EFTA00212996

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, 
Defendant. 
09-80591 
Civil Action No. 
CIV-MARRP 
MAGISTRATE JUDGE 
JOHNSON 
COMPLAINT AND 
DEMAND FOR JURY TRIAL 
PILED by  en 
 D C 
INTAKE 
APR 1 7 2009 
STEVEN M LARIMORE 
CLERK U.S DIST. CT. 
S.0 OF FLA. MIAMI 
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 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 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. 
Podluust Orseck, P.A. 
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358 2800 Fax 305.358.2382 • Fort Lauderdale 954.46.3.4346 
www.podhunttorn 
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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 lauderdak 954.463.4346 
www.podhonst.com 
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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 
vnvw.podhuntack 
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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 
intimation. 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 305358.2800 Fax 305.3582382 • Fort Lauderdale 954.463.4346 
www.podhurst.cout 
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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 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 'nought 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. 
Atter 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 Hagler Street, Suite 800, Miatni, FL 33130. Miami 305.358.2803 Fax 305358.7382 • Fort Lauderdale 954.463.4346 
www.podhuotcom 
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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. 
IR. 
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 sec 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 33U0, Miami 305.3582800 Fax 305-358Z82 • Fott Lauderdale 954463.4346 
I 
www.podInustomn 
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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(b), § 2423(b), § 2423(c), § 2251, § 2252, § 2252A(a)(1), § 
2252A(g)(1), 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, 
7 
25 West Hagler Street, Suite 800, Miami, Ft 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 
www.podhurst.mm 
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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 Enaaae in Prostitution or 
Sexual Actin in, pursuant to 18 U.S.C. 4 2255 in Violation of 18 U.S.C. S 2422(68 
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(6). 
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 Orsecic, P.A. 
8 
25 West Hagler Street Suite 800, Misrule FL 33130, Miami 305.358.2800 Fax 305-358Z82 • Fort Lauderdale 954.463.4346 
www.podhunt com 
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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 I 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(f), 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 Raster Street. Suite 800, Miami, Ft 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.4634316 
www.podhurstcom 
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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 I 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(cX1), 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, 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. 
10 
25 West Flagler Street Suite 800, Miami, FL 33130, Miami 305358.2800 Fax 305.358.2382 • Fort Lauderdale 954463.4346 I 
www.podhurst.com 
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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. & 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 Flagler Street, Suite 800, Miami, FL 33130, Miami 305358.2800 Fax 305358.2382 • Fort Lauderdale 954.463.4346 
www.podhurst.com 
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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 jury. 
Podhurst Orseck, P.A. 
12 
25 West Flagkr Street, Suite 800, Miami, FL 33130, Miami 305 3582800 Fax 305358.2382 • Fort Lauderdale 954.4e3.4346 
www.podhunt.com 
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COUNT FIVE 
(Cause of Action for Transport of Visual Depiction of Minor Enaaaing in Sexually Explicit 
Conduct pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. & 2252(a)( I)) 
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 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 Street, Suite MO, Miami, FL 33130, Miami 305358 2800 Fax 306358.2382 • Fort Lauderdale 954.463.4346 I 
www.podhuntocin 
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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 Pornotraplpi pursuant to 18 U.S.C. 4 2255 in 
Violation of 18 U.S.C. 2252A(a)(1)1 
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 Resler Sheet, Suite 800, Miami. FL 33130, Miami M.358.28® Fax 305358.2382 • Fort Lauderdale 954.463.4346 I 
roww.podhuracout 
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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 Master Street. Suite 800. Miami, FL 33130, Miami 305.3582800 Fax 305358.2382 • Fort Lauderdale 954.463.4346 I 
www.podhurstoom 
EFTA00213010

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 Emitting 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 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)(1). 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 Hagler Street, Suite 600, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.1382 • Fort Lauderdale 954463.4346 t 
winv.podbutstcom 
EFTA00213011

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 17, 2009 
C• 
6• 1 
Robert C. Jose
 134:Tio. 040856 
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) 
riosefsbergeoodhurst.corn 
kezell@podhurst.corn 
Attorneys for Plaintiff 
DEMAND FOR JURY TRIAL 
Plaintiff demands to have her case tried before a jury. 
Robert C. Josefs 
Bar No. 04\326 
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) 
riosefsbergOnodhurst.com 
kezell@podhurst.com 
Attorneys for Plaintiff 
C • 
kon 
Podhurst Orseck, P.A. 
17 
25 West Flagler Street Suite 800, Miami, FL 33130, Miami 305358.2500 Fax 305.358.2382 • Fort Lauderdale 9544614346 
www.podhurst cam 
EFTA00213012

