EFTA00184224

caseem-649agtaapcbriaPrtiNtli3°Efgr gnTiratisgclegaiSielRasPelig (?)-?-29f 
Upon information and belief, one or more nude photographs of Plaintiff that were taken when 
she was a minor were confiscated by the Palm Beach Sheriff's Office during its execution of a 
search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information 
and belief, those photographs arc still in the custody of law enforcement. 
26. 
It is virtually impossible to calculate the exact number of times that Defendant 
sexually exploited and abused Plaintiff. From the age of 15, Plaintiff was sexually exploited and 
abused by Defendant on a daily basis and, most often, multiple times each day. While some of 
the precise dates these acts occurred are unknown to Plaintiff; these dates are known to 
Defendant, as he is reported to have kept a written log of each instance in which he engaged in 
these lewd acts with then minor Plaintiff and others. Upon information and belief, these logs are 
also in the custody of law enforcement. 
27. 
In or around September 2002, Defendant purchased a commercial round-trip 
airline ticket, and provided a passport, U.S. currency, and accommodations for Plaintiff to fly to 
Thailand. While thousands of miles away from Defendant on this extended trip alone for the 
first time in more than four years, Plaintiff met, fell in love, and married a young man. She 
escaped from Defendant's abuse with the help and insistence of her new husband and, instead of 
returning to Defendant, boarded a plane to Australia with one suitcase. 
28. 
Since November 2002, Plaintiff has lived a modest life in Australia, while 
maintaining lines of communication with her family and without contact with Defendant or any 
of the people in his entourage. However, suddenly, in 2008, Plaintiff received numerous phone 
calls from one of Defendant's agents. During these phone calls to Plaintiff, he repeatedly asked 
whether she knew anything about the civil cases against Defendant, whether she knew any of the 
females who were proceeding with the civil suits, whether she was planning on tiling suit, 
whether she was communicating and/or cooperating with anyone against Defendant, and whether 
10 
Podhurst Orseck, P.A. 
'A wool Paolo, Shoot Co rho n 
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EFTA00184424

Case 8:21tivagl-Mg4
Kjaacument 361-30 _Entered on FLSD Docket 02/10/2016 Page 12 of 
uocument 
.0;zred on FLSD Docket 05/04/2009 Page 11 of 27 
she would return to the United States to testify. Terrified by Defendant's demonstrated ability to 
track her down on her changed cell phone number halfway across the world, Plaintiff attempted 
to reassure Defendant's agent that she would remain quiet. During the course of one of these 
phone calls from Defendant's agents, Defendant himself spoke on the phone, continued to 
question her intentions, and, upon being reassured by Plaintiff, thanked her for not getting 
involved. 
29. 
Around January 2009, Plaintiff received a lever from the United States Attorney's 
Office for the Southern District of Florida, informing her of her potential civil claims against 
Defendant under 18 U.S.C. § 2255. Plaintiff contacted undersigned counsel within days and 
diligently and repeatedly pursued a good faith viable settlement of her claims against Defendant. 
Unable to reach a settlement, this lawsuit followed. 
30. 
As a result of these encounters with Defendant, Plaintiff, Jane Doe No. 102, has in 
the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, 
emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, 
confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, 
invasion of her privacy, separation from her family, and other damages associated with 
Defendant's controlling and manipulating her on a daily basis for years into a perverse and 
unhealthy way of life. 
31. 
Defendant, Jeffrey Epstein, committed the above-referenced acts upon 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 
II 
Podhurst Orseck, P.A. 
25 West Hagler Street, Suite 800, Miami, FL 33130, Miami 305358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 
YrWW.pOdilUrStXem 
EFTA00184425

