EFTA00175214

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. 
IS. 
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 Flatter Street, Suite 800, Miami, FL 33130, Miami 
Fax 
• Fott Lauderdale 
podluustcom 
EFTA00175434

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 Plaintiff's 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(6), § 2423(b), § 2423(c), § 2251, § 2252, § 2252A(a)(1), § 
2252A(g)( I), 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 Hagler Street, Suite 800, Miami, PL 33130, Miami 386358.2800 Pax 
• Fort Lauderdale 
www.podhuzst.com 
EFTA00175435

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 Engaae in Prostitution or 
Sexual Activity pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. & 2422(b)1 
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 life. These injuries are permanent in nature, and Plaintiff will continue to 
suffer these losses in the future. 
Podhurst Orseck, P.A. 
8 
75 West Meer Street, Suite 800, Wand, FL 33130, Miami 
Fax 
• Fort Lauderdale 
vevnv.pod.hurst.com 
EFTA00175436

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 Engaae in Illicit Sexual Conduct pursuant to 18 
U.S.C. & 2255 in Violation of 18 U.S.C. 4 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(0, 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 Flask/ Street, Suite 800, Miami, FL 33130, MIMI 305358.2800 Fax 
• Fort Lauderdale 
www.podhurst.com 
EFTA00175437

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 Doc, 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. 6 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. § 1591(c)(1), in violation of 18 U.S.C. § 1591(a)(1). 
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, toss 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. 
10 
25 West Flagkr Street Suite 800, MWµ FL 33130, Miami 
Fax 
• Fort Lauderdale 
www.podluust.cout 
EFTA00175438

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. 4 2255 in 
Violation of 18 U.S.C. 4 22511 
36. 
Plaintiff, Jane Doc, 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 Flatter Street, Suite 800, Miami, FL 33130, MS=005.358.2800 Fax 305358.2382 • Port Lauderdale 
unt.corn 
EFTA00175439

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 ►eading 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. 
12 
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 
Fax 
• Fort Lauderdale 
envw.podhurst.cont 
EFTA00175440

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)(1)) 
40. 
Plaintiff, Jane Doc, hereby adopts, repeats, =lieges, 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 Plaintiff's 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 Stint, Suite 800, Miami, FL 33130, MIAS 
Fax 
• Fort Lauderdale 
EFTA00175441

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. ti 2255 in 
Violation of 18 U.S.C. § 2252A(a)(111 
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 in 
interstate or foreign commerce child pornography in violation of 18 U.S.C. § 2252A(a)(1). 
Podhurst Orseck, P.A. 
14 
25 West Plaster Street, Suite SOO, Minnie P1.33130, Miami 
Pax 
• Port Lauderdale 
weassaillawrisarn 
EFTA00175442

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 15 of 19 
47. 
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 
Fax 
• Fort Lauderdale 
www.podhursteom 
EFTA00175443

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(2)1 
50. 
Plaintiff', Jane Doe, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs I 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)(I). 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 Flasks Street Suite 800, Miami, FL 33130, Miami 
Fax 
• Fort Lauderdale 
www.podhuntcom 
EFTA00175444

Case 9:09-cv-80591-1<AM 
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 17, 2009 
Robert C. Jose 
erg, Bar No. 040856 
Katherine W. Ezell, Bar No. 114771 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 800 
Miami, Florida 33130 
(fax) 
Attorneys for Plaintiff 
DEMAND FOR JURY TRIAL. 
Plaintiff demands to have her case tried before a jury. 
Robert . Jose 
rg, Bar No. 0408 6 
Katherine W. Ezell, Bar No. 114771 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 800 
• Forid 33130 
(fax) 
riosefsberg@podhurst.com 
kezellftodhurst.com 
Attorneys for Plaintiff 
Podhurst Orseck, P.A. 
17 
25 West Fielder Street Suite 800, Miami, FL 33130, Miami 
Fax 
• Fort Lauderdale 
www.podhurst.corn 
EFTA00175445

