EFTA00184224

Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 2 of 4 
DECLARATION OF 
1. My name is 
• and I was born in 
2. I was paid by Jeffrey Epstein to interact sexually with him as a minor 
on dozens of occasions in his mansion in Palm Beach, Florida from 
around 2002 to 2005, and also to bring him other girls who were my 
approximate age for the same purposes. I understand that evidence 
collected fi-om Epstein's home showed conclusively that I was there 
as a minor, along with many other underage girls. Given how many 
girls Epstein was sexually abusing, there could not have been any 
doubt in anyone's mind that had access to the testimonial and other 
evidence that Epstein sexually molested me as a minor (and many 
others). 
3. My son was very young when the FBI came to speak with me the first 
time. I did not know what to do and I was scared. I called Epstein, 
who told me not to wofry and that he would hire an attorney for me. I 
believed that if I told the truth about what happened at Epstein's 
house, the police would take my baby from me. That made me really 
scared. 
4. Through the attorney that Jeffrey Epstein obtained for me, it was 
arranged for me to give a statement to the prosecutor investigating 
Epstein. 
5. While with the attorney Epstein obtained for me I gave a statement to 
the prosecutor that was favorable to Epstein. The prosecutors knew 
the truth because of the volume of evidence they had, and they 
continued to recognize me as a victim of Epstein's crimes. 
6. I had been greatly intimidated, which is why I could not be truthful 
initially and I wanted to end the threat of the possibility of my child 
being taken. My involvement with Epstein from a very young age 
was a deep, dark secret and Epstein told me to keep it a secret. I knew 
that I was expected to keep it a secret. 
7. The more I thought about what was going on, the more I realized that 
what Epstein had done to both me and my friends was wrong and that 
anyone who was not very wealthy would be punished. At this time, I 
EFTA00184404

Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 3 of 4 
wanted Epstein held accountable the same way anyone else would be. 
I spoke about this with one of my friends around May 2008. I then 
called an attorney, Brad Edwards, around June 2008, understanding 
that he was hired to get the prosecutors to talk to us and hear the truth 
from me. That was especially important to me because I was finally 
represented by someone other than Epstein's attorney and wanted to 
talk to the prosecutors about everything I knew. 
8. The prosecutors had a lot of information revealing the truth about the 
situation at Epstein's house. I had lot of information, too, because I 
was one of the young teenagers who had brought many other young 
teenagers to Epstein for the purpose of getting paid by Epstein. I 
wanted to assist the prosecutors in the investigation. I hired Mr. 
Edwards to let them know that I was cooperative and ready to tell 
them all of the helpful information I had. I understood that Mr. 
Edwards did that. 
9. I authorized Mr. Edwards to join me in the lawsuit against the U.S. 
Attorney's Office to enforce my rights and to try to get me my chance 
to confer with the prosecutors before Mr. Epstein took a plea or the 
case was resolved in any way. I just wanted to be treated fairly in the 
process. 
10. When Epstein pled guilty to a state crime at the end of June 2008, 
no one notified me that his plea had anything to do with my case 
against him. I did not know, for example, that this plea had some 
connection to a crime he committed against me particularly. In fact, 
at this young age, I had no idea what was going on and nobody tried 
to explain it to me. 
11. In July 2008, I attended a federal court hearing with Mr. Edwards. 
It was then that I learned for the first time at that hearing that the 
prosecutors worked out some sort of secret deal with Epstein that 
might block his prosecution for crimes against me. It also appeared 
that there was a lot of continued communication between Epstein and 
the U.S. Attorney's Office. I was really upset that the U.S. 
Attorney's Office seemed like it would not talk with me or the other 
victims about what was going on. It was easier to get them to talk to 
me when I was represented by Epstein's attorney. 
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Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 4 of 4 
12. I wanted to see this secret deal that the Government had with 
Epstein, but they would not give it to me at the hearing. Later, the 
other victims and I finally got to see the secret deal after the judge 
forced the prosecutors to show it to us. 
13. I understand that I did not initially help the investigation by 
speaking on Epstein's behalf untruthfully. But I was intimidated and 
had good reason to protect myself and my son — reasons that I think 
everyone who was talking to me could obviously see. Also, the 
agents and attorneys obviously had a lot of evidence that provided 
proof of what Epstein had actually done. Epstein was still supporting 
me, providing me a lawyer and in my mind protecting me, so I was in 
a position where I felt I had to say certain things. And Epstein 
expected me to say those things. 
14. Once I wanted to cooperate and tried to cooperate, I was never 
given the opportunity to confer with prosecutors from the time they 
were informed by my attorney that I was a cooperating witness. I was 
never told about the secret deal until after it was already concluded. I 
would have had my attorney object if I had been given the chance. 
15. I don't feel like I was treated fairly in this process. And I know 
Epstein got a really good plea deal because he is rich and powerful. 
That doesn't seem fair either. 
Executed this asS5Th 
, day of January, 2015. 
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Case 9:08-cv-80736-KAM Document 361-28 Entered on FLSD Docket 02/10/2016 Page 1 of 3 
EXHIBIT 
28 
EFTA00184407