Case_9:08-9:09
-8073.6-KAM. _Document 361-30 Entered on FLED Dockgt 02/10/2016 
'
aP2 13 of 
ease 9:09-v-a0555-kAm uocument 1 ErItgred on F-LED uocket u5/04/2009 Page 1 of 27 
in 18 U.S.C. § 2421, § 2422(a), § 2422(h), § 2423(a), § 2423(6), § 2423(e), § 2251, § 2252, § 
2252A(a)(1), and § 2252A(gX1). 
32. 
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. 102. 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 Entine in Prostitution or 
Sexual Activity pursuant to 18 U.S.C. 6 2255 in Violation of 18 U.S.C. S 2422(b)) 
33. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs I through 32 above. 
34. 
Defendant, Jeffrey Epstein, used a facility or means of interstate and/or foreign 
commerce to knowingly persuade, induce, entice, or coerce Jane Doe No. 102, 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). 
35. 
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
12 
Podhurst Orseck, P.A. 
25 West Flagler Street Suite EILO, Miami, FL 33130, Miami 305193.21300 Fax 305,358.2382 • Fort Lauderdale 954.463.4146 I 
%rem .podhurst corn 
EFTA00184426

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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, 
separation from her family, and other damages associated with Defendant's manipulating and 
leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical 
and psychological expenses, and Plaintiff will in the future suffer additional medical and 
psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 
income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in 
nature, and Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as 
this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right 
by a jury. 
COUNT TWO 
(Cause of Action for Transportation of Minor with Intent to Eneale in Criminal Sexual 
Activity pursuant to 18 U.S.C. 6 2255 in Violation of 18 U.S.C. 6 2423(an 
37. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 32 above. 
38. 
Defendant, Jeffrey Epstein, knowingly transported then minor Plaintiff, Jane Doe 
No. 102, in interstate and/or foreign commerce, with the intent that Plaintiff engage in 
prostitution, or in any sexual activity for which any person can be charged with a criminal 
offense, in violation 18 U.S.C. § 2423(a). As previously stated in paragraphs 20, 21, and 27, 
13 
Podhurst Orseck, P.A. 
25 West Flagler Street Suite 800. Miami, FL 33130, Miami 305358.2000 Fax 306.358.2382 • Fort Lauderdale 954.463.4346 1 
www.podhuretcorn 
EFTA00184427

Case :08-cv-80736-KAM,Dcument 361-30 Entered 
on  F1312 Docket 02/10/2016 Page 15 of 
ease 909-cv-a0bbb-KAn4 uocument 1 E2t9red on FLSD uocket 05/04/2009 Page 14 of 27 
Defendant transported Plaintiff, Jane Doe No. 102, across state lines and across international 
borders numerous times from the time that Plaintiff was merely 15 years old through adulthood 
with the primary intent of sexually exploiting her. 
39. 
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
40. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
leading her into a perverse and unhealthy way of life 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 Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as 
this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right 
by a jury. 
14 
Podhurst Orseck, P.A. 
25 West Flagkt Street. Suite 800. Miami, FL 33130, Mlaral 305358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4316 
envw.podkurstcom 
EFTA00184428

Case.9:08-cv-80736-KAM..Qocu_ment 361-30 Entered on FLSD Docket 02/10/2016 Page 16 of 
Case
 'Document 1 E2Wred on FLSD Docket 05/04/2009 Page 15 of 27 
COUNT THREE 
'Cause of Action for Travel with Intent to EBIZA2C in Illicit Sexual Conduct pursuant to 18 
U.S.C. 6 225$ in Violation of 18 U.S.C. 6 2423(b)I 
41. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs I through 32 above. 
42. 
Upon information and belief, Defendant, Jeffrey Epstein, traveled in interstate 
and/or foreign commerce with the intent to engage in illicit sexual conduct, as defined in 18 
U.S.C. § 2423(), with minor females, including the then minor Plaintiff, in violation of 18 
U.S.C. § 2423(6). 
43. 
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
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 continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical 
and psychological expenses, and Plaintiff will in the future suffer additional medical and 
psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 
income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in 
nature, and Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
15 
Podhurst Orseck, P.A. 
25 West Plaster Street, Suite 800, Miami, PL 33130, Miami 306.3581800 Fax 305358.2392 • Fort Lauderdale 954.463.4346 I 
www.podlturst.com 
EFTA00184429

