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Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 1 of 19
IN THE UNITED ST ATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
JANE DOE No. 101, 09-80591
Civil Action No.
Plaintiff:
C I V 1·=-11!-ft-------+e--y ~ D.C .
.. IH M R R n INTAKE
vs.
JEFFREY EPSTEIN,
.MAGISTRATE JUDGE
JOHNSON
COMPLAINT AND
APR 1 7 2009
STEVEN M. LARIMORE
CLERK U.S. DIST. CT.
S.D. OF FLA. MIAMI
Defendant. DEMAND FOR JURY TRIAL
--------------------I
COMPLAINT AND DEMAND FOR JURY TRIAL
Plaintiff, Jane Doe No. 101 ("Jane Doe"), brings this Complaint against Defendant,
Jeffrey Epstein, and states as follows:
PARTIES, JURISDICTION, AND VENUE
1. At all times material to this cause of action, Plaintiff, Jane Doe, was a resident of
Palm Beach County, Florida.
2. This Complaint is hrought under a fictitious name to protect the identity of
Plaintiff, Jane Doe, because this Complaint makes sensitive allegations of sexual assault and
abuse of a then minor.
3. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a
residence located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida.
4. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is
currently incarcerated in the Palm Beach County Stockade.
5. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an
adult male born in 1953.
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 2 of 19
6. This Court has jurisdiction of this action and the claims set forth herein pursuant
to 18 U.S.C. § 2255.
7. This Court has venue of this action pursuant to 28 U.S.C. § 1391(a), as a
substantial part of the events giving rise to the claim occurred in this District.
STATEMENT OF FACTS
8. At all relevant times, Defendant, Jeffrey Epstein, was an adult male,
approximately 50 years old. Epstein is known as a billionaire financier and money manager with
a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth, power,
and influence. He owns a fleet of aircraft that includes a Gulfstream IV, a helicopter, and a
Boeing 727. Until his incarceration, he maintained his principal place of residence in the largest
home in Manhattan, a 51,000-square-foot eight-story mansion on the Upper East Side. Upon
information and belief, he also owns a $6.8 million mansion in Palm Beach, Florida, a $30
million 7,500-acre ranch in New Mexico he named "Zorro," and a 70-acre private island known
as Little St. James in St. Thomas, U.S. Virgin Islands. The allegations herein concern
Defendant's conduct while at his lavish estate in Palm Beach.
9. Upon information and belief, Defendant has a sexual preference for underage
minor girls. He engaged in a plan, scheme, or enterprise in which he gained access in his home
to countless relatively economically disadvantaged minor girls, sexually assaulted or molested
these girls, and then gave them money.
10. Beginning in or around 2001 through in or around September 2007, Defendant
used his resources and his influence over vulnerable minor children to engage in a systematic
pattern of sexually exploitative behavior.
11. Defendant's plan and scheme reflected a particular pattern and method.
Defendant coerced and enticed impressionable, vulnerable, and relatively economically less
Podhurst Orseck, P.A. 2
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 3 of 19
fortunate minors to participate in various acts of sexual misconduct that he committed upon
them. Defendant's scheme involved the use of underage girls as well as other individuals to
recruit other underage girls. Upon information and belief, Defendant or an authorized agent
would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach
residence. His assistants would seek out economically disadvantaged and underage girls from
West Palm Beach and surrounding areas who would be enticed by the money being offered generally $200 to $300 per "massage" session-and who Defendant and/or his assistants
perceived as less likely to complain to authorities or have credibility issues if allegations of
improper conduct were made. The then minor Plaintiff and other minor girls, some as young as
14 years old, were transported to Defendant's Palm Beach county mansion by Defendant's
employees, agents, and/or assistants in order to provide Defendant with "massages."
12. Defendant would pay the procurer of each girl's "appointment" approximately
$200. Many of the instances of illegal sexual conduct committed by Defendant were perpetrated
with the assistance, support, and facilitation of at least three assistants who helped him
orchestrate this child exploitation enterprise. These assistants would often arrange times for
underage girls to come to Defendant's residence, transport or cause the transportation of
underage girls to Defendant's residence, escort the underage girls to the massage room where
Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove
their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the
conclusion of each "massage appointment," and, upon information and belief, take nude
photographs and/or videos of the underage girls' for Defendant without their knowledge.
