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Case 9:10-cv-81111-WPD Document 1 
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organization was 
who served as both his scheduler and a recruiter/procurer of the girls. 
also served as a recruiter and helped Epstein satisfy his criminal sexual desires by, 
on occasion, directly participating in sexual abuse and prostitution of the minor girls. Epstein 
also used otherwise-legitimate business activities to help further the purpose of the criminal 
enterprise. These apparently legitimate activities provided "cover" for Epstein and his associates 
to commit the crimes. Epstein and his associates maintained the appearance of running an 
upstanding investment business, as well as other legitimate businesses with connections to 
modeling agencies and other powerful business and political people, to discourage the minor 
girls from reporting the abuse to law enforcement. Ghislane Maxwell and Jean Luc Brunel 
helped to provide "cover" by creating the impression that legitimate modeling opportunities were 
available for the girls. There are many other known and unknown associates of the criminal 
organization, that worked throughout the country and possibly internationally, who performed 
functions to perpetuate the criminal activities of the organization. 
88. Defendant Jeffrey Epstein participated in this enterprise through a pattern of criminal 
activity in that he engaged in at least two incidents of criminal activity, as defined and required 
in Florida Statute 772.102 and as described below, that have the same or similar intents, results, 
accomplices, victims, or methods of commission and are not isolated incidents. 
89. Defendant Jeffrey Epstein engaged in criminal activity by committing, attempting to 
commit, conspiring to commit or soliciting, coercing or intimidating another person to commit 
one or more of the following predicate acts as outlined and defined in Florida Statute 772.102: 
(a) 
Procuring for prostitution, or causing to be prostituted, any person who is 
under the age of 18 yews in violation of Florida Statutes Chapter 796.03; 
(b) 
Acts of battery in violation of Florida Statutes Chapter 784; 
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(c) 
Forcing, compelling or coercing another to become a prostitute in 
violation of Florida Statutes Chapter 796.04; 
(d) 
knowingly recruiting, enticing, harboring, transporting, providing or 
otherwise obtaining by any means a person, knowing that coercion would be used to 
cause that person to engage in prostitution in violation of Florida Statutes Chapter 
796.045; 
(e) 
tampering with a witness in violation of Florida Statutes Chapter 914.22; 
(f) 
altering, destroying, removing, or concealing records or documents or 
other evidence with the purpose to impair its verity or availability in violation of Florida 
Statutes Chapter 918.13; 
(g) 
maintaining a place (or more accurately "places") for the purpose of 
lewdness or prostitution; offering or securing another for the purpose of prostitution or 
for some other lewd or indecent act; receiving persons into his Palm Beach mansion for 
the purpose of prostitution or lewdness; directing, taking or transporting or agreeing to 
direct take or transport persons to his Palm Beach mansion with knowledge or reasonable 
belief that the purpose of such directing, taking or transporting was prostitution or 
lewdness; all in violation of Florida Statutes Chapter 796.07. 
90. The criminal acts of Defendant Epstein occurred repeatedly over a substantial period of 
time and were not isolated events. 
91. Under Defendant, Jeffrey Epstein's plan, scheme, and enterprise, Defendant, Jeffrey 
Epstein, paid employees and underlings, including but not limited to 
to bring him 
minor girls to his Palm Beach mansion in order for the Defendant to solicit, induce, coerce, 
entice, compel or force such girls to engage in acts of prostitution and sexual misconduct with 
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Defendant Epstein and sometimes 
and to otherwise commit acts of sexual 
battery thereon, and further Defendant Epstein worked in concert as part of the enterprise with 
those who were free to act independently and advance their own interests, including Ghislaine 
Maxwell and Jean Luc Brunel, to obtain minor girls for sexual purposes. 
92. Plaintiff,■ was the victim of Defendant, Jeffrey Epstein's plan, scheme, and enterprise 
and was so injured by reason of his violations of the provisions of s. 772.104. Plaintiff,. was 
called on the telephone by Defendant Epstein and other employees of his, including 
and transported to the Defendant, Jeffrey Epstein's residence, where she was placed in a 
room along with the Defendant, enticed to commit acts of prostitution, and had acts of sexual 
battery and sexual exploitation committed against her. Defendant, Jeffrey Epstein, conspired 
with his assistants and employees in order to accomplish their common motive or intent of 
seeking out, gaining access to, and exploiting minor children such as the Plaintiff, MJ, in the 
aforementioned ways, and he further conspired with his employees, assistants and underlings to 
ensure that the crimes of this criminal enterprise were concealed or undetected by law 
enforcement. 