Case 9:08-cv-80736-KAM Document 361-28 Entered on FLSD Docket 02/10/2016 Page 2 of 3 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave.. Suite 400 
West Palm Beach, FL 33401 
Facsimile: 
June 7, 2007 
DELIVERY BY BAND 
Miss 
Re: 
Crime Victims' and Witnesses' Riehts 
Dear Miss 
Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense, 
you have a number of rights. Those rights are: 
(1 ) 
The right to be reasonably protected from the accused. 
(2) 
The right to reasonable, accurate, and timely notice of any public court proceeding 
involving the crime or of any release or escape of the accused. 
(3) 
The right not to be excluded from any public court proceeding, unless the court 
determines that your testimony may be materially altered if you are present for other 
portions of a proceeding. 
(4) 
The right to be reasonably heard at any public proceeding in the district court 
involving release, pica, or sentencing. 
(5) 
The reasonable right to confer with the attorney for the United States in the case. 
(6) 
The right to full and timely restitution as provided in law. 
(7) 
The right to proceedings free from unreasonable delay. 
(8) 
The right to be treated with fairness and with respect for the victim's dignity and 
privacy. 
Members of the U.S. Department of Justice and other federal investigative agencies, 
including the Federal Bureau of Investigation, must use their best efforts to make sure that these 
rights are protected. If you have an concerns in this regard, please feel free to contact me at 
or Special Agent 
from the Federal Bureau of Investigation at 
You also can contact the Justice Department's Office for Victims of Crime in 
Washington, D.C. at 
That Office has a website at www.ovc.gov. 
You can seek the advice of an attorney with respect to the rights listed above and, if you 
believe that the rights set forth above are being violated, you have the right to petition the Court for 
relief. 
08-80736-CIV-IvIARRA 
000978 
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Case 9:08-cv-80736-KAM Document 361-28 Entered on FLSD Docket 02/10/2016 Page 3 of 3 
MISS 
JUNE 7, 2007 
PAGE 2 
In addition to these nghts, you are entitled to counseling and medical services, and protection 
from intimidation and harassment. If the Court determines that you are a victim, you also may be 
entitled to restitution from the perpetrator. A list of counseling and medical service providers can 
be provided to you, if you so desire. If you or your family is subjected to any intimidation or 
harassment, please contact Special Agent Kuyrkendall or myself immediately. It is possible that 
someone working on behalf of thc targets of the investigation may contact you. Such contact does 
not violate thc law. However, if you arc contacted, you have the choice of speaking to that person 
or retbsing to do so. If ou refuse and feel that you are being threatened or harassed, then please 
contact Special Agent 
or myself. 
You also are entitled to notification of upcoming caseevents. At this time, your case is under 
investigation. If anyone is charged in connection with the investigation, you will be notified. 
Sincerely, 
United States Attorney 
By: 
A.
Assistant United States Attorney 
cc: 
Special Agent 
Kuyrkcndall, P.B.I. 
OR-807364 :II-MAR RA 
000979 
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Case 9:08-cv-80736-KAM Document 361-29 Entered on FLSD Docket 02/10/2016 Page 1 of 4 
( 
( 
EXHIBIT 
29 
EFTA00184410

