nla3 Yz N?q qr NEeD K?i N?M?qr EeD k??O d6 I I i i CTX GH FT I CTX U3 U3 U3 U3 S6 E"L I I I5K7C:I 9O U3 Cn qrr qr q??r?q 9qr CTX G5 qr CX rC l0 WS zN pf1 ODV8L?m jC1DxV CTX CTX A qr 10Cy rYY Ң??P?V CTX C"C rqM?rq?q?qr qr CTX YY Jb?C.y CTX CTX GG4 A A G5 C.C M??r 10Cy rq YY C?J?yO c/XE?lgF GM??H p?ݡG Dp9Oh CTX CTX CJ4 I J6 CJ4 CK qrrM?q qq 9/CX?o CX qYqr rC dd?Z c6S ttcx A CTX CTX 10Cy rq rqYY X?qiX:4 3J Db ZH uD-8 1g?BH I vS 7Oo7u E?K?O J6 UJP U0 UT??ʴ UT UT UT O(p U(u UF1 iZ qr?r CX CX Yr zKW:E A K5M P-M UW VW L1J KJ56 N/Q SQ rC 6J ߵl ߵl 5TZ w8ĥDG oj?K _4 N)?Y Hp pRqc?W26 vz?WBrz?ZB??3X H4 CTX A CTX X4 U5 P8 5D qr qr 10Cy qr YY Mo?ANp D01jJ 9F bzEV 4O 8V CTX O!o CTX KK AA qr A C5 qr rYY 1A?CC V9 a c?F CTX A G5 qr EeD?M CTX 9?rY 10Cy rq qY ȠX1 a f??B CTX 9F I CTX 6D N?qr rrqq qC O?J RmA??b"0 M?.F q?D B?G CTX CTX F4 d6P A F4 qr rYY 4G AV8 CTX UY UL0 U0 U0 U0 UF UF UFAGA UA UA UAL UL UL UL UL UL UL U7 U7 U7 U7 U7 U7 U7 2EH GTU U/U OUoU UV G1 CTX TUV 1G 7A UA UAL X7 U7 U7 U77XL UL UL ULLYX KTX 8Y GJ A UMAT UD 7M GVW GF10 MWA LL MPM M?M 4M XY qr qr qr NEeD 10Cy qYY E2 GH l1 Pd h3V g?KIq V5kL O65S d_xKKU vV 5H p1 Z6 CTX U0 U1 CTX U0 U1 A0 1D qr qr 10Cy YY K??Kl 1B AMwv 1K F1 KV yW Gd T?H CTX CTX I CK M?qr K?SK?PQZ I IRZX 8YCX 10Cy qr CX kv zg S5kB??a iG wA CTX U2 6Y CTX U2 6Y I K,,j j,s 6Y P!p qr 10Cy qr YY G?O 9K mSd X0 9r?yal 1d bY0 XNf??qN D?J CTX P!Z b!o C,C qrM 10Cy qr8 I fX2 9R lO KV CTX Oo CTX A qr r?qr rq YY Lsy7H4 C,6E IL CTX U3 CTX J,O3_3xx qrM?r q?CX Y9/C 9CX CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8
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