JEFFREY EPSTEIN Plaintiff/Counter-Defendant vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually Defendant/Counter-Plaintiff Electronically Filed PM A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 10Cy n??m?n k?o?h I A I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R h?H?T3P K?z X?K H?o I Idc rM?M rM 10Cy f헊?f?Tz e?e:Aa I v"x i X5 EO5 5a r?q CX 9r Cy rq rqC M3 ş?:c p/p0 5H V)V 6T Y2 G5 qrM?r?qr?r9 q?10Cy rCX qr l1 X?l 3K fm?Q Z2f CX CX gT L??T 2E Cy 3P EM3 J4T L?h??M q?ᡚ?Y r??O?rJt CTX i P!e i I CTX rC YY I 1e 2j CTX X0T1i k3v Jh/e0h1 H(K W/Q0 CTX j?!k 5B r2 CTX A A A 4v z"p A A A0A?A AK CTX A A?!k CX qCX YCX i!d A fi8 l8 yuZ 6L pH m?c sP;0 6ZR Ni P0 0Q X(P0s s(s p0 Pp CTX qq dR B/J Va A y!k N?M??N rC f?Nla3 Yz N?q qr NEeD K?i N?M?qr EeD k??O GH FT I CTX U3 U3 U3 U3 S6 E"L I I I5K7C:I 9O U3 Cn qrr qr q??r?q 9qr CTX G5 qr CX rC l0 WS zN pf1 ODV8L?m jC1DxV CTX CTX A qr 10Cy rYY Ң??P?V CTX C"C rqM?rq?q?qr qr CTX YY Jb?C.y CTX CTX GG4 A A G5 C.C M??r 10Cy rq YY C?J?yO c/XE?lgF GM??H p?ݡG Dp9Oh CTX CTX CJ4 I J6 CJ4 CK qrrM?q qq 9/CX?o CX qYqr rC dd?Z c6S ttcx A CTX CTX 10Cy rq rqYY X?qiX:4 3J Db ZH uD-8 1g?BH I vS 7Oo7u E?K?O J6 UJP U0 UT??ʴ UT UT UT O(p U(u UF1 iZ qr?r CX CX Yr zKW:E A K5M P-M UW VW L1J KJ56 N/Q SQ rC 6J ߵl ߵl 5TZ w8ĥDG oj?K _4 N)?Y Hp pRqc?W26 vz?WBrz?ZB??3X H4 CTX A CTX X4 U5 P8 5D qr qr 10Cy qr YY Mo?ANp D01jJ 9F bzEV 4O 8V CTX O!o CTX KK AA qr A C5 qr rYY 1A?CC V9 a c?F CTX A G5 qr EeD?M CTX 9?rY 10Cy rq qY ȠX1 a f??B CTX 9F I CTX 6D N?qr rrqq qC O?J RmA??b"0 M?.F q?D B?G CTX CTX F4 d6P A F4 qr rYY 4G AV8 CTX UY UL0 U0 U0 U0 UF UF UFAGA UA UA UAL UL UL UL UL UL UL U7 U7 U7 U7 U7 U7 U7 2EH GTU U/U OUoU UV G1 CTX TUV 1G 7A UA UAL X7 U7 U7 U77XL UL UL ULLYX KTX 8Y GJ A UMAT UD 7M GVW GF10 MWA LL MPM M?M 4M XY qr qr qr NEeD 10Cy qYY E2 GH l1 Pd h3V g?KIq V5kL O65S d_xKKU vV 5H p1 Z6 CTX U0 U1 CTX U0 U1 A0 1D qr qr 10Cy YY K??Kl 1B AMwv 1K F1 KV yW Gd T?H CTX CTX I CK M?qr K?SK?PQZ I IRZX 8YCX 10Cy qr CX kv zg S5kB??a iG wA CTX U2 6Y CTX U2 6Y I K,,j j,s 6Y P!p qr 10Cy qr YY G?O 9K mSd X0 9r?yal 1d bY0 XNf??qN D?J CTX P!Z b!o C,C qrM 10Cy qr8 I fX2 9R lO KV CTX Oo CTX A qr r?qr rq YY Lsy7H4 C,6E IL CTX U3 CTX J,O3_3xx qrM?r q?CX Y9/C 9CX CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8 Epstein Rothstein et al WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via electronic service through the e-file portal to all parties on the attached service list this October Tonja Haddad Coleman Tonja Haddad Coleman Esq Florida Bar No Tonja Haddad PA SE 1h Street Suite Fort Lauderdale Florida facsimile Attorneys for Epstein SERVICE LIST CASE NO Jack Scarola Esq jsx searcylaw.com mep searcylaw.com Searcy Denney Scarola et al Palm Beach Lakes Blvd West Palm Beach FL Jack Goldberger Esq jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss PA Australian Ave South Suite West Palm Beach FL Marc Nurik Esq East Broward Blvd Suite Fort Lauderdale FL Bradley Edwards Esq brad pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman Andrews A venue Suite Fort Lauderdale Florida Fred Haddad Esq Dee FredHaddadLaw.com Financial Plaza Suite Fort Lauderdale FL Chester Brewer Jr Esq wcblaw alaol.com wcbcg aol.com Chester Brewer Jr P.A One Clearlake Centre Suite Australian A venue South West Palm Beach FL cont Epstein Rothstein et al Tonja Haddad Coleman Esquire Tonja tonjahaddad.com efiling tonjahaddad.com Law Offices of Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Attorneys for Jeffrey Epstein Epstein Rothstein et al From To subject Date Thanks so much Michele Dargan Brildley Edwards Re epsteln Tuesclay June PM am going to continue to pursue the Bear Stearns angle tomorrow But as for now I will run two graphs citing Radar as the source It should be up on the web within the hour at w.palmbeachdallynews.com On PM Bradley Edwards bedwards rra-law.com wrote Unfortunately she has not had time to send the docs I hope she gets them out today but it may not happen There is nothing to really comment on It doesnt surprise me at all that he despite being a registered sex offender is being released early and lt also wont be a surprise when he is released without the victims being notified Par for the course with this case I will try to get you the docs you want See you Thursday Bradley Edwards Partner Rothstein Rosenfeldt Adler Attorneys at Law las Olas City Centre East las Olas Boulevard Suite Fort Lauderdale FL facsimile bedwards rra-law,com From Michele Dargan maUto:mdargan pbdaUynews,comJ Sent Tuesday June PM To Bradley Edwards Subject Re epstein Brad havent received those documents yet Will she be able to forward them to me today Also I am filing a story to the web about his release date Found out Its July and I am citing Radaronllne about his lnvolvment in the Bear Stearns case Do you want to comment on the fact that hes getting released on July On PM Bradley Edwards bedwards rra-law.com wrote sent the request to my secretary and she will send you those docs today Bradley Edwards Partner Rothstein Rosenfeldt Adler Attorneys at Law Las Olas City Centre East Las Olas Boulevard Suite Fort Lauderdale FL facsimile bedwards rra-law.com mallto:bedwards rra-Jaw.com From Michele Dargan rnailto;mdargao pbdaiiyoews.mm mai!to:mdargao obdaflynews.com Sd Sent Tuesday June PM To Bradley Edwards Subject Re epstein Brad Thanks for the link I appreciate it Also would you e-mail those documents that we talked about your motion to unseal and the Posts atty if she has a separate one and also the Epstein attorney document that was filed on Friday Thanks so much Mlchele On PM Bradley Edwards bedwards rra-law.com wrote http UW radamoline com/exclusives/2009to6/excl prison-early Bradley Edwards Partner Rothstein Rosenfeldt Adler Attorneys at Law Las Olas City Centre East Las Olas Boulevard Suite Fort Lauderdale FL facsimile bedwards rra-law.com maHto bedwards rra-law,com Michele Dargan staff writer Palm Beach Daily News phone fax From To Subject Pate Attachments Bradley Edwards Mkhele Dargan Epstein applicable statutes Friday September PM lmiu1eQQt gtt 1maae002.alf did not pull the conspiracy version and convictions of conspiracy would add some amount of time how much I dont know hope this helps I cut the statutes stralght from Westlaw U.S.C.A United States Code Annotated Currentness Title Crimes and Crlminal Procedure Refs Annas e.aru Crimes Refs Annos Cbapter Transportation for Illegal Sexual Activity and Related Crimes Refs Annas Coercion and enticement a Whoever knowingly persuades induces entices or coerces any individual to travel in Interstate or foreign commerce or in any Territory or Possession of the United States engage in prostitution or in any sexual activity for which any person can be charged with a criminal offense or attempts to do so shall be fined under this title or imprisoned not more than years or both Whoever using the mail or any facility or means of Interstate or foreign commerce or within the speclal maritime and terrltorial jurisdiction of the United States knowingly persuades induces entices or coerces any individual who has not attained the age of years to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense or attempts to do so shall be fined under this title and imprisoned not less than years or for life U.S.C.A United States Code Annotated Currentness Title Crimes and Criminal Procedure Refs Annas ea.ru Crimes Refs Annas Chapter Transportation for Illegal Sexual Activity and Related Crimes Refs Annos Transportation of minors a Transportation with intent to engage in criminal sexual activity,--A person who knowingly transports an Individual who has not attained the age of years in interstate or foreign commerce or in any commonwealth territory or possession of the United States with Intent that the individual engage in prostitution or in any sexual activity for which any person can be charged with a criminal offense shall be fined under this tltte and imprisoned not less tban years or for life Travel with intent to engage in illicit sexual conduct.--A person who travels in interstate commerce or travels Into the United States or a United States citizen or an alien admitted for permanent residence in the United States who travels in foreign commerce for the purpose of engaging in any Illicit sexual conduct with another person shall be fined under this title or imprisoned not more than years or both Engaging in illicit sexual conduct in foreign places.--Any United States citizen or alien admitted for permanent residence who travels in foreign commerce and engages in any lcit sexual conduct with another person shall be fined under this tltle or imprisoned not more than years or both Ancillary offenses.--Whoever for the purpose of commercial advantage or private financial gain arranges induces procures or facilitates the travel of a person knowing that such a person is traveling in Interstate commerce or foreign commerce for the purpose of engaglng in Illicit sexual conduct shall be fined under this title Imprisoned not more than years or both Attempt and conspiracy,--Whoever attempts or consi;iires to violate subsection a or shall be pynishabie lo the same manner as a completed vialatlon of that subsection Definition.--As used In this section the term Illicit sexual conduct means a sexual act as defined in section with a person under years of age that would be in violation of chapter if the sexual act occurred in the special maritime and territorial jurisdiction of the United States or any commercial sex act as defined In section with a person under years of age Defense.--In a prosecution under this section based on illicit sexual conduct as defined In subsection It Is a defense which the defendant must establish by a preponderance of the evidence that the defendant reasonably believed that the person with whom the defendant engaged in the commercial sex act had attained the age of years 1a u.s.c.A United States Code Annotated currentness Title Crimes and Criminal Procedure Refs Annos e.ar:u Crimes Refs Annas Chapter Peonage Slavery and Trafficking In Persons Refs Annos Sex trafficking of children or by force fraud or coercion a Whoever knowingly in or affecting interstate or foreign commerce or within the special maritime and territorial jurisdiction of the United States recruits entices harbors transports provides obtains or malntalns by any means a person or benefits financially or by receiving anything of value from participation in a venture which has engaged in an act described in violation of paragraph knowing or in reckless disregard of the fact that means of force threats of force fraud coercion described in subsection or any combination of such means will be used to cause the person to engage In a commercial sex act or that the person has not attained the age of years and will be caused to engage in a commercial sex act shall be punished as provided In subsection The punishment for an offense under subsection a is if the offense was effected by means of force threats of force fraud or coercion described in subsection or by any combination of such means or if the person recruited enticed harbored transported provided or obtained had not attained the age of years at the time of such offense by a fine under this title and imprisonment for any term of years not less than or for Jife or if the offense was not so effected and the person recruited enticed harbored transported provided or obtained had attained the age of years but had not attained the age of years at the time of such offense by a fine under this title and lmpr!sonment tor not less than to years or for life In a prosecution under subsectlon a in which the defendant had a reasonable opportunity to observe the person so recruited enticed harbored transported provided obtained or maintained the Government need not prove that the defendant knew that the person had not attained the age of 1a years Whoever obstructs attempts to obstruct or in any way interferes with or prevents the enforcement of this section shall be fined under this title imprisoned for a term not to exceed years or both In this section The term abuse or threatened abuse of Jaw or legal process means the use or threatened use of a law or legal process whether administrative civil or criminal In any manner or for any purpose for which the law was not designed in order to exert pressure on another person to cause that person to take some action or refrain from taking some action The term coercion means A threats of serious harm to or physical restraint against any person any scheme plan or pattern intended to cause a person to believe that fallure to pelform an act would result in serious harm to or physical restraint against any person or the abuse or threatened abuse of law or the legal process The term commercial sex act means any sex act on account of which anything of value Is given to or received by any person The term serious harm means any harm whether physical or nonphysical including psychological financial or reputational harm that is sufficiently serious under all the surrounding circumstances to compel a reasonable person of the same background and in the same circumstances to perform or to continue performing commercial sexual activity in order to avoid Incurring that harm The term venture means any group of two or more individuals associated in fact whether or not a legal entity Twelfth Section of the Adam Walsh Act added u.s,c to the list of offenses for which a defendant is to be sentenced to life under U,S,C A The amendment adds u.s.c to the list of instant offenses of convictions that are covered sex crimes under USSG Ch TWO Pt A Refs Annas U.S.C.A United States Code Annotated Currentness Federal Sentencing Guidelines Chapter Two Offense Conduct Offenses Against the Person Criminal Sexual Abuse and Offenses Related to Registration as a Sex Offender HISTORICAL NOTES Amendments Chapter Two Part A Subpart Three is amended in the heading