Case 9:08-cv-80736-KAM Document 361-29 Entered on FLSD Docket 02/10/2016 Page 2 of 4 
JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE 
CRIME VICTIMS' RIGHTS ACT AND REQUEST FOR A HEARING ON APPROPRIATE 
REMEDIES 
CASE NO: 08-80736-Civ-Marra/Johnson 
EXHIBIT I 
EFTA00184411

Cqse 9:08-cv-80736-KAM Cement 361-29 Entered on FLSD 
ket 02/.1 
U.S. (Impartment of Justice 
Federal Bureau of Investigation 
FBI - Wesl Palm Beach 
Suite 500 
505 South Flagler Drive 
West Palm Beach, Ft. 33401 
Phone:
Fax: 
May 70.200E 
Re: laalle 
Dear 
Your name was referred to the FBfs Victim Assistance Program as being a possible victim of a federal 
crime. We appreciate your assistance and cooperation while we are Investigating this case. We would like to 
make you aware of the victim services that may be available to you and to answer any questions you may have 
regarding the criminal justice process throughout the investigation. Our program is part of the FBI's effort to 
ensure the victims are treated with respect end are provided information about their rights under federal law. 
These rights Include notification of the status of the case. The enclosed brochures provide information about 
the FBI's Victim Assistance Program, resources and instructions for accessing the Victim Notification System 
(VNS). VNS is designed to provide you with information regarding the status of your case. 
This case Is currently under cnvetitigation. This can be a lengthy process and we request your 
continued patience while we conduct a thorough investigation. 
As a crime victim, you have the foibwing rights under 18 United States Code § 3771: (1) The right to 
be reasonably protected from the accused; (2) The right to reasonable, accurate, and timely notice of any 
public court proceeding, or any parole proceeding, involving the alma or of any release or escape of the 
accused; (3) The right not to be excluded from any such public coin proceeding, unless the court, atter 
receiving clear and convincing evidence, determines that testimony by the victim would be materially altered If 
the victim heard other testimony et that proceeding; (4) The right to be reasonably heard at any public 
proceeding in the district court Involving release. plea, sentencing, or any parole proceeding; (5) The 
reasonable tight to confer with the attorney for the Government in the case; (6) The right to full and timely 
restihrtI0n as provided in law; (7) The right to proceedings tree from unreasonable delay, (8) The right to be 
treated v4th fatness end with respect for the victim's dignity and privacy. 
We will make our beat efforts to ensure you are accorded the rights described. Most of these rights 
pertain to events occurring after the arrest or Indictment of en individual for the crime, and it will become the 
responsibility of the prosecuting Untied States Attorney's Office to ensure you are accorded those rights. You 
may also seek the advice of a private attorney with respect to these rights. 
The Victim Notification System (VNS) Is designed to provide you with direct information regarding the 
case as it proceeds through the criminal justice system. You may obtain current information about this matter 
on the Internet at WWW.Notify.USDOJ.GOV or frorn the VN5 Call Center at 1.856-DOJ-4YOU (1-856-365-
4968) (TDD/TTY: 1466-228-4619) (International:1-502-213-2767). In addition, you may use the Call 
Center or Internet to update your contact information andier change your decision about participation in the 
notification program. if you update your information to Include a current email address. VNS will send 
Information to that address. You H11I need the following Victim Identification Number (Vial) '2074381' end 
Personal identification Number (PIN) '1816' anytime you contact the Calf Center and the gra( time you log on to 
VNS on the Internet. In addition, the first time you access the VNS Internet see, you will be prompted to enter 
your last name (or business name) as currently contained in VN3. The name you should enter Is 
EFTA00184412

