EFTA00192835

Dy signifia this agreement. Epstein usons and eertilks that mari of dies. Items is 
mataial Io Nb agreement and If supported by independall eawideration and Ne a lunch 
°Demy onc of the... condition; alloua the United Steel to edect to terminate the agnement 
and to invertigke and protocole Epstein and any °the; individuel or entity te dey and ail 
Coderai offenses 
sysigningthis agreement, Renias usent and outilles thmhe mare °tee (euh.: 
Uw Shah Arceiximent to the Coralituion of the United States uovides 141 ln a11 uirninal 
prosecutions the keuao1stioll enjoy the right to a spzedy and publie trid. Esowin furexr 
is 'watt dut Ruk Ill(b) of the Redent{ Rulea ofCriminel Procedtae provides dut the Cowt 
may &kolas an 
Infonnation, or complaini for traweessuy delay it pteartaing 
a charge to the Grand Rn, Ming an Informatiog ce ln bringing a Uri:adent to trial. Epstein 
hereby soumets that the United States Attorney for ne Southem Distrietof Floride de r« sikh 
proseseution Epstein egree and contenu thal anyckley Dom the due of titis Agnerunt to 
the date of initiation of prou:notion, 03 provided for th the tenu tantes:cd herein, thall te 
dan
 be a neeessary *lapa Alamos mue«, and he hcreby %s'Iwo anydefense b mach 
proxoution on the t'oued Nat nich delay operatcd w deny him nets Linder Rule 48(b) of 
the Roderai Rides of enterrai Procedwe and the Sbilh Arnendmentto the Constitution of the 
UnitedStaffatom speedy trial or to bu lie proseeutionby tesson of the moins of the 'talle 
of limitations for a pulod of monte <quai la Na period banco the signIng of Une 
0g:cernent and the kaaeh of US OgIVellall 03 us th'« offensa that vere the subito of the 
grand jury's Investigation. Epstein further muta and ratifia tint he undenumda Mat the 
Flfth Amenament and Rule 7(a) of the Roderai Rule. of Crimiral Wou:dure Koulak daall 
Mordes mut lys charged in en {cillement praentod to a grand Jury. Epstein hereby aigres 
and (CeSetw the if • prosecution apaisai him h irntinned for any offense that usis the 
'objecter0e grandjuria inwangation, il may be by way of anInfonnwion sIgned and filai 
by the United States Anone); end hereby nives Ma rie to be Indktcd by e gnnd jury as 
ha any aie offense, 
lit 
tyy 
lff 
hie 6of 7 
Case No. 08-80736-CV-MARRA 
P-011809 
EFTA00192855

By signing Ibis agreement, Epstein asserts and certifies that the above has been read 
and explained to him. Epstein hereby states that be understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
Dated:  77P/4" 
Dated: 
Dated: 
A. MARIE VTLLAFARA 
ASSISTANT U.S. ATTORNEY 
OERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
Page 7 of 7 
Case No. 08-80736-CV-MARRA 
P-01 1810 
EFTA00192856

By signing this agreement, Epstein asserts and certifies that the above has been read 
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
Dated: 
Dated:  HD 7 
Dated: 
A. MARIE VILLAFARA 
ASSISTANT U.S. ATTORNEY 
JEFFREY EPSTEIN 
EFCOL 
ES Q. 
OUNSEL TO JEFFREY EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
Pogo 7 of 7 
Case No. 08-80736-CV-MARRA 
P-011811 
EFTA00192857

By Arniog :Ms Lirknamt, PosWai steers end catnips NY the above Ina bran IS 
ad explained whim. Epsiola hereby macs the he uodastsais the coodEloca of Mt Non. 
Erossorrtion Aryirsmeat sod wets to comply with them 
R. ALEXANDER ACOSTA 
%MIMED SIAM ATTORNEY 
Mud: 
Deb!:  
Oast 
HY: 
A. MARIE YILLAPA9A 
ASSISTANT US ATTORNEY 
JEFFREY EPSTEIN 
ATTORNEY FOR EIFTIO3Y EPSOM 
hp /of 7 
Case No. 08-80736-CV-MARRA 
P-01 1 8 12 
EFTA00192858