by adding at the end AND OFFENSES RELATED TO REGISTRATION AS A SEX OFFENDER Reason for Amendment This amendment responds to the AcHfrr Wiilsti C::hild;Ptpt ction at1c!:,:Saf4:9ty Ad f29Q tfie AclarrfW l!ih A Pub.L which contained a directive to the Commission created new sexual offenses and enhanced penalties for existing sexual offenses The amendment lmplements the directive by creating two new guidelines Crimtnal Sexual Abuse and Offenses Related to Registration as a Sex Offender and Aggravated Offenses Relating to Registration as a Sex Offender It further addresses relevant provisions in the Adam Walsh Act by making changes to Chapter Two Part A Subpart Criminal Sexual Abuse and Part Offenses Involving Commercial Sex Acts Sexual Exploitation of Minors and Obscenity Obstruction of Justice Groups of Closely Related Counts Repeat and Dangerous Sex Offender Against Minors Conditions of Probatlon Term of Supervised Release Conditions of Supervised Release and Appendix A Statutory Index First sectlon of the Adam Walsh Act amended U,S,C to add a new mandatory minimum term of imprisonment of years for offenses related to the aggravated sexual abuse of a child under years old or of a child between and years old if force threat or other means was used In response to the new mandatory minimum for these offenses the amendment increases the base offense level at Criminal Sexual Abuse Attempt to Commit Criminal Sexual Abuse from level to level The base offense level of has been retained for all other offenses At least one specific offense characteristic applied to every conviction under U.S.C sentenced under in fiscal year Accordingly the mandatory minimum months imprisonment is expected to be reached or exceeded In every case with a base offense level of The amendment provides a new appllcatron note that precludes application of the specific offense characteristic at regarding conduct described in U,S.C or bl if the conduct that forms the basis for a conviction under u,s,c is that the defendant engaged In conduct described In u.s,c a or tu force threat or other means The amendment also precludes applicatlon of the specific offense characteristic for the age of a victim at if the defendant was convicted under section The heightened base offense level of takes into account the age of the victim These instructions therefore avoid unwarranted double countlng Second section of the Adam Walsh Act increased the statutory maximum term of imprisonment under u.s,c from years to years for the sexual abuse of a person In official detention or under custodial authority In response to increased penalty the amendment increases the base offense level from to in Criminal Sexual Abuse of a Ward or Attempt to Commit such Acts The amendment also adds a new definition of minor consistent with how this term Is defined elsewhere in the guidelines manual In addition the amendment includes an application note precluding application of Abuse of Position of Trust or Use of Special Skill for these offenses because an abuse of position of trust is assumed in all such cases and therefore is built into the base offense level Third section of the Adam Walsh Act created a new subsection at U,S.C Section a provides a penalty of any term of years If the sexual conduct would have violated U.S.C had the contact been a sexual act Section conduct involves the aggravated sexual abuse of a child under years old or of a child between and years old if force threat or other means was used as defined in U.S,C a and bl Prior to the Adam Waist Act the penalty for offenses involving children under years old was twice that otherwise provided and the penalty for sexual contact involving behavior described in s,c was a statutory maximum term of imprisonment of years The amendment addresses thls new offense by increasing the minimum offense level in the age enhancement In subsection of Abusive Sexual Contact or Attempt to Commit Abusive Sexual Contact from level to level Fourth section of the Adam Walsh Act created a new offense under U.S,C a for the failure to register as a sex offender The basic offense carries a statutory maximum term of imprisonment of years Section also Included a directive to the Commission that when promulgating guidelines for the offense to consider among other factors the seriousness of the sex offenders conviction that gave rise to the requirement to register relevant further offense conduct during the period for which the defendant failed to register and the offenders criminal history The amendment creates a new guideline Failure to Register as a Sex Offender to address the directive The new guideline provides three alternative base offense levels based on the tiered category of the sex offender level if the defendant was required to register as a Tier I offender level if the defendant was required to register as a Tier II offender and level if the defendant was required to register as a Tier offender The amendment also provides two specific offense characteristics First subsection provides a tiered enhancement to address criminal conduct committed while the defendant ls ln a failure to register status Specifically provides a six-level increase if while in a failure to register status the defendant committed a sex offense against an adult a six-level increase If the defendant committed a felony offense against a minor and an eight-level increase if the defendant committed a sex offense against a minor Second provides a three-level decrease if the defendant voluntarily corrected the failure to register or voluntarily attempted to register but was prevented from registering by uncontrollable circumstances and the defendant did not contribute to the creation of those circumstances The reduction covers cases in which the defendant either does not attempt to register until after the relevant registration period has expired but subsequently successfully registers thereby correcting the failure to register status or the defendant either before or after the registration period has expired attempted to register but circumstances beyond the defendants control prevented the defendant from successfully registering An application note specifies that the voluntary attempt to register or to correct the failure to register must have occurred prior to the time the defendant knew or reasonably should have known a jurisdiction had detected the failure to register The application note also provides that the reduction does not apply if the enhancement for committing one of the enumerated offenses in applies Additionally the amendment adds to the list of offenses that are considered groupable under because the failure to register offense is an ongoing and continuous offense Fifth section of the Adam Walsh Act created two new aggravated offenses relating to the registration as a sex offender Section of the Act created cl which carries a mandatory minimum term of Imprisonment of years and a statutory maximum term of imprisonment of years if a defendant commits a crime of violence while in a fallure to register status with the sentence to be consecutive to the punishment provided for the failure to register Section of the Adam Walsh Act created a new offense at U.S,C that prohibits the commission of various enumerated offenses while in a failure to register status The penalty for this offense is a mandatory term of Imprisonment of years to be Imposed consecutively to the underlying offense The amendment creates a new guideline at Aggravated Offenses Relatihg to Registration as a Sex Offender to address these new offenses The new guideline provides that for offenses under section the guideline sentence is the minimum term of Imprisonment required by statute and for offenses under section the guideline sentence is the term of imprisonment required by statute Chapters Three and Four are not to apply This is consistent with how the guidelines treat other offenses that carry both a specified term of imprisonment and a requirement that such term be Imposed consecutively See Procedure for Determining Offense Level on Multiple Counts and SGl.2 Sentencing on Multiple Counts of Conviction The guideline includes an application note that provides an upward departure stating that a sentence above the minimum term required by section is an upward departure from the guideline sentence An upward departure may be warranted for example in a case involving a sex offense committed against a minor or if the offense resulted in serious bodily Injury to a minor Sixth section of the Adam Walsh Act added a new mandatory minimum term of imprisonment of years under U.S.C for sex trafficking of an adult by force fraud or coercion In response the amendment provides a new base offense level of in Promoting a Commercial Sex Act or Prohibited Sexual Conduct with an IndMdual Other than a Minor if the offense of conviction is U.S.C but retains a base offense level of for all other offenses In addition the amendment limits application of the specific offense characteristic at that applies if the offense Jnvolved fraud or coercion only to those offenses receiving a base offense level of Offenses under U.S.C necessarily involve fraud and coercion and therefore such conduct is built Into the heightened base offense level of This limitation thus avoids unwarranted double counting Seventh section of the Adam Walsh Act added a new mandatory minimum term of imprisonment of years under U.S,C for sex trafficking of children under years of age and added a new mandatory minimum term of imprisonment of years and increased the statutory maximum term of Imprisonment from years to life under u.s,c for sex trafficking of children who had attained the age of years but had not attained the age of years Further the Adam Walsh Act Increased the mandatory minimum term of imprlsonment from years to years and Increased the statutory maxlmum term of Imprisonment from years to life under both for persuading or enticing any person who has not attained the age of years to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense and u.s.c a for transporting a person who has not attained the age of years In Interstate or foreign commerce with the Intent that the person engage in prostitution or in any sexual activity for which any person can be charged with a criminal offense In response the amendment provides alternative base offense levels in Promoting a Commercial sex Act or Prohibited Sexual Conduct with a Minor Transportation of Minors to Engage In a Commercial Sex Act or Prohibited Sexual Conduct Travel to Engage in Commerclal Sex Act or Prohibited Sexual Conduct with a Minor Sex Trafficking of Children Use of Interstate Facllities to Transport Information about a Minor based on the statute of conviction and the conduct described in that conviction For convictions under U.S.C the base offense level is For convictions under U.S.C the base offense level is The amendment further provides a base offense level of for convictions under 1B u,s,c and a The two-level enhancement for the use of a computer at applied to percent of offenders convicted under U.S,C and sentenced under in fiscal year In addition the two-level enhancement for the offense involving a sexual act or sexual contact at applied to percent of offenders convicted under U,S.C a and sentenced under thls guideline in fiscal year With application of either enhancement the mandatory minimum term of imprisonment of months will be reached In the majority of convictions under lB U,S.C and a before application of other guidelines adjustments Further the amendment addresses the interaction of two specific offense characteristics with the alternative base offense levels First every conviction under U.S.C necessarily involves a commercial sex act With the base offense levels being determined based on the statute of conviction the amendment clarifies that which provides a two-level enhancement if the offense involved a commercial sex act does not apply if the defendant Is convicted under U.S.C Second the amendment precludes application of the age enhancement in if the base offense level is determined under subsection a of for a conviction under U,S.C The base offense level provided by subsection a of takes into account the age of the victim and therefore limitations on application of subsections and of avoid unwarranted double counting Eighth section of the Adam Walsh Act created a new section U.S,C adopting new recordkeeping obligations for the production of any book magazine periodical film videotape or digital Image that contains a visual depiction of simulated sexually explicit conduct Section has a statutory maximum of one year imprisonment for the failure to comply with the recordkeeping requirements and a statutory maximum term of Imprisonment of five years if the violation was to conceal a substantive offense that involves either causing a minor to engage in sexually explicit conduct for the purpose of producing a visual depletion or trafficking in material Involving the sexual exploitation of a minor The new offense is similar to lB U.S.C which is referenced to Recordkeeping Offenses Involving the Production of Sexually Explicit Materials Fallure to Provide Required Marks in Commercial Electronic Mail Accordingly the amendment refers the new offense to Ninth section of the Adam Walsh Act created a new offense in U,S,C that prohibits engaging In chlld exploitation enterprises defined as violatlng U.S.C l2.Q.l Jf the victim is a minor chapter Involving a minor victim chapter except for u.s,c and or chapter Involving a minor victim as part of a series of felony violations constituting three or more separate incidents and involving more than one victim and committing those offenses in concert with three or more other people The statute provides a mandatory minimum term of imprisonment of years The amendment creates a new guideline at Child Exploitation Enterprises