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 18 of 19 
eaJS 44 (Rev. 111051 
CIVIL COVER SHEET 
TheJS 44 civil cower sheet and the information contained herein neither replace nett Stapplernenl the filing and service ofplcadings or other parer* as required by law. c wept as pnw ided 
thy Weal rulesofCOWL This fain, approved by the Judicial Conferenceof the United Mates in September 1974. is required fortlw use of the Clerk of (-oust for Om nu those of Initiating 
the civil docket shoo. (SEE NSTRIXTKENS ON THE REVERSE OF THE FOAMY 
NOTICE: Attorneys MUST Indicate All Re-filed Cases Below. 
I. (a) PLAINTIFFS 
Jane Doe No. 101 
(b) County Of Raidawc of First Listed Plaintiff 
West Palm Reach 
(EXCEPT TN U.S. PLAINTIFF CASES) 
(C) Attorney's (Finn Name. Address. and Tekplane Nutrtherl 
Robert C. Joseisberg, Esq./Katherine W. Ezell, Esq. 
Podhurst Orseek, P.A. 
25 W. Flagler St., Suite 800 
Worn: RI Al I an 09__ 
so set 
n un% 
ND Check County Where Action Arose: 0 MIAMI- DADE 0 MONROE 0 BROWARD 41 PALM BEACH 0 MARTIN 0 ST. LUCIE 0 INDIAN RIVER 
DEFENDANTS 
Jeffrey Epstein 
County of Residence of Fill Lined Defendant Flit iff
(IN U.S. PLAINTIFF CA 
NOTE: IN LAND CONDEMNATION CASE USE THE LOCATION Of T I1F IRA 
LANDINVOLVED 
22rit 
D.G. 
APR 1 
Attorneys (ItKienva) 
Jack A. Goldberger, Esq., Atterbwy 
Australian Ave., #1400, West Palm 
STEVEN M..I
.RAORE 
v.6 0l
It • 
O OKEECHOBEE 
HIGHIANDS 
II. BASIS OF JURISDICTION once m'•X"in one Box Only) 
0 I 
U.S. Otwoomere 
„p 3 Federal Question 
Plaintiff 
HIS. (iammon& Not a Party) 
0 2 U.S. Covenment 
0 4 
Diversity 
fkfendant 
(Indicate Citizenship of Panics in hem IIII 
III. CITIZENSHIP OF PRINCIPAL PARTIES(PEt um^ ir.One Box for Plaintiff 
Fa Divas* Casa Only) 
PTE 
(Maas &DM State 
fawn of Another Mate 
Cozen or Subject era 
FORM COOS 
1 
2 
.1 
3 
DEW 
sod One Box for Defendant) 
ETV 
DEE 
I 
Incorporased or &moil Place 
of Business In Dus Mate 
0 
4 
14 
0 
2 
Incorporated and Prin. ipal Place 
of Business In Another state 
0 
S 
0 5 
0 
3 
Foreign Nation 
0 
6 
O 6 
I 
CONTRACT 
rotas 
PORSIMMERLNIALIT 
BANERVTCT 
OTHER STATUTES
0 1101rmaance 
0 120 Menne 
III 130 Miller Act 
0 140 Negotiable &Mani 
0 150 Recovery of Overpayment 
a Enforcement of ludpnent 
0 151 Medicare Act 
0 152 Reosvery &Defaulted 
Student Loans 
(Excl. Velcro& 
153 Rumen' of OkeTtunTcs 
of Veteran's1km% 
160 Stockholders' San 
190 Other Comma 
195 Comma Product Liability 
196 FROCAM 
PERSONAL INJURY 
PERSONAL INJURY 
El 310 Airplane 
0 
362 Panama Injury • 
0 315 Mirka Product 
Med. Malposetict 
Liability 
n 365 Personal Injury • 
0 320 Assault. libel & 
Product Lability 
Slander 
0 
368 Asbestos Personal 
0 330 Federal laroloyers' 
Injury Product 
Liability 
lability 
0 340 Marine 
PERSONAL. PROPERTY 
0 345 Manne Prodwi 
0 
37001MM:rata 
Liability 
0 
371 knob in Lending 
0 350 Motor Natick 
0 
380 Other Pena& 
0 355 Mae ‘'chick 
homy Damage 
Product Liability 
0 
385 Progeny Manage 
M 160 Other Personal 
Product lab& 
AMUR 
0 610 Apictilturt 
n 620 Other Food& Drug 