13. Epstein designed the scheme to secure a private place in Defendant's mansion
where only persons employed and invited by Epstein would be present, so as to reduce the
chance of detection of Defendant's sexual abuse and prostitution as well as to make it more
Podhurst Orseck, P.A. 3
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 4 of 19
difficult for the minor girls to flee the premises and/or to credibly report his actions to law
enforcement or other authorities. The girls were usually transported by his employees, agents,
and/or assistants or by a taxicab paid for by Defendant in order to make it difficult for the girls to
flee his mansion.
14. Upon arrival at Defendant's mansion, each underage victim would generally be
introduced to one of Defendant's assistants, who would gather the girl's personal contact
information. The minor girl would then be led up a flight of stairs to a room that contained a
massage table and a large shower. The staircase leading to the room was plastered with nude
photographs of young girls, including some photographs depicting two or more young girls
engaged in lewd acts. Upon information and belief, Defendant, Jeffrey Epstein, had such
photographs in each of his four homes and on his computer.
15. At times, if it was the girl's first "massage" appointment, another female would
be in the room to "lead the way" until Defendant would have her leave. Generally, Defendant
would start his massage wearing only a small towel, which eventually would be removed.
Defendant would direct the girl to massage him, giving her specific instructions as to where and
how he wanted to be touched, and then direct her to remove her clothing. He would then
perform one or more lewd, lascivious, and sexual acts, including masturbation, fondling the
minor's breasts and/or sexual organs, touching the minor's vagina with a vibrator and/or back
massager, digitally penetrating her vagina, performing intercourse, oral sex, and/or anal sex,
and/or coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution. The
exact degree of molestation and frequency with which the sexual crimes took place varied and is
not yet completely known; however, at least when Defendant was in Palm Beach, Florida, such
acts occurred usually on a daily basis and, in most instances, several times a day.
Podhurst Orseck, P.A. 4
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 5 of 19
16. As previously stated in paragraph 14, Defendant displayed nude photographs of
underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S.
Virgin Islands. Upon infonnation and belief, some of the photographs in the possession of
Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the
day of his arrest, police found two hidden cameras and photographs of underage girls on a
computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may
have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and may have
transported lewd photographs of Plaintiff (among many other victims) to his other residences and
elsewhere using a facility or means of interstate commerce.
17. Consistent with the foregoing plan and scheme, Defendant used his money,
wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff.
Plaintiff, Jane Doe, was recruited by one of Defendant's agents to give Defendant a massage for
compensation. Plaintiff was apprehensive, but needed the money and finally agreed to go.
Plaintiff was first b10ught to Defendant's mansion in or about the spring of 2003, when she was
merely 17 years old and in high school. Epstein's procurer drove her to Jeffrey Epstein's
mansion. Plaintiff was led up a flight of stairs by a blonde woman to a spa room with a shower
and a massage table, where she was left alone. A woman with dark hair, an accent, and naked
from the waist up entered and tried to coax Plaintiff to remove her shirt, but Plaintiff refused.
After the woman showed Plaintiff how to use the lotions that were there, the woman left.
Defendant walked in wearing only a small towel. He lay down on the massage table still
wearing the small towel, and Plaintiff began to massage his shoulders and neck. Nervously, she
asked him what he did for a living. Defendant responded that he was a scientist. Defendant
asked Plaintiff what year she would graduate high school, to which Plaintiff honestly replied that
she would graduate in 2004. Plaintiff massaged Defendant's lower back and calves. Defendant
Podhurst Orseck, P.A. 5
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 6 of 19
told her to remove his towel. Defendant told her that he had just worked out and wanted his
buttocks massaged. Although disgusted, she was afraid to refuse and did it. At some point,
Defendant ordered Plaintiff to remove her clothes. In shock, fear, and trepidation, Plaintiff partly
complied, removing only her shirt and bra. When Defendant turned over, Plaintiff was afraid
and embarrassed and she wanted to leave. Defendant repeatedly told her to relax and
complimented her, saying that she had a nice body. Defendant then pulled Plaintiff closer to
him. He began masturbating and then began fondling her breasts. He asked her to do more and
mentioned more money, which she adamantly declined. Defendant continued masturbating until
he ejaculated. Plaintiff next recalls that she received $200 and was transported by the procurer,
whom she later learned received $200 for having brought her to Epstein's mansion.