IN RE: 
IMIESTIGA11074 OP 
JEMMY IIPSTIPN 
612jamiamm
twor 
IT APPEARING that W pullet seek to elerity cenaln peosisloas «page 4, puma 7 
of Oa Non,hosccutIon Agnarnan Nation': 'pongees* 7), Wu agreement Is neodiflod ot 
%Porn: 
7A 
The United States tat the right to au@ to an Indopendmt ettedftaity the responsibility 
ftr consulting with ted, subject to the good YON apron; of Epsteires counsel. relict* 
Wt money reftatiftetive for els ladiviehmis Wonted ur/.<: to Agyeemenl. IS No 
lirfted %us elects 4> assign this rospottititey to at. iftetepenteM thitatarty, boa the 
Undid States end P.pstelsa robin the right to make µok ION objemloas to We eummey 
npiesenusftvo rvapasied by the Intl:widen, third-pray ?dot to the Mn ckalpariees of 
the anomey represeabilve. 
70. 
lbc panics will jointly moans a short veekan nsbmIssicm to No Indowklent thInSparty 
:exalting the solo piths atterney roprescntatins and regaiding Epocein's Agromert on 
pay wok attorney rtmeoentethe hit te her stouter ontoussey hearty rate tot tronstating 
toch *Cm subject to i7e pfterisken of prograph C. Infra. 
7C 
Piesewit to additional paragraph 7A,E➢srin/as,Ereedlo py We fees or the ottomey 
nyernaftstive telakd by the ladepenclud ihtd patty.11t pcooision, hosnwr, stall ea 
obligate Pastel» to pay the fee and cot of oftneolod inolun nw «Silts* b;',,
;tin« comblerelce of ',medal fettleincm. en °nano teprestrgatIn elects to flit e 
corium.: lovesoit penman. to I8 V.S.C. t 2235 or cleat to pate Sty mho: waited 
,7medY. the Pun rif h 7 obitgatilin of Ne Atnemeet to pay the togs of the eteftecy 
repitscralive,M opposed to any netstory et oft* obligilkot to pay reat:neifie 
attorneys foes sad costs mots el those Oallehlig k t 2253 to boe: doe cons of Ne annrey 
repextmelve. shall caw. 
Case No. 08-80736-CV-MARRA 
P-011813 
EFTA00192859

Ey t;p:ng Mb Addentkm, Efmcb Isme end meien GA1 iba above km boer iod ani 
espisIned b Mm. !nuk henby. sist Pat te vederrards OM GhlifiCatiord CO We Non-
Pr oucuton Agraimen1 and *pm to tomply wkihztote. 
R. ALEXANDER ACOSTA 
VinTED STATER ATTOMEY 
A. MARE VII1APA A 
ASSISTANT VS. ATTORNEY 
Dáie.1  
ril
-
Os& 
Dw.* 
GERALD LEPCOURT,ESO. 
COUNSEL TO MPFREY MIEN 
LILLY ANN SANCHEZ. ESQ. 
ATTORNEY POR WEM ETSTEN 
Case No. 08-80736-CV-MARRA 
P-011814 
EFTA00192860

By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
Dated: 
Dated: 
Dated: 
A. MARIE VILLAFARA 
ASSISTANT U.S. ATTORNEY 
JEFFREY EPSTEIN 
RALD LEFCO r RT ESQ. 
COUNSEL TO JEFFR Y EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
Case No. 08-80736-CV-MARRA 
P-011815 
EFTA00192861

By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with than. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
Dated: 
Dated: 
Dated: )
219"" 
A. MARIE VILIAFAFIA 
ASSISTANT U.S. ATTORNEY 
JEFFREY EPSTEIN 
OBRALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY ANPPSANCHEZ, ES . 
ATTORNEY FOR JEFFREY EPSTEIN 
Case No. 08-80736-CV-MARRA 
P-011816 
EFTA00192862

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
R ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
DELIVERY BY FACSIMILE 
Lilly Ann Sanchez 
Fowler White Burnett, PA 
1395 Stickel! Ave, le Floor 
Miami, FL 33131 
Re: 
Jeffrey Epstein 
Dear Ms. Sanchez: 
99N£ !Street 
USK FL 13112 
003)961.9100 - Tetteatle 
O03)3366444 - FaesteSk 
December 19, 2007 
I write to follow up on the December le meeting between defense counsel and the Eps 
prosecutors, as well as our First Assistant, the Miami FBI Special A ent in Charge and mysel . 
'Section 2255 provides that: Imlay person who, while a minor, was a victim of a violation of (enumerated SCCII0115 
of Title IS] and who suffen personal Injury as a result of such violation ... may sue in any appropriate United States 
DiStliet Court and shall recover the actual damages such person sustains and the cost of the suit, Including a 
reasonable attorney's fee." 
Case No. 08-80736-CV-MARRA 
P-011817 
EFTA00192863