0 625 Diva Reamed Wane 
of Property 2I USC 88I 
0 630 Liquor Laws 
0 640 R.R. & Truck 
a 650 Airline Reg. 
0 660 Chortaltorel 
Salina's:olds 
0 690 Other 
0 422 Appeal 28 LSC 158 
0 423 Wishrhawal 
21 CSC 157 
400 State Reapportionment 
410 Manna 
430 Banks and Banking 
450 Commerce 
460 Deportation 
470 Racket& Influenced and 
Coma Ortanizations 
480 Consumer Credri 
490 CatkSai TV 
MO Selective Mrs& 
850 SecuritteaCcsnmoditiew 
PROPERTY RIGID'S 
0 820 Cab tight 
0 830 Patent 
0 840 Track ark 
LABOR 
SOCIALS/XI:R(1'Y 
0 710 Fan I Aber Sancta* 
Act 
II 720 LaboMmit. Rebhan 
0 710 Latechlamt Reponire 
& Disclosure Act 
0 740 Railway Lag Act 
1 7900th, Tahoe Litigation 
1 791 Enspl Ret. Inc 
Smutty Act 
I 861 HIA (1395th 
0 862 Black Lung (9231 
0 863 D1WODIWW (405(61) 
0 864 SSID Tkk XVI 
0 865 RSI (405(g)I 
&chow 
875 Custom& Challenge 
12 US(' 3410 
890Other Sum& ACliORS 
MI Agricultural Mt 
892 Economic Stabihnnion Act 
893 Environmental Matters 
894 Energy All-cation Act 
895 Freedom of Intonation 
Act 
900Appeal of Eh lkierminuat 
Under Equal Access 
krJustice 
0 950 Cannhatonathy of 
State Manses 
FEDERAL TAX SUITS 
) 
REAL mann 
CIVIL. RIGHTS 
PRISONER PETITIONS 
fl 870 Taxes (U S Plaintiff 
or Defendant) 
n 871 IRS Third Party 
26 I TS(' 7609 
210 Lad Condemnation 
220 Foehloata 
230 Rent LAIC a Ejectment 
240 Tons m Land 
245 Ton Product Lobilky 
290 All Other Real Properly 
0 MI Voting 
0 442 Employment 
0 M3 'lousing. 
Accommodations 
0 444 Welfare 
0 445 AS. w.DiSailiS - 
Employment 
0 446 AS. w.Diratilinek - 
Other 
TT 4I0 Other Civil Rights 
1 
GO Mot ions to Vacate 
Soden: c 
Habeas Capin: 
1 
510 General 
1 
535 Death Penalty 
1 
540 !thalamus & Other 
1 
550 Chil Rights 
0 555 Prison Conditton 
V. ORIGIN 
(Plat an -X-  in One Box Only) 
g/ 
Odin*, 
rt 2 Removed from 
II 3 Re-filed-
• 
Proceeding 
State Court 
(see VI Won) 
4 Reinstated or O 5 Trans erred front
anotha district 
Reopened 
OfmcifY) 
A 
to District 
6 Multidistrict 
CI 7 
g5 from
Magistrate 
Juderllatt
Litigation 
VI. RELATED/RE-FILED 
CASE(S). 
(See ingenaions 
shad page): 
a) Re-filed Case CI YES (ONO 
b) Related Cases OYES rl NO 
JUDGE Kenneth A. Marra 
DOCKET See Attached 
NU MUER 
VII. CAUSE OF 
ACTION 
Cie the U.S. Civil Statute under which you are filing and Write a Brief StaleittaIt of Cause (Do not cite jurisdictional statutes unless 
dhersity): 
18 U.S.C. 2255 (Predicate Statutes IS U.S.C. 2422(6), 2423(6), 2423(e), 2251, 2252, 2252A(aX I ). 2252A(g)(1) 
and 159t1 
LENOIR OF TRIAL via 4 
days estimated (for both sides to try entire case) 
O CHECK IF THIS IS A CLASS ACTION 
DEMANDS 
CHECK YES only if demanded in complaint: 
JURY DEMAND: 
[I
 YesP No 
VIII. REQUESTED IN 
COMPLAINT: 
UNDER F.R.C.P. 23 
ABOVE INFORMATION IS TRUE & CORRECT TO 
SIGN ATI RE OF ATTORNEY or RECORD 
DATE 
THE BEST OF MY KNOWLEDGE 
)AG1/41-trsajs.---& Us) • Ev-Q___ 
W/6, 
FOR (}FHCESSE
?ile
FP
Odd 
t1/7/Z) 
A V(11 
?S 
V 
RECFJPT I 
EFTA00213013

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 
EFTA00213014