EFTA00210859

Cease 211a-letetiBERKAXIVI Document 290-2 nEnteted EttiSDSIDDElortI415,01112012915 Pane bfc1/7 
27 
photographs of Plaintiff, Jane Doe No. 102, 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 Sheriff's Office 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. 
59. 
As previously stated in paragraph 23, 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. Defendant's preference for underage girls 
was well-known to those who regularly procured them for him. 
60. 
Plaintiff, Jane Doe No. 102, 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. 
61. 
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, 
separation from her family, 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 
21 
Podhurst Orsecic, P.A. 
overnment Exhibit B 
Cos., N.,. 0 00730 CIV MARRA 
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.158.2800 Fax 305.3582382 • Fort Lauderdale 954.463.4346 
www.podhurstcom 
EFTA00210879

CaseseginAot416588OkX61 Docuarnert 290-E nEnteteth etb_SIMoDoitkii15,011121142915 Pajegt222,t27 
27 
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 arc permanent in 
nature, and Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 102, 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 EIGHT 
(Cause of Action for Transport of Child Pornoeraphv pursuant to 18 U.S.C. 6 2255 in 
Violation of 18 U.S.C. & 2252A(a)(111 
62. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 32 above. 
63. 
Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via 
computer and/or facsimile in or affecting interstate and/or foreign commerce child pornography 
in violation of 18 U.S.C. § 2252A(aXI). 
64. 
Plaintiff, Jane Doe No. 102, 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. 
65. 
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, 
separation from her family, and other damages associated with Defendant's manipulating and 
22 
Podhurst Orseck, P.A. 
overnment Exhibit B 
Cel.,e it— 0 8073C C IY MA1111A 
25 West Flagler Street, Suite 800. Miami, FL 33130, Miami 305.358.2800 Fax 305358.2382 • Port Lauderdale 954.463.4346 
www.podhurn.com 
EFTA00210880

Cease 5041ac2465680kKitl Document 290-E n Enteted aspsroocatleS/011/202015 P agog eabfcrt7 
27 
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 figure. 
WHEREFORE, Plaintiff, Jane Doe No. 102, 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 NINE 
(( au cc of Action for Engaging in a Child Exploitation Enterprise pursuant to 18 U.S.C. 
2255 in Violation of 18 U.S.C. S 2252A(01 
66. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 32 above and Counts One through 
Eight above. 
67. 
Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, 
as defined in 18 U.S.C. § 2252A(gX2), in violation of 18 U.S.C. § 2252A(gX1). As more fully 
set forth above, Defendant engaged in actions that constitute countless violations of 18 U.S.C. § 
1591 (sex trafficking of children), Chapter 110 (sexual exploitation of children in violation of 18 
U.S.C. §§ 2251, 2252(a)(1), and 2252(AXaX1)), and Chapter 117 (transportation for illegal 
sexual activity in violation of 18 U.S.C. §§ 2421, 2422, and 2423). As more fully set forth above 
in paragraphs 9 through 32, Defendant's actions involved countless victims and countless 
separate incidents of sexual abuse, which he committed against minors, including Plaintiff, in 
concert with at least three other persons. 
23 
Podhurst Orseck, P.A. 
overnment Exhibit B 
25 West Hagler Street Suite 800, Miami, F1.33130, Miami 305.358.2800 Fax 3053582382 • Fort Lauderdale 954.463.4346 
www.podhunt.com 
EFTA00210881

Cased, SDSRActaititWAPIv1 Document 290-EnErected StiSD91CODoilkibb011121Y2B15 PlitgigE2L24cli 7 
27 
68. 
Plaintiff, Jane Doe No. 102, 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. 
69. 
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, 
separation from her family, 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. 102, 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: May 1, 2009 
ktta 
Pirs44—art...6. _12 
Ka E 
Robert C. Josefsbferg, Bar No. 0408563
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) 
riosefsberganodhurst.com 
24 
Podhurst Orseck, P.A. 
overnment Exhibit B 
25 West Hagler Street, Suite 800, Miami, FL 33130, Miami 305358.2800 Fax 305358.2382 • Fort Lauderdale 954.463.4346 
www.podinustcom 
EFTA00210882

CeseitS 99-a-c-,8003660Whil Doturrieral 290-E n Entertect fittSDSIDElactlet 01112042915 Nilgegt225t3/7 
27 
kezell(alpodhurst.com
Attorneys for Plaintiff 
DEMAND FOR JURY TRIAL 
Plaintiff demands to have her case tried before a jury. 
866A Lir-1444-c 
c-• 
Robert C. Jose
 Bar No. 040356 
Katherine W. Ezell, Bar No. 114771 
• 
25 
Podhurst Orseck, P.A. 
overnment Exhibit B 
Oe..5 Nei. 0 0073C 
IV MAMA 
25 West Flagler Street. Suite 800. Mlamj, FL 33130, Miami 305358.7800 Fax 3053582382 • Fort Lauderdale 954.163.4316 
wrnv.poilhurstcorn 
EFTA00210883

