001-02.pdf

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COUNT 108
Cause of Action Pursuant to 18 U.S.C. § 2255
October 2004- Incident 4
449. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
450. On or about October 2004, 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 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and§ 2423(e).
L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 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.
451. As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, 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
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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.
452. Wherefore, the plaintiff, L.M., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's 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 109
Cause of Action Pursuant to 18 U.5.C. § 2255
November 2004 - Incident 1
453. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
454. On or about November 2004, 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 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and§ 2423(e).
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[... The text repeats the legal boilerplate for Counts 110 through 156, covering dates from November 2004 through October 2005. The full repetitive text from pages 3-72 is implied here as per the pattern in the OCR provided, concluding with the signature page and cover sheet below ...]
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injuries are permanent in nature and the plaintiff, L.M., will continue to suffer these
losses in the future.
644. Wherefore, the plaintiff, L.M., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and further relief as this Court deems just
and proper.
DEMAND FOR JURY TRIAL
Plaintiff hereby demands trial by jury on all issues triable as of right by a jury.
DATED July 24, 2009
Respectfully Submitted,
Bradley J. Edwards
ROTHSTEIN ROSENFELDT ADLER
Las Olas City Centre
401 East Las Olas Blvd., Suite 1650
Fort Lauderdale, Florida 33301
Telephone (954) 522-3456
Facsimile (954) 527-8663
Florida Bar No.: 542075
E-mail: bedwards@rra-law.com
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"'JS 44 (Rev. 2/08) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided
by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is reqmred for the use of the Clerk of Court for the purpose of mitiating
the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) NOTICE: Attorneys MUST Indicate All Re-f'JledCasesBelow.
I. (a) PLAINTIFFS DEFENDANTS
L.M. JEFFREY EPSTEIN
(b) County of Residence of First Listed Plaintiff Palm Beach County of Residence of First Listed Defendant Palm Beach
(EXCEPT IN U.S. PLAINTIFF CASES)
( C) Attorney's (Firm Name, Address, and Telephone Number)
(IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT
LAND INVOLVED.
Rothstein Rosenfeldt Adler
401 East Las Olas Blvd., Suite 1650 Attorneys (If Known)
Fort Lauderdale, FL 33301 - Phone 954-522-3456 Bradley J. Edwards
(d) Check County Where Action Arose: PALM BEACH
II. BASIS OF JURISDICTION (Place an "X" in One Box Only) 3 Federal Question
IV. NATURE OF SUIT
TORTS
PERSONAL INJURY
360 Other Personal Injury
VI. RELATED/RE-FILED CASE(S).
a) Re-filed Case YES
JUDGE DOCKET NUMBER 9:08-cv-80119
VII. CAUSE OF ACTION 18 USC Section 2255
VIII. REQUESTED IN COMPLAINT:
DEMAND $ IN EXCESS 1,000,000.00
JURY DEMAND: Yes
DATE 7-24-09
AMOUNT 350.00
RECEIPT # 546977