X-2HIBI-3T Case Document Filed Page of Case Document Entered on FLSD Docket Page of Case Document Filed Page of IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA JANE DOE No Plaintiff vs JEFFREY EPSTEIN Civil Action No CIV-RYSKAMP MAGISTRATE JUDGE VITUNAC FILED by 1:JS D.C INTAKE MAY STEVEN LAl-llMORE CLERK U.S DIST CT S.D OF FLA MIAMI COMPLAINT AND Defendant DEMAND FOR JURY TRIAL I COMPLAINT AND DEMAND FOR JURY TRIAL Plaintiff Jane Doe No brings this Complaint against Defendant Jeffrey Epstein and states as follows PARTIES JURISDICTION AND VENUE At all times material to this cause of action Plaintiff Jane Doe No was a resident of Palm Beach County Florida This Complaint is brought under a fictitious name to protect the identity of Plaintiff Jane Doe No 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 residence located at El Brillo Way Palm Beach Palm Beach County Florida Defendant Jeffrey Epstein is currently a citizen of the State of Florida as he is currently incarcerated in the Palm Beach County Stockade At all times material to this cause of action Defendant Jeffrey Epstein was an adult male born in Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of This Court has jurisdiction over this action and the claims set forth herein pursuant to U.S.C This Court has venue of this action pursuant to U.S.C as a substantial part of the events giving rise to the claim occurred in this District STATEMENT OF FACTS At all relevant times Defendant Jeffrey Epstein was an adult male spanning the ages of and years old Epstein is known as a billionaire financier and money manager with a secret clientele limited exclusively to billionaires He is a man of tremendous wealth power and influence He owns a fleet of aircraft that includes a Gulfstream IV a helicopter and a Boeing as well as a fleet of motor vehicles Until his incarceration he maintained his principal place of residence in the largest home in Manhattan a 51,0-square-foot eight-story mansion on the Upper East Side Upon information and belief he also owns a million mansion in Palm Beach Florida a million ranch in New Mexico he named Zorro a 70-acre private island known as Little St James in St Thomas U.S Virgin Islands a mansion in Londons Westminster neighborhood and a home in the Avenue Foch area of Paris The allegations herein concern Defendants conduct while at his lavish homes and/or numerous other locations both nationally and internationally Upon information and belief Defendant has a sexual preference for underage minor girls He engaged in a plan scheme or enterprise in which he gained access to countless vulnerable and relatively economically disadvantaged minor girls and sexually assaulted molested and/or exploited these girls and then gave them money Beginning in or around through in or around September Defendant used his resources and his influence over vulnerable minor girls to engage in a systematic pattern of sexually exploitative behavior Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of Defendants plan and scheme reflected a particular pattern and method Defendant coerced and enticed impressionable vulnerable and relatively economically less fortunate minor girls to participate in various acts of sexual misconduct that he committed upon them Defendants scheme involved the use of underage girls as well as other individuals to recruit other underage girls Upon information and belief Defendant and/or an authorized agent would call and alert Defendants assistants shortly before or after he arrived at his Palm Beach residence His assistants would call economically disadvantaged and underage girls from West Palm Beach and surrounding areas who would be enticed by the money being offered and who Defendant and/or his assistants perceived as less likely to complain to authorities or have credibility issues if allegations of improper conduct were made The then minor Plaintiff and other minor girls some as young as years old were transported to Defendants Palm Beach mansion by Defendants employees agents and/or assistants in order to provide Defendant with massages Many of the instances of illegal sexual conduct committed by Defendant were perpetrated with the assistance support and facilitation of at least three assistants who helped him orchestrate this child exploitation enterprise These assistants would often arrange times for underage girls to come to Defendants residence transport or cause the transportation of underage girls to Defendants residence escort the underage girls to the massage room where Defendant would be waiting or would enter shortly thereafter urge the underage girls to remove their clothes deliver cash from Defendant to the underage girls and/or their procurers at the conclusion of each massage appointment and upon information and belief take nude photographs and/or videos of the underage girls for Defendant with and/or without their knowledge Defendant would pay the procurer of each girls appointment hundreds of dollars Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of Epstein designed this scheme to secure a private place in Defendants Palm Beach mansion where only persons employed and invited by Epstein would be present so as to reduce the chance of detection of Defendants sexual abuse and prostitution as well as to make it more difficult for