te2;s:e."6Oil-c_"-8.07-36-KAM Aliment 361-29 "L"nterescitin FLSD Edo kets0,2110S92.6 Fr,a1",./of 4 
11
II you have additional questions which Involve this matter, please contact the office listed above. When 
you caU, please provide the file number loaned et the top of this letter. Please remember, your participation 
In the notlecation part of this program le voluntary. In order to continue to receive notifications, fl Is your 
responsibility to keep your contact information current. 
Sincerely, 
4
1.0; 
(LA. 
0.
1 
1;tie 
Twiler Smith 
Victim Specialst 
TOTAL P.0? 
EFTA00184413

Case 9:08-cv-80736-KAM Document 361-30 Entered on FLSD Docket 02/10/2016 Page 1 of 
28 
EXHIBIT 
30 
EFTA00184414

• casecgigOvefig4foWkAWPcnerthlifitli30ENWEfielfict
itaigogfe2.414313)1Paeenct4224f 
IN THE UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF FLORIDA 
JANE DOE No. 102, 
Plaintiff, 
VS. 
JEFFREY EPSTEIN, 
Civil Action No 
09-80656 
CIV-RYSKAMP 
MAGISTRATE JUDGE 
VITUNAC 
FILED by  133 
 D C 
INTAKE 
MAY - 1 2009 
I 
STEVEN M. ‘ARIMORE 
CLERK U.S DIST CT 
5.0. OF FLA. MIAMI 
COMPLAINT AND 
Defendant. 
DEMAND FOR JURY TRIAL 
COMPLAINT AND DEMAND FOR JURY TRIAL 
Plaintiff, Jane Doe No. 102, 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 No. 102, 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 No. 102, 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, 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. 
Podhurst Orseck, P.A. 
25 West Flagkr Street Sulk SOO, Miami., FL 33134 Warn 
EXHIBIT 
CA 
Fort Lauderdale 954.463.4346 
www.podIturst.com 
EFTA00184415

castia4.154127eASWAPPetgiedThegt1-130EW-61-Aft.RDWARRititAlitkinOad'eclvsfW 
6. 
This Court has jurisdiction over 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(b), 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, spanning the 
ages of 45 and 55 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, as well as a fleet of motor vehicles. 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," a 70-acre private island known as Little St. James in St. Thomas, U.S. Virgin Islands, a 
mansion in London's Westminster neighborhood, and a home in the Avenue Foch area of Paris. 
The allegations herein concern Defendant's conduct while at his lavish homes and/or numerous 
other locations both nationally and internationally. 
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 to countless 
vulnerable and relatively economically disadvantaged minor girls, and sexually assaulted, 
molested, and/or exploited these girls, and then gave them money. 
10. 
Beginning in or around 1998 through in or around September 2007, Defendant 
used his resources and his influence over vulnerable minor girls to engage in a systematic pattern 
of sexually exploitative behavior. 
2 
Podhurst Orseck, P.A. 
25 Welt Plaster Street, Suitt 800. Miami, FL 33130, Miami 305.358.2900 Fax 305358.2382 • Fort Lauderdale 954.463.4316 I 
www.pocilitustxten 
EFTA00184416

casecWwdEaNskARP93MA5130ERrseslagAbBees%/MBilOaga9s(429f 
II. 
Defendant's plan and scheme reflected a particular pattern and method. 
Defendant coerced and enticed impressionable, vulnerable, and relatively economically less 
fortunate minor girls 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 and/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 call economically disadvantaged and underage girls from West 
Palm Beach and surrounding areas who would be enticed by the money being offered 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 12 years old, were transported to Defendant's Palm Beach 
mansion by Defendant's employees, agents, and/or assistants in order to provide Defendant with 
"massages." 
12. 
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 with and/or without their 
knowledge. Defendant would pay the procurer of each girl's "appointment" hundreds of dollars. 
3 
Podhurst Orseck, P.A. 
25 Wert Flagkr Street, Suite SOO, Miami, FL 33130, Miami 305.356= Fax 305.358.2382 • Fort Lauderdale 951.463.4316 
EFTA00184417