Case 9:08-cv-80736-KAM Document 361-30 Entered on FLSD Docket 02/10/2016 Page 17 of 
Case 9:09-cv-80656-KAM Document 1 Eared on FLSD Docket 05/04/2009 Page 16 of 27 
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 Coercion and Enticement to Entine in Prostitution or Sexual Activity 
pursuant to 18 U.S.C. S 2255 In Violation of 18 U.S.C. S 2422(01 
45. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 32 above. 
46. 
Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, and/or 
coerced Jane Doe No. 102 to travel in interstate and/or foreign commerce 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(a). 
47. 
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
48. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical 
and psychological expenses, and Plaintiff will in the future suffer additional medical and 
psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 
16 
Podhurst Orseck, P.A. 
25 West Hagler Street Suite 800, Miami, FL 33130, Miami 305358.2900 Fax 305.358.2382 • Fort Lauderdale 954.4634316 
www.podhuntcom 
EFTA00184430

cas9:08-1 .807gelt\ki°WatrleiR3°E4Pcieogi ngbWoEigibeth8Micur9ageiVoilff
ase 9: 9-cv- 
6-
income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in 
nature, and Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as 
this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right 
by a jury. 
COUNT FIVE 
(Cause of Action for Transportation with Intent to Engage in Criminal Sexual Activity 
pursuant to IS U•S.C. 6 2255 In Violation of 18 U.S.C. 8 24211 
49. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 32 above. 
50. 
Defendant, Jeffrey Epstein, knowingly transported, or attempted to transport, 
Plaintiff, Jane Doe No. 102, in interstate and/or foreign commerce, with the intent that Plaintiff 
engage in prostitution and/or in any sexual activity for which any person can be charged with a 
criminal offense, in violation of 18 U.S.C. § 2421. As previously stated in paragraphs 20, 21, 
and 27, Defendant transported Plaintiff, Jane Doe No. 102, across state lines and across 
international borders numerous times from the time that Plaintiff was merely 15 years old 
through adulthood with the primary intent of sexually exploiting her. 
51. 
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
52. 
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, 
17 
Podhurst Orseck, P.A. 
25 Weat Flatlet Street. Suite BOO, Mturd, FL 33130. Miami 305.358.M00 Fax 305)58.2382 • Fon Lauderdue 951.163.4316 I 
www.podhuratcom 
EFTA00184431

Case 9:08-y-80736-KAM Document 361-30 Entered on FLSD Docket 02/10/2016 Page 19 of 
Case 9:09-cv-80656-KAM Document 1 Eggrred on FLSD Docket 05/04/2009 Page 18 of 27 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
leading her into a perverse and unhealthy way of life 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 Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as 
this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right 
by a jury. 
COUNT SIX 
!Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. & 2255 in 
Violation of 18 U.S.C. & 22511 
53. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 32 above. 
54. 
Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, or coerced the 
then minor Plaintiff to engage in sexually explicit conduct for the purpose of producing a visual 
depiction of such conduct, in violation of IS U.S.C. § 2251. As previously stated in paragraphs 
14, 24, and 25, Defendant kept and 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. 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 
I8 
Podliurst Orseck, P.A. 
25 West Flagkz Street, Suite 800. Miami, it 33130, Miami 305.358.Tb00 Fax 305355.2382 • Fort tsoderdale 954.463.4346 
www.podhumt.com 
EFTA00184432

Case 9:08-cv-80736-KAM Document 361-30 Entered on FLSD Docket 02/10/2016 Page 20 of 
Case 9:09-cv-80656-KAM Document 1 Egered on FLSD Docket 05/04/2009 Page 19 of 27 
Beach. 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. 102, with his hidden cameras and may have 
transported lewd photographs of Plaintiff (among many other victims) to his other residences and 
elsewhere using a facility or means of interstate and/or foreign commerce. Upon information 
and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were 
confiscated by the Palm Beach Sheriff's Office during its execution of a search warrant of 
Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those 
photographs are still in the custody of law enforcement. 
55. 
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
56. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical 
and psychological expenses, and Plaintiff will in the future suffer additional medical and 
psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 
19 
Podhurst Orseck, P.A. 
7S Wed Masan SOTOM Gibe Alm. MIAMI. R. ail VI. Miami INS Wi min Paw Inc MR 7.1R7 • Fent laudsntal 9S4 4Al lit/ 
t 
www nrwIlmr. rents 
EFTA00184433