the minor girls to flee the premises and/or to credibly report his actions to law enforcement or other authorities The girls were usually transported by his employees agents and/or assistants or by a taxicab paid for by Defendant in order to make it difficult for the girls to flee his mansion Upon arrival at Defendants Palm Beach mansion each underage victim would generally be introduced to one of Defendants assistants who would gather the girls personal contact information The minor girl would then be led up a flight of stairs to a room that contained a massage table and a large shower The staircase leading to the room was plastered with nude photographs of young girls including some photographs depicting two or more young girls engaged in lewd acts Upon information and belief Defendant Jeffrey Epstein had such photographs in each of his six homes and/or on his computers At times if it was the girls first massage appointment another female would be in the room to lead the way until Defendant would have her leave Generally Defendant would start his massage wearing only a small towel which eventually would be removed Defendant and/or the other female would direct the girl to massage him giving the minor girl specific instructions as to where and how he wanted to be touched and then direct her to remove her clothing He would then perform one or more lewd lascivious and sexual acts including masturbation fondling the minors breasts and/or sexual organs touching the minors vulva vagina and/or anus with a vibrator and/or back massager and/or his finger and/or his penis digitally penetrating her vagina performing intercourse oral sex and/or anal sex and/or coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution and/or Podhurst Orseck P.A Case Document Entered on FLSD Docket Page of Case Document Filed Page of enticing the then mmor girl to engage in sexual acts with another female in Defendants presence The exact degree of molestation and frequency with which the sexual exploitations took place varied and is not yet completely known however Defendant committed such acts regularly on a daily basis and in most instances several times a day In order to facilitate the daily exchanges of money for sexual assault and abuse Defendant kept U.S currency readily available Defendant Epstein traveled to his mansion in Palm Beach for the purpose of luring minor girls to his mansion to sexually abuse and/or batter them He used the telephone to contact these minor girls for the purpose of coercing them into acts of prostitution and to enable himself to commit sexual battery against them and/or acts of lewdness in their presence and he conspired with others including assistants and/or his driver and/or pilot and his socialite friend/partner Ghislaine Maxwell to further these acts and to avoid police detection Defendants systematic pattern of sexually exploitative behavior referred to in paragraph and described in paragraphs through the present paragraph occurred in all of Defendants domestic and international residences and/or places of lodging and/or modes of transportation Consistent with the foregoing plan and scheme Defendant used his money wealth and power to unduly and improperly manipulate and influence the then minor Plaintiff A vulnerable young girl Plaintiff was working as a changing room assistant at The Mar-A-Lago Club in Palm Beach making approximately an hour when she was first lured into Defendants sexually exploitative world In or about the summer of when Plaintiff was merely fifteen years old while attending to her duties at Mar-A-Lago Plaintiff was recruited by Ghislaine Maxwell who lived traveled socialized and worked with Defendant Ms Maxwell asked Plaintiff if she was interested in learning massage therapy and earning a great deal of money while learning the profession Plaintiffs father who was a maintenance manager at The Mar-A Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of Lago Club was not apprehensive because he felt comforted that an older woman had approached Plaintiff with this opportunity As a result Plaintiffs father dropped off Plaintiff at Defendants mansion that same day Ms Maxwell met Plaintiff and her father outside of Defendants Palm Beach mansion where Ms Maxwell assured the minor girls father that Ms Maxwell would provide transportation home for his teenaged daughter Ghislaine Maxwell led Plaintiff up a flight of stairs to a spa room with a shower and a massage table Defendant was lying naked on the massage table Plaintiff was shocked but with no experience with massages thought this could be massage therapy protocol Ms Maxwell then took off her own shirt and left on her underwear and started rubbing her breasts across Defendants body impliedly showing Plaintiff what she was expected to do Ms Maxwell then told Plaintiff to take off her clothes The minor girl was apprehensive about doing this but in fear proceeded to follow Ms Maxwell by removing everything but her underwear She was then ordered to remove her underwear and to straddle Defendant The encounter escalated with Defendant and Ms Maxwell sexually assaulting battering exploiting and abusing Plaintiff in various ways and in various locations including the steam room and shower At the end of this sexually exploitive abuse Defendant and Ms Maxwell giddily