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Case 9:09-cv-80591-KAM 
Document 9 
Entered on F LSD Docket 05/01/2009 
Page 8 of 22 
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. 
23. 
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(6), § 2423(e), § 2251, § 2252, § 2252A(a)(1), and § 
2252A(g)(1). 
24. 
In June 2008, 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 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, must 
admit liability unto Plaintiff Jane Doe No. 101. 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 Enea2e in Prostitution or 
Sexual Activity pursuant to 18 U.S.C. & 2255 In Violation of 18 U.S.C. & 24220311 
25. 
Plaintiff; Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 24 above. 
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26. 
Defendant, Jeffrey Epstein, used a facility or means of interstate and/or foreign 
commerce to knowingly persuade, induce, entice, or coerce Jane Doe 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. 
Asa 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 
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COUNT TWO 
(Cause of Action for Travel with Intent to Etienne in Illicit Sexual Conduct pursuant to 18 
U.S.C. & 2255 in Violation of 18 U.S.C. & 2423flin 
29. 
Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs I through 24 above. 
30. 
Upon information and belief. Defendant, Jeffrey Epstein, traveled in interstate 
and/or foreign commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 
U.S.C. § 2423(f), with minor females, including the then minor Plaintiff, in violation of 18 
U.S.C. § 2423(b). 
31. 
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. 
32. 
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, 
10 
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Case 9:09-cv-80591-KAM 
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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. 6 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 
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35. 
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. 
36. 
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 those 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. 
12 
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Case 9:09-cv-80591-KAM 
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COUNT FOUR 
(Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit 
Conduct pursuant to 18 U.S.C. 4 2255 in Violation of 18 1:.S.C. 2252(a)(1)) 
37. 
Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 24 above. 
38. 
Defendant, Jeffrey Epstein, upon information and belief, knowingly mailed, 
transported, shipped, or sent via computer and/or facsimile in or affecting interstate or foreign 
commerce at least one visual depiction of the minor Plaintiff engaging in sexually explicit 
conduct in violation of 18 U.S.C. § 2252(a)(1). As previously stated in paragraphs 14, 16, and 
34, upon information and belief, Defendant displayed a myriad of nude 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 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 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. 
39. 
As previously stated in paragraph 22, 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 
13 
EFTA00213173

Case 9:09-cv-00591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 14 of 22 
of a minor child. Defendant Jeffrey Epstein, at all times material to this cause of action, knew 
and should have known of Plaintiffs age of minority. Defendant's preference for underage girls 
was well-known to those who regularly procured them for him. 
40. 
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. 
41. 
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. 
14 
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Case 9:09-cv-80591-KAM 
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COUNT FIVE 
fCause of Action for Transport of Child Pornography pursuant to 18 U.S.C. & 2255 In 
Violation of 18 U.S.C. & 2252AI:0(111 
42. 
Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 24 above. 
43. 
Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via 
computer or facsimile in or affecting interstate and/or foreign commerce child pornography in 
violation of 18 U.S.C. § 2252A(a)(1). As previously stated in paragraph 16, Defendant displayed 
a myriad of nude photographs of underage girls throughout his homes, including 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 throughout his home in Palm Beach. On the day of his arrest, police found two hidden 
cameras and nude 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. 
44. 
As previously stated in paragraph 22, 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 
15 
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Case 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 16 of 22 
and should have known of Plaintiffs age of minority. Defendant's preference for underage girls 
was well-known to those who regularly procured them for him. 
45. 
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. 
46. 
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. 
16 
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Page 17 of 22 
COUNT SIX 
(Cause of Action for Entwine in a Child Exploitation Enterprise pursuant to 18 U.S.C. Zi 
2255 in Violation of 18 U.S.C. & 2252A(O 
47. 
Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 24 above and Counts One through 
Five. 
48. 
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(gX1). As more fully 
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(A)(a)(1)), and Chapter 117 (transportation for illegal sexual activity 
in violation of 18 U.S.C. §§ 2422, and 2423). As more fully set forth above in paragraphs 9 
through 19, Defendant's actions involved countless victims and countless separate incidents of 
abuse, and he committed those offenses against minors in concert with at least three other 
persons. 
49. 
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. 
50. 
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 finure 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, 
17 
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Case 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 18 of 22 
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. 
Date: May 1, 2009 
s/Katherine W. Ezell 
Robert C. Josefsberg, Bar No. 040856 
Katherine W. Ezell, Bar No. 114771 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 800 
18 
Attorneys for Plaintiff 
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DEMAND FOR JURY TRIAL 
Plaintiff demands to have her case tried before a jury. 
s/Katherine W. Ezell 
Robert C. Josefsberg, Bar No. 040856 
Katherine W. Ezell, Bar No. 114771 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 800 
Miami. Florida 33130 
Attorneys for Plaintiff 
19 
EFTA00213179

