IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant I NOTICE OF FILING COMES NOW the Defendant/Counterplaintiff BRADLEY EDWARDS by and through his undersigned counsel and hereby provides notice that the transcript of the Deposition of Jeffrey Epstein taken has been filed with the Clerk of the Circuit Court Palm Beach Co lnty I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Fax and U.S Mail to all Counsel on the att 267this clay of January a ar No Se enney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard est Palm Beach Florida Phone Fax Attorney for BRADLEY EDWARDS Case No Plaintiffs Notice of Filing COUNSEL LIST Jack A Goldberger Esquire Atterbury Goldberger Weiss P.A Australian A venue South Suite tjst Palm Beach FL Phone Fax Farmer Jaffe Weissing Edwards Fistos Lehrman PL Andrews Avenue Suite Fort Lauderdale FL Phone Fa Joseph Ackerman Jr Esquire Fotler White Burnett P.A Phillips Point West Flagler Drive West Palm Beach FL Phone Fax rc Nurik Esquire One Broward Blvd Suite For;t Lauderdale FL Phone Fax IN THE CIRCUIT COURT OF THE 15TH JUbICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY_J EDWARDS individually and L.M individually ORIGINAL Defendant VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN January a.m a.m SEARCY DENNEY SCAROLA BARNHART SHIPLEY PA Palm aeach Lakes Boulevard West Palm Beach Florida Stenographically Reported By Tammy Nestor RPR w.phippsreporting.com I APPEARANCES ON BEHALF OF PLAINTIFF JACK SCAROLA __ QUTB-E SEARCY DEN SCAROLA BARNHA SHIPLEY PA Beach Lakes Boulevard West Palm Beach Florida ON BEHALF OF DEFENDANT CHRISTOPHER KNIGHT ESQUIRE JOSEPH ACKERMAN JR ESQUIRE FOWLER WHITE I EXAMINATION By Mr Scarola I I PAGE EXHIBIT DESCRIPTION PAGE Third Amended Com.plaint in LM Epstein w.phippsreporting.com I THE VIDEOGRAPHER Todays date is January The ti i approximately a.m This-is the Videotaped deposition of Jeffrey.Epstein in he matter of Epstein versus Edwards This deposition is being conducted at Palm Be ch Lakes Bo levard West Palm Beach Florida The court porter is Tammy Nestor of Phipps Reporting The videographer is Chris Kennedy of Legal Video Services Inc in I association with Phipps Reporting And will the counsel please announce appearances for the_ record MR SCAROLA My riame_ is Jack Scarola Im counsel for Brad Edwards Brad is also present MR KNIGHT Christopher Knight on behalf of Jeffrey Epstein MR GOLDBERGER Jack Goldberger behalf of Jeffrey Epstein MR INDYKE Darren Indyke on behalf of Jeffrey Epstein MR ACKERMAN Joseph Ackerman on behalf of Jeffrey Epstein w.phippsreporting.com JEFFREY EPSTEIN Was called as a witness and after being duly sworn on oath _Wa exa ined and tified as fcillows EXAMINATION BY SCAROLA Would you please sta your full name and your current residence address A Im Jeffrey 267Edward Epstein And my residence address is Red Hook Boulevard in Virgfn Islands Do you maintain any other residences presently A have vacation homes in New Mexico Palm Beach New York and Paris Would you give us the address of each please A Yes New York is East 71st Street New 267Mexico is Zorro Ranch Road Paris is Avenue och F-O-C-H And where else Palm Beach is El Brillo Way THE VIDEOGRAPHER Pardon me sir THE WITNESS Yes THE VIDEOGRAPHER Excuse me Do you have your mike on Thanks w.phippsreporting.com I BY MR SCAROLA Do you now or have you ever had a sexual add:i.ction MR KNIGHT Im going to instruct him not to answer the question Thats outside of the area of thi.s abuse of 267process lawsuit And just to let you know hes here.to answer all the questions you want relative to the abuse of pcess The judge has been pretty clSar reiative to the discovery regarding any of the prior sexuai allegations et cetera And just owe-dont ste your time or our timej Ill be consistent on that per.what the judge has pr vi6u ly discussed 267regarding discovery SCAROLA Well you and I have a very different understanding of what the courts ptior rulings have bee But well let the court deal with ihat BY MR SCAROLA Do you now or have you ever had a sexual preference for minors MR KNIGHT Same BY MR SCAROLA Have you ever acted on a sexual preference for minors w.phippsreporting.com MR KNIGHT Sarne BY MR Sc;:AROLA Have you ever informed anyone other than your legal counsel that you have a s.exual preference for minors MR KNI HT Sarne BY MR SCAROLA Have you ever informed anyone other than your legal counsel that you have acted on a sexual preference for minors MR KNIGHT Sarne BY MR SCAROLA Have you ever sought or received evaluation counseiing or treatment for any form of sexual addiction MR KNIGHT Sarne BY MR SCAROLA Have you ever sought or received evaluation counseling or treatment for any sex-related issue MR KNIGHT Sarne BY MR SCAROLA Have you ever retained the services of a consultant to assist in changing your public image following your arrest on sex-related charges w.phippsreporting.com MR KNIGHT Same BY MR SCAROLA Have you ever discussed with.anyone 267undertaking.an _effort to change your public image fc