told Plaintiff to return the following day and told her she had lots of potential Defendant paid Plaintiff hundreds of dollars told her it was for two hours of work and directed one of his employees to drive her home Defendant and/or his procurers thereafter lured the then minor Plaintiff to his Palm Beach mansion every day for the next two weeks in order to engage in a similar pattern of sexual exploitation Defendant and/or his procurers arranged at the end of each incident the transportation and scheduling for the following days appointment Additionally Defendant telephoned the minor Plaintiff himself and/or had Ms Maxwell telephone Plaintiff to make arrangements Plaintiff was often times driven to and from Epsteins mansion by Epstein Podhurst Orseck P.A Case Document Entered on FLSD Docket Page of Case Document Filed Page of himself or his driver Alternatively Defendant or Ms Maxwell would arrange and pay for Plaintiffs transportation home by taxicab During Plaintiffs second incident of being sexually exploited and assaulted by Defendant at Defendants Palm Beach mansion Defendant asked Plaintiff to quit her job at The Mar-A-Lago Club and travel with him to earn much more money while learning the massage profession Thus Plaintiff an impressionable and vulnerable young girl of modest means quit her job as a changing room assistant was lured by Defendant and continued to be victimized by Defendant who immersed the minor Plaintiff into Defendants lewd and abusive lifestyle Under Defendants dominion and control Defendant continuously groomed the minor adolescent Defendants daily routine required the minor Plaintiff to perform sexually on Defendant multiple times per day and to provide Defendant massages multiple times per day Plaintiff had absolutely no say as to when how many times or what was done during each sexual encounter Often Plaintiff was joined by Ms Maxwell Ms Maxwells assistant and/or a countless array of young women who would be brought to one of Defendants homes for the sexual trysts and then be sexually exploited by Defendant The first time that Defendant transported Plaintiff to another state in order to engage in sexual acts with her occurred when she was merely fifteen years old and after only two weeks of daily sexually abusive encounters with Defendant Defendant used his private jet to transport the minor Plaintiff to Manhattan where he provided her with spending money and accommodations with him at his mansion From the time that Plaintiff was years old Defendant abused her to serve his every sexual whim obtaining and purchasing passports and whatever was needed for her to travel with him and/or for him Defendant transported Plaintiff in his private jet to locations that included Palm Beach New York City Santa Fe Los Angeles San Francisco St Louis and numerous other domestic destinations as well as international Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of destinations including Europe the Caribbean and Africa He provided accommodations with him in order to have her available to him at all times wherever he went including while transporting the minor Plaintiff on his private jet Each time they would travel to one of these destinations the same pattern of sexual abuse would occur often with a vast array of aspiring models actresses celebrities and/or other females including minors from all over the world Upon information and belief Defendant transported minor girls from Turkey the Czech Republic Asia and numerous other countries many of whom spoke no English To Plaintiffs knowledge the only females specifically excluded from Defendants sexual escapades were African-Americans In addition to being continually exploited to satisfy Defendants every sexual whim Plaintiff was also required to be sexually exploited by Defendants adult male peers including royalty politicians academicians businessmen and/or other professional and personal acquaintances Whenever Defendant transported Plaintiff with him in his private jet to any destination Defendant would pay Plaintiff a flat rate per day while he and/or his above mentioned associates would sexually exploit and abuse minor Plaintiff Most of these acts of abuse occurred during a time when Defendant knew that Plaintiff was approximately and years old and after years of daily sexual exploitation continued into her adulthood Despite Defendants stating shortly before Plaintiffs sixteenth birthday that he soon would have to trade her in because she was getting too old Defendant continued to sexually exploit Plaintiff until she fled at age Defendants predilection for young girls was well known to those who regularly procured them for him and to his circle of friends On one of Defendants birthdays a friend of Defendant sent him three 12-year-old girls from France who spoke no English for Defendant to sexually exploit and abuse After doing so they were sent back to France the next day Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of Any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by his own actions and are rendered irrelevant by the provision of applicable federal statutes concerning the sexual exploitation and abuse of a minor child Defendant Jeffrey Epstein at all times material to this cause of action knew and should have known of Plaintiffs age of minority Defendant