CaSeCUM50-ngal<ARebg leunrhati i M ENVOInTLWOSBoagtaiR/280(9 1RagPearof529f
13. 
Epstein designed this scheme to secure a private place in Defendant's Palm Beach 
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 
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 Palm Beach mansion, each underage victim would 
generally be introduced to one of Defendant's assistants, who would gather the girl's personal 
contact information. The minor girl would then be led up a flight of stairs to a room that 
contained a massage table and a large shower. The staircase leading to the room was plastered 
with nude photographs of young girls, including some photographs depicting two or more young 
girls engaged in lewd acts. Upon information and belief, Defendant, Jeffrey Epstein, had such 
photographs in each of his six homes and/or on his computers. 
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 and/or the other female would direct the girl to massage him, giving the minor girl 
specific instructions as to where and how he wanted to be touched, and then direct her to remove 
her clothing. lie 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 vulva, 
vagina, and/or anus with a vibrator and/or back massager and/or his finger(s) and/or his penis, 
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 and/or 
4 
Podhurst Orseck, P.A. 
MI let 
Cl.
I 
Cc. 
• C 16 
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EFTA00184418

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enticing the then minor girl to engage in sexual acts with another female in Defendant's 
presence. The exact degree of molestation and frequency with which the sexual exploitations 
took place varied and is not yet completely known; however, Defendant committed such acts 
regularly on a daily basis and, in most instances, several times a day. In order to facilitate the 
daily exchanges of money for sexual assault and abuse, Defendant kept U.S. currency readily 
available. 
16. 
Defendant, Epstein, traveled to his mansion in Palm Beach for the purpose of 
luring minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to 
contact these minor girls for the purpose of coercing them into acts of prostitution and to enable 
himself to commit sexual battery against them and/or acts of lewdness in their presence, and he 
conspired with others, including assistants and/or his driver(s) and/or pilot(s), and his socialite 
friend/partner, Ghislaine Maxwell, to further these acts and to avoid police detection. 
Defendant's systematic pattern of sexually exploitative behavior referred to in paragraph 10 and 
described in paragraphs I 1 through the present paragraph occurred in all of Defendant's 
domestic and international residences and/or places of lodging and/or modes of transportation. 
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. 
A vulnerable young girl, Plaintiff was working as a changing room assistant at The Mar-A-Lago 
Club in Palm Beach making approximately S9 an hour when she was first lured into Defendant's 
sexually exploitative world. In or about the summer of 1998, when Plaintiff was merely fifteen 
years old while attending to her duties at Mar-A-Lago, Plaintiff was recruited by Ghislaine 
Maxwell, who lived, traveled, socialized, and worked with Defendant. Ms. Maxwell asked 
Plaintiff if she was interested in learning massage therapy and earning a great deal of money 
while learning the profession. Plaintiff's father, who was a maintenance manager at The Mar-A-
Podhurst Orseck, P.A. 
25 West Hagler Sine, Suite 800, Miami. FL 33130, Waal 305.3582800 Fax 305358.2382 • Fort Lauderdale 954.163.4316 
envw.posthtus1.coot 
EFTA00184419