to cover this new offense The guideline provides a base offense level of JS and four specific offense characteristics The Commission anticipates these offenses typically will involve conduct encompassing at least one of the specific offense characteristics resulting in an offense level of at least level Thus the mandatory minimum term of imprisonment of months typically is expected to be reached or exceeded before appllcatlon of other guideline adjustments Tenth section of the Adam Walsh Act increased the statutory maximum term of imprisonment from years to years under U,S,C for knowingly using a misleading domain name with the Intent to deceive a minor into viewing material harmful to minors on the Internet In addition section of the Act created a new section U.s.c that carries a statutory maximum term of imprisonment of years for knowingly embedding words or digital images into the source code of a Web site with the intent to deceive a person into viewing material constituting obscenity Section carries a statutory maximum term of imprisonment of years for knowingly embedding words or digital images into the source code of a Web site with the intent to deceive a minor into viewing material harmful to minors on the Internet In response to the new offense the amendment expands the scope of subsection of Importing Mailing or Transporting Obscene Matter Transferring Obscene Matter to a Minor Misleading Domain Names by adding to this enhancement embedded words or dig Ital images into the source code on a Web site Eleventh section of the Adam Walsh Act added a new provision in U,S.C that carries a statutory maximum term of imprisonment of years for falsifying or covering up by any scheme or making materially false or fraudulent statements or making or using any false writings or documents that relate to offenses under chapters and and under section of chapter The amendment adds a new speciflc offense characteristic at subsection A of Obstruction of Justice enhancing the offense level by four levels if the defendant was convicted under u.s.c l.QQ.l and the statutory maximum term of years Imprisonment applies because the matter relates to sex offenses The amendment also added language to Application Note stating an upward departure may be warranted under the guideline in a case involving a particularly serious sex offense Twelfth section of the Adam Walsh Act added 1s u.s.c to the 1st of offenses for which a defendant is to be sentenced to life under u.s.c Al The amendment adds 1a u.s.c to the list of instant offenses of convictions that are covered sex crimes under Thirteenth section of the Adam Walsh Act amended U.S.C and The amendment adds a new subdivision to a of and to a of to requlre a defendant to comply with the new registration requirements provided by the Adam Walsh Act The amendment also modlfies the language in a and a relating to defendants convicted of a sexual offense described in U.S,C Not all states have implemented the new requirements continuing to register sex offenders pursuant to the sex offender registry in place prior to July the date of enactment of the Adam Walsh Act Thus it ls necessary to maintain the language in the guidelines providing for conditions of probation and supervised release for those offenders Fourteenth section of the Act amended U.S,C which provides that the authorized term of supervised release for any offense under enumerated sex offenses is any term of years or life In response the amendment adds offenses under chapter and sections and of title Unjted States Code or u.s.c and lli.l to the definition of sex offense under for which the length of the term of supervised release shall be not less than the minimum term of years specified for the offense and may be up to life finally the amendment provides a definition of minor In relevant guidelines that is consistent with how this term ls defined elsewhere in the guidellnes Outdated background commentary also is deleted by this amendment The effective date of this amendment is November Bradley Edwards Partner Rothstein Rosenfeldt Adlerj Attorneys at Law Las Olas City Centre East Las Olas Boulevard Suite Fort Lauderdale FL facsimile bedwards rra-law.com H;,licy Edwa1ds009065"eMni1Contenthlm From csarnoffl verizon.net Se:nt Sep To Bradley Edwards Cc Bee Subject Visas Please read this important I think you can offer a trafficked victim protection asylum and an incentive for coming forward on the case Ask your clients if they know of any victims who were foreign so they can tell them about this and assuage their fears This is a break through for some of the girls because theyll be able to bring their families into the US on these visas According to Acosta some visas are issued annually and the last time he checked only apply annually That means that the word is NOT out about the visas on purpose may I add and furthe1more that there is ZERO effort on the part of law enforcement to get it out fear of having visa abused More importantly How are you feeling Hope youre healing quickly Conchita Congress passes Violence Against Women Act of20 Immigrants Rights Update VoL No October Passed by Congress on Oct the Victims of Trafficking and Violence Protection Act of H.R includes the Violence Against Women Act of VAWA which expands and improves on the protections for battered spouses and children that were originally enacted in the Violence Against Women Act of VAWA Most notably VA WA eliminates the extreme hardship requirement for self-petitioners and allows all self-petitioners to adjust their status in the United States The act also creates two new nonimmigrant visas for victims of trafficking and for victims of certain serious crimes including victims of crimes against women see Congress Creates New and Visas for Victims of Exploitation Individuals granted these visas may subsequently adjust to permanent resident status The bill passed both houses by enom10us margins in the House and in the Senate and President Bill Clinton has promised to swiftly sign it VA WA The original VA WA included provisions to address the particular problems faced by battered immigrant women and children Under pre-VA WA immigration law immigrant spouses and children of U.S citizens or lawful permanent residents LPRs were dependent on the citizen or LPR to petition to immigrate them and this dependency left them particularly subject to abuse on the part of that relative The VA WA created a procedme whereby abused spouses and their children or abused children and their parents can self-petition to obtain LPR status without the cooperation of the abusing relative The VA WA also enabled battered spouses and children to obtain suspension of deportation or cancellation of removal if they were present in the U.S for at least three years rather than file:/ClfDocun,ents 20and 20Scltings/frial/Oesktop/E I of O:OI PM l3nulley Edwards009065"eMai1Contcnt.htm the seven years normally required for suspension or ten years for cancellation Obstacles based on family/marital status removed VA WA removes a nuniber of obstacles that battered spouses and children have encountered in attempting to use provisions of the VA WA intended to help them For example a battered spouse whose maniage is defective because her husband failed to tell her that he was already married is not eligible to immigrate under VA WA VA WA corrects this problem by allowing individuals who believed that they were married to a U.S citizen or PR to self-petition VA WA also allows individuals to self-petition even though they have been divorced from the citizen or LPR provided that the marriage tenninated within the past two years and a connection between the termination of the marriage and the abuse of the immigrant can be shown These changes also apply to VA WA suspension of deportation and cancellation ofremoval Moreover individuals may self-petition even if the citizen relative has died provided they petition within two years of the death No need to leave U.S to apply for VA WA visa The new law allows all VA WA self-petitioners to apply for adjustment of status in the United States regardless of whether they were inspected when they entered the country or whether they subsequently maintained lawful status Extreme Hardship and other requirements for VA WA self-petitioners The act also eliminates the disparate treatment of self-petitioners who under prior law had to meet certain requirements not applied to regular family immigrant visa applicants Most significantly self-petitioners no longer need to show that their deportation would cause extreme hardship This eliminates an enormous evidentiary hurdle from the self-petition procedure The law also allows abused spouses and children of U.S employees and military personnel living abroad to self-petition Under the new law if the U.S citizen or LPR parent or spouse subsequently loses that status for reasons related to their abusive conduct the loss does not affect the abused immigrants eligibility to immigrate if they petition within two years Moreover abused immigrants with approved self-petitions may remany without causing the petition to be revoked Good moral character Self-petitioners under the new law still must show that they have good moral character However the new law partially exempts them from the bar establishing good moral character outlined in INA section l0l Under that provision immigrants cannot establish good moral character if they have committed or been convicted of certain criminal acts The new law removes the bar if the act constitutes a ground of admissibility or deportability that is waivable and the act was connected to the abuse the applicant suffered This rule also applies to applicants for VA WA suspension or cancellation Children who age out Under the act children who have filed a self-petition or are derivative beneficiaries of a parents petition no longer age out or become subject to normal family visa rules when they become years old Instead they are treated as self petitioners under the appropriate category as unmarried sons or daughters of U.S citizens or LPRs or married sons or daughters of citizens with the parents priority date Iii c:/CVoocmncnl5 on/e Docs/eMail/Bn!dley of I IO I I I PM Brndlcy _Edward 009065"cMai1Concenthtnt Relaxed continuous physical presence requirement The act allows applicants for VA WA cancellation of removal to show that they have three years continuous physical presence in the U.S despite a single absence longer than days or cumulative absences exceeding days if there is a connection between the absence and the abuse perpetrated against the applicant The act also eliminates application of the stop:"time rule under which service of a Notice to Appear stops the accrual of continuous physical presence in VA WA cancellation and suspension cases And it requires the attorney general to parole the children or parents of individuals who are granted VA WA suspension or cancellation Motions to reopen The act allows individuals who become eligible for VA WA suspension or cancellation because of the changes made by the new law to move to reopen their proceedings It also amends the INAs time limitations on motions to reopen allowing individuals to file a motion to reopen to apply for VA WA cancellation within one year of the entry of a final order The attorney general may also waive the one-year limitation in cases of extraordinaiy circumstances or extreme hardship to a child New waivers of grounds of inadmissibility and deportability The act establishes waivers of certain grounds of inadmissibility for abused immigrants There is a waiver of the ground of inadmissibility for reentering the U.S without inspection following a one-year period of unlawful presence or after having been ordered removed This waiver is available to individuals who can establish a connection between the abuse they suffered and their departure or reentry There is also a waiver of the ground of deportability for having a conviction for a crime of domestic violence or for violation of a protective order if the abused immigrant can show that she was not the primary perpetrator of violence in the relationship She must also show that she was acting in self defense or that the crime did not result in serious bodily injury and was connected to the abuse that the immigrant suffered The act makes available to abused immigrants the INAs waivers for certain criminal grounds fraud or misrepresentation i and health grounds Expanding the availability of these waivers was considered necessary because they had been limited to spouses of U.S citizens or LPRs Abused immigrants may no longer have such a relationship Public charge The act amends the public charge ground of exclusion to provide that cash or other benefits received pursuant to U.S.C section which pem1its VAWA beneficiaries to obtain cash and other government assistance in connection with their escape from domestic violence may not be considered in public charge determinations Changes to Cuban Adjustment Act NACARA and HRJFA The act also amends the Cuban Adjustment Act the adjustment of status provisions of the Nicaraguan Adjustment and Central American Relief Act NACARA and the Haitian Refugee Immigration Fairness Act HRIFA These amendments allow abused spouses or children who are dependents of individuals eligible for relief under these laws to adjust their status without having to reside with the principal or maintain the relationship Under the act persons who become LPRs through VA WA may also apply for naturalization after they have resided in the U.S in LPR status for three years file:/f/CVDocuments 20and 20Sellingsfrri11I/De ktoplE on/cDocs/eMail/Brndley _Edwards009065"cM ailContcnt.htm or IO I I I PM oV rgo Ĺ?F U?r JX A c?z?Ӻc 9U?u pI Hr iv FFZ Ѝ?W?Q??FU?d Š?𢤃?K?F H9P L?V?S u?H SL 8?xs?j fK K1?SL M?tY Ќ?K ؿKZ?