Those who were free to act independently and advance their own interests, 
including Ghislaine Maxwell and Jean Luc Brunel, also worked with the enterprise to conceal 
the activities of the enterprise. 
93. After law enforcement began to detect the criminal activities of Defendant Epstein and 
the other persons involved in the criminal enterprise, the enterprise used resources and 
information to conceal the illegal activities of the enterprise, threaten the victims of the crimes of 
the enterprise if they revealed the scope of the enterprise to law enforcement, and concealed or 
destroyed documents relevant to the prosecution of the various members of the enterprise. The 
enterprise also made various efforts to discourage the victims from cooperating with law 
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enforcement and from filing civil lawsuits to vindicate their rights. Epstein and other members 
of the enterprise made cash payments and gave gifts to the victims of the enterprise in order to 
discourage them from reporting crimes to law enforcement and other authorities. 
94. Through information and belief, this criminal enterprise gained valuable consideration 
from the practice of sex-trafficking underage children and providing underage children to other 
adults and otherwise derived valuable consideration for running a national and oftentimes 
international sex-trafficking and underage prostitution ring, typically by coercing and 
introducing the economically disadvantaged underage minor females into prostitution and 
sometimes into being underage sex slaves for the enterprise. 
95. The evidence clearly and convincingly establishes that Plaintif.was injured by reason 
of violations of the provisions of 772.103, and as such is entitled to threefold the actual damages 
sustained and a minimum of $200, and reasonable attorney's fees and court costs. 
96. In the alternative, and pursuant to s. 772.104, Plaintiff IN was injured due to sex 
trafficking committed in violation of s. 772.103 and is thus entitled to threefold the amount 
gained from the sex trafficking and to a minimum amount of damages not less than $200. 
reasonable attorney's fees and court costs. 
97. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, 
loss to her property and business opportunities and other losses. 
WHEREFORE, under the provisions of Florida Statutes Chapter 772, Plaintiff, MJ, 
demands judgment against Defendant, Jeffrey Epstein, for any minimum damages authorized by 
law, all actual damages sustained (to be trebled as authorized by law), court costs and attorneys' 
fees, and such other and 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. 
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Case 9:10-cv-81111-WPD Document 1 
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COUNT XXV 
Cause of Action Pursuant to Florida Statute 796.09 
Against Defendant, Jeffrey Epstein 
98. Plaintiff adopts and realleges paragraphs 1 through 60 above. 
99. The allegations contained herein in Count XXV are a separate and distinct legal remedy. 
100. Defendant, Jeffrey Epstein, was a wealthy and powerful man, and Plaintiff was an 
economically disadvantaged and impressionable minor. 
101. Plaintiff ■had never engaged in any act of prostitution prior to meeting Epstein or 
being introduced to any of the members of the criminal enterprise of which Defendant Epstein 
was an operating member and leader. 
102. Defendant, Jeffrey Epstein, used his vast wealth and power to coerce Plaintiff into 
prostitution and/or coerced her to remain in prostitution. 
103. Defendant, Jeffrey Epstein, coerced Plaintiff into prostitution in one or more of the 
following ways: 
A. 
Domination of her mind and body through exploitive techniques; 
B. 
Inducement; 
C. 
Promise of greater financial rewards; 
D. 
Exploitation of a condition of developmental disability, cognitive 
limitation, affective disorder, and/or substance dependency; 
E. 
Exploitation of human needs for food, shelter or affection; 
F. 
Exploitation of underprivileged and vulnerable economic condition or 
situation; 
G. 
Use of a system of recruiting other similarly situated minor girls to further 
coerce and induce Plaintiff into the lifestyle of prostitution; and 
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H. 
Exploitation through demonstration of abundant wealth and power to 
impress a young and vulnerable then minor Plaintiff and to coerce her into prostitution. 