casvasuiwitwocasapoif30EipaesliK§baaaileadokopicad.3 
Lago Club, was not apprehensive because he felt comforted that an older woman had approached 
Plaintiff with this opportunity. As a result, Plaintiffs father dropped off Plaintiff at Defendant's 
mansion that same day. Ms. Maxwell met Plaintiff and her father outside of Defendant's Palm 
Beach mansion, where Ms. Maxwell assured the minor girl's father that Ms. Maxwell would 
provide transportation home for his teenaged daughter. Ghislaine Maxwell led Plaintiff up a 
flight of stairs to a spa room with a shower and a massage table. Defendant was lying naked on 
the massage table. Plaintiff was shocked, but, with no experience with massages, thought this 
could be massage therapy protocol. Ms. Maxwell then took off her own shirt and left on her 
underwear and started rubbing her breasts across Defendant's body, impliedly showing Plaintiff 
what she was expected to do. Ms. Maxwell then told Plaintiff to take off her clothes. The minor 
girl was apprehensive about doing this, but, in fear, proceeded to follow Ms. Maxwell by 
removing everything but her underwear. She was then ordered to remove her underwear and to 
straddle Defendant. 
The encounter escalated, with Defendant and Ms. Maxwell sexually 
assaulting, battering, exploiting, and abusing Plaintiff in various ways and in various locations, 
including the steam room and shower. At the end of this sexually exploitive abuse, Defendant 
and Ms. Maxwell giddily told Plaintiff to return the following day and told her she had "lots of 
potential." Defendant paid Plaintiff hundreds of dollars, told her it was for two hours of work, 
and directed one of his employees to drive her home. 
18. 
Defendant and/or his procurers thereafter lured the then minor Plaintiff to his 
Palm Beach mansion every day for the next two weeks in order to engage in a similar pattern of 
sexual exploitation. Defendant and/or his procurers arranged at the end of each incident the 
transportation and scheduling for the following day's appointment. Additionally, Defendant 
telephoned the minor Plaintiff himself and/or had Ms. Maxwell telephone Plaintiff to make 
arrangements. Plaintiff was often times driven to and from Epstein's mansion by Epstein 
6 
Podhurst Orseck, P.A. 
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EFTA00184420

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himself or his driver. Alternatively, Defendant or Ms. Maxwell would arrange and pay for 
Plaintiff's transportation home by taxicab. 
19. 
During Plaintiff's second incident of being sexually exploited and assaulted by 
Defendant at Defendant's Palm Beach mansion, Defendant asked Plaintiff to quit her job at The 
Mar-A-Lago Club and travel with him to earn much more money while learning the massage 
profession. Thus, Plaintiff, an impressionable and vulnerable young girl of modest means, quit 
her job as a changing room assistant, was lured by Defendant, and continued to be victimized by 
Defendant, who immersed the minor Plaintiff into Defendant's lewd and abusive lifestyle. 
Under Defendant's dominion and control, Defendant continuously "groomed" the minor 
adolescent. Defendant's daily routine required the minor Plaintiff to perform sexually on 
Defendant multiple times per day and to provide Defendant massages multiple times per day. 
Plaintiff had absolutely no say as to when, how many times, or what was done during each 
sexual encounter. Often, Plaintiff was joined by Ms. Maxwell, Ms. Maxwell's assistant, and/or a 
countless array of young women who would be brought to one of Defendant's homes for the 
sexual trysts and then be sexually exploited by Defendant. 
20. 
The first time that Defendant transported Plaintiff to another state in order to 
engage in sexual acts with her occurred when she was merely fifteen years old and after only two 
weeks of daily sexually abusive encounters with Defendant. Defendant used his private jet to 
transport the minor Plaintiff to Manhattan, where he provided her with spending money and 
accommodations with him at his mansion. From the time that Plaintiff was 15 years old, 
Defendant abused her to serve his every sexual whim, obtaining and purchasing passports and 
whatever was needed for her to travel with him and/or for him. Defendant transported Plaintiff 
in his private jet to locations that included Palm Beach, New York City, Santa Fe, Los Angeles, 
San Francisco, St. Louis, and numerous other domestic destinations, as well as international 
7 
Podhurst Orseck, P.A. 
25 West Fla glee Street. Se 800, Miami. FL 33130, Miami 305.358.2800 Fax 3053581382 • Fort Lauderdale 954.463.4346 
svww.pxthurst 
EFTA00184421