and Ms Maxwell acknowledged and celebrated Plaintiffs th birthday Defendants preference for underage girls was well-known to those who regularly procured them for him As previously stated in paragraph Defendant displayed nude photographs of underage girls throughout his homes in New York City Palm Beach Santa Fe and the U.S Virgin Islands Plaintiff Jane Doe No saw photographs of naked young girls in each of Defendants homes including a photograph of herself naked at Defendants home in Palm Beach When she asked Defendant about it he stated dismissively that he had naked photographs of her in all of his homes Upon information and belief some of the photographs in Defendants possession were taken with hidden cameras set up in his home in Palm Beach On the day of his arrest police found two hidden cameras and photographs of underage girls on a computer in Defendants home Upon information and belief Defendant may have taken lewd photographs of Plaintiff Jane Doe No with his hidden cameras and may have transported lewd photographs of Plaintiff among many other victims to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce In addition while Plaintiff was a minor teenager and upon Ms Maxwells insistence after Ms Maxwell rejected as inappropriate photographs that Plaintiff presented of herself fully clothed Ms Maxwell photographed Plaintiff naked in different sexually explicit positions Ms Maxwell then presented these nude photographs of Plaintiff to Defendant as a birthday present for Defendant from Ms Maxwell Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurstcom Case Document Entered on FLSD Docket Page of Case Document Filed Page of Upon information and belief one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Sheriffs Office during its execution of a search warrant of Defendants Palm Beach mansion on October Upon information and belief those photographs are still in the custody of law enforcement It is virtually impossible to calculate the exact number of times that Defendant sexually exploited and abused Plaintiff From the age of Plaintiff was sexually exploited and abused by Defendant on a daily basis and most often multiple times each day While some of the precise dates these acts occurred are unknown to Plaintiff these dates are known to Defendant as he is reported to have kept a written log of each instance in which he engaged in these lewd acts with then minor Plaintiff and others Upon information and belief these logs are also in the custody of law enforcement In or around September Defendant purchased a commercial round-trip airline ticket and provided a passport U.S currency and accommodations for Plaintiff to fly to Thailand While thousands of miles away from Defendant on this extended trip alone for the first time in more than four years Plaintiff met fell in love and married a young man She escaped from Defendants abuse with the help and insistence of her new husband and instead of returning to Defendant boarded a plane to Australia with one suitcase Since November Plaintiff has lived a modest life in Australia while maintaining lines of communication with her family and without contact with Defendant or any of the people in his entourage However suddenly in Plaintiff received numerous phone calls from one of Defendants agents During these phone calls to Plaintiff he repeatedly asked whether she knew anything about the civil cases against Defendant whether she knew any of the females who were proceeding with the civil suits whether she was planning on filing suit whether she was communicating and/or cooperating with anyone against Defendant and whether Podhurst Orseck P.A Case Document Entered on FLSD Docket Page of Case Document Filed Page of she would return to the United States to testify Terrified by Defendants demonstrated ability to track her down on her changed cell phone number halfway across the world Plaintiff attempted to reassure Defendants agent that she would remain quiet During the course of one of these phone calls from Defendants agents Defendant himself spoke on the phone continued to question her intentions and upon being reassured by Plaintiff thanked her for not getting involved Around January Plaintiff received a letter from the United States Attorneys Office for the Southern District of Florida informing her of her potential civil claims against Defendant under U.S.C Plaintiff contacted undersigned counsel within days and diligently and repeatedly pursued a good faith viable settlement of her claims against Defendant Unable to reach a settlement this lawsuit followed As a result of these encounters with Defendant Plaintiff Jane Doe No has in the past suffered and will in the future continue to suffer physical injury pain and suffering emotional distress psychological and/or psychiatric trauma mental anguish humiliation confusion embarrassment loss of educational opportunities loss of self-esteem loss of dignity invasion of her privacy separation from her family and other damages associated with Defendants controlling and manipulating her on a daily basis for years into a perverse and unhealthy way of life Defendant Jeffrey Epstein committed the above-referenced acts upon Plaintiff in violation of federal 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 transport of child pornography child