ǐ_Y D??v QEh A??HA8 u?F 漊j ų?W sx YQ OϏ h5??yk gF4 Aj L?zX?E4 PCř Uc Ae f?J t?Hh?n AԹhj sz e?l iS K?Nťh T??y r9 1eH 8F I A qF Xb Oҹ HC HI?nc??F Zc H?3j?U _v?BF!?Q?ŏc SAI?w p??Wk a?k⑾?d?Cj?Gu fM?uw ߩJ??u ðnw v??ݖ I jF y?i6s Tu o?Ch X?U Zc?-(?Vj Pa?ϲ?l?Z Uvk H??X 2e g?ϗ WG Y둂 臸Y wR m??T0qj I5WB?3 R?Z mP m"?ô i shXp?pn O?R?I u??E??YO??NS zN J,?M bI"??s??ea?J?K k??H U?J??μϪ T?U??q Q?Ƨ?O _7 bTz!??w ll1aJley cMai1Co11tenl.hlm Sep PM bedwards rra-law.com wrote Long day I will call you tomorrow Client went through hell today Original Message From csamoffl verizon.net mailto:csarnoffl verizon.net Sent Thursday September AM To Bradley Edwards Subject Not a mention of the name after a hour interview Sent via BlackBerry from T-Mobile file:/QIDocumenls 20and 20Seuings/TriaVOesktop/E of I IO I PM Bradley_ EdwardsO I 276Mai1Content.htm From Michele Dargan Sent Jul To Bradley I Edwards Cc Bee Subject Re Epstein Brad We have no way of getting the members or the ba1med members lists However I spoke to Donald Tmmp today nothing like getting it from the horses mouth Anyway he said Epstein is not a member and would not confirm or deny that he ever was a member He would not comment at all which is very rare for him on whether or not Epstein got booted from the club or if he had recruited girls from Mar-A Lago Sorry I couldnt be more help I really thought that he would say something He usually does comment for all of our stories Thats why this was quite unusual If you get any info please pass it on like if any info comes out during depos of anything related to Epstein getting booted from the club or about him recmiting girls from there You know I will run with it Michele On AM Bradley Edwards wrote Hi Michele I was wondering if you were able to get a members list at the Maralago and even more importantly if you were able to get a list of banned members from the Maralago Rumor has it that he was banned for having sex with and attempting to have sex with minors at the club and we already know of ce11ain minors that he took from the club to his house I will take a deposition of someone there if we need to do that to get the true information on this but there are so many depositions to take in this case and we are setting them right now around the country that I would like to avoid this one if we could get the info another way Thanks Bradley Edwards Partner file./Clf oeuincnl 20and 20Settingsffrinl/DeskmplE I of2 PM Bradley _Edwards i 7032"cMai1ContenLlum Rothstein Rosenfeldt Adlert Attorneys at Law Las Olas City Centre East Las Olas Boulevard Suite Fort Lauderdale FL facsimile bedwards na-law.com Michele Dargan staff writer Palin Beach Daily News phone fax file:/CVOocumentso 27420Settingsffrial/Desktop/E on/cOoc!l.leMail/Br11dley _EdwardsD 7032"1:MailContent him of I to I Ml Bradley _Ed wards0 I I 29"eMailConlcnthtm From Michele Dargan Sent Jul To Bradley Edwards Cc Bee Subject Re Epstein Brad I didnt get your e-mail until I got in this morning Friday so it was too late you did mean it took place this morning right Anything interesting On PM Bradley Edwards wrote Michele I forgot to tell you that I have a hearing in Hafeles courtroom lB I think at on our motion to add punitive damages Should be some interesting things said for you Things that have not been said before Bradley Edwards Partner Rothstein Rosenfeldt Adler Attorneys at Law Las Olas City Centre East Las Oas Boulevard Suite Fort Lauderdale FL facsimile bedwarcls rra-Iaw.com From Michele Dargan mailto:mdargan pbdailynews.com Sent Wednesday July PM To Bradley Edwards Subject Re Epstein Brad We have no way of getting the members or the banned members lists filc:/I/CVDoc11menl!1 20ond 2762DSctting.efrrial/Desl on/eDocs/cl llQil/Br11dfcy _Edw-JrdsOl MailContent.htm of I PM IJradlcy _ELlwJrdsO I 7129"eMailCoolcnl him However I spoke to Donald Trump today-nothing like getting it from the horses mouth Anyway he said Epstein is not a member and would not confirm or deny that he ever was a member He would not comment at all which is very rare for him on whether or not Epstein got booted from the club or if he had recruited girls from Mar-A-Lago Sorry I couldnt be more help I really thought that he would say something He usually does comment for all of our stories Thats why this was quite unusual If you get any info please pass it on Jike if any info comes out during depos of anything related to Epstein getting booted from the club or about him recruiting girls from there You know I will tun with it Michele On AM Bradley Edwards wrote Hi Michele I was wondering if you were able to get a members list at the Maralago and even more importantly if you were able to get a list of banned members from the Maralago Rumor has it that he was banned for having sex with and attempting to have sex with minors at the club and we already know of certain minors that he took from the club to his house I will take a deposition of someone there if we need to do that to get the true information on this but there are so many depositions to take in this case and we are setting them right now around the country that I would like to avoid this one ifwe could get the info another way Thanks Bradley Edwards Partner Rothstein Rosenfeldt Adler Attorneys at Law Las Olas City Centre East Las Olas Boulevard Suite Fort Lauderdale FL facsimile bedwards 1Ta-law.com file:!//CVDocurncnls 2Dund 20Sellingsffri1/Desk10pli!a on/eDocs/eMnil/Bradley _EdwordsO 29"eMailConlenLhlm of I I 6ll.O IO I I P.MJ Icy j,JwardsO Ii I 29"cMai1Contenthlm Michele Dargan staff writer Palm Beach Daily News phone fax file:/CVDocuments 20und 20Sclling:;ffrial/Desklop/E MoilC lt lent.hhn of I PM Brno Icy_ Edwards020726"cMailConlcnthtm From Bradley Edwards Sent Jul To Michele Dargan Cc Bee Subject RE Epstein Thank you We have our answer then All the pieces are public record Complaint filed by Josephsberg regarding Epstein being at the club with Ghislaine Maxwell and taking a year old home with him a newspaper article that indicated he was banned for similar conduct dont remember who published it but I read it a few months back and a no comment from Trump Hes banned Dont worry we will get the official word We are setting many depositions soon and certain people that will be set will know that information I will keep you informed Good work Ill be in touch Bradley Edwards Partner Rothstein Rosenfeldt Adler Attorneys at Law Las Olas City Centre East Las Olas Boulevard Suite Fort Lauderdale FL facsimile bedwards 267a-law.com From Michele Dargan mailto:mdargan pbdailynews.com Sent Wednesday July PM To Bradley Edwards Subject Re Epstein Brad filc:lf/CVDocuments 20on 20Setlings/T rial/Dca:top/E on/cDocs/eMail/Brodley of IO I PMJ i I I We have no way of getting the members or the banned members lists However I spoke to Donald Trump today nothing like getting it from the horse mouth Anyway he said Epstein is not a member and would not confom or deny that he ever was a member He would not comment at all which is ve1y rare for him on whether or not Epstein got booted from the club or if he had recruited girls from Mar-A-Lago Sorry I couldn be more help I really thought that he would say something He usually does comment for all of our stories Thats why this was quite unusual If you get any info please pass it on like if any info comes out during depos of anything related to Epstein getting booted from the club or about him recruiting girls from there You know I will run with it Michele On AM Bradley Edwards wrote Hi Michele I was wondering if you were able to get a members list at the Maralago and even more importantly if you were able to get a list of banned members from the Maralago Rumor has it that he was banned for having sex with and attempting to have sex with minors at the club and we already know of certain minors that he took from the club to his house I will take a deposition of someone there if we need to do that to get the true information on this but there are so many depositions to take in this case and we are setting them right now around the country that I would like to avoid this one if we could get the info another way Thanks Bradley Edwards Partner Rothstein Rosenfeldt Adlerl Attorneys at Law Las Olas City Centre East Las Olas Boulevard Suite Fo11 Lauderdale FL facsimile bedwards rra-law.com filc://ICVDocume11ts 20and 20ScUings/Trial/Deslt;top/E on/eDocs/eMail/Brodley of3 I I PM i Michele Dargan staff writer Palm Beach Daily News phone fax fild//Cj/Doc11mcnts on/el lCS eMailffirodley_ Edvmrds020726"eMai1Coment.htm of I IO I I I JO PM Uro.Jli,y _Ed1rds0207J2"eMuiJContenl.htm From Bradley Edwards Se Jul To Michele Dargan Cc Bee Subject RE Epstein Michele I forgot to tell you that I have a hearing in Hafeles courtroom I think at on our motion to add punitive damages Should be some interesting things said for you Things that have not been said before Bradley Edwards Pmtner Rothstein Rosenfeldt Adlerj Attorneys at Law Las Olas City Centre East Las Olas Boulevard Suite Fort Lauderdale FL facsimile bedwards rra-law.com From Michele Dargan mailto:mdargan pbdailynews.com Sent Wednesday July PM To Bradley Edwards Subject Re Epstein Brad We have no way of getting the members or the banned members lists However I spoke to Donald Trump today nothing like getting it from the horses mouth t"ile:l/fCVDoeuments 20and 276ZOScttings/Trial/De5klop/l I or I I I I JO PM le lo I I Brnd Icy_ Ed wnrds020732"cMai1ConlcnL.hlm Anyway he said Epstein is not a member and would not confirm or deny that he ever was a member would not comment at all which is very rare for him on whether or not Epstein got booted from the club or if he had recruited girls from Mar-A-Lago Sony I couldn be more help I really thought that he would say something He usually does comment for all of om stories Thats why this was quite unusual If you get any info please pass it on Jike if any info comes out during depos of anything related to Epstein getting booted from the club or about him recruiting girls from there You know I will mn wit it Michele On AM Bradley Edwards wrote Hi Michele I was wondering if you were able to get a members list at the Maralago and even more importantly if you were able to get a list of banned members from the Maralago Rumor has it that he was banned foJ having sex with and attempting to have sex with minors at the club and we already know of certain minors that he took from the club to his house I will take a deposition of someone there if we need to that to get the true information on this but there are so many depositions to take in this case and wear setting them right now around the country that I would like to avoid this one if we could get the info another way Thanks Bradley Edwards Partner Rothstein Rosenfeldt Adler Attomeys at Law Las Olas City Centre East Las Olas Boulevard Suite Fort Lauderdale FL facsimile bedwards rra-law.com Michele Dargan staff writer file:/Cj/DocumcnLl 20and t!ings/Trial/OcskloplE oit/cDoc,,/cMuil/Bradley _EdwordS020732"eMoilContcnthtm of PMl _I i i v.u us020732"cMailCu1enl.h1m Palm Beach Daily News phone fax Jile:/IICVDocumen1s 20and 20Set1ingsffriol/Desl;1op1e him of I I lO PM UNlTED STA TES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV-80119-MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant Related cases I ORDER This cause is before the Court upon Plaintiff Jane Does Motion for Injunction Restraining Fraudulent Transfer of Assets Appointment of a Receiver to Take Charge of Property of Epstein and to Post a Million Bond to Secure Potential Judgment DE Defendant Jeffrey Epstein filed a response in opposition to the motion DE and Plaintiff filed a reply DE The motion is now fully briefed and ripe for review Plaintiffs motion argues that Defendant is fraudulently transferring his assets with the specific intent to defeat any judgment that might be entered against him in this and other similar cases Plaintiff therefore seeks an order enjoining Defendant from fraudulent transfers of his assets appointing a receiver to take charge of Defendants property and requiring Defendant to post a million dollar bond against any potential judgment in this case EXHIBITU The relief sought by Plaintiff is injunctive and essentially amounts to a prejudgment writ of attachment Rosen Cascade Intern Inc F.3d Cir vacating district courts preliminary injunction freezing defendants assets No relief of this character has been thought justified in the long history of equity jurisprudence De Beers Consol Mines Ltd United States U.S Preliminary injunctive rehef freezing a defendants assets in order to establish a fund with which to satisfy a potential judgment for money damages is simply not an appropriate exercise of a federal district courts authority Rosen F.3d at Indeed iJt is entirely settled by a long and unbroken line of Florida cases that in an action at law for money damages there is simply no judicial authority for an order requiring the deposit of the amount in controversy into the registry of the court or indeed for any restraint upon the use of a defendants unrestricted assets prior to the entry of judgment Id at quoting Konover Realty Assoc Ltd Mladen So.2d Fla 3d DCA In Florida an injunction cannot be entered to prevent a party from using or disposing of his assets prior to the conclusion of a legal action Briceno Bryden Investments Ltd So.2d Fla 3d DCA See also SM Racks Inc Sistemas Mecanicos Para Electronica S.A Fed.Appx th Cir affirming districts courts denial of preliminary injunction to freeze defendants assets Proctor Eason,651 So.2d Fla 2d DCA Defendant not required to deposit funds in court registry prior to final judgment where Plaintiff failed to show unavailability of an adequate remedy at law and the likelihood of irreparable hann two elements essential to entry of an injunction Lawhon Mason So.2d Fla 2d DCA quashing trial court order requiring defendant to give plaintiffs ten days notice prior to the transfer of any assets in excess of Additionally as the Eleventh Circuit explained in Rosen ln