case&MASMIMAARecbgbeS4a43°E2Witargath90505i1018(PPagPeiiigf929f 
destinations, including Europe, the Caribbean, and Africa. He provided accommodations with 
him in order to have her available to him at all times wherever he went, including while 
transporting the minor Plaintiff on his private jet. Each time they would travel to one of these 
destinations, the same pattern of sexual abuse would occur, often with a vast army of aspiring 
models, actresses, celebrities, and/or other females, including minors, from all over the world. 
Upon information and belief, Defendant transported minor girls from Turkey, the Czech 
Republic, Asia, and numerous other countries, many of whom spoke no English. To Plaintiff's 
knowledge, the only females specifically excluded from Defendant's sexual escapades were 
African-Americans. 
21. 
In addition to being continually exploited to satisfy Defendant's every sexual 
whim, Plaintiff was also required to be sexually exploited by Defendant's adult male peers, 
including royalty, politicians, academicians, businessmen, and/or other professional and personal 
acquaintances. Whenever Defendant transported Plaintiff with him in his private jet to any 
destination, Defendant would pay Plaintiff a flat rate per day while he and/or his above-
mentioned associates would sexually exploit and abuse minor Plaintiff. 
22. 
Most of these acts of abuse occurred during a time when Defendant knew that 
Plaintiff was approximately 15, 16, and 17 years old, and, after years of daily sexual exploitation, 
continued into her adulthood. Despite Defendant's stating shortly before Plaintiff's sixteenth 
birthday that he soon would have to trade her in because she was getting too old, Defendant 
continued to sexually exploit Plaintiff until she fled at age 19. Defendant's predilection for 
young girls was well known to those who regularly procured them for him and to his circle of 
friends. On one of Defendant's birthdays, a friend of Defendant sent him three I2-year-old girls 
from France who spoke no English for Defendant to sexually exploit and abuse. After doing so, 
they were sent back to France the next day. 
8 
Podhurst Orseck, P.A. 
25 West Fbgler StreeL Suite 800, Miami, FL 33130, Miami 305-358 28® Fax 305358.2382 • Fort Lauderdale 951.10.4316 I 
www.podhunt.com 
EFTA00184422

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23. 
Any assertions by Defendant that he was unaware of the age of the then minor 
Plaintiff are belied by 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. Defendant and Ms. Maxwell acknowledged and celebrated Plaintiff's 
161h birthday. Defendant's preference for underage girls was well-known to those who regularly 
procured them for him. 
24. 
As previously stated in paragraph 14, Defendant displayed nude photographs of 
underage girls throughout his homes in Ncw York City, Palm Beach, Santa Fe, and the U.S. 
Virgin Islands. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each of 
Defendant's homes, including a photograph of herself naked at Defendant's home in Palm 
Beach. When she asked Defendant about it, he stated dismissively that he had naked photographs 
of her in all of his homes. 
25. 
Upon information and belief, some of the photographs in Defendant's possession 
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 may have taken lewd 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. In addition, while Plaintiff was a 
minor teenager and upon Ms. Maxwell's insistence after Ms. Maxwell rejected as inappropriate 
photographs that Plaintiff presented of herself fully clothed, Ms. Maxwell photographed Plaintiff 
naked in different sexually explicit positions. 
Ms. Maxwell then presented these nude 
photographs of Plaintiff to Defendant as a birthday present for Defendant fmm Ms. Maxwell. 
9 
Podhurst Orseck, RA. 
25 west Flash:TSUI-et Suite 800, Miami, FL 33130, Miami 305.358.2.1303 Fax 305.358.2382 • Port taudadale 954.463.4346 i 
www.podhurst.com 
EFTA00184423