exploitation enterprises and other crimes specifically including but not limited to those crimes designated Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of in U.S.C a a a and 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 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 Plaintiff hereby exclusively seeks civil remedies pursuant to U.S.C COUNT ONE Cause of Action for Coercion and Enticement of Minor to Engage in Prostitution or Sexual Activity pursuant to U.S.C in Violation of U.S.C Plaintiff Jane Doe No hereby adopts repeats realleges and incorporates by reference the allegations contained in paragraphs through above Defendant Jeffrey Epstein used a facility or means of interstate and/or foreign commerce to knowingly persuade induce entice or coerce Jane Doe No when she was under the age of years to engage in prostitution and/or sexual activity for which any person can be charged with a criminal offense or attempted to do so pursuant to U.S.C in violation of U.S.C Plaintiff Jane Doe No was a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against Defendant Jeffrey Epstein pursuant to this Section of the United States Code Podhurst Orse P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of As a direct and proximate result of the offenses enumerated in U.S.C being committed against the then minor Plaintiff by Defendant Plaintiff has in the past suffered and will in the future continue to suffer physical injury pain and suffering emotional distress psychological and/or psychiatric trauma mental anguish humiliation confusion embarrassment loss of educational opportunities loss of self-esteem loss of dignity invasion of her privacy separation from her family and other damages associated with Defendants manipulating and leading her into a perverse and unhealthy way of life 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 Plaintiff will continue to suffer these losses in the future WHEREFORE Plaintiff Jane Doe No demands judgment against Defendant Jeffrey Epstein for all damages available under U.S.C including without limitation actual and compensatory damages attorneys fees costs of suit and such other further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT TWO Cause of Action for Transportation of Minor with Intent to Engage in Criminal Sexual Activity pursuant to U.S.C in Violation of U.S.C a Plaintiff Jane Doe No hereby adopts repeats realleges and incorporates by reference the allegations contained in paragraphs through above Defendant Jeffrey Epstein knowingly transported then minor Plaintiff Jane Doe No in interstate and/or foreign commerce with the intent that Plaintiff engage in prostitution or in any sexual activity for which any person can be charged with a criminal offense in violation U.S.C a As previously stated in paragraphs and Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of Defendant transported Plaintiff Jane Doe No across state lines and across international borders numerous times from the time that Plaintiff was merely years old through adulthood with the primary intent of sexually exploiting her Plaintiff Jane Doe No was a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against Defendant Jeffrey Epstein pursuant to this Section of the United States Code As a direct and proximate result of the offenses enumerated in U.S.C being committed against the then minor Plaintiff by Defendant Plaintiff has in the past suffered and will in the future continue to suffer physical injury pain and suffering emotional distress psychological and/or psychiatric trauma mental anguish humiliation confusion embarrassment loss of educational opportunities loss of self-esteem loss of dignity invasion of her privacy separation from her family and other damages associated with Defendants manipulating and leading her into a perverse and unhealthy 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 Plaintiff will continue to suffer these losses in the future WHEREFORE Plaintiff Jane Doe No demands judgment against Defendant Jeffrey Epstein for all damages available under U.S.C including without limitation actual and compensatory damages attorneys fees costs of suit and such other further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of COUNT THREE Cause of Action for Travel with Intent to Engage in Illicit Sexual Conduct pursuant to U.S.C in Violation of U.S.C Plaintiff Jane Doe No hereby adopts repeats realleges and incorporates by reference the allegations contained in paragraphs through above Upon information and belief Defendant Jeffrey Epstein traveled in interstate and/or foreign commerce with the intent to engage in illicit sexual conduct as defined in U.S.C with minor females including the then minor Plaintiff in violation of U.S.C Plaintiff Jane Doe No was a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against Defendant Jeffrey Epstein pursuant to this Section of the United States Code As a direct and proximate result of the offenses enumerated in U.S.C being committed against the then minor Plaintiff by Defendant Plaintiff has in the past suffered and will in the future continue to suffer physical injury pain and suffering emotional distress psychological and/or psychiatric trauma mental anguish humiliation confusion embarrassment loss of educational opportunities loss of self-esteem loss