Case 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 20 of 22 
CERTIFICATE OF SERVICE 
WE HEREBY CERTIFY that on this et day of May, 2009, we electronically filed the 
foregoing document with the Clerk of the Court using CM/ECF. We also certify that the 
foregoing document is being served this day on all counsel of record identified on the attached 
Service List either via transmission of Notices of Electronic Filing generated by CM/ECF or in 
some other authorized manner for those counsel or parties who are not authorized to receive 
electronically Notices of Electronic Filing. 
Respectfully submitted, 
PODHURST ORSECK, P.A. 
Attorneys for Plaintiff 
By: 
20 
8/Katherine W. Ezell 
Robert C. Josefsberg 
Fla. Br No. 040856 
riosefsbenzenodhurst.cont
Katherine W. Ezell 
Fla. Bar No. 114771 
Impainglbiggssan 
City National Bank Building 
25 W. Flagler Street, Suite 800 
Miami, FL 33130 
EFTA00213180

Case 9:09-cv-80591-KAM 
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Entered on FLSD Docket 05/01/2009 
Page 21 of 22 
SERVICE LIST 
JANE DOE NO. 101 v. JEFFREY EPSTEIN 
Case No. 08-CV-80591-MARRIWOHNSON 
United States District Court, Southern District of Florida 
Robert Critton, Esq. 
Burman, Critton, Luther & Coleman LLP 
515 North Flagler Drive, Suite 400 
West Palm Beach, FL 33401 
rcritebcldlaw.com
Jack Goldberger, Esq. 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, FL 33401 
jagesq@bellsouth.net 
Bruce E. Reinhart, Esq. 
Bruce E. Reinhart, P.A. 
250 South Australian Avenue, Suite 1400 
West Palm 
401 
Phone: 
Fax: (5 
ecfAbrucerm 
awcom 
Co-counsel for Defendant, Jeffrey Epstein 
Jack Scarola, Esq. 
Jack P. Hill, Esq. 
Searcy Denney Scarola Barnhart & Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, Florida 33409 
Phone: 
Fax: ( 
iph@earcvlaw.com 
Counsel for Plaintiff C.M.A. 
Adam Horowitz Esq. 
Smart Mermelstein, Esq. 
Herman & Mermelstein 
18205 Biscayne Blvd. 
Suite 2218 
Miami, FL 33160 
21 
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Page 22 of 22 
mermelstein@sexabuseattomev.com 
Counsel for Plaintiffi in Related Cases Nos. 08-80069, 08-80119,08-80232, 08-80380, 08-
80381, 08-80993, 08-80994 
Spencer Todd Kuvin, Esq. 
Theodore Jon Leopold, Esq. 
Leopold Kuvin, P.A. 
2925 PGA Boulevard, Suite 200 
Palm Beach Gardens.FL 33410 
Phone: 
Fax: (5 
skuvinOle000ldkuvin.corn 
tleonold@leopoldkuvin.com 
Counsel for Plaintiff In Related Case No. 08-08804 
Richard Willits, Esq. 
Richard H. Willits, P.A. 
2290 10th Ave North, Suite 404 
Lake Worth, FL 33461 
Phone: 
Fax: (5 
jawverwillits@,aoLcom 
reelrbw@hotmail-corn 
Counsel for Plaintiff in Related Case No. 08-80811 
Brad Edwards, Esq. 
Law Office of Brad Edwards & Associates, LLC 
2028 Harrison Street, Suite 202 
Boll 
Phone 
Fax: ( 
bedwardsQrra-law.corn 
bo@bradedwardslaw.com 
Counsel for Plaintiff in Related Case No. 08-80893 
Isidro Manuel Garcia, Esq. 
Garcia Elkins & Boehringer 
224 Datum Avenue, Suite 900 
West Palm Beach, FL 33401 
Phone 
Fax: ( 
Counsel for Plaintiff in Related Case No. 08-80469 
22 
EFTA00213182