104. As a direct and proximate result of the offenses committed by Defendant, Jeffrey Epstein, 
against Plaintiff pursuant to Florida Statutes §796.09, the Plaintiff has in the past suffered, and 
will in the future suffer, injury, pain and suffering, emotional distress, psychological trauma. 
mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her 
privacy and other damages associated with Defendant, Jeffrey Epstein, controlling, manipulating 
and coercing her into a perverse and unconventional way of life for a minor. 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 the Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe, demands judgment against the Defendant, Jeffrey 
Epstein, for compensatory damages, punitive damages as specifically allowed by this and other 
statutes and by law, attorney's fees, and such other and 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 XXV 
Cause of Action Pursuant to Florida Statute 726.101 
Against Defendant, Jeffrey Epstein 
105. This count alleges an action for redress of fraudulent transfers brought under Florida's 
Uniform Fraudulent Transfer Act, sections 726.101, et seq., Fla.Stats. ("FUFTA"). 
106. Plaintiff adopts and realleges paragraphs 1 through 60 above. 
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107. 
is a creditor of defendant Jeffrey Epstein. She has various claims against him for 
repeated sexual molestation of her when she was a minor, as alleged in the other counts of this 
complaint. 
108. Given the egregious acts of sexual molestation the defendant perpetrated against her-
has a claim against defendant, once punitive damages are added, is worth in excess of 
$50,000,000. Therefore, he is facing judgments in excess of $50,000,000 from her. Epstein is 
thus a debtor of N 
as defined in the FUFTA. 
109. Defendant Jeffrey Epstein has numerous overseas contacts and sophistication in 
international business transactions. He previously served as a trader at Bear Stearns and founded 
his own financial management firm, J. Epstein and Col. (later called Financial Trust Co.) located 
on his private island in the U.S. Virgin Islands where, until his recent incarceration, he managed 
the assets of billionaire clients. 
110. Defendant Jeffrey Epstein has transferred, is transferring, and intends to transfer in the 
near future his assets, to locations overseas and elsewhere and/or to nominee individuals who 
conceal Epstein's interest in the assets, with the actual intent to hinder, delay and defraud-
To prevent 
from satisfying any judgment that she might obtain in her pending lawsuit again 
him, Epstein has moved and intends to move his significant financial assets to locations overseas 
(i.e., to Israel) or in other unreachable areas and to title his assets (including real property, 
aircraft, boats, vehicles, and financial instruments) in the names of other persons or entities, even 
though he maintains (directly or indirectly) control over those assets. 
These transfers are 
designed by Epstein to prevent ■ 
from being able to collect on any judgment she might obtain 
against him, including any punitive damages judgment. 
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11 I. In recent lawsuits against him very similar to those filed by 
defendant Epstein has 
refused to answer and taken the Fifth when asked whether he intends to conceal assets from 
those with claims against him. 
112. In recent lawsuits against him very similar to those filed by 
defendant Epstein 
refused to answer and took the Fifth Amendment when asked whether he intends to remain in the 
country in the future. 
113. Epstein could currently post a $15 million bond to satisfy a judgment in this case without 
financial or other difficulty. 
WHEREFORE plaintiff Mdemands judgment against defendant Epstein as follows: 
(a) An accounting by defendant Jeffrey Epstein of all of his significant financial assets, 
whether held in this country or overseas, and all significant transfer of assets in the last three 
years; 
(b) Avoidance of the fraudulent transfers or obligations to the extent necessary to satisfy 
M
s claims; 
(c) An attachment or other provisional remedy against the asset transferred or other 
property of the transferee in accordance with applicable law; 
(d) An injunction against defendant Jeffrey Epstein and such transferees as may be 
appropriate, or both, against further transfers of any assets pending further order of the Court and 
posting of a bond to protect M.. 
(e) Appointment of a receiver to take charge of the assets of defendant Jeffrey Epstein 
until the Court is satisfied that 
interests in having assets available from the defendant to 
satisfy any judgment are fully protected; 
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(t) Posting by defendant Jeffrey Epstein of a $15,000,000 bond to satisfy any judgment 
obtained by 
in her pending lawsuits; and 
(g) All other relief that the circumstances may require to protect. and her ability to 
satisfy any judgment she might obtain. 
Plaintiff also demands a jury trial on all issues so triable by jury. 
Dated: 
2.0‘0
Respectfully submitted, 
FARMER, JAFFE, WEISSING, 
EDWARDS, FISTOS & LEHRMAN, PL 
Attorneys for Plaintiff(s) 
425 North Andrews Avenue, Suite 2 
Fort Lauderdale, Fl 33301 
TELEPHONE 
Fax 
BY: 
29 
Bradley J. Edwards 
Florida Bar No. 542075 
EFTA01159005