llowing your arrest for and conviction of a sex-related crime MR KNIGHT Same BY MR SCAROLA A convicted A Have you ever been convicted of a crime Yes What was the crime of which you 267were Two counts one soliciting prostitution and procuring a 267minor for prostitution Did you in fact commit those acts MR GOLDBERGER I can invoke the Fifth Amendment privilege for you or you can invoke it yourself I prefer you invoke the privilege THE WITNESS Im going to invoke my Fifth Amendment right BY MR SCAROLA How many times have you solicited for prostitution A Im going invoke my Fifth Amendment right w.phippsreporting.com How many times have 267you solicited a minor for prostitution A Same answer How many times have you solicited for prostitution in the State of 267Florida A Same answer How many times have.you solicited a minor for prostitution in the State of Florida A Same answer How many times have you solicited for prostitution in the Virgin Islands MR KNIGHT Can.we stop it here just for a second Can we go off the record for one minute THE VIDEOGRAPHER The time is We are going off the record Thereupon a discussion.was held off the record MR SCAROLA I would like you to take it down please MR KNIGHT Fine MR SCAROLA And well go back on the record Thank you THE VIDEOGRAPHER Stand by MR KNIGHT Im wondering if you have any w.phippsreporting.com intention to ask any 267questions and you may be any questions oytside of this clearly hara sing area relative to is 0es that are outside of the four cornets,ofth complaint or whether this is just going tobe a continuance of questions of this 225witness that have no other means of advancing.this lawsuit Sut onli have mean of doing othe things of which I wont I dont care to list them here Do you plan to go into other areas MR SCAROLA I am I am planning on taking a very thorough and comprehensive deposition of Mr Epstein MR KNIGHT Are you asking planning to ask any questions that are not sexual or criminal in nature MR SCAROLA Oh Im sure there will be many that you would probably not consider sexu or criminal in nature but I dont know MR KNIGHT Lets proceed for a little while see what we can do because certainly we have taken the time out to come up here peoples schedules have ti en made et cetera people have traveled long distances but we 267may have to quit and go to the court w.phippsreporting.com BY MR SCAROLA Have your ever solicited for prostitution in the Virgin Islands A Same answer That is that the you are invoking-your Fifth Amendment A A Yes 267right Yes Mr Scarola Have you ever solicited for prostitut on in New York A Same answer Have you ever solicited for prostitution in new.Mexico A Same answer Have you ever solicited for prostitution in Paris A Same answer Have you ever solicited for prostitution anywhere at 267any ime A Same answer Have you ever solicited a minor for prostitution anywher at any time A Same answer Who is the prostitute that you solicited w.phippsreporting.com for prostitution with respect to the claim on which you were convicted A Same answer Who is the minor that you solicited:for prostitution with respect to the 267claim on which you pled gui ty A Same answer Did you fact plead _guilty to soliciting for prosti.tution MR KNIGHT Asked and answered THE WITNESS Yes sir BY MR SCAROLA Did you in act plead,guilty_to solici.tir?,g a minor for prostitution A No Where was it that you solicited for prostitution in the manner in the matter in which you pled_guilty A Same answer When was it that you solicited for prostitution in the matter in which you pled guilty A Same answer Have you ever discussed your sex-related arrest or conviction with any reporter or news media representative w.phippsreporting.com MR KNIGHT Im going to instruct you nqt to answer the question MR SCAROLA And what is the basis of that instruction MR KNIGHT What is the basis MR SCAROLA Yes MR KNIGHT What does it have to do with this lawsuit Its for no other reason othet than to harass him There are plenty of areas you can go into which are reasonable We are here MR SCAROLA So the objection relevancy is that correct MR KNIGHT No it goes beyond relevancy MR SCAROLA Well what is it then MR KNIGHT Well it is harassing It is used it is being used to intimidate the witness It is being used for various different reasons And I believe it is improper BY MR SCAROLA Have you ever discussed your sex-related activities with minors in the State of Florida with any reporter or news media representative MR KNIGHT Same instruction We are w.phippsreporting.com going to take a quick break if we can go off the record THE VIDEOGRAPHER The time is We are going off the record Theieupon a recess was taken at a.m THE VIDEOGRAPHER The time is a.m We are back on the re ord MR KNIGHT As rmentioned earlier we are here to answer questions relevant to the lawsuit that is at issue Relative to your question earlier and the instruction not to answer I do believe it was appropriate but Im going to have Mr Goldberger address what be believes the is the