of dignity invasion of her privacy separation from her family and other damages associated with Defendants manipulating and leading her into a perverse and unhealthy way of life 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 Plaintiff will continue to suffer these losses in the future WHEREFORE Plaintiff Jane Doe No demands judgment against Defendant Jeffrey Epstein for all damages available under U.S.C including without limitation Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of actual and compensatory damages attorneys fees costs of suit and such other further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT FOUR Cause of Action for Coercion and Enticement to Engage in Prostitution or Sexual Activity pursuant to U.S.C in Violation of U.S.C a Plaintiff Jane Doe No hereby adopts repeats realleges and incorporates by reference the allegations contained in paragraphs through above Defendant Jeffrey Epstein knowingly persuaded induced enticed and/or coerced Jane Doe No to travel in interstate and/or foreign commerce to engage in prostitution and/or sexual activity for which any person can be charged with a criminal offense or attempted to do so pursuant to U.S.C in violation of U.S.C a Plaintiff Jane Doe No was a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against Defendant Jeffrey Epstein pursuant to this Section of the United States Code As a direct and proximate result of the offenses enumerated in U.S.C being committed against the then minor Plaintiff by Defendant Plaintiff has in the past suffered and will in the future continue to suffer physical injury pain and suffering emotional distress psychological and/or psychiatric trauma mental anguish humiliation confusion embarrassment loss of educational opportunities loss of self-esteem loss of dignity invasion of her privacy separation from her family and other damages associated with Defendants manipulating and leading her into a perverse and unhealthy way of life 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 Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and Plaintiff will continue to suffer these losses in the future WHEREFORE Plaintiff Jane Doe No demands judgment against Defendant Jeffrey Epstein for all damages available under U.S.C including without limitation actual and compensatory damages attorneys fees costs of suit and such other further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT FIVE Cause of Action for Transportation with Intent to Engage in Criminal Sexual Activity pursuant to U.S.C in Violation of U.S.C Plaintiff Jane Doe No hereby adopts repeats realleges and incorporates by reference the allegations contained in paragraphs through above Defendant Jeffrey Epstein knowingly transported or attempted to transport Plaintiff Jane Doe No in interstate and/or foreign commerce with the intent that Plaintiff engage in prostitution and/or in any sexual activity for which any person can be charged with a criminal offense in violation of U.S.C As previously stated in paragraphs and Defendant transported Plaintiff Jane Doe No across state lines and across international borders numerous times from the time that Plaintiff was merely years old through adulthood with the primary intent of sexually exploiting her Plaintiff Jane Doe No was a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against Defendant Jeffrey Epstein pursuant to this Section of the United States Code As a direct and proximate result of the offenses enumerated in U.S.C being committed against the then minor Plaintiff by Defendant Plaintiff has in the past suffered and will in the future continue to suffer physical injury pain and suffering emotional distress Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of psychological and/or psychiatric trauma mental anguish humiliation confusion embarrassment loss of educational opportunities loss of self-esteem loss of dignity invasion of her privacy separation from her family and other damages associated with Defendants manipulating and leading her into a perverse and unhealthy 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 Plaintiff will continue to suffer these losses in the future WHEREFORE Plaintiff Jane Doe No demands judgment against Defendant Jeffrey Epstein for all damages available under U.S.C including without limitation actual and compensatory damages attorneys fees costs of suit and such other further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT SIX Cause of Action for Sexual Exploitation of Children pursuant to U.S.C in Violation of U.S.C Plaintiff Jane Doe No hereby adopts repeats realleges and incorporates by reference the allegations contained in paragraphs through above Defendant Jeffrey Epstein knowingly persuaded induced enticed or coerced the then minor Plaintiff to engage in sexually explicit conduct for the purpose of producing a visual depiction of such conduct in violation of U.S.C As previously stated in paragraphs and Defendant kept and displayed a myriad of nude photographs of underage girls throughout his homes including his homes in New York City Palm Beach Santa Fe and the U.S Virgin Islands Plaintiff Jane Doe No saw photographs of naked young girls in each of Defendants homes including a photograph of herself naked at Defendants home in Palm Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of