actions at law plaintiffs in Florida possess an adequate exclusive prejudgment remedy for the sequestration of assets under the attachment statute Fla Stat.Ann West provided that they can satisfy the enumerated statutory grounds for relief Accordingly the use of injunctive relief as a substitute for the remedy of prejudgment attachment with its attendant safeguards is improper 3d at emphasis added Here Plaintiff did not move to amend her complaint to allege a claim under the Florida Uniform Fraudulent Transfers Act FUFT A Fla Stat et seq Rather she filed the present motion for injunctive relief Even if she had moved to amend her complaint it is certainly not clear that she could meet the required statutory elements Plaintiffs motion is premised on the contention that Defendant is fraudulently transferring his assets However Plaintiffs motion is entirely devoid of evidence of Defendants alleged fraudulent transfers The Court declines to conclude that Defendant is fraudulently transferring assets based upon the adverse inferences relied upon by Plaintiff Plaintiffs supplemental filing regarding the titles of approximately five of Defendants vehicles is clearly de minimis particularly in light of Plaintiffs repeated characterization of Defendant as a billionaire Based upon the foregoing it is hereby ORDERED AND ADJUDGED that Fraudulent transfer claims under Florida law arise under the Florida Uniform Fraudulent Transfers Act FUFTA Fla Stat I et seq FUFTA as set forth in Florida Statute provides the substantive requirements that must be pied to state a valid fraudulent transfer claim Nationsbank N.A Coastal Utilities Inc So.2d Fla Dist Ct App The plaintiff must show that there was a creditor to be defrauded a debtor intending fraud and a conveyance of property which could have been applicable to the payment of the debt due Id Plaintiff Jane Does Motion for leave to Provide Recently-obtained Deposition Testimony and Affidavit DE in is GRANTED Plaintiff Jane Does Motion for Injunction Restraining Fraudulent Transfer of Assets Appointment of a Receiver to Take Charge of Property of Epstein and to Post a Million Bond to Secure Potential Judgment DE in I is DENIED DONE AND ORDERED in Chambers at West Palm Beach Palm Beach County Florida this th day of November Copies to all counsel of record Fron TOI Subjact1 D11tei a,ra HA mc Bradley fdY rds Strategy Wednesd;iy July PM I think our best bet is to go after those dose to Epstein EXHIBITV IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY FLORIDA CASE NO RAZORBACK FUNDING LLC et al Plaintiffs vs SCOTT ROTHSTEIN et al Defendants DAY AFTERNOON SESSION DEPOSITION OF SCOTT ROTHSTEIN DATE TAKEN Monday December p.m p.rn TIME PLACE N.E Fourth Street Miami FL Taken on Behalf of Razorback Examination of the witness taken before Terri Wright United Reporting Inc Southeast Third Avenue Fort Lauderdale Florida United Reporting Inc EXHIBITW Page Page funds that were supposed to be held in trust A It was simply what Frank and I had the whole reason it stayed in Mr Preve and I discussed from time to time the fact that anything we could do to add additional levels of security for the investors was good So it stayed in the package unless someone said they didn want it Now the Epstein settlements were used by you based on actual cases with Jeffrey Epstein A Yes on that J?alm Beach person A Yes Do you recall that A Yes And do you recall that my clients were investors who invested in that A I do That would be Discala and Von A1lmen and other people of the Razorback group A I do Do you recall when they came to your office and you brought down boxes for Michael Legamaro to review A The boxes were actually already in my office Well theres some testimony that you called and asked Ken Jenne and Fistas to bring them down and they United Reporting Inc Page brought down boxes for you at a show as to show these are the real cases A I believe that a substantial number of the boxes were already in my office And there were additional boxes and I did have people bring them to me I dont remember who brought them to me but yes And do you recall Mr Lega.maro what he did with respect to his review of those boxes of the cases A I recall bringing the boxes in the only real recollection I have of that meeting was after meeting with them and bringing the boxes in I walked out for a period of time let them go through the boxes came back in answered questions that they had and we went forward You pulled out some kind of a flight manifest do you recall that A Yeah At some point in time I believe it was either Brad Edwards or Russ Adler pointed out to me that one of the pieces of evidence they were UBing in the actual case was the flight manifest And I actually used that to make a fairly big show I found that those most of the time in these cases the more significant our underlying investigation was and the more tantalizing it was the more interested the investors got We had that real piece of evidence and we used it to our advantage to attempt to secure the investor United Reporting Inc manifest A A Page Did Russ help you make it more tantalizing that Did he help me Did he help you make it more tantal zing1 The only way Russ would have helped me make it more tantalizing was by just discussing the size of the case But other than that no he didnt do anything that I recall during that meeting with regard to the actual manifest I did Didnt you add some sensational names to the manifest that weren there to start with1 A A I did I did Tell us about that There were I said that there were additional manifests if I remember correctly I said there were additional manifests that we had discovered containing Bill Clintons name Prince Andrew all being shown flying with young girls on the plane And do you know whether let me baok up The original manifests that were in evidence in the real case didn have those names on it A No but its interesting you bring that up because the way I came up with Bill Clinton and Prince Andrew was Mr Adler and Mr Edwards both told me on different occasions that the reason the case when we United Reporting Inc Page were discussing the actual real case the reason it was becoming so quote unquote tasty because they had information that he had been flying Bill Clinton around and Prince Andrews around the piece that was missing from the real case was the connection to the young girls The young girls connection to the young girls was fiction it was a lie A Not as far as Mr Epstein is concerned but as far as the other people are concerned yes Do you know whether Ad1er Mr Adler or Mr Edwards injected any of that into the depositions in the real case in order to assist with the Ponzi A I dont know No no I dont know whether they did that or not I wouldnt think they would When you were asked this morning about Brad Edwards you really hesitated I dont know if you know you did that You were answering yes no maybe so On him you really paused A On the question as whether or not he would have turned us in you mean Whether he was a player or whether he was invo1ved and you didnt quite answer A Just because of the way I knew Brad and socialized with him I did not know that he was at that level There are certain people Barry Stone second he United Reporting Inc Page found out about it would have absolutely done what was appropriately supposed to do from an ethical standpoint And then there were people who I would say would never do that And then there are people in the middle I believe Brad Edwards is probably in the middle Did you have your investigators that be Jenne and Wayne Black and Fistas investigate Epstein himself and try to get evidence from Epstein A I didnt know do you have of any knowledge of that A No sir Did you instruct them to file any kind of pleadings in federal Court or anything like that in order to help you promote the Ponzi A No As far as the Epstein case is concerned Mr Scherer I never asked Mr Adler or Mr Edwards or anyone else associated with that case to do anything for the purpose of furthering the Ponzi other than bring me the boxes That was all my creation Thank you Im going to talk to you about Ted Morse a little bit You said he was one of your best friends he was one of your intercircle A Correct United Reporting Inc JEFFREY EPSTEIN Piaintiff/Cowiter-Defendant vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually Defendant/Counter-Plaintiff IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No CA __ AFFIDAVIT OF JEFFREY EPSTEIN The undersigned Jeffrey Epstein having first been duly swom hereby deposes and says I am over eighteen years old and have personal knowledge of the facts stated herein I am the Counter-Defendant in the above captioned action the Action and submit this Affidavit in support of my Motion for Summary Judgment the Summary Judgment Motion with respect to the Fourth Amended Counterclaim the Counterclaim of Counter-Plaintiff Bradley Edwards Edwards1 In the Counterclaim Edwards has asserted unsupported claims against me for Abuse of Process and Malicious Prosecution As more fully described below at the time that I commenced the Action against Edwards and Scott Rothstein Rothsteint in December I had a good faith basis for filing the same based on the facts that existed at the time I filed suit as set forth below and more fully in my Summary Judgment Motion I filed the Action against Rothstein and Edwards because based on the facts described below and in the Summary Judgment Motion I believed at the time of filing my original Complaint that these two individuals and other unknown partners of theirs at Rothstein Rosenfeldt Adler RRA engaged in serious misconduct involving a widely publicized illegal Ponzi scheme operated through their law firm the Ponzi Scheme that featured the very civil cases litigated against me by Edwards which were being used to defraud potential investors in the Ponzi Scheme In early November stories in the press on the news and on the internet were legion about the implosion of RR.A the Ponzi Scheme perpetrated at that tinn and the misuse in the Ponzi Scheme of certain civil cases then being litigated against me by RRA partner Edwards Toe cases Edwards was litigating against me which are described in the Summary Judgment Motion the Epstein Cases were being used to defraud investors out of millions of dollars and to fund the RR.A Ponzi Scheme In November I also became aware of news stories that as a result of the Ponzi scheme at RRA the Florida Bar had commenced investigations into over one half of the attorneys employed by RRA At or about the same time in November I also became aware that the law finn of Comad Scherer filed a Complaint against Scott Rothstein and others Razorback Funding LLC et al Scott Rothstein et al Case No hereinafter referenced as the Razorback Cornplaine on behalf of some of the Ponzi Scheme investors Upon reviewing the Razorback Complaint I learned that the Razorback Complaint detailed the use of the Epstein Cases i.e the cases being litigated against me by Edwards to defraud investors in the Ponzi Scheme including but not limited to improper discovery practices and other methods to bolster the cases Prior to my filing the initial Complaint in the Action I also became aware that the Federal government filed an Information against Scott Rothstein which included allegations of RRA as an Enterprise in which Rothstein and his yet unidentified co conspirators engaged in a racketeering conspiracy money laundering conspiracy mail and wire fraud conspiracy and wire fraud and specifically alleged that a potential investors were told by Rothstein and other co-conspirators that confidential settlement agreements were available for purchase settlements were allegedly available in amounts ranging from hundreds of thousands of dollars to millions of dollars and could be purchased at a discount and repaid to the investors at face value over time Rothstein and other co-conspirators utilized the offices of RRA and the offices of other co-conspirators to convince potential investors of the legitimacy and success of the law firm which enhanced the credibility of the purported investment opportunity Rothstein and other co-conspirators utilized funds obtained through the Pomi Scheme to supplement and support the operation and activities of RRA to expand RRA by the hiring of additional attorneys and support staff to fund salaries and bonuses and to acquire larger and more elaborate office space and equipment in order to enrich the personal wealth of persons employed by and associated with the RRA Enterprise Prior to filing the initial Complaint in the Action consistent with the allegations made by the press in the Razorback Complaint and in the Rothstein Infonnation it was clear that the activity in the Epstein Cases being litigated by Edwards intensified substantially during the short six months during which Edwards was a partner at RR.A from April through the end of October Furthermore during that six month period questionable discovery like that detailed in the Razorback Complaint had taken place in the Epstein Cases being litigated against me by Edwards including Edwards noticing the depositions of famous dignitaries and celebrities such as Bill Clinton Donald Trump and David Copperfield who appeared to have no connection whatsoever to any claims of misconduct made by Edwards clients Equally consistent with the allegations in the press and in the Razorback Complaint that the Epstein Cases were being deliberately misused for purposes unrelated to the litigation in order to lure investors into the Ponzi Scheme is the fact that on July Edwards filed a two hundred tbirtywfour page one fifty-six count federal complaint against me on behalf of a plaintiff LM for whom Edwards was already prosecuting a case against me in state court involving the very same facts alleged in the federal complaint The complaint was filed in federal court