With this in mind, I have considescd defamecount' nouns, rep/ding the Section 2255 
prtions of the Agreement. As I previously absent:Iour Intral has been to place the victims in the 
woe position as they would have been had Mr. Epstein been convicted al trial. No more; no less. 
From our muting. It appears Mu the defense wets that ibis was the Weed. Uwing the comae of 
nesoliMions that intent was reduced 10 tithing in Pang aph3 7 and 8, which all wrote previnsfr. 
was fa: from simple to undersuod. I meld thus propose that we solve our eksagitements over 
ink:veterans by saying precisely whet we mean in a simple fashion. I would replace Paragraphs 7 
sod S with the following language: 
"Any person, who while a minor, was a victim of a violation of an offense enumerated in 
Title IS. United States Code. Section 2255, will have the same riche to proceed undo 
Secdon nss 14 ale would have had. if Mt.Epsteinbeen tried federally and convicted of an 
enumerated °Menu- For ImPose Of imPlenwnling this awagraph, the United Saks shall 
provide Mr. Epstein's atkencys with a list of individuals *horn it was petpued toriame in an 
44kt:oral as victims of an exonerated offense by Mr. P.pskin Any judicial authority 
ink:pitting thin provision, including any euthorityiklennining which evidentiary burdens if 
any e plaintiff must meet, shall consider that it is the intent of the panics In place these 
identified 1114111113 in the 1411% position ILI they would have been had Mt. Epstein been 
convicted al vial. No mac; no kis." 
2 
Case No. 08-80736-CV-MARRA 
P-011818 
EFTA00192864

Srstrely. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
3 
Case No. 08-80736-CV-MARRA 
P-011819 
EFTA00192865

U.S. Department of Justice 
Washington, D.C. 20530 
June 23, 2008 
Jay Lefkowitz„ Esq. 
Kenneth Starr, Esq. 
Kirkland and Ellis LLP 
777 South Figueroa Street 
Los Angeles, CA 90017 
Gentlemen: 
This Office has completed a thorough review of the U.S. Attorney's handling of the matter 
involving your client, Jeffrey Epstein. We have received and reviewed your letters of May 19, 
June 3 and June 19, 2008, the attachments to the June 19 letter, as well as your submissions to 
the Criminal Division and the U.S. Attorney's Office. Additionally, we have reviewed en 
extensive set of materials provided by the U.S. Attorney's Office and conferred with a number of 
highly experienced Department attorneys about this matter. The Deputy Attorney General has 
also been briefed. 
As you know, the Department of Justice vests considerable discretion in its U.S. Attorneys, and 
the Deputy Attorney General will intervene in only the most unusual of circumstances. We do 
not believe such intervention is warranted here. Even if we were to substitute our judgment for 
that of the U.S. Attorney, we believe that federal prosecution of this case is appropriate. 
Moreover, having reviewed your allegations of prosecutorial misconduct, and the facts 
underlying them, we see nothing in the conduct of the U.S. Attorney's Office that gives us any 
reason to alter our opinion. 
cc: 
Alex Acosta 
Sincerely, 
John Roth 
Senior Associate Deputy Attorney General 
Case No. 08-80736-CV-MARRA 
P-011820 
EFTA00192866

FEDERAL SENTENCING GUIDELINES CALCULATION 
(Using November 1.2004 Guidelines Manual} 
Each count of §§ 1591, 2422(b) and 2423(6): 
Base Offense Level under 2G1.3: 
Offense involved sexual contact: 
24 
+2 
26 
Counts do not group, so add 5 levels for more than 5 units, pursuant to 3D1.4 
Offense Level 31 
Apply Repeat and Dangerous Sex Offender against Minors enhancement at 4B1.5 
Total Offense Level 36 
Assuming Criminal History Category!, advisory guideline range is 188 - 235 months with 
lifetime supervised release. 
Case No. 08-80736-CV-MARRA 
P-011821 
EFTA00192867