18. Defendant thereafter lured the then minor Plaintiff to the Epstein mansion on at
least one and perhaps two other occasions in the spring and/or summer of 2003. The procurer
made another appointment for her to return, but Plaintiff didn't want to see Defendant. By
having his assistants continue to contact Plaintiff and attempt to lure her to the mansion for other
sexual acts, Defendant engaged in a continuous course of conduct that injured Plaintiff upon
each instance of contact and/or abuse.
19. In addition to the direct sexual abuse and molestation of the then minor Plaintiff,
Defendant used his money, wealth, and power to unduly and improperly manipulate and
influence the then minor Plaintiff to bring him another minor girl in a promised exchange for
money. Rather than go herself, Plaintiff and the procurer took another girl there one time.
20. As a result of these encounters with Defendant, Plaintiff, Jane Doe, has in the past
suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
Podhurst Orseck, P.A. 6
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 7 of 19
other damages associated with Defendant's controlling and manipulating her into a perverse and
unhealthy way of life.
21. Any assertions by Defendant that he was unaware of the age of the then minor
Plaintiff are belied by her telling him her high school graduation year, as well as his own actions,
and are rendered irrelevant by the provision of applicable federal statutes concerning the sexual
exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this
cause of action, knew and should have known of Plaintiffs age of minority. In fact, his
preference for underage girls was well-known to those who regularly procured them for him.
22. Defendant, Jeffrey Epstein, committed the above-referenced acts upon the then
minor Plaintiff in violation of federal statutes condemning the coercion and enticement of a
minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual
conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual
depictions of a minor engaging in sexually explicit conduct, transport of child pornography, child
exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes
designated in 18 U.S.C. § 2422(b), § 2423(b), § 2423(e), § 2251, § 2252, § 2252A(a)(l), §
2252A(g)(l), and§ 1591.
23. After investigations by the Palm Beach Police Department, the Palm Beach State
Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's 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 June 2008 in the Fifteenth Judicial
Circuit in Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if
he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such,
Podhurst Orseck, P.A. 7
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 8 of 19
must admit liability unto Plaintiff, Jane Doe. Plaintiff hereby exclusively seeks civil remedies
pursuant to 18 U.S.C. § 2255.
COUNT ONE
(Cause of Action for Coercion and Enticement of Minor to Engage in Prostitution or
Sexual Activity pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2422(b))
24. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 23 above.
25. Defendant, Jeffrey Epstein, used a facility or means of interstate commerce to
knowingly persuade, induce, or entice Jane Doe, when she was under the age of 18 years, to
engage in prostitution and/or sexual activity for which any person can be charged with a criminal
offense pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(b).
26. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code.
27. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
and will in the future suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
other damages associated with Defendant's manipulating and leading her into a perverse and
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
capacity to enjoy li.fe. These injuries are permanent in nature, and Plaintiff will continue to
suffer these losses in the future.
Podhurst Orseck, P.A. 8
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 9 of 19
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
a Jury.
COUNT TWO
(Cause of Action for Travel with Intent to Engage in Illicit Sexual Conduct pursuant to 18
U.S.C. § 2255 in Violation of 18 U.S.C. § 2423(b))
28. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 23 above.
29. Upon information and belief, Defendant, Jeffrey Epstein, traveled in interstate
commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. §
2423(t), with minor females, in violation of 18 U.S.C. § 2423(b ).
30. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code.
31. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
and will in the future suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
other damages associated with Defendant's manipulating and leading her into a perverse and
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has
suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
Podhurst Orseck, P.A. 9
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 10 of 19
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
suffer these losses in the future.
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
a Jury.
COUNT THREE
(Cause of Action for Sex Trafficking of Children pursuant to 18 U.S.C. § 2255 in Violation
of 18 U.S.C. § 1591(a))
32. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 23 above.
33. Defendant, Jeffrey Epstein, knowingly, in or affecting interstate or foreign
commerce, recruited, enticed, and obtained Plaintiff, Jane Doe, knowing that she had not attained
the age of 18 years and would be caused to engage in a commercial sex act as defined in 18
U.S.C. § 159l(c)(l), in violation of 18 U.S.C. § 1591(a)(l).
34. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code.
35. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
and will in the future suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
other damages associated with Defendant's manipulating and leading her into a perverse and
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 11 of 19
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
suffer these losses in the future.
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
a Jury.