our client is entitled to but at the same ti there ar other issues we want to put on the record I will allow you to ask more questions but if its going to stay on this line we may have to adjourn MR GOLDBERGER Okay This is Jack Goldberger A couple issues First as to the questions that Mr Scarol you a ked concerning conversations that Mr Epstein may w.phippsreporting.com or may not have had with I believe you couched it as news reporters or news media he would be invoking Fifth Amendment privileges as to thos questions in addition to the objection raised by Mr Knight MR KNIGHT Im withdrawing the instruction MR GOLDBERGER Okay All right Anyhow hes invoking Fifth Ame.ndment privileges as to that line of questioning As to the total line of questioning where you are asking Mr Epstein about sex-related issues as you know your client Mr Edwards has filed a lawsuit in federal court where he is seeking to overturn the non-prosecution agreement that Epstein is a party to I believe that _you are asking these questions in effbrt to further Mr Edwards attempts-to set aside that non-prosecution 267agreement and I think it serv no purpose other than to assist your ciient in that lawsuit And I just think its totally out ide the realm of the discovery that is allowed in this case And Im simply not going to allow my client to answer those questions given the fact w.phippsreporting.com that your client has filed an action to set aside the non-prosecution agreement that Mr Epstein is a party to MR SCAROLA Would you please mark this as Exhibit No to this deposition MR KNIGHT As soon as you get the sticker on it Ill look at that one Thereupcin Deposition Exhibit No was marked for identification i6 THE VIDEOGRAPHER Is someones phone by a microphone or their pocket MR GOLDBERGER I am THE VIDEOGRAPHER If you can put it to the side please MR GOLDBERGER Im all the way over here MR KNIGHT Mine is off MR GOLDBERGER Ill shut it off MR KNIGHT Okay Thank you BY MR SCAROLA You have been handed a copy of whats been marked as 267Exhibit No to this deposition It is a copy of Plaintiffs Third Amended Complaint in a case styled LM versus Jeffrey Epstein Have_you seen this document.before w.phippsreporting.com A Not to the best of my recollection no Do you recall having been sued by Bradley Edwards on behalf of an individual who was identified by.the initials LM A Yes sir And is this one of the cases that you contend was abusively prosecuted by Bradley Edwards A Im not sure if this is the act comp1aint Well is this the case A I dont know Which case is it that you contend.Bradley Edwards abusively prosecuted _against you A It was the LM ca I dont know if this is the specific case WelL I want you to assume_that there was only one LM case that was filed by Bradley Edwards against you A Thats correct Do you have any recollection that is at odds with that assumption A Yes I do You have a recollection that there was i_ri fact a federal court case as well as a state court case correct w.phippsreporting.com A A Correct All right Now is it your I believe thats Is it your contention MR 267KNIGHT Finish your answer Did you finish your answer THE WITNESS Thats all right BY MR SCAROLA Is it your contention that Bradley MR KNIGHT And.any time you want to finish your answe_r please do so THE WITNESS Sure BY MR _SCAROLA Is it your contention that Bradley wards abusively prosecuted the state court ca on behalf of LM A I dont know Sorry Is it your contention that Bradley Edwards abusively prosecuted the federal court case on behalf of LM MR KNIGHT Objection asks for legal conclusions Obviously there were lawsuits that were raised in this case MR SCAROLA You dont need to make a speaking objection w.phippsreporting.com I MR KNIGHT 267Okay MR SCAROLA that intended to coach the witness Mr Knight MR KNIGHT Im going to object MR.-SCAROLA So if you say you are objecting on the basis that it calls for a legal conclusion thats fine And now I would like the witn answer unless-you are instructing him not to answer KNIGHT Im not instructing him not to answer BY MR SCAROLA Okay Then would you please answer th question A Im sorry Would you repeat it Yes sir Is it your contention that Bradley.Edwards abusively proseQuted the federal court action on behalf of LM A A Yes sir How Bradley Edwards filed a 234-count federal complaint in conjunction with his partner Scott Rothstein to enable his partners at RRA to defraud south Florida investors of millioris of dcillars His partner Scott Rothstein and his partnet w.phippsreporting.com Mr Adler have excuse me Mr Rothstein has now in depositiqn admitted.that they needed to file a complaint to show investors that there was real action in Mr Rothsteins words going on in federal court The investors ha not been able to find a filed complaint and had complained to Mr Rothstein that there was no filed complaints two days excuse me before Mr Edwards filed the federal complaint for A Were you ever served with that complaint Not to the best of my recol ec ion So one