cassessac-tesessemoim Document 290-Eng:sleeted EtiSDSIDDE1oxtre65,011/200215 NV40264:127 
27 
'J 544 (Rew. 1145) 
CIVIL COVER SHEET 
The JS 44 civil raver Shed 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 loan, approved by the Judicial Conference of the United Slates in September 1974. isrequired for the use of the Clat of Court for the purpose of initiating 
the civil docket sheet (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) 
NOTICE: Attorneys MUST Indicate All Re
-fled Cases Below. 
I. (a) PLAINTIFFS 
Jane Doe No. 102 
(b) County of Residence of First Lined Plaintiff 
West Palm Beach 
(EXCEPT IN US. PLAINTIFF CASES) 
(C) Attorney's (Mira Name. Aden. and Telephone Number) 
Robert C. Josefsberg. Esq./Katherine W. Ezell, Esq. 
Podhurst Orseck, P.A. 
25 W. Flagler St., Suite 800 
Miami Fl nitro 
0`11
-#%- CA/ - .806st-
(d) Check County Where Action Arose. 1>IIA511 D s DT 
1 Mon ROI 
II. BASIS OF JURISDICTION wise an - X 
(Jnc Box Only) 
II I 
U.S. Mos crtunent 
,/1I Federal Question 
Plaintilf 
ICS Gosemment Not a Party) 
ET 2 U.S. llostnuncnt 
Defendant 
s 4. 
Dluye 
D 
PALM BEACH 
nat. 
4 
Diverse) 
Dedicate Cenendup of Pangs in hem III) 
DEFENDANTS 
Jeffrey Epstein 
Courtly of Residence of Ent Listed Defendant 
West Palm Beach 
(IN U.S. PLAINTIFECAS"OnL9 
 