Casec9ag4c.6-98g_INAFIAVedaeurgt111-"EgailncgaWogailbethialiBladNeAvf 
income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in 
nature, and Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as 
this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right 
by a jury. 
COUNT SEVEN 
(Cause of Action for Transport of Visual Depiction of Minor Enstaalna in Sexually Explicit 
Conduct pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. S 2252(a)(1)1 
57. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs I through 32 above. 
58. 
Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via 
computer and/or facsimile in or affecting interstate and/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)( I ). As previously stated in paragraphs 14, 24, and 25, 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. Plaintiff, Jane Doe No. 102, saw 
photographs of naked young girls in each of Defendant's homes, including a photograph of 
herself naked as a minor at Defendant's home in Palm Beach. As previously stated in paragraph 
24, Defendant told Plaintiff that he had photographs of her naked in all of his homes. 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 
20 
Podhurst Orseck, P.A. 
W...171.nien CrIves• C. .1 INA %Al *gni CI 11111 Mi..ni II1C VA /OM Raw IRS ICA 11A1 . Few. I wad...Asia RV AA' ALA 
••••••••• nerthr.n.""en 
EFTA00184434

Casec9aidg3A-M<AVcBgleurrUr51;3°E4gaec§inAlbsagailig8iiii86flagNeoiir 
photographs of Plaintiff, Jane Doe No. 102, with his hidden cameras and may have transported 
lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere 
using a facility or means of interstate and/or foreign commerce. Upon information and belief, 
one or more nude photographs of Plaintiff that were taken when she was a minor were 
confiscated by the Palm Beach Sheriff's Office during its execution of a search warrant of 
Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those 
photographs are still in the custody of law enforcement. 
59. 
As previously stated in paragraph 23, any assertions by Defendant that he was 
unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by 
the provision of applicable federal and state statutes concerning the sexual exploitation and abuse 
of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew 
and should have known of Plaintiff's age of minority. Defendant's preference for underage girls 
was well-known to those who regularly procured them for him. 
60. 
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
61. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical 
and psychological expenses, and Plaintiff will in the future suffer additional medical and 
21 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 805, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4146 
EFTA00184435

Case 9:08-cv-607361KAM. _Document 361-30 Entered on FLSD Docket 02/10/2016 Page 23 of 
case 9:09-cv-oub56-KAm uocument 1 Egired on FLSD Docket 05/04/2009 Page 22 of 27 
psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 
income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in 
nature, and Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as 
this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right 
by a jury. 
COUNT EIGHT 
fCause of Action for Transport of Child Pornography pursuant to 18 U.S.C. 6 2255 iq 
Violation of 18 U.S.C. ti 2252A(alITH 
62. 
Plaintiff, Jane Doc No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 32 above. 
63. 
Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via 
computer and/or facsimile in or affecting interstate and/or foreign commerce child pornography 
in violation of I8 U.S.C. § 2252A(a)(1). 
64. 
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
65. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
22 
Podhurst Orseck, P.A. 
25 West Flatter Sheet, Suite 800, Miami, FL 33130, Miami 305.358.7800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 
www.podhumt.com 
EFTA00184436

5aseagavoggiligge lacument 363.-30 Entered ou F1,512 Docke_02/10/2016 Page 24 of 
uocument 
Enpred on 
Docket OW04/2009 Page 23 of 27 
leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical 
and psychological expenses, and Plaintiff will in the future suffer additional medical and 
psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 
income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in 
nature, and Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as 
this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right 
by a jury. 
COUNT NINE 
(Cause of Action for Eneseine in a Child Exploitation Enterprise pursuant to 18 U.S.C. 
2255 in Violation of 18 U.S.C. fi 2252/V211 
66. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 32 above and Counts One through 
Eight above. 
67. 
Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, 
as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 U.S.C. § 2252A(g)(1). As more fully 
set forth above, Defendant engaged in actions that constitute countless violations of 18 U.S.C. § 
1591 (sex trafficking of children), Chapter 110 (sexual exploitation of children in violation of 18 
U.S.C. §§ 2251, 2252(a)(1), and 2252(A)(a)(1)), and Chapter 117 (transportation for illegal 
sexual activity in violation of 18 U.S.C. §§ 2421, 2422, and 2423). As more fully set forth above 
in paragraphs 9 through 32, Defendant's actions involved countless victims and countless 
separate incidents of sexual abuse, which he committed against minors, including Plaintiff, in 
concert with at least three other persons. 
23 
Podhurst Orseck, P.A. 
25 West Flagler Street Suite BOO, Mixing. FL amso Miami 303356.2800 Fax 305.358.2382 • Fort Lauderdale 954.4614316 
podhuratcom 
EFTA00184437