contention is that Mr Edwards abusively prosecuted a 267federal court action on behalf of LM with which you were never s_erved correct A I had I was notified that the case was in fact filed But you were never served.with the case correct A correct A I was notified that the case was filed But rou were 267never served with the ase Not to the best of my recollection Okay What damage did you incur as a consequence of the filing of a complaint _with which you were never 267served w.phippsreporting.com A I incurred many legal much legal fe ny legal fees iri fact to try to figure out why what was going on and in fact getting prepared to defend the case though I had not yet been served Were the allegations in the federal c:;:omplaint on behalf of LM any different than the allegations in the state court case on be lf of LM A dont recall Did you in 267fact engage in any sexual conduct with LM A Im sorry but I.m sure the jury is going to recognize this is simply meant to harass me and I have to take the Fifth Amendment since your client Mr Edwards is trying.to overturn my pros cution agreement How many times did you engage in sexual conduct 267with LM A Im going to have to invoke my Fifth Amendment right again sir A Do you know who LM is Again Im going to assert my right MR KNIGHT We are going to go off the record and take another break THE VIDEOGRAPHER The time is We w.phippsreporting.com are going off the record Thereupon a recess 267was taken at a.m THE VIDEOGRAPHER The time is We are on the record MR KNIGHT Okay We have asked on several occasions that you ask questions that are relevant to the lawsuit at bar There have been some questions that were getting to it You are back into the sexual stuff which feel is inappropriate and also relative to the issues that were ised by Mr Goldberger As such we are going to recess and ask further direction from the court on wh is allowable and what is not allowable in this deposition MR SCAROLA So you are terminating the deposition at this time MR KNIGHT We are recessing.t,he deposition to get direction from the court MR SCAROLA Until when MR KNIGHT we will find out what the court says MR SCAROLA When Are you contacting the judge right now w.phippsreporting.com MR KNIGHT ram not We are going to file an appiopriate motion and we are going to I take it to the judge and see what he does Thank you MR SCAROLA so that the record clear it is my intenticin to ask ver specific que tions about every factual allegation included in every qlatm brought by Mr Edwards_ on behalf of every victim in every case in which it is alleged that Mr Edwirds has abusively prosecuted that claim I want to know about the connection betwe Mr Epstein and ea6h one of those alle ed victims I want to know about every individual who had information concerning the events that are alleged in tho;e cociplaints every individual who was in a position to have possibly had information about the events alleged in those complaints I want to ask this witne about every person whose deposition was-taken and scheduled to be taken the relationship of those rsons to Mr Epstein knowledge that those persons may have with respect to Mr Epsteins activities_ with minors other crimes committed by w.phippsreporting.com Mr Epste as part of an ongoing and continuous course of conduct supportive of claims for punitive damages against Mr Epstein and supportive of RICO claims gainst him And had this deposition been permitted to continue we would have covered each of those areas and substantially more MR KNIGHT Thank you THE VIDEOGRAPHER The time is We are going off the record Thereupon the deposition was adjourned at a.m w.phipp reportihg.com STATE OF FLORI,DA COUNTY OF BROWARD CERTIFICATE OF REPORTER I TAMMY NESTOR Registered Professional Reporter do hereby certify ihat I was authorized to and did stenographically report the foregoing dep9sition of JEFFREY EPSTEIN that a review of the transcript was requested _and that th transcript is a true record of my stenographic ndtes I further certify that I am not a relative employee attorney or counsel of any of the parties nor am I a relative-or employee of any of parties 225attor eys or c6unsel 267conn ct with the actiort nor I finanbially interested in the action Dated this 25th day of TA w.phippsreporting.com STATE OF FLORIDA COUNTY OF BROWARD CERTIFICATE OF OATH the undeisigned authority certify that JEFFREY EPSTEIN personal appeared before me and was sworn Witness my hand and official seal this 25th day of i,a:ry or Court Reporter Notary Public State of Florida Commission No EE Commission Exp Date w.phippsreporting.com January FOWLER.WHITE PAGE LINE ERRATA A able abuse abusively access Ackerman acted action activities acts addiction addition address adjourn adjourned Adler admitted advancing agreement allegation allegations alleged bar asking allow BARNHART asks allowable basis assert allowed each assist Aniended association Amendment behalf assume assumption announce attempts answer believe ATTERBUR ATTN believes attorney