. . 
Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 18 of 19 
VAN (Rev. II/05) 
• 
ThelS 44 civil coves sheet and the information contained herein neither replace nor supplement the filing and service of (shadings or otha papas as required by law, except as proyided 
.by local rules of cant This font; approved by the Judicial Con femme of the United States in September 1974. is reamed for the use of the Clak of Coun for the oat 
g 
initiating 
thecivil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM) 
NOTICE: Attorneys MUST Indicate All Re-Med Cues Below. 
CIVIL. COVER SHEET 
1. (a) PLAINTIFFS 
Jane Doe No. 101 
(b) County of Residence of Fins Listed Plaintiff 
Weat Palm Beach 
(EXCEPT IN U.S. PLAINTIFF CASES) 
(C) Attorney's (Firm Name, Address. and Telephone Pianaba) 
Robert C. Josefsberg, Esq./Katherine W. Ezell, Esq. 
Podhurst Orseck, P.A. 
25 W. Flagler St., Suite 800 
Miami RI 1111A 
so scf 
Macre-
(d)Cheek County Where Action Arose: 0MIA/M.DADE 0 MONROE 0 BROWARD 9 PALM BEACH 0 MARTIN 0 ST. LUCIE 0 INDIAN RIVER n OKEECHOBEE 
HIGHLANDS 
II. BASIS OF JURISDICTION 
(Place en 'X' in One Bin Onlyl 
III. CITIZENSHIP OF PRINCIPAL PARTIESeurr scr• in One Dim tot nada 
Per Divinity Casts Only) 
NA One Box for Defendant) 
I US. Ooyenimaa 
,of) 3 Federal Question 
PTV 
DEP 
P17 
DEF 
Plaintiff 
(U.S. Government Not a Parry) 
Cilium of This State 
1 
*.0 I 
Incorporated or Principal Place 
of Huskiest In This State 
4 
14 
0 2 US. Government 
Defendant 
0 4 
Diversity 
lindicate Citiwnthip of Peak, in hem III) 
Oaten of nanny: Sine 
0 
2 
0 2 
Incorporated and Ponca* Place 
of Business In Another State 
0 
S 
0 5 
Citizen cc Subject of a 
0 
3 
0 3 
Foreign Nation 
O 
6 
0 6 
Foreign Comers. 
DEFENDANTS 
Jeffrey Epstein 
County of Residence of First Listed Defendant F 
IIN US PLAINTIFF CA Rime 
NOTE: IN LAND CONDEMNATION CASE 
USE /II IC LOCA1 ION OF 
'f RA 
LAND INVOLVED. 
1m 
APR 1 
Attorneys (If Known) 
STEVEN 
Jack A. Goldberger, Esq., Atterbury oldb 
irefa
in
E
(Australian Ave., 41400, West Palm B
art 
r 
-• 
... ..... _ .... _ . _ _ _ 
CONTRACT 
TOR
I
 is 
PORFKITUREMENALTY 
BANKRUPTCY 
DINER STATUTES
0 110 Incur/ince 
0 120 Marine 
0 130 Miller Act 
O 140 Negotiable Inurtunem 
0 150 Recovery a ()nip:imam 
& Enfortenant of Judgment 
0 IS) Medium Act 
0 152 Recovery of Defaulted 
Student Loam 
(Fad. %tains) 
0 IS) Recovery of Overpaymers 
of Newman's Aeneas 
O 160 Stockholden' Suits 
0 190 Other Cotermi 
0 195 Convect Product Liability 
0 196 Franchise 
PERSONAL INJURY 
0 310 Airplane 
0 315 Mutant Product 
Liability 
0 320 Assault Libel & 
Standee 
0 330 Federal Employer? 
Lability 
0 MOMenne 
0 345 /twine Product 
Liability 
CI 350 Motor Vehicle 
f) 355 Molot Vehick 
Product Liability 
11 360 (kho Personal 
Injury 
PERSONAL. INJURY 
0 
362 Petiond Injury • 
Med MaBracike 
0 
365 Penonal Injury- 
Produce Liability 
0 368 Asbestos Personal 
Injury Prockm 
liability 
PERSONAL PROPERTY 
0 
370 Other Frail 
0 
371 Tub in tending 
0 
380 Other Penned 
PrnPerlY Damage 
0 
385 Property thorny 