casec-W*.tf_97a6WARectmed-AaT30ErpniicraPRolleakriM44864110aaasaM,
• 
68. 
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
69. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical 
and psychological expenses, and Plaintiff will in the future suffer additional medical and 
psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 
income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in 
nature, and Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as 
this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right 
by a jury. 
Date: May I, 2009 
fickla-A4 
krs....-4-1,4,-,6 
Robert C. Josefsb'erg, Bar No. 04085 
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) 
rjosefsbergApodhurst.com 
24 
Podhurst Orseck, I? A. 
25 West Flagler Street, Suite 80D, Mbiui, P1.33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346 
www.podluustann 
EFTA00184438

caseegig-16607v0M<AwcieoWniV33° Epe rsgat8Bgg
<V5VA/12%3816Palg:n (P2,1 
•
 
kezellarloodhurst.corn 
Attorneys for Plaintiff 
DEMAND FOR JURY TRIAL 
Plaintiff demands to have her cast tried before a jury. 
41,360 etto ir 
Robert C. Jose 
rg, Bar No. 04 56 
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) 
rjoscfsbere4podhurst.com 
keze110,podhurst.com 
Attorneys for Plaintiff 
25 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 803, Miami, FL 33130, MIami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 054.463.4346 
www.podhluet.cout 
EFTA00184439