best attorneys beyond answered Australian blank appearances authority bottom appeared authorized Boulevard appointment available Brad appropriate Avenue Bradley approximatel a.m area break areas Brickell arrest Brillo aside brought back asked BROWARD w.phippsreporting.com claim claims clear Clearlake clearly Clerk client coach come Commission commit committed complained complaint complaints comprehensiv computer concerning conclusion conclusions conduct counsel day conducted days conjunction counseling deal connected counts declare connection COUNTY defend consequence couple DEFEND AN consider course Defendant consistent court defraud consultant DENNEY contacting deposition contend contention courts covered continuance DESCRIPTI crime continue different crimes continuous direction criminal conversations discovery current convicted discussed conviction discussion copy damage distances corners damages distribution Darren correct document date doing couched Dated dollars w.phippsreporting.com duly earlier East Edward Edwards EE effort El email employee enable engage ENTER entitled Epstein Epsteins Errata Espirito ESQUIRE et evaluation event events exact EXAMINATI examined excuse execute Exhibit Exp fact facts factual federal feel Forum guilty fees forwarded Fifth found four hand figure FOWLER handed file Friday harass filed full harassing further held filing F-o-c:.H homes financially Hook find getting hours fine give I finish given identification First go identified Floor image Florida goes improper going inappropriate included Foch incur following incurred follows individual Goldberger foregoing individually form Indyke w.phippsreporting.com information informed initials instruct instructing instruction intended intention interested intimidate investors invoke invoking Islands issue issues Jack January Jeffrey Joseph JR judge JUDICIAL jury Kennedy Knig know knowledge Lakes lawsuit lawsuits legal letter Lets line list little LM l4 long look L.M maintain manner mark marked matter means meant media mentioned Mexico Mia.mi microphone mike millions Mine minor minors minute Monday motion name nature need needed new news non-prosecuti Notary notes notice notified oath object objecting objection Obviously occasions odds official Oh Okay Nestor ongoing ordered never w.phippsreporting.com ordering original outside overturn PA PAGE Palm Pardon Paris part parties partner partners party penalties people peoples perjury permitted person personally persons Phipps phone Place PLAINTIFF Plaintiffs Plaintiff plan planning Plaza plead please pied plenty pocket position possibly prefer preference prepared present presently pretty question record previously questioning prior questions privilege Red privileges regarding probably quick Registered proceed quit relationship process relative procuring raised production Ranch relevancy Professional read relevant prosecuted read-only repeat real report prosecution realm Reported prostitute reason reporter prostitution reasonable reporters reasons Rep-orting recall public representative received punitive requested recess purpose residence recessing put residences recognize p.m respect recollection w.phippsreporting.com retained return review RICO right Road Rothstein Rothsteins RPR RRA rulings Santo says Scarola schedule scheduled schedules Scott seal SEARCY second see seeking seen served serves services set sexual sex-related Sheet SHIPLEY show shut side things sticker sign think stop signature Third Street simply thirty stuff sir thorough styled time solicited substantially sued Suite soliciting supportive times someones sure soon Todays sorry sworn total totally sought transcript south take speaking traveled specific taken treatment Stand true state Tammy truly terminating try stated testified trying stay Thank two stenographic Thanks stenographica undersigned w.phippsreporting.com understandin undertaking vacation various version versus victim victims Video videographer videotaped Virgin vs waive want waste way WEISS West well WHIf.E wish withdrawing 14th witness 15TH witnes wondering words TE 66th 71st York Zorro 25th w.phippsreporting.com L.M Plaintiff VS IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CIVIL DIVISION CASE NO CA XMB AB JEFFREY EPSTEIN Defendant I PLAINTIFFS THIRD AMENDED COMPLAINT Plaintiff L.M by and through her undersigned counsel sues the _Defendant Jeffrey Epstein and alleges GENERAL ALLEGATIONS AS TO ALL COUNTS This is an action in an amount in excess of exclusive of interest and costs and is within the jurisdictional limits of this Court This Complaint is brought under a fictitious name in order to protect the identity of the plaintiff because this Complaint makes allegations of a sensitive sexual nature At all times material to this cause of action the plaintiff L.M hereinafter referred to as Plaintiff was a resident of Palm Beach County Florida At all times material to this cause of action Defendant Jeffrey Epstein had a residence located at El Brillo Way West Palm Beach Palm