COUNT FOUR
(Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. § 2255 in
Violation of 18 U.S.C. § 2251)
36. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 23 above.
37. Defendant, Jeffrey Epstein, knowingly induced, enticed, or coerced then minor
Plaintiff Jane Doe to engage in sexually explicit conduct for the purpose of producing a visual
depiction of such conduct in violation of 18 U.S.C. § 2251. As previously stated in paragraphs
14 and 16, Defendant displayed a myriad of photographs of underage girls throughout his homes
in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. Upon information and
belief, many of the photographs in the possession of Defendant were taken with hidden cameras
set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden
cameras and photographs of underage girls on a computer in Defendant's home. Upon
information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of
Plaintiff, Jane Doe, with his hidden cameras and may have transported lewd photographs of
Podhurst Orseck, P.A. 11
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 12 of 19
Plaintiff (among many other victims) to his other residences and elsewhere using a facility or
means of interstate commerce.
38. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code.
39. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
and will in the future suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
other damages associated with Defendant's manipulating and leading her into a perverse and
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
suffer these losses in the future.
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
a.1ury.
Pod.hurst Orseck, P.A. 12
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 13 of 19
COUNT FIVE
(Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit
Conduct pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2252(a)(l))
40. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 23 above.
41. Defendant, Jeffrey Epstein, knowingly mailed, transported, or shipped in
interstate or foreign commerce child pornography in violation of 18 U.S.C. § 2252(1). As
previously stated in paragraphs 14, 16, and 37, upon information and belief, Defendant displayed
a myriad of photographs of underage girls throughout his homes in New York, Palm Beach, New
Mexico, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in
the possession of Defendant were taken with hidden cameras set up throughout his home in Palm
Beach. On the day of his arrest, police found two hidden cameras and photographs of underage
girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey
Epstein, may have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and
may have transported lewd photographs of Plaintiff (among many other victims) to his other
residences and elsewhere using a facility or means of interstate commerce.
42. As previously stated in paragraph 21, any assertions by Defendant that he was
unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by
the provision of applicable federal and state statutes concerning the sexual exploitation and abuse
of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew
and should have known of Plaintiffs age of minority. In fact, his preference for underage girls
was well-known to those who regularly procured them for him.
43. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code.
Podhurst Orseck, P.A. 13
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 14 of 19
44. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
and will in the future suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
other damages associated with Defendant's manipulating and leading her into a perverse and
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
suffer these losses in the future.
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
Epstein, for all damages available under 18 U .S.C. § 2255, including, without limitation, actual
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
a Jury.
COUNT SIX
(Cause of Action for Transport of Child Pornography pursuant to 18 U.S.C. § 2255 in
Violation of 18 U.S.C. § 2252A(a)(l))
45. Plaintiff~ Jane Doe, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 23 above.
46. Defendant, Jeffrey Epstein, knowingly mailed, transported, or shipped m
interstate or foreign commerce child pornography in violation of 18 U.S.C. § 2252A(a)(l).
Podhurst Orseck, P.A. 14
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 15 of 19
4 7. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U .S.C.
§ 2255, and, as such asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code.
48. 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.
49. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
and will in the future suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
other damages associated with Defendant's manipulating and leading her into a perverse and
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
suffer these losses in the future.
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
Epstein, for all damages available under 18 U .S.C. § 2255, including, without limitation, actual
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
a Jury.
Podhurst Orseck, P.A. 15
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 16 of 19
COUNT SEVEN
(Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to 18 U.S.C. §
2255 in Violation of 18 U.S.C. § 2252A(g))
50. Plaintiff: Jaae Doe, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 23 above.
51. Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise,
as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 USC § 2252A(g)(l ). As more fully set
forth above in paragraphs 9 through 19, Defendant's actions involved countless victims and
countless incidents of abuse, and he committed those offenses against minors in concert with at
least three other persons.
52. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C.
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this
Section of the United States Code.
53. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered,
and will in the future suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment,
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
other damages associated with Defendant's manipulating and leading her into a perverse and
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses,
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to
suffer these losses in the future.
Podhurst Orseck, P.A. 16
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurst.com
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 17 of 19
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey
Epstein, for all damages available under 18 U .S.C. § 2255, including, without limitation, actual
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by
a Jury.