CONFIDENTIAL PLEA NEGOTIATIONS 
TERMS OF EPSTEIN NON-PROSECUTION AGREEMENT 
■ 
Epstein pleads guilty (not nolo contendere) to an Information filed by the 
Palm Beach County State Attorney's Office charging him with: 
(a) 
lewd and lascivious battery on a child, in violation of Fl. Stat. 
800.04(4); 
(b) 
solicitation of minors to engage in prostitution, in violation of Fl. 
Stat. 796.03; and 
(c) 
engaging in sexual activity with minors at least sixteen years of age, 
in violation of Fl. Stat. 794.05. 
■ 
Epstein and the State Attorney's Office make a joint, binding 
recommendation that Epstein serve at least two years in prison, without any 
opportunity for withholding adjudication or sentencing; and without 
probation or community control in lieu of imprisonment. 
■ 
Epstein agrees to waive all challenges to the information filed by the State 
and the right to appeal. 
■ 
Epstein agrees that, if any of the victims identified in the federal 
investigation file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest 
the jurisdiction of the U.S. District Court for the Southern District of 
Florida over his person and the subject matter. Epstein will not contest that 
the identified victims arc persons who, while minors, were victims of 
violations of Title 18, United States Code, Sections(s) 2422 and/or 2423. 
■ 
After Epstein enters his state court plea and is sentenced, the FBI and the 
U.S. Attorney's Office will close their investigations. 
Case No. 08-R0736-CV-MARRA 
P-011822 
EFTA00192868

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 1 of 19 
IN THE UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF FLORIDA 
JANE DOE No. 101, 
Plaintiff, 
VS. 
JEFFREY EPSTEIN, 
09 - 8059 1 
Civil Action No. 
CIV-MARRP 
MAGISTRATE JUDGE 
JOHNSON 
Etrpy  ,fir 
 DC
INTAKE 
APR 1 7 2009 
STEVEN M. LARIMORE 
CLERK U.S. OIST. CT. 
S.O. OF FLA. MIAMI 
COMPLAINT AND 
Defendant. 
DEMAND FOR JURY TRIAL 
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 
I. 
At all times material to this cause of action, Plaintiff, Jane Doe, 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, 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 Bulb  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. 
Podhunt Orseck, P.A. 
25 West Hagler Street Suite 800, MWµ FL 33130, MINA 3053582800 Fax 305358.238I • For Lauder:10e 051.4624346 
www.podhuyst corn 
CILSC No. 08.80736-CV-MARRA 
P-011823 
EFTA00192869

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 S6.8 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 
Podhurat Orseck, P.A. 
2 
2s West Flagler Street Sae 800, Mkerd, FL 33134 WKS 3053582000 Pax 301.158.2382 • Pert Lauderdale 954.463.°46 I 
www.podhwitaom 
Case No. 08-80736-CV-MARRA 
P-011824 
EFTA00192870

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 3 o(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 Orscck, P.A. 
3 
25 West Flaglier Strait, Suite 500, Miami, FL 33130, Mimi 3C635&2200 PM 3053582382 • loon Isuderdele %tate* 
Case No. 08.80736-CV-MARRA 
R-011825 
EFTA00192871

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. 
Upun 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 Epstcin, 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 Orsecic P.A. 
4 
23 West Flagler Sate, Suite 800, Miami. FL 33130, Mad X6.35511300 Pax 3(59582342 • Port Lauderdale 954.461.4346 
veww.podlturattom 
Case No. 08-80736-CV-MARRA 
P-011826 
EFTA00192872

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, Ncw Mexico, and the U.S. 
Virgin Islands. Upon information 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 thought 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 Epstcin'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 Was Mar Street Suite 800. Miami. Fl. 33130, Miam1305358.2800 Fax 305356238 • Port Louden:W.9544634346 
www.podhuntscom 
Case No. 08-80736-CV-MARRA 
P-011827 
EFTA00192873

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 Wed Hasler Street, Suite KO, Wail, FL 33130, Mond 3053532800 Pax 305358.2382 • Port Lauderdale 954.4614346 1 
www.podtauslcom 
Case No. 08-80736-CV-MARRA 
P-011828 
EFTA00192874