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JS 44 (Res. 11103) 
CIVIL COVER SHEET 
11m1544 civil cooa sheet andthe information contained herein neilM replace na supplement the filing and service ofpleadings orother papers as requirolby law, except as provided 
by local rules ofcourt. This form approved by the Judicial Conference of the United States in Seolonber 1974. accoutred for the ascot dmClerk of Court for the outpost of initiating 
the civil docket Sheet (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) 
NOTICE: Attorneys MUST Indicate All Re-filed Cases Below. 
I. (a) PLAINTIFFS 
Jane Doe No. 102 
(b) County of Residence of FS Listed Plaintiff 
West Palm Beach 
tExcErr IN U.S. PLAINTIff CASES) 
(e) Attorney's (Firm Nut. Aden= ad lambent Numbed 
Robert C. Josefsbergy Esq./Katherine W. Ezell, Esq. 
Podhurst Orseck, P.A. 
25 W. Flagler St., Suite 800 
Minima SI 1111A 
O81 
OD Check County Where Action Arose 0 MIAMI. DADE 
CI MONROE vt3 BR 
&tut 
!CCM ANOS 
II. BASIS OF JURISDICTION 
t PI= an'X'' in One Box Only) 
III. C TIZENSHIP OF PRINCIPAL PARTIES(Plaoem'x-In one ao, for Nam& 
(For Dian*/ Casa Only) 
and One Box (or VeknclarsI 
O I 
U.S. Government 
VI 3 
FederalQuestion 
PT! 
DEF 
PT! 
DFF 
Plaintiff 
(U.S. Gomm= Not a Pay) 
Citizen of TVs Sat 
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I 
:I 
Incorporator Next* Place 
of Stuarts' In na stye 
O 
4 
O4 
0 2 U.S. Government 
Deferdant 
0 4 
Divinity 
Ordiese titiunship of Panics in Item III) 
Citizen °Mail= Sae 
0 
2 
0 
2 
Incorporated ant Principal Place 
of Banns In Another State 
0 
5 
0 
5 
titan or Subject 644 
0 
3 
0 
3 romp Notice 
0 
6 
0 6 
Penios Colwv
134c4510-
• 
DEFENDANTS 
Jeffrey Epstein 
County of Residence of First Lined Defendant 
West Palm Beach 
(IN US. PLAINTIFF; riccP CV II 
NOTE: IN LAND CONDEMNATION ClAtra 
ga. 
LAND INVOLVED 
, iNTAKE 
Jack A. Goldberger, Esq., Atterbury Goldberger, 1 
09
 et al., 250 S. 
20
Australian Ave., #1400, West Palm'BearetVEN3840/4110114obett 
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Morays (1(1(nown) 
PALM BEACH 0 MARTIN 0 ST. LtICIE fl INDIWIRD 
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FLEI 11.11711101043E 
clip"! it 
run r
1 
CONTRACT 
tants 
EillIFILIVREaltiALTY 
0 MO Apicultige 
0 62001M Food & Dug 
O 623 Ding Rawl Seizure 
of hope= 21 USC131 
0 
630 Liquor Laws 
11 640 R.R. & Dock 
0 
650 Aldine Rey 
O 660 Ostyak's& 
SaferiHealdt 
0 690 Other 
BANKRUPTCY 
enuartenars
0 
400 State Resparttrana 
0 
410 Anima 
O 430 Banks end flanking 
0 agitating= 
0 
460 Deportation 
0 
470 Racketeer Influenced and 
Cor=4 Onitamliont 
0 
480 Consumer Credit 
n 490 tatelSat TV 
O 810 San= Sere= 
O 830 SearitiatOrnmoditki/ 
Exchange 
0 105 (unman Challenge 
12 USC 1410 
0 
890 Other StstWory Anion 
0 
891 Agricultural Acts 
O 892 Economic Siabalmaion Act 
CI 893 Emanates= Mitten 
0 
894 Cagy Allocation Act 
0 
ICS Freedom of Information 
Au 
0 
900Appeal *Mt Determination 
Under Equal Amos 
.0 liwice 
0 
930 Constinsiondiry of 
Slat Slats 
0 I1D Iran= 
0 I 20 Marine 
0 130 Milkv Au 
O latiNecotiribk Intinontal 
0 150 Recovery of Overpayment 
& Enforcemas of lodatni 
0 151 Medicine Act 
0 I32 Recovery oft:kind= 
Sakai Loans 
(Excl. Wawa) 
O 133 Recovery a °yammers 
of Vtienn's Baths 
O 160 Slockhklea Suits 
0 000thm footrace 
O 195 Carnet Plod= Liability 
0 196 Franchise 
PERSONAL INJURY 
0 310 Airplay 
0 315Airplane Product 
Liabality 
0 120 Assault Libel & 
Slander 
0 310 Fat= Employas' 
L lability 
(7 340 Mmine 
0 345 Mans Pia= 