but was never served on me or prosecuted leading me to conclude that the only reason it was filed was to enhance the case files shown at the offices of RRA to potential investors in the Ponzi Scheme Also while a partner at RR.A Edwards filed a motion in Federal court in which he requested that the court order me to post a fifteen million dollar bond in the Jane Doe case This case according to the Razorback Complaint was being touted at that same time to investors in the Ponzi Scheme In connection with that motion Edwards filed papers discussing my net worth and filed supplemental papers purporting to list in great detail my vehicles planes and other items of substantial value all at a time when according to the accounts in the press the Information and the Razorback Complaint the Ponzi Scheme was unraveling and the need for new investors in the Ponzi Scheme was becoming urgent The court rejected the Motion cal1ing it 225devoid of evidence The facts set forth above and in the Summary Judgment Motion were the facts upon which I relied in a detennining that I had incurred damages such as attorneys fees and disbursements paid to defend against these actions which appeared to be unrelated to the underlying litigation against me and asserting my causes of action against Edwards and Rothstein in the Action FURTHER AFFIANT SA YITH NAUGHT STATE OF NEW YORK ss COUNTY OF NEW YORK Sworn and subscribed to before me the undersigned authority by Jeffrey Epstein this th day of September LElt.EY GROFF Mic lt of NIW GINlwatCounl CIMIHltl Jul I ul.J Case Jocument Entered on FLSD ooc,.,:t,;il Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA L.M CASE NO 09-CV-81092-Cohn-Seltzer Plaintiff vs JEFFREY EPSTEIN Defendant COMPLAlNT AND DEMAND FOR JURY TRIAL FILED by VT D.C ELECTRONIC July STDN II RIMORt CLUll U.S DIST CT OF FLA MIANI Plaintiff LM hereby sues the Defendant Jeffrey Epstein and states as follows At all times material to this cause of action L.M was a resident of Palm Beach County Florida This Complaint is brought under a fictitious name to protect the identity of L.M because this Complaint makes sensitive allegations of sexual assault and abuse of a then-minor At all times material to this cause of action Defendant Jeffrey Epstein had a mansion located at El Brillo Way Palm Beach Palm Beach County Florida At all times materials to this cause of action Defendant Jeffrey Epstein was an adult male born in Defendant Jeffrey Epstein is currently a citizen of the State of Florida This is substantiated by the residence that he maintains at El Brillo Way West Palm Beach Florida where he spends the majority of his time and intentions to remain at that address permanently are further evidenced by his statements to the Court during Page of EXHIBITT 2al.U4 Case JOcument Entered on FLSD Doc1 Page of his State Plea colloquy on June case number taken before the Honorable Judge Dale Pucillo wherein he indicated that after his release from the Palm Beach County Jail he intends to reside permanently at his home at El Brillo Way West Palm Beach Florida and he plans to work in West Palm Beach Florida as well This Court has jurisdiction of this action and the claims set forth herein pursuant to U.S.C L.M seeks damages in excess of million dollars This Court has venue of this action pursuant to U.S.C as a substantia I part of the events giving rise to the claims occurred in this District STATEMENT OF FACTS Upon information and belief the Defendant Jeffrey Epstein has demonstrated a sexual preference and obsession for minor girls The Defendant Jeffrey Epstein developed a plan scheme and criminal enterprise that included an elaborate system wherein the then-minor L.M was brought to the Defendant Jeffrey Epsteins residence by the Defendant employees recruiters and assistants When the assistants and employees left the then-minor L.M and on some occasions other minor girls alone in a room at the Defendants mansion the Defendant Jeffrey Epstein himself would appear remove his clothing and direct the then-minor L.M to remove her clothing He would then perform one or more lewd lascivious and sexual acts including but not limited to masturbation touching of the then minor Plaintiffs sexual organs coercing or forcing the then-minor L.M to perform oral sex on him using vibrators or sexual toys on the then-minor L.M coercing the Page of ht2M then-mnor L.M into sexual acts with himself or others and digitally penetrating the then-minor L.M He would then pay L.M for engaging in this sexual activity L.M was first brought to the Defendant Jeffrey Epsteins mansion in when she was a fourteen-year old in middle school The then-minor L.M was a vulnerable child without adequate parental support at all times material to this Complaint The Defendant Jeffrey Epstein a wealthy financier with a lavish home significant wealth and a network of assistants and employees used his resources and his influence over a vulnerable minor child to engage in a systematic pattern of sexually exploitive behavior Beginning in approximately August and continuing until approximately the end of October the Defendant Jeffrey Epstein repeatedly coerced induced and/or enticed the impressionable vulnerable and economically deprived then-minor L.M to commit various acts of sexual misconduct and sexually abused L.M These acts included but were not limited to fondling and nappropriate and illegal sexual touching of the then-minor L.M forcing the then-minor L.M into oral sex sexual misconduct and masturbation of the Defendant Jeffrey Epstein in the presence of the then-minor L.M handling and fondling of the then-minor L.M.s sexual organs for the purpose of masturbation and encouraging the then-minor L.M to become involved in prostitution Defendant Jeffrey Epstein committed and conspired with others to commit numerous criminal sexual offenses against the then minor Plaintiff including but not limited to sexual battery solicitation of prostitution coercing a minor into a life of prostitution and lewd and lascivious assaults upon the person of the then-minor LM Defendant Jeffrey Page of Iv ocumfn1"f hteredonFLSD Dockt:C Page of transported L.M and other minors in interstate commerce with the I engage in prostitution and in other sexual activity for which he and charged with criminal offenses Defendant Jeffrey Epstein also ans of interstate commerce to knowing persuade and induce minors engage in prostitution and other sexual activity for which he and arged with criminal offenses ldition to the direct sexual abuse and molestation of the then-minor leffrey Epstein instructed coerced and otherwise induced the then I him numerous other minor girls some as young at years old for further satisfying his deviant sexual attraction to mlnors and for lution On information and belief Epstein sexually abused hundreds ugh his recruiting system Defendant Jeffrey Epstein used his I power to unduly and improperly manipulate and influence the then tg him these other minor girls for purposes of prostitution and in ey This influence led the then-minor L.M away from the life of a child and into a delinquent lifestyle This conduct also involved and other minors in interstate commerce and using means of to persuade and induce L.M and others to engage in prostitution activity for which he and others could be charged with criminal endant Jeffrey Epstein at all times material to this Complaint knew own of L.M.s minority The Defendant Jeffrey Epstein at all times Page of Epstein knowing intent that the LJ others could be knowingly used including L.M to others could be In a LM Defendant minor L.M to brin the purposes of purposes of prosti1 of minor girls thrc money wealth anc minor L.M to brir exchange for man middle school age transporting L.M interstate commerc and in other sexu offenses The De and should have kI Sof Case Jocument Entered on FLSD Doc Page of material to this Complaint knew and should have know of the minority of the other girls he was sexually abusing The acts referenced above in paragraphs through committed by Defendant Jeffrey Epstein against the then-minor Plaintiff L.M were committed in violation of numerous State criminal statutes condemning the sexual exploitation of minor children prostitution and prostitution-related offenses sexual performances by a child lewd and lascivious assaults sexual battery contributing to the delinquency of a minor and other crimes specifically including but not limited to those criminal offenses outlined in Chapters and of the Florida Statutes as well as those designated in Florida Statutes and The acts reference above in paragraphs through committed by Defendant Jeffrey Epstein against the then-Minor Plaintiff L.M were committed in violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C and The crimes committed against L.M by Epstein were committed on average four times per month from the beginning of August through the end of October the exact dates being unknown to l.M Page of lof234 Case Jocument Entered on FLSO Docl c,C Page of In June after investigations by the Palm Beach Police Department the Palm Beach State Attorneys Office the Federal Bureau of Investigation and the United States Attorneys Office for the Southern District of Florida Defendant Jeffrey Epstein entered pleas of guilty to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution in the Fifteenth Judicial Circuit in the Palm Beach County Florida Defendant Jeffrey Epstein is in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and as such must admit liability unto Plaintiff Jane Doe No In this action Plaintiff hereby exclusively seeks civil remedies pursuant to U.S.C As a condition of his plea and in exchange for the Federal Government not prosecuting the Defendant Jeffrey Epstein for numerous federal offenses Defendant Jeffrey Epstein additionally entered into an agreement with the Federal Government to the following Any person who while a minor was a victim of an offense enumerated in Title United States Code Section will have the same rights to proceed under section as she would have had if Mr Epstein had been tried federally and convicted of an enumerated offense For purposes of implementrng this paragraph the United States shall provide Mr Epsteins attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr Epstein Any judicial authority interpreting this provision including any authority determining evidentiary burdens if any a Pfalntiff must meet shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been Page of Case ocument Entered on FLSD Doch Page of had Mr Epstein been convicted at trial No more no less Plaintiff L.M is covered by this paragraph and entitled to rights under this paragraph The defendant Jeffrey Epstein is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged in this Complaint and must effectively admit liability to the Plaintiff L.M including admitting liability for all counts enumerated in this Complaint Plaintiff L.M is entitled to damages as further alleged below including damages as provided in U.S.C as amended by Pub Title VII and Stat COUNT Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activlty travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to Page of 9Df2M Case Jocument Entered on FLSD Docr,..:c Page of this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M Incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above Page of Case ocument Entered on FLSD Doc Page of On or about August the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These Page of ol Case _0cument Entered on FLSD Oock1 Page of injuries are permanent in nature and the plaintiff LM will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government Page of 1i of Case ocument Entered on FLSD Dockel Page of As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has In the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy an_d other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff LM will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT4 Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a Page of Case __,,ocument Entered on FLSD Docl Page of violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her lnto a perverse and conventional way of life for a minor The then minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Page of 1JolZJ4 Case _ocument Entered on FLSD Oocl Page of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning Jhe coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in S,C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of Case Jcument Entered on FLSD Dock Page of suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to Page of or Case cument Entered on FLSD Doc1 Page of engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated In Title United States Code Section being committed against her L.M has ln the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self.esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of ti of Case vcument Entered on FLSD Docl Page of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT7 Cause of Action Pursuant to u.s.c September Incident Plaintiff l.M adopts and realleges paragraphs through above On or about September the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of Page of Case ocument Entered on FLSD Dock Page of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff LM demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C September Incident Plaintiff LM adopts and rea!leges paragraphs through above On or about September the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in inicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct Page of Case ocument Entered on FLSD Doch Page of child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate resuJt of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of Case ocument Entered on FLSD Doc Page of COUNTS Cause of Action Pursuant to U.S.C October Incident Plaintiff l.M adopts and realleges paragraphs through above On or about October the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controfling manipulating and coercing her into a perverse Page of 20ofD4 Case _ocument Entered on FLSD Dael Page of and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT10 Cause of Action Pursuant to U.S.C October lncid1nt Plaintiff L.M adopts and realleges paragraphs through above On or about October the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and Page of of Case ocument Entered on FLSD Doclt Page of l.