Beach Upon information and belief many of the photographs in the possession of Defendant were taken with hidden cameras set up in his home in Palm Beach On the day of his arrest police found two hidden cameras and photographs of underage girls on a computer in Defendants home Upon information and belief Defendant Jeffrey Epstein may have taken lewd photographs of Plaintiff Jane Doe No with his hidden cameras and may have transported lewd photographs of Plaintiff among many other victims to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce Upon information and belief one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Sheriffs Office during its execution of a search warrant of Defendants Palm Beach mansion on October Upon information and belief those photographs are still in the custody of law enforcement Plaintiff Jane Doe No was a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against Defendant Jeffrey Epstein pursuant to this Section of the United States Code As a direct and proximate result of the offenses enumerated in U.S.C being committed against the then minor Plaintiff by Defendant Plaintiff has in the past suffered and will in the future continue to suffer physical injury pain and suffering emotional distress psychological and/or psychiatric trauma mental anguish humiliation confusion embarrassment loss of educational opportunities loss of self-esteem loss of dignity invasion of her privacy separation from her family and other damages associated with Defendants manipulating and leading her into a perverse and unhealthy way of life 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 Podhurst Orseck P.A WP.t FfaulPr StrPPt SnitP Mi:amL FT Miami vi Fax Fort AUnPrdalP w_nndh11n;.trnm Case Document Entered on FLSD Docket Page of Case Document Filed Page of income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and Plaintiff will continue to suffer these losses in the future WHEREFORE Plaintiff Jane Doe No demands judgment against Defendant Jeffrey Epstein for all damages available under U.S.C including without limitation actual and compensatory damages attorneys fees costs of suit and such other further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT SEVEN Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit Conduct pursuant to U.S.C in Violation of U.S.C a Plaintiff Jane Doe No hereby adopts repeats realleges and incorporates by reference the allegations contained in paragraphs through above Defendant Jeffrey Epstein knowingly mailed transported shipped or sent via computer and/or facsimile in or affecting interstate and/or foreign commerce at least one visual depiction of the minor Plaintiff engaging in sexually explicit conduct in violation of U.S.C a As previously stated in paragraphs and Defendant displayed a myriad of nude photographs of underage girls throughout his homes including his homes in New York City Palm Beach Santa Fe and the U.S Virgin Islands Plaintiff Jane Doe No saw photographs of naked young girls in each of Defendants homes including a photograph of herself naked as a minor at Defendants home in Palm Beach As previously stated in paragraph Defendant told Plaintiff that he had photographs of her naked in all of his homes Upon information and belief many of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach On the day of his arrest police found two hidden cameras and nude photographs of underage girls on a computer in Defendants home Upon information and belief Defendant Jeffrey Epstein may have taken lewd Podhurst Orseck P.A Case Document Entered on FLSD Docket Page of Case Document Filed Page of photographs of Plaintiff Jane Doe No with his hidden cameras and may have transported lewd photographs of Plaintiff among many other victims to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce Upon information and belief one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Sheriffs Office during its execution of a search warrant of Defendants Palm Beach mansion on October Upon information and belief those photographs are still in the custody of law enforcement As previously stated in paragraph any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provision of applicable federal and state statutes concerning the sexual exploitation and abuse of a minor child Defendant Jeffrey Epstein at all times material to this cause of action knew and should have known of Plaintiffs age of minority Defendants preference for underage girls was well-known to those who regularly procured them for him Plaintiff Jane Doe No was a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against Defendant Jeffrey Epstein pursuant to this Section of the United States Code As a direct and proximate result of the offenses enumerated in U.S.C being committed against the then minor Plaintiff by Defendant Plaintiff has in the past suffered and will in the future continue to suffer physical injury pain and suffering emotional distress psychological and/or psychiatric trauma mental anguish humiliation confusion embarrassment loss of educational opportunities loss of self-esteem loss of dignity invasion of her privacy separation from her family and other damages associated with Defendants manipulating and leading her into a perverse and unhealthy way of life The then minor Plaintiff incurred