Liability 
0 350 Motor Veld= 
0135 Motor Vehicle 
Product Liability 
I/ )60 Oiber Imo= 
Brit= 
PERSONAL INJURY 
n 
362 Penoral Inkny - 
Met Maliattice 
O 
365 Personal Injury • 
hodun Listary 
0 
368 Asbestos Personal 
Injury Proad 
Cl 472 Appeal NI USC ISE 
0 423 Withdrawal 
28 USC 137 
ER J;r02.4 '141:1Cri 11 4 
0 820 Copyright 
0 830 Pt= 
0840 Talmud' 
Liability 
PERSONAL PROPERTY 
0 
3700he Dad 
0 
371 Ina in Lending 
11 11100thei tenon 
Property Canape 
f3 
1115 'Napery Damage 
Product Liability 
L4ROR 
SOCIAL SECURITY 
0 
711:Wok LatoceStanlasdi 
Act 
0 
720 LabonMps. Relations 
0 
730 Labx/Mpraltmoning 
a Disclosum Act 
0 
740 Railway Labor MI 
0 
790 Orin's= Litiption 
0 
791 Encl. Ret. Inc. 
Scanty Act 
0861 MIA (1393M 
0 1162 Blmk Lung (92Il 
0 863 DIWODIWW I405(10) 
0 664 55113 Tide XVI 
0 865 RSI (403(0) 
I 
REAL PROPERTY 
CIVIL RIGHTS 
PRISONERFESTOONS 
FEDERAL TAX SUITS 
0210 Lend Coademnolice 
0 220 Foreclosure 
1 230 Rea tale & Eject/ant 
1 240 Tons to Land 
0 243 Ton Piston Liability 
0 290All Other Real Popery 
O441 Voting 
13 442 Eraployincat 
0 443 Housing( 
Accommodation 
0 444 Welfare 
0 443 Amer. arDitabilitiet • 
natant= 
0 446 Amer. tDitabititia • 
Other 
0 440Other Civil Rights 
0 
510 Moderato Vacate 
Sentence 
Hams Corpm: 
CI 
530 General 
1 
533 De= Pena& 
0 
540 Madam & Cala 
0 
SSOCivil Rislas 
C3 
555 Prison Condition 
1 870 faxes (U S Plana 
or Defenlan) 
Cl 871 IRS —Third Party 
26 USC 7609 
I. ORIGIN 
• 1 Original 
Proceeding 
(Place a 
in One Son Only) 
O 2 Removed from 
I 
3 
Re-filed-
Stale Cow 
(see VI below) 
fiansfored flan 
O 
4 Reinstated or 
3 Dreary )strict 
O 6 Multidistrwt 
Reopened 
D 
Litigation 
Aupereal to DilITICI 
n 7 
rn'm
Magistrate 
Judirnan 
VI. RELATED/RE-FILED 
CASE(S). 
(Set inisevcoores 
scox4 pp): 
a) Re-filed Case CI YES 0 NO 
6) Related Cases (OYES ONO 
JUDGE Kenneth A. Marra 
DOCKET See Attached 
NUMBER 
VII. CAUSE OF 
ACTION 
Cie the U.S. Civil Statute under which you arc filing and Write a Lind Slalomed of Cause (Do wt cite taritdiaionid statutes makes 
diversity): 
18 U.S.C. 2255 (Predicate Statutes 18 U.S.C. 2422(6), 2423(6). 2423(e), 225I, 2252, 2252A(aX1), 2252A(g)( I ) 
LENGTH OF TRIAL via 4 
days estimated (far bath sides to try entire ease) 
VIII. REQUESTED IN 
O CHECK IF THIS IS A CLASS ACTION 
DEMANDS 
CHECK YES only if demanded in complaint 
JURY DEMAND: 
pi Yes r No 
COMPLAINT: 
UNDER 
R.0 P 23 
ABOVE INFORMATION IS TRUE & CORRECT 10 
THE BEST OF MY KNOWLEDGE 
SKIN fL
.
 IRE OF ATTORNEY 0.F RFC 
DATE 
1,4) 
R OFFICE LSI oNlye.„, 
AMOUNT` 
< Si% 
RECEIPTS .Ct
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EFTA00184440

Case HAP.. Ncifiya
KRocument 361-30 _fltered on FLSD Docket 02/10/2016 Page 28 of 
uocument 1 qgered on FLSD Docket 05/04/2009 Page 27 of 27 
r• 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
WEST PALM BEACH DIVISION 
ATTACHMENT TO CIVIL COVER SHEET 
FOR: Jane Doe letv. Jeffrey Epstein 
VI: 
RELATED/RE-FIELD CASE(S): 
08-80069 
08-80119 
08-80232 
08-80380 
08-80381 
08-08804 
08-80811 
08-80893 
08-80993 
08-80994 
08-80469 
09-80591 
EFTA00184441

Case 9:08-cv-80736-KAM Document 361-31 Entered on FLSD Docket 02/10/2016 Page 1 of 
13 
EXHIBIT 
31 
EFTA00184442

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13 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-CIV-Marra/Matthewman 
JANE DOE #1 and JANE DOE #2, 
Petitioners, 
1. 
UNITED STATES OF AMERICA, 
Respondent. 
UNITED STATES' RESPONSE TO 
PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT 
The United