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff LM incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff LM has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of Case Jcument Entered on FLSD Docke Page of October Incident Plaintiff L.M adopts and realleges paragraphs through above On or about October the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff LM incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and Page of enses The plaintiff has suffered a loss of income a loss of the ncome in the future and a loss of the capacity to enjoy life These inent in nature and the plaintiff L.M will continue to suffer these ref ore the plaintiff L.M demands judgments against the defendant compensatory damages of at least the minimum amount provided fees costs and such other and further relief as this Court deems just ereby demands trial by jury on all issues triable as of right by a jury COUNT12 Cause of Action Pursuant to U.S.C October Incident itiff adopts and realleges paragraphs through above about October the exact date being unknown to L.M Epstein committed a federal sexual offense against her including a Us federal criminal statutes condemning the coercion and nor to engage in prostitution or sexual activity travel with intent to ual conduct sex trafficking of children sexual exploitation of minor of visual depictions of a minor engaging in sexually explicit conduct nterprises and other crimes specifically including but not limited to nated in U.S.C a and victim of one or more offenses enumerated in U.S.C and cause of action against the defendant Jeffrey Epstein pursuant to Page of psychological ex capacity to earn injuries are perm losses in the futur Whe Jeffrey Epstein fi by law attorneys and proper and Plain Ono Defendant Jeffrey violation of nu mere enticement of a mi engage in illicit se children transport child exploitation those crimes desig L.M is therefore a as such asserts a Case icument Entered on FLSD Docki Page of this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emottonal distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff LM will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT13 Cause of Action Pursuant to U.S.C November Incident Plaintiff L.M adopts and realleges paragraphs through above Page of Case i.:_.cument Entered on FLSD Dockt Page of On or about November the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These Page of Case cument Entered on FLSD Dockt Page of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT14 Cause of Action Pursuant to U.S.C November Incident Plaintiff L.M adopts and realleges paragraphs through above On or about November the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government Page of Case vcument Entered on FLSD Dockt:a Page of As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff LM will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT15 Cause of Action Pursuant to November Incident Plaintiff L.M adopts and realleges paragraphs through above On or about November the exact date being unknown to LM Defendant Jeffrey Epstein committed a federal sexual offense against her including a Page of Case _Jcument Entered on FLSD Doc!l.t Page of violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her LM has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then.minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff l.M will continue to suffer these losses in the future Page of of Case _..,cument Entered on FLSD Dockc Page of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT16 Cause of Action Pursuant to U.S.C November Incident Plaintiff L.M adopts and realleges paragraphs through above On or about November the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of Case L,-.,cument Entered on FLSD DockeL Page of suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff LM has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C December Incident Plaintiff L.M adopts and realleges paragraphs through above On or about December the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to Page of olUf Case ocument Entered on FLSD Docktt Page of engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff LM will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of 3ZotZ34 Case icument Entered on FLSD Dock1 Page of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT18 Cause of Action Pursuant to U.S.C December Incident Plaintiff L.M adopts and realleges paragraphs through above On or about December the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and 1he agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of Page of Case _..,cument Entered on FLSO Oockb Page of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT19 Cause of Action Pursuant to U.S.C December Incident Plaintiff l.M adopts and realleges paragraphs through above On or about December the exact date being unknown to l.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct Page of Case cument Entered on FLSO Dockt Page of Jtar child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of Case G-ueument Entered on FLSD Dockei Page of COUNT20 Cause of Action Pursuant to U.S.C December Incident Plaintiff L.M adopts and realleges paragraphs through above On or about December the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse Page of Case vvcument Entered on FLSD Dockal Page of and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychologlcal expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Januaey lncjdent Plaintiff L.M adopts and realleges paragraphs through above On or about January the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitutlon or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and Page of L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self 225esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then 225minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff LM has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of Case L,vcument Entered on FLSD Dockb Page of 3ot2l4 January Incident Plaintiff L.M adopts and realleges paragraphs through above On or about January the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and l.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her LM has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and Page of Case L,vcument Entered on FLSD Dockel Page of psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These are permanent in nature and the plaintiff L.M will continue to suffer these in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C January Incident Plaintiff L.M adopts and realleges paragraphs through above On or about January the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to Page of Case 267vcument Entered on FLSD Dockel Page of 40Gf this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her Into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C January Incident Plaintiff L.M adopts and realleges paragraphs through above Page of 4t oU34 Case L..-vCument Entered on FLSD Docke Page of On or about January the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federat sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and l.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These Page of Case Jcument Entered on FLSD Dockt Page of injuries are permanent In nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT25 Cause of Action Pursuant to U.S.C February Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government Page of 1.UC Case L..JCument Entered on FLSD Dock Page of As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M wfll continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C February Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February the exact date being unknown to LM Defendant Jeffrey Epstein committed a federal sexual offense against her including a Page of Case 267vcument Entered on FLSD Dockb Page of violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self estJ3em loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff LM has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Page of 5CIIU4 Case uocument Entered on FLSD Dockt:il Page of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Februarv Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her Including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitutlon or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of Case ocument Entered on FLSD DockE:a Page of suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C February Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to Page of ol Case uocument Entered on FLSD Docket Page of engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of llfe for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of llf Case vocument Entered on FLSD Docket Page of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT29 Cause of Action Pursuant to U.S.C March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of Page of Case i..,ocument Entered on FLSD Docket Page of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a petverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct Page of l!Oot;ZJ,4 Case uueument Entered on FLSD Docket Page of child exploitation enterprisest and other crimes specifically including but not limited to those crimes designated in U.S.C a and LM is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of 5t Case uocument Entered on FLSD Dockec Page of COUNT31 Cause of Actign Pursuant to U.S.C Mareh Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychologfcal trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse Page of Case uocument Entered on FLSD Docket Page of and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff LM will continue to suffer these losses in the future Nherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT32 Cause of Action Pursuant to u.s.c March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in ill!cit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and Page of Case uocument Entered on FLSD Doc et Page of L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has In the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Eps1ein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff LM incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount providetl by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of ssorm Case Document Entered on FLSD Docket Page of April Incident Plaintiff L.M adopts and realleges paragraphs through above On or about April the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U,S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and Page of Case Document Entered on FLSD Docket Page of Ol psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT34 Cause of Agtion Pursuant to u.s.c April Incident Plaintiff L.M adopts and realteges paragraphs through above On or about April the exact date being unknown to LM Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent-to engage in ilcit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not llmited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Page of Case Document Entered on FLSO Docket Page of Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical aryd psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C April Incident Plaintiff L.M adopts and realleges paragraphs through above Page of Case Document Entered on FLSD Docket Page of On or about April the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss cf income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life_ These Page of Case Document Entered on FLSD Docket Page of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff l.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT36 Cause of Action Pursuant to u.s.c April Incident Plaintiff L.M adopts and rea/leges paragraphs through above On or about April the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government Page of Case Document Entered on FLSD Docket Page of As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlng manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff incurred medical and psychological expenses and the plaintiff l.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT37 Cause of Action Pursuant to U.S.C May Incident Plaintiff L.M adopts and realleges paragraphs through above On or about May the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of Page of of Case Document Entered on FLSD Docket Page of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and LM is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of llfe for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Page of Case Document Entered on FLSD Docket Page of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a Jury COUNT73 Cause of Action Pursuant to U.S.C February Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February the exact dale being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually expllcit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of Page of Case Document Entered on FLSD Docket Page of 11lot7.M self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C February Incident Plaintiff adopts and realleges paragraphs through above On or about February the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct Page of Case 225JIC Document Entered on FLSD Docket Page of child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M wm continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of Case Document Entered on FLSD Docket Page of COUNT75 Cause of Action Pursuant to U.S.C February Incident Plaintiff L.M adopts and realleges paragraphs through above On or about February the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse Page of Case Document Entered on FLSD Docket Page of and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT76 Cause of Action Pursuant to U.S.C February Incident Plaintiff LM adopts and realleges paragraphs through above On or about February the exact date being unknown to l.