Product Liability 
PRISONER PETITIONS 
0 610 Aricultwe 
0 620 Other Food & Ding 
0 625 Drng Related Seizure 
of Progeny 21 USC It 1 
0 630 Liquor Eras 
0 610 R.R. & Truck 
0 650 Airline Rey. 
0 660 °cessations' 
Salerydkalth 
0 690 Odsra 
0 422 Appeal 28 USC 158 
il 423 Withdramil 
28 USC 157 
0 400 State RratiPorlionnwel 
0 410 Antitnni 
0 430 Buds ad Hankins 
0 450 Commerce 
0 460 Dcganation 
0 410 RacLacce laktemed and 
Comp Organizations 
0 480 COlittaixr Credit 
0 490 CabkrSat TV 
0 MO Selective Strike 
0 1.50 SeturitimiCernmedihrst 
Exchange 
0 875 Customer Challenw 
It USC 3410 
0 1190001w Sunder/ Aederat 
0 VI AgrkulWral Acts 
0 192 Economy° Subiliration Act 
0 893 Env imminent& Mitten 
A 894 Energy Allocation Act 
0 895 Frealom of Damnation 
AN 
0 9C0Appeal of Fes Detarninedient 
(Asks Equal Accent 
to 'mike 
0 950 Comilmikmallty of 
State susses 
=7111128:T Id BCH I i6 
0 820 Copyrights 
0 830 Patent 
0 840 Trademark 
LABOR 
SOCIAL SECURITY 
0 710 Fair Labor Standard. 
Act 
0 720 LabooMgra Relations 
0 730 Labotrylpytkeponifts 
& Din/ovum Am 
n 740 Railway Labor Act 
0 790 Othet Labor Litiplion 
0 
791 Mora tom Inc. 
Security AG 
0 861111A (B950) 
0 162 Black Lung (923) 
0 561 DIWC/DIww (a0Sta 
0 864 SSIDTitk XVI 
0 865 RSI (405(s)) 
1 
REAL PROPERTY 
CIVIL. RIGHTS 
FEDF.FtAL TAX SUITS 
0 210 Land Condemnation 
fl 220 FOP:CIO:a= 
0 230 Rent Lease & Ejectment 
O 240 Torts to Land 
0 245Ton Product Liability 
0 290 All Other Rea/ Progeny 
0 441 Voting 
0 44/ Einploymem 
0 443 Housing/ 
Accommodations 
0 444 Welfare 
0 445 Ansa. wablubilitics • 
Employment 
0 446 Amer. w/Disabilkics - 
Other 
0 440 Other Civil Risks 
0 510 klotiora to Vacate 
Sentence 
Ilsheas Corpus: 
0 530 General 
0 535 Death Pawky 
0 
540 Mandamus & Othry 
0 
550 Civil RIgNs 
0 
555 Prison ConditNn 
06'70 Tue. (U.S. Finkel& 
or Defensive) 
0 1171 IRS -Teed Pally 
26 USC 7609 
V. ORIGIN 
(Mem an "X" in One Box Cary) 
Appeal to District 
,21 I Original 
n 
2 Removed from 
0 
3 Ro-filed-
Proceeding 
Stale Cowl 
(see VI Delon) n 4 ReilDaled or Cl 5 Tanoth
ranstrffed
disurr
l
Reopened 
(sPocifY) 
Cl 6 IMituip
kiddon
sirici 
CI 7 itr agilfslifromm
e
Judgment 
VI. RELATED/RE-FILED 
(korarsch .o. 
CASE(S). 
mood meek 
a) Ite-Med Case 0 YES (€) NO 
JUDGE Kenneth A. Marra 
b) Related Cases GIVES 0 NO 
K
DOCET 
ER Sec Attached 
NUMB
VII. CAUSE OF 
ACTION 
VIII. REQUESTED IN 
COMPLAINT: 
ABOVE INFORMATION IS TRUE & CORRECT TO 
SIGNATURE OP AITORtjEY OF RECORD 
THE BEST OF MY KNOWLEDGE 
)AaNewiwas— LA) 
e the U.S. Chid Statute under which you are filing and Write a Brief Statement of Cause (Do sot cite Judvdleilonal statutes unless 
dl entity): 
18 U.S.C. 2255 (Predicate Statutes 18 U.S.C. 2422(6), 2423(6), 2423(e), 2251, 2252, 2252A(aX1), 2252A(g)( I) 
and 15911 
LENGTH OP TRIAL via 4 
days estimated (for both sides to try entire cue) 
0 
CHECK IP THIS IS A CLASS ACTON 
DEMANDS 
CHECK YES only if demended in complaint: 
JURY DEMAND: 
Wisfa is No 
UNDER
 23 
DATE 
*Rio 0.1 
TOR OFTICEr 
n
AMOUNT?S. Z.> °WM" 
7C /RIP? 
041/17 
EFTA00175446