Beach County Florida EXHIBIT De __ ptr._ CON CA XMB AB Defendant Jeffrey Epstein is currently a citizen of the State of Florida as he curreritly resides at El Brillo Way West Palm Beach Florida where he is currently under community control as a condition of his sentence in criminal case number At all times material to this cause of action Defendant Jeffrey Epstein was an adult male born in All of the allegations within this Complaint occurred in West Palm Beach Florida Upon information and belief Defendant Jeffrey Epstein has demonstrated a sexual preference and obsession for minor girls Defendant Jeffrey Epstein along with numerous assistants developed a plan scheme and criminal enterprise that included an elaborate system wherein the then minor Plaintiff was brought to Defendant jeffrey Epsteins residence by the Defendants employees recruiters and assistants When the assistants and employees left the then minor Plaintiff and other minor girls alone in a room at the defendants mansion Defendant Jeffrey Epstein himself would appear remove his clothing and direct the then minor Plaintiff to remove h-er 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 coercing the then minor Plaintiff into sexual acts with himself or others and digitally penetrating the then minor Plaintiff He would then pay the plaintiff for engaging in this sexual activity CA XMB AB The plaintiff was first brought to Defendant Jeffrey Epsteins mansion in when she_ was a thirteen or fourteen-year old The then minor Plaintiff 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 July and continuing until approximately September Defendant Jeffrey Epstein coerced induced and/or enticed the impressionable vulnerable and economically deprived then minor Plaintiff to commit various acts of sexual misconduct These acts included but were not limited to fondling and inappropriate and illegal sexual touching of the then minor Plaintiff forcing or inducing the then minor Plaintiff into sexual misconduct masturbation of Defendant Jeffrey Epstein in the presence of the then minor Plaintiff handling and fondling of the then minor Plaintiffs sexual organs and encouraging the then minor Plaintiff to become involved in prostitution Defendant Jeffrey Epstein committed numerous criminal sexual offenses against the then minor Plaintiff including but not limited to sexual battery solicitation of prostitution molestation coercing a minor into prostitution contributing to the delinquency of a minor and the commission of lewd and lascivious acts upon the person of the then minor Plaintiff In addition to the direct sexual abuse and molestation of the then minor Plaintiff Defendant Jeffrey Epstein instructed coerced and otherwise induced the then CA XMB AB In acting in the manner described in paragraphs through Defendant Jeffrey Epstein violated a duty to refrain from committing criminal actions against Plaintiff that proximately caused damages to Plaintiff In committing various crimes against Plaintiff Defendant violated penal statutes that were designed to protect a class of persons of which Plaintiff is a member against a particular type of harm Particularly the Florida Statutes which Epstein violated include but may not be limited to A Chapter Lewd or lascivious offenses Defendant Epstein engaged in sexual activity with Plaintiff when Plaintiff was less than years of age and also encouraged or enticed her at that time to become involved in prostitution or some other act of sexual activity Defendant also violated this statute by touching in a lewd or lascivious manner the breasts genitals genital area or buttocks or the clothing covering them of Plaintiff at a time when Plaintiff was less than years old or enticed Plaintiff at that time to so touch Epstein Epstein masturbated in the presence of Plaintiff when Plaintiff was less than years of age Section Contributing to the delinquency of a child Defendant induced or endeavored to induce by act threat command or persuasion the then minor Plaintiff to commit or perform acts follow a course of conduct and live in a manner that caused or tended to cause Plaintiff to become or remain delinquent when he committed the acts described in paragraphs above against Plaintiff CA XMB AB minor Plaintiff to bring him numerous other minor children for the purposes of further satisfying his deviant sexual attraction to minors Defendant Jeffrey Epstein used his money wealth and power to unduly and improperly manipulate and influence the then minor Plaintiff to bring him these other minor girls in exchange for money This influence led the then minor Plaintiff away from the life of an adolescent teenage child and into a delinquent lifestyle The above-described acts took place in Palm Beach County Florida at the residence of the 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 and abuse of a minor child The defendant Jeffrey Epstein at all times material to this cause of action knew and should have known of the Plaintiffs minority The above-described acts were perpetrated upon the person of the then minor Plaintiff on numerous occasions COUNT I Negligence Per Se violation of criminal statutes The plaintiff adopts and realleges paragraphs through above Defendant Jeffrey Epstein negligently injured Plaintiff and/or failed to understand or appreciate that his conduct as alleged herein would injure Plaintiff on numerous occasions between approximately July and approximately September CA XMB AB Section Pro uring a minor for prostitution Defendant procured for prostitution or caused to be prostituted Plaintiff when Plaintiff was 267under the age of Section Prohibiting prostitution Defendant owned maintained and operated a place to wit his home located at El Brillo Way West Palm Beach Palm Beach County Florida for the purpose of lewdness or prostitution he received minors into his house for the purpose of lewdness or prostitution and directed took transported or offered or agreed to transport Plaintiff to and from his house with the reasonable belief that the purpose of such directing taking or transporting was lewdness or prostitution Section Sex trafficking Defendant knowingly recruited enticed harbored transported or obtained Plaintiff knowing that coercion would be used to cause Plaintiff to engage in prostitution Section Forcing compelling or coercing another to become a prostitute Defendant coerced Plaintiff to become a prostitute and Section Sexual abuse of a child Defendant intruded into the genitals of Plaintiff when Plaintiff was a child and touched her genitals or intimate parts he intentionally masturbated in front of her he intentionally exposed his genitals in her presence and encouraged Plaintiff to engage in prostitution As to each of the above referenced criminal statutes Plaintiff was a member of the class of persons intended to be protected the injury was of the type the CA XMB AB statute intended to protect and the injuries suffered by Plaintiff proximately resulted from the violation of the criminal statute As a direct and proximate result of Defendant Jeffrey Epsteins acts on Plaintiff 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 the plaintiff will in the future suffer additional medical and psychological expenses The plaintiff has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the Plaintiff will continue to suffer these losses in the future WHEREFORE the plaintiff L.M demands judgment against the 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 Intentional Sexual Tort Per Se in Violation of Criminal Statutes The plaintiff adopts and realleges paragraphs through above Defendant Jeffrey Epstein intentionally injured Plaintiff sexually on numerous occasions between approximately July and approximately September CA XMB AB and further sexually exploited her and contributed to her delinquency during that time In sexually abusing battering and exploiting Plaintiff in the manner described in paragraphs through Defendant Jeffrey Epstein violated a duty to refrain from committing criminal actions against Plaintiff that proximately caused damages to Plaintiff In committing various crimes against Plaintiff Defendant violated penal statutes that were designed to protect a class of persons of which Plaintiff is a member against a particular type of harm Particularly the Florida Statutes which Epstein violated include but may not be limited to A Chapter Lewd or lascivious offenses Defendant Epstein engaged in sexual activity with Plaintiff when Plaintiff was less than years of age and also encouraged or enticed her at that time to become involved in prostitution or some other act of sexual activity Defendant also violated this statute by touching in a lewd or lascivious manner the breasts genitals genital area or buttocks or the clothing covering them of Plaintiff at a time when Plaintiff was less than years old or enticed Plaintiff at that time to so touch Epstein Epstein masturbated in the presence of Plaintiff when Plaintiff was less than years of age Section Contributing to the delinquency of a child Defendant induced or endeavored to induce by act threat command or persuasion the then minor Plaintiff to commit or perform acts follow a course of conduct and live in CA XMB AB a manner that caused or tended to cause Plaintiff to become or remain delinquent when he committed the acts described in paragraphs above against Plaintiff Section Procuring a minor for prostitution Defendant procured for prostitution or caused to be prostituted Plaintiff when Plaintiff was under the age of Section Prohibiting prostitution Defendant owned maintained and operated a place to wit his home located at El Brillo Way West Palm Beach Palm Beach County Florida for the purpose of lewdness or prostitution he received minors into his house for the purpose of lewdness or prostitution and directed took transported or offered or agreed to transport Plaintiff to and from his house with the reasonable belief that the purpose of such directing taking or transporting was lewdness or prostitution Section Sex trafficking Defendant knowingly recruited enticed harbored transported or obtained Plaintiff knowing that coercion would be used to cause Plaintiff to engage in prostitution Section Forcing compelling or coercing another to become a prostitute Defendant coerced Plaintiff to become a prostitute and Section Sexual abuse of a child Defendant intruded into the genitals of Plaintiff when Plaintiff was a child and touched her genitals or intimate parts he intentionally masturbated in front of her he intentionally exposed his genitals in her presence and encouraged Plaintiff to engage in prostitution CA XMB AB As to each of the above referenced criminal statutes Plaintiff was a member of the class of persons intended to be protected the injury was of the type the statute intended to protect and the injuries suffered by Plaintiff proximately resulted from the violation of the criminal statute As a direct and proximate result of Defendant Jeffrey Epsteins criminal acts on Plaintiff 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 a sociated 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 will in the future suffer additional medical and psychological expenses The plaintiff has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff will continue to suffer these losses in the future WHEREFORE the plaintiff L.M demands judgment against the 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 Ill Cause of Action Pursuant to Florida Statute Against Defendant Jeffrey Epstein The plaintiff adopts and realleges paragraphs through above CA XMB AB 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 Exploitation through demonstration of abundant wealth and power to impress a young and vulnerable then minor Plaintiff and to coerce her into prostitution CA XMB AB 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 the plaintiff will in the future suffer additional medical and psychological expenses The plaintiff has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the Plaintiff will continue to suffer these losses in the future WHEREFORE the plaintiff L.M demands judgment against the 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 COUNT IV Intentional Infliction of Emotional Distress Against Defendant Jeffrey Epstein The plaintiff adopts and realleges paragraphs through above The defendant Jeffrey Epsteins conduct towards the then minor plaintiff was intentional and reckless and was outrageous in character and so extreme in degree going beyond all bounds of decency CA XMB AB The defendant Jeffrey Epsteins intentional deliberate and reckless conduct caused severe emotional distress to the plaintiff Defendant at the time he committed these numerous sexual assaults on Plaintiff 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 the defendant Jeffrey Epsteins intentional and reckless conduct the plaintiff has in the past suffered and in the future will continue to 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 the defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and unconventional way of life for a minor The then minor Plaintiff j_ncurred medical and psychological expenses and the plaintiff will in the future suffer additional medical and psychological expenses The plaintiff has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff will continue to suffer these losses in the future WHEREFORE the plaintiff L.M demands judgment against the 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 Battery CA XMB AB The plaintiff L.M repeats and realleges paragraphs through above On numerous occasions Defendant Epstein did in fact intentionally touch Plaintiff L.M on her person against her will and/or without her legal consent Defendant Epstein battered Plaintiff 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 July and September The conduct described in this count constitutes battery against the person of the then minor Plaintiff As a direct and proximate result of Defendant Jeffrey Epsteins battery on Plaintiff 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 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 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 CA XMB AB future and a loss of the capadty to enjoy life These injuries are permanent in nature and Plaintiff will continue to suffer these losses in the future WHEREFORE Plaintiff demands judgment against the 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 CERTICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been provided this i day of May via U.S Mail and email transmittal to all those on the attached service list Farmer Jaffe Weissing Edwards Fistos Lehrman Andrews Ave Suite Fort Lauderdale FL fax brad ath 267ustice.com By EYJ EDWARDS Florida Bar No Robert Critton Jr BURMAN CRITTON et al Banyan Boulevard Suite West Palm Beach FL Jay Howell Esq Jay Howell Assoc Cesery Boulevard Suite Jacksonville FL Jack Alan Goldberger Esq Atterbury Goldberger et al Australian Avenue South Suite West Palm Beach FL CA XMB AB SERVICE LIST