Date: April 1 7, 2009
~ 0 b....,._J c. ~:n':A:--~ ~ 1f ~ K-4) £
Robert C. Josefsberg, Bar No. 040 56
Katherine W. Ezell, Bar No. 114771
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800
Miami, Florida 33130
(305) 358-2800
(305) 358-2382 (fax)
rjosefsberg@podhurst.com
kezell@podhurst.com
Attorneys for Plaintiff
DEMAND FOR JURY TRIAL
Plaintiff demands to have her case tried before a jury.
Podhurst Orseck, P.A. 17
-=go~~-~~ ~l
Robert C. Josefs~ 04086
Katherine W. Ezell, Bar No. 114771
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800
Miami, Florida 33130
(305) 358-2800
(305) 358-2382 (fax)
rjosefsberg@podhurst.com
kezell@podhurst.com
Attorneys for Plaintiff
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 www.podhurstcom
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 18 of 19
°"JS 44 (Rev. 11/05) 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 fonn, approved by the Judicial Conference of the United States in Seotember 1974. is reauired for the use of the Clerk of Court for the ourpose of initiating
the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) NOTICE: Attorneys MUST Indicate All Re-filed Cases Below.
I. (a) PLAINTIFFS
Jane Doe No. 101
(b) County of Residence of First Listed Plaintiff West Palm Beach
(EXCEPT IN U.S. PLAINTIFF CASES)
( C) Attorney's (Finn Name, Address, and Telephone Number)
Robert C. Josefsberg, Esq./Katherine W. Ezell, Esq.
Podhurst Orseck, P.A.
25 W. Flagler St., Suite 800 /
DEFENDANTS
Jeffrey Epstein
County of Residence of First Listed Defendant
(IN U.S. PLAINTIFF CA
NOTE: IN LAND CONDEMNATION CASE , USE THE LOCATION OF THE TRA T
LAND INVOLVED. APR 1 7
Attorneys (If Known)
Mi<>mi FT 11111) o9-Cv- So59" I -- r<\o.rrtA./~ ·D
I
I
(d) Check County Where Action Arose: 0 MIAMI-DADE O MONROE O BROWARD (J PALM BEACH O MARTIN O ST. LUCIE O INDIAN RIVER O OKEECHOBEE
HIGHLANDS
If. BASIS OF JURISDICTION (Placean"X"inOneBoxOnly) Ill. CITIZENSHIP OF PRINCIPAL P ARTIES(Place an "X" in One Box for Plaintiff
0 I U.S. Govermnent
Plaintiff
0 2 U.S. Govenunent
Defendant
,/J 3 Federal Question
(U.S. Government Not a Party)
0 4 Diversity
(Indicate Citizenship of Parties in Item Ill)
IV NATURE OF SUIT (Placean"X"inOneBoxOnlv\
CONTRACT TORTS
0 I IO Insurance PERSONAL INJURY PERSONAL INJURY
0 120 Marine 0 3 IO Airplane 0 362 Personal Injury -
0 130 Miller Act 0 315 Airplane Product Med. Malpractice
0 140 Negotiable Instrument Liability 0 365 Personal Injury -
0 150 Recovery of Overpayment 0 320 Assault, Libel & Product Liability
& Enforcement of Judgment Slander 0 368 Asbestos Personal
0 151 Medicare Act 0 330 Federal Employers' Injury Product
0 152 Recovery of Defaulted Liability Liability
Student Loans 0 340Marine PERSONAL PROPERTY
(Exel. Veterans) 0 345 Marine Product 0 370 Other Fraud
0 153 Recovery of Overpayment Liability 0 371 Truth in Lending
of Veteran's Benefits 0 350 Motor Vehicle 0 380 Other Personal
0 160 Stockholders' Suits 0 355 Motor Vehicle Property Damage
0 190 Other Contract Product Liability 0 385 Property Damage
0 195 Contract Product Liability !9 360 Other Personal Product Liability
0 I 96 Franchise lniurv
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS
0 210 Land Condemnation 0 441 Voting 0 5 IO Motions to Vacate
0 220 Foreclosure 0 442 Employment Sentence
0 230 Rent Lease & Ejectment 0 443 Housing/ Habeas Corpus:
0 240 Torts to Land Accommodations 0 530General