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and Page of Case Document Entered on FLSD Docket Page of L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT77 Cause of Action Pursuant to u.s.c Page of Case Document Entered on FLSD Docket Page of March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U,S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her LM has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff LM will in the future suffer medical and Page of of Case Document Entered on FLSD Docket Page of psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT78 Cause of Action Pursuant to U.S.C March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to Page of Case Document Entered on FLSD Docket Page of this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT79 f:zj Cause of Action Pursuant to U.S.C March Incident Plaintiff LM adopts and realleges paragraphs through above Page of Case Document Entered on FLSD Docket Page of of On or about March the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These Page of Case Document Entered on FLSD Docket Page of injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT BO Cause of Action Pursuant to U.S.C March Incident Plaintiff L.M adopts and realleges paragraphs through above On or about March the exact date being unknown to l.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government Page of Case Document Entered on FLSD Docket Page of As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of Bfe for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C April Incident of Plaintiff adopts and realleges paragraphs through above On or about April the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of Page of Case Document Entered on FLSD Docket Page of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Page of Case Document Entered on FLSD Docket Page of 1llaf231 Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT82 Cause of Action Pursuant to U.S.C April Incident Plaintiff L.M adopts and realleges paragraphs through above On or about April the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in USC a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of Case Document Entered on FLSD Docket Page of suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff LM has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C April Incident Plaintiff L.M adopts and realleges paragraphs through above On or about April the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual Page of of Case Document Entered on FLSD Docket Page of conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her l.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff LM incurred medical and psychological expenses and the plaintiff L.M wilt in the future suffer medfcal and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of Case Locument Entered on FLSD Docket Page of ofll4 by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C April Incident Plaintiff L.M adopts and realleges paragraphs through above On or about April the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense agatnst her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against lier L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of Page of of Case Document Entered on FLSD Docket Page of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C May Incident Plaintiff adopts and realleges paragraphs through above On or about May the exact date being unknown to LM Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation Page of Case Document Entered on FLSD Docket Page of of23 enterprises and other crimes specifically including but not limited to those crimes designated In U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of Case Document Entered on FLSD Docket Page of COUNT86 Cause of Action Pursuant to U.S.C May Incident Plaintiff L.M adopts and realleges paragraphs through above On or about May the exact date being unknown to L.fyi Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliatlon embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse Page of Case Document Entered on FLSD Docket Page of and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT87 Cause of Action Pursuant to U.S.C May Incident Plaintiff L.M adopts and realleges paragraphs through above On or about May the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is Page of Case Document Entered on FLSD Docket Page of therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT88 Cause of Action Pursuant to U.S.C Page of Case Document Entered on FLSD Docket Page of May Incident Plaintiff L.M adopts and realleges paragraphs through above On or about May the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel Vvith intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant1 Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her LM has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and Page of P?U?q??Am 뢒a z?e?M sI H??W 4d u?ɹN??V?RP w?w i OR_ 2h Qg9 Oc0?qV ά?1?zB FT ta?Zv A dY?q y?ܪ?_?eg i?O a k?q QN?Nsw?N jJ p?g ę?RS l?Y?u?u??Fp I0AN?P Q?o?Y P?pb z?Lƾ Ο?m;s JHo VU b?Ě JqɱUL l?y wL I I5 td i MD L?ݶ 4k AG?O?3 ﵬsy B?n ƻ;?E??B?W?wP?t?S N?w w?t SiW?JN j?A?W ȁ?K t?B r?ה 1eA g?I F3?ӛ 2?k??ATȰK chn CO I V??F Em Ds OU S0o z?1w D?Jn_lۼ??N I?I 8X UJ v4n C?b??Y??iMtlݵ xdO f8?ޑ Zwk ly?OG?Ɛ?P?0 j??DI Hn Q?0R 0?MI A I E?p3 Case Document Entered on FLSD Docket Page of psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C June 2004-lncident Plaintiff L.M adopts and realleges paragraphs through above On or about June the exact date being unknown to LM Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to Page of Case Document Entered on FLSD Docket Page of this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C June Incident Plaintiff L.M adopts and reafleges paragraphs through above Page of Case Document Entered on FLSD Docket Page of On or about June the exact date being unknown to LM Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in _sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff LM will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These Page of Case Document Entered on FLSD Docket Page of Ulof:234 injuries are permanent in nature and the plaintiff L.M wl/1 continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT91 Cause of Action Pursuant to U.S.C June Incident Plaintiff L.M adopts and reaHeges paragraphs through above On or about June the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government Page of Case Document Entered on FLSD Docket Page of 13hfU4 As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and sufferingt emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cau of Action Pursuant to U.S.C June Incident Plaintiff L.M adopts and realleges paragraphs through above On or about June the exact date being unknown to l.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a Page of Case Document Entered on FLSD Docket Page of violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff l.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Page of of23 Case Document Entered on FLSD Docket Page of Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT93 Cause of Action Pursuant to U.S.C Julv Incident Plaintiff L.M adopts and realleges paragraphs through above On or about July the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S a and is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past Page of Case Document Entered on FLSD Docket Page of suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff l.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the mlnimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT94 Cause of Action Pursuant to U.S.C July Incident Plaintiff L.M adopts and realleges paragraphs through above On or about July the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual Page of Case Document Entered on FLSD Docket Page of conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically includingf but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M wl in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided Page of Case Document Entered on FLSD Docket Page of by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT95 Cause of Action Pursuant to U.S.C July Incident Plaintiff L.M adopts and realleges paragraphs through above On or about July the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of Page of Case Document Entered on FLSD Docket Page of 145olC self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein contr0Uing manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M Incurred medical and psychological expenses and the plaintiff LM will in the future suffer medical and psychological expenses The plaintiff LM 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 LM will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT96 Cause of Action Pursuant to U.S.C July Incident Plaintiff adopts and realfeges paragraphs through above On or about July the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation Page of Case Document Entered on FLSD Docket Page of 1Mlof2:M enterprises and other crimes specifically including but not Hmited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff LM demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury Page of Case Document Entered on FLSD Docket Page of COUNT97 Cause of Action Pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse Page of Case Document Entered on FLSD Docket Page of Mlt1fU4 and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT98 Cause of Action pursuant to U.S.C August Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and Page of Case Document Entered on FLSD Docket Page of 14fotzJ4 L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humlliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C Page of Case Document Entered on FLSD Docket Page of August Incident Plaintiff LM adopts and raalleges paragraphs through above On or about August the exact date being unknown to LM Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medlcal and Page of Case Document Entered on FLSD Docket Page of ol psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cau1e of Action Pursuant to U.S.C Aygust Incident Plaintiff L.M adopts and realleges paragraphs through above On or about August the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to Page of Case Document Entered on FLSD Docket Page of this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff LM incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enioy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all rssues triable as of right by a jury COUNT Cause of Action Pursuant to U.S.C September Incident Plaintiff L.M adopts and realleges paragraphs through above Page of Case Document Entered on FLSD Docket Page of of On or about September the exact date being unknown to L.M Defendantt Jeffrey Epstein committed a federal sexual offense against her including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of mtnor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plainttff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These Page of Case Document Entered on FLSD Docket Page of llf234 As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a loss of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses in the future Wherefore the plaintiff L.M demands judgments against the defendant Jeffrey Epstein for compensatory damages of at least the minimum amount provided by law attorneys fees costs and such other and further relief as this Court deems just and proper and hereby demands trial by jury on all issues triable as of right by a jury COUNT Cause of Action Pursuant to u.s.c September Incident Plaintiff L.M adopts and realleges paragraphs through above On or about September the exact date being unknown to L.M Defendant Jeffrey Epstein committed a federal sexual offense against her including a Page of Case Document Entered on FLSD Docket Page of violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity travel with intent to engage in illicit sexual conduct sex trafficking of children sexual exploitation of minor children transport of visual depictions of a minor engaging in sexually explicit conduct child exploitation enterprises and other crimes specifically including but not limited to those crimes designated in U.S.C a and L.M is therefore a victim of one or more offenses enumerated in U.S.C and as such asserts a cause of action against the defendant Jeffrey Epstein pursuant to this Section of the United States Code and the agreement between the Defendant Jeffrey Epstein and the United States Government As a direct and proximate result of the offenses enumerated in Title United States Code Section being committed against her L.M has in the past suffered and will in the future suffer physical injury pain and suffering emotional distress psychological trauma mental anguish humiliation embarrassment loss of self-esteem loss of dignity invasion of her privacy and other damages associated with defendant Jeffrey Epstein controlling manipulating and coercing her into a perverse and conventional way of life for a minor The then-minor plaintiff L.M incurred medical and psychological expenses and the plaintiff L.M will in the future suffer medical and psychological expenses The plaintiff L.M has suffered a fess of income a loss of the capacity to earn income in the future and a loss of the capacity to enjoy life These injuries are permanent in nature and the plaintiff L.M will continue to suffer these losses ln the future Page of