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 
EFTA00175447

Case 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 1 of 22 
IN THE UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF FLORIDA 
JANE DOE No. 101, 
Civil Action No. 9:09-cv-80591-KAM 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
FIRST AMENDED COMPLAINT AND 
DEMAND FOR JURY TRIAL 
FIRST AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL 
Plaintiff, Jane Doe No. 101, 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 No. 101, was a 
resident of Palm Beach County, Florida. 
2. 
This Complaint is brought under a fictitious name to protect the identity of 
Plaintiff, Jane Doe No. 101, 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, 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. 
EFTA00175448

Case 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 3 of 22 
II. 
Defendant's plan and scheme reflected a particular pattern and method. 
Defendant coerced and enticed impressionable, vulnerable, and relatively economically less 
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. 
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 sexually 
explicit photographs and/or videos of the underage girls' for Defendant without their knowledge. 
Defendant would pay the procurer of each girl's "appointment" hundreds of dollars. 
3 
EFTA00175449

Case' 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 5 of 22 
enticing the then minor girl to engage in sexual acts with another female in Defendant's 
presence. 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. In order to facilitate the daily exchanges of money for sexual assault and abuse, Defendant 
kept U.S. currency readily available. 
16. 
As previously stated in paragraph 14, Defendant displayed photographs of nude 
underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. 
Virgin Islands. Upon information and belief, some of the photographs Defendant's possession of 
Defendant were taken with hidden cameras set up in his home in Palm Beach. On the day of his 
arrest, police found two hidden cameras and photographs of underage girls on a computer in 
Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken 
lewd photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have 
transported lewd photographs of Plaintiff (among many other victims) to his other residences and 
elsewhere using a facility or means of interstate and/or foreign commerce. Upon information 
and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were 
confiscated by the Palm Beach Police Department during its execution of a search warrant of 
Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those 
photographs are still in the custody of law enforcement. 
17. 
Defendant, Epstein, traveled to his mansion in Palm Beach for the purpose of 
luring minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to 
contact these minor girls for the purpose of coercing them into acts of prostitution and to enable 
himself to commit sexual battery against them and/or acts of lewdness in their presence, and he 
conspired with others, including assistants and/or his driver(s) and/or pilot(s), and his socialite 
5 
EFTA00175450

Case' 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 7 of 22 
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. 
19. 
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. 
20. 
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. 
21. 
As a result of these encounters with Defendant, Plaintiff, Jane Doe No. 101, has in 
the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, 
emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, 
confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, 
invasion of her privacy, and other damages associated with Defendant's controlling and 
manipulating her into a perverse and unhealthy way of life. 
22. 
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 
7 
EFTA00175451

Case 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 9 of 22 
26. 
Defendant, Jeffrey Epstein, used a facility or means of interstate and/or foreign 
commerce to knowingly persuade, induce, entice, or coerce Jane Doc No. 101, 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, or attempted to do so, pursuant to 18 U.S.C. § 2255 in 
violation of 18 U.S.C. § 2422(b). 
27. 
Plaintiff, Jane Doe No. 101, 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. 
28. 
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 continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 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 No. 101, 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. 
9 
EFTA00175452

Casa 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 11 of 22 
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 Sexual Exploitation of Children pursuant to 18 U.S.C. 6 2255 in 
Violation of 18 U.S.C. 22511 
33. 
Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 24 above. 
34. 
Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, or coerced the 
then minor Plaintiff, Jane Doe No. 101, 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 City, Palm Beach, Santa Fe, 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 in his home in Palm Beach. On the day of his arrest, police 
found two hidden cameras and photographs of underage girls on a computer in Defendant's 
home. 
Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd 
photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have transported 
lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere 
using a facility or means of interstate and/or foreign commerce. Upon information and belief, 
one or more sexually explicit photographs of Plaintiff that were taken when she was a minor 
were confiscated by the Palm Beach Police Department during its execution of a search warrant 
of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those 
photographs are still in the custody of law enforcement. 
11 
EFTA00175453