(For Diversity Cases Only) and One Box for Defendant)
PTF DEF PTF DEF
Citizen of This State e-· I 'J 1 Incorporated or Principal Place 0 4 04
of Business In This State
Citizen of Another State 0 2 0 2 Incorporated and Principal Place 0 5 0 5
of Business In Another State
0 3 0 3 Foreign Nation 0 6 0 6
FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
0 610 Agriculture 0 422 Appeal 28 USC 158 0 400 State Reapportionment
0 620 Other Food & Drug 0 423 Withdrawal 0 410 Antitrust
0 625 Drug Related Seizure 28 USC 157 0 430 Banks and Banking
of Property 21 USC 881 0 450 Commerce
0 630 Liquor Laws PROPERTY RIGHTS 0 460 Deportation
0 640 R.R. & Truck 0 820 Copyrights 0 4 70 Racketeer Influenced and
0 650 Airline Regs. 0 830 Patent C'onupt Organizations
0 660 Occupational 0 840 Trademark 0 480 Consumer Credit
Safety/Health 0 490 Cable/Sat TV
0 690Other 0 810 Selective Service
&BOR SOCIAL SECURITY 0 850 Securities/Commodities/
0 710 Fair Labor Standards 0 861 HIA ( 1395ft) Exchange
Act 0 862 Black Lung (923) 0 875 Customer Challenge
0 720 Labor/Mgmt. Relations 0 863 DIWC/DJWW (405(g)) 12 USC 3410
0 730 Labor/Mgmt.Reporting 0 864 SSID Title XVI 0 890 Other Statutory Actions
& Disclosure Act 0 865 RSI ( 405( g)) 0 891 Agricultural Acts
0 740 Railway Labor Act FEDERAL TAX SUITS 0 892 Economic Stabilization Act
0 790 Other Labor Litigation 0 870 Taxes (U.S. Plaintiff 0 893 Environmental Matters
0 791 Empt. Ret. Inc. or Defendant) 0 894 Energy Allocation Act
Security Act 0 871 IRS-Third Party 0 895 Freedom of Information
26 USC 7609 Act
I
0 245 Tort Product Liability 0 444 Welfare 0 535 Death Penalty 0 900Appeal of Fee Determination
0 290 All Other Real Property 0 445 Amer. w/Disabilities -
V. ORIGIN
,VJ I Original
Proceeding
Employment
0 446 Amer. w/Disabilities -
Other
0 440 Other Civil Rights
(Place an "X" in One Box Only)
0 2 Removed from O 3
State Court
VI. RELATED/RE-FILED
CASE(S). ( See instructions
second page):
0 540 Mandamus & Other
0 550 Civil Rights
0 555 Prison Condition
Re-filed- O 4 Reinstated or 0
(see VI below) Reopened
a) Re-filed Case O YES ~ NO
JUDGE Kenneth A. Marra
5 Transferred from
another district
(specify)
b) Related Cases
0
0 6 Multidistrict
Litigation
G1YES ONO
~3~i1 See Attached
Under Equal Access
to Justice
950 Constitutionality of
State Statutes
0 7
Appeal to District
Judge from
Magistrate
Jud2:rnent
Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless
diversity):
VII. CAUSE OF
ACTION
VIII. REQUESTED IN
COMPLAINT:
18 U.S.C. 2255 (Predicate Statutes 18 U.S.C. 2422(b), 2423(b), 2423(e), 2251, 2252, 2252A(a)(l), 2252A(g)(l)
and 1591)
LENGTH OF TRIAL via 4 days estimated (for both sides to try entire case)
;0 CHECK IF THIS IS A CLASS ACTION DEMAND$ CHECK YES only if demanded in complamt:
UNDER F.R.C.P. 23 JURY DEMAND: ["¢Yes ~O No
ABOVE INFORMATION IS TRUE & CORRECT TO SIONA TURE OF ATTORNEY OF RECORD DATE
THE BEST OF MY KNOWLEDGE ~~ ~ W , 09 FOR OFFICE~SE ON_L.;i ,
AMOUNrJJ~ z:,,. 0 RECEIPT# '77'>{ /9,FP __ _
ol/~7 /4) Y
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 19 of 19
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
WEST PALM BEACH DIVISION
ATTACHMENT TO CIVIL COVER SHEET
FOR: Jane Doe No. 101 v. Jeffrey Epstein
VI. RELATED/RE-FILED CASE(S):
08-80069
08-80119
08-80232
08-80380
08-80381
08-08804
08-80811
08-80893
08-80993
08-80994
08-80469