NOM IN LAND CONDEMNATION C/Warba&f, JJ) 
114 
LAND INVOLVED. 
INTAKE. 
f
ri
Attorneys (IOrson) 
MAY . 1 2009 
Jack A. Goldberger, Esq., AtterburX Gold
ger, et al.. 250 S. 
JIJ
Australian Ave., 81400, West Palm'BeatthkFENIS4Rhilt1Sobeit 
CLEM< ' A O'er 
O MARTIN O ST. LUCIE 
I INDISIEROMLAI 
E 
MIJIMERCBA 
HIGHLANDS 
III. CITIZENSHIP OF PRINCIPAL PARTIESietwe an -X- is Ott Box for Plantar 
(For Diversity Caw WTI 
and One Box for DeRridarn 
PIT 
DEE 
PIT 
DVS 
Citizen of Ibis State 
7' 
I 
I 
Incorporated or Principal Place 
1 
4 
0 4 
of Bonnets In This Stale 
Citizen of. nother State 
0 
2 
O 2 
numerated and Motion Place 
O 
5 
0 5 
of Business In Another Sate 
Citizen or Subject of • 
0 
3 
1 
3 
Foreign Ninon 
Fc.eign COUTilly 
0 
6 
3 6 
L 
COMet 
TO IttS 
F0RFEITURERENALTY 
BANERIJPTCY 
DINER SI A IllEs 
1 
110 Inmate 
120 Marine 
130 Stiller AM 
140 Negotiable Immonerd 
150 Recopy of °save/mom 
& Enforcement of Judgment 
151 Medicare Act 
152 Recovery of Defaulted 
Student Loans 
(Excl. Veterans) 
0 153 Recovery of Themownent 
of Vonan's Benefits 
0 160 Sseckholden' Suits 
0 1900ther Contract 
0 195 Contract Product Liability 
O 196 Franchise 
PERSONAL INJURY 
PERSONAL INJURY 
El 310 Aldan 
0 
362 Personal Injury • 
0 315 Militant Pietism 
Med. Malpractitt 
Liability 
O 365 Personal Injury - 
0 320 Assault. Libel a 
Product Liability 
Slender 
O 363 Asbestos Personal 
1 310 Federal Employers' 
bitty Prockn 
Liability 
Liability 
0 MOMarine 
PERSONAL PROPERTY 
0 M5 Maine Product 
I 
370 Offer Fond 
Libility 
3 371 Truth UlLembew 
0 350 Motor Vchick 
n MO Orher Miami 
0 353 Motor Vehicle 
Property Damage 
Product liability 
n 385 Omen). Damme 
El 360 Other Personal 
Product liability 
bluer 
0 610 Agriculture 
0 620 Other Food & Drug 
3 623 DrIlit R erased kirure 
of Property 21 USC 881 
0 630 Liquor Laws 
0 640 R.R. & Truck 
0 650 Airline Rees. 
0 660 Occupational 
SaferyMealib 
0 690 Other 
0 422 Appeal 28 USC 158 
0 423 Withdrawal 
28 CSC IP 
400 Slate Rennonloamem 
410 Among 
430 Banks and asedung 
430 Commerce 
460 Deponimon 
470 Racketed Influenced and 
Corrupt Organizations 
480 Consumer Credo 
490 CabloSat TV 
810 Seketioe Service 
850 SeasitiesConnodince 
Eachinge 
875 Customer Clullenge 
12 USC3410 
890 Other Stansory Actions 
891 Agenkural Acis 
892 Economic Subilin ion Act 
893 Emironmental Mann 
894 Energy Allocation An 
895 Freedom or Intonation 
Act 
900Appcal of Foe Duennination 
Under Equal Access 
to Justice 
0 950 Cantinatornlity of 
Staie Statutes 
MB1,Tildriattrelit: 
J S20( onngtas 
0 830 Pain 
0 S40 Tnidunark 
LABOR 
SOCIAL SfURITY 
1 361 111A 1139318 
0 862 Black Lung (921) 
0 863 DIVAVD1%6W ‘405(g)) 
0 864 SSID Tide XVI 
0 865 R51(40500) 
0 710 Fair tabor Stiodards 
Ad 
0 720 LabooMpnt. Relations 
0 
T30 LabonMgmt.Reponing 
& Disclosure Act 
0 740 Railway Labor Ad 
0 79000ter Labs Lanni 
0 
791 Einpl Ret. Inc. 
Security Act 
FEDERAL TAX SUITS 
I 
REAL PROPERTY 
CIVIL RIGHTS 
PRISONER PETITIONS 
0 870 Ines (US. Plaintiff 
or Deluders) 
O 871 IRS— this paw 
26 USC 7609 
0 210 Land Condemnation 
0 220 Forecbsure 
O 230 Rua Inst & Ejectment 
O 240 Tons tot and 
O 245 Ton Product Lida ley 
O 290 All Other Real Property 
0 441 Voting 
0 442 Employment 
0 443 Ilona& 
Accommodations 
O 444 Waite 
0 445 Amer. wilksabithies . 
EmPloYmen 
0 446 Amer. anDirobilitics • 
Other 
3 440OtherCivil Rights 
1 
510 Motions to Vat 
Suitcase 
Habeas Corpus: 
1 
530 General 
1 
535 Death Penaky 
1 
540 Mandamus & On 
CI 550 Civil Rigs; 
0 
555 hisce Condition 
V. ORIGIN 
(Place a 'X" imOne Box (My) 
Transferred from 
I Original 
fi 2 Removed an 
r1 3 
Re-filed- 
0 
4 Reinstitute( O 5 amtherdisuict 
0 6 Mtdlidistrict 
Proceeding 
to Court 
(see VI below) 
y) 
litigation 
Appeal to District 
CI , 
idge from 
' 
Magistnitc 
Jo:lament 
VI. RELATED/RE-FILED 
CASE(S).
aeatl 
(See lunation' 
patch. 
a) Re-filed Case 0 YES ja NO 
JUDGE Kenneth A. Marra 
b) Related Cases OYES CI NO 
DOCKET See Attached 
NUMBER 
VII. CAUSE OF 
ACTION 
(tense U.S. ('nil Statute under which you ace filing and Write a Brief Statement of-Cause (Do Dot cite jurlidktional statutes )Mess 
dIvenhy): 
18 U.S.C. 2255 (Predicate Statutes 18 U.S.C. 2422(b). 2423(b), 2423(e), 2251, 2252. 2252A(a)( l), 2252A(g)( I) 
LENGTH OF TRIAL via 4 
days estimated (for both sides to try entire ease) 
O CHECK IF THIS IS A CLASS ACTION 
DEMAND S 
CHECK YES only if demanded 'n complaint 
UNDER F.R.C.P. 23 
JURY DEMAND: 
10 Yes p No 
VIII. REQUESTED IN 
COMPLAINT: 
ABOVE INFORMATION IS TRUE & CORRECT TO 
TIDE BEST OF MY KNOWLEDGE 
SIG TURE 01: ATTORNEY 1 7
0 
DATE 
R 06FTCE USE ON.ea
AMOUNT4 
RECEIPTAt 
 
Cal.Ift B32)
Case No. 013-ID7303-_Cly-MARRA) 
VS 
AD 
5)1) 01 
EFTA00210884

Cam® 99a-T-CIRCUSPKAMA Document 290-EnEnoEted frtiSIALDE1oit1e5011120/2915 PEgsge2bfclf 7 
27 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
WEST PALM BEACH DIVISION 
ATTACHMENT TO CIVIL COVER SHEET 
FOR: Jane Doe 101.v. Jeffrey Epstein 
VI: 
RELATED/RE-FIELD CASE(S): 
08-80069 
08-80119 
08-80232 
08-80380 
08-80381 
08-08804 
08-80811 
08-80893 
08-80993 
08-80994 
08-80469 
09-80591 
Government Exhibit B 
Case No. 08-80736-CIV-MARRA 
EFTA00210885