medical and psychological expenses and Plaintiff will in the future suffer additional medical and Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.cotn Case Document Entered on FLSD Docket Page of Case Document Filed Page of psychological expenses Plaintiff has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and Plaintiff will continue to suffer these losses in the future WHEREFORE Plaintiff Jane Doe No demands judgment against Defendant Jeffrey Epstein for all damages available under U.S.C including without limitation actual and compensatory damages attorneys fees costs of suit and such other further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT EIGHT Cause of Action for Transport of Child Pornography pursuant to U.S.C in Violation of U.S.C a Plaintiff Jane Doe No hereby adopts repeats realleges and incorporates by reference the allegations contained in paragraphs through above Defendant Jeffrey Epstein knowingly mailed transported shipped or sent via computer and/or facsimile in or affecting interstate and/or foreign commerce child pornography in violation of U.S.C a Plaintiff Jane Doe No was a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against Defendant Jeffrey Epstein pursuant to this Section of the United States Code As a direct and proximate result of the offenses enumerated in U.S.C being committed against the then minor Plaintiff by Defendant Plaintiff has in the past suffered and will in the future continue to suffer physical injury pain and suffering emotional distress psychological and/or psychiatric trauma mental anguish humiliation confusion embarrassment loss of educational opportunities loss of self-esteem loss of dignity invasion of her privacy separation from her family and other damages associated with Defendants manipulating and Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of leading her into a perverse and unhealthy way of life 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 Plaintiff will continue to suffer these losses in the future WHEREFORE Plaintiff Jane Doe No demands judgment against Defendant Jeffrey Epstein for all damages available under U.S.C including without limitation actual and compensatory damages attorneys fees costs of suit and such other further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT NINE Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to U.S.C in Violation of U.S.C Plaintiff Jane Doe No hereby adopts repeats realleges and incorporates by reference the allegations contained in paragraphs through above and Counts One through Eight above Defendant Jeffrey Epstein knowingly engaged in a child exploitation enterprise as defined in U.S.C in violation of U.S.C As more fully set forth above Defendant engaged in actions that constitute countless violations of U.S.C sex trafficking of children Chapter sexual exploitation of children in violation of U.S.C a and A a and Chapter transportation for illegal sexual activity in violation of U.S.C and As more fully set forth above in paragraphs through Defendants actions involved countless victims and countless separate incidents of sexual abuse which he committed against minors including Plaintiff in concert with at least three other persons Podhurst Orseck P.A West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of Plaintiff Jane Doe No was a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against Defendant Jeffrey Epstein pursuant to this Section of the United States Code As a direct and proximate result of the offenses enumerated in U.S.C being committed against the then minor Plaintiff by Defendant Plaintiff has in the past suffered and will in the future continue to suffer physical injury pain and suffering emotional distress psychological and/or psychiatric trauma mental anguish humiliation confusion embarrassment loss of educational opportunities loss of self-esteem loss of dignity invasion of her privacy separation from her family and other damages associated with Defendants manipulating and leading her into a perverse and unhealthy way of life 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 Plaintiff will continue to suffer these losses in the future WHEREFORE Plaintiff Jane Doe No demands judgment against Defendant Jeffrey Epstein for all damages available under U.S.C including without limitation actual and compensatory damages attorneys fees costs of suit and such other further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Date May Podhurst Orseck P.A Bvbd twE Robert Josefs Katherine Ezell Bar No Podhurst Orseck P.A West Flagler Street Suite Miami Florida fax rjosefsberg podhurst.com West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of kezell podhurst.com Attorneys for Plaintiff DEMAND FOR JURY TRIAL Plaintiff demands to have her case tried before a jury Podhurst Orseck P.A wv Robert Jose Katherine Ezell Bar No Podhurst Orseck P.A West Flagler Street Suite Miami Florida fax rjosefsberg podhurst.com kezell podhurst.com Attorneys for Plaintiff West Flagler Street Suite Miami FL Miami Fax Fort Lauderdale w.podhurst.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of Rev CIVIL COVER Case Document Entered on FLSD Docket Page of Case Document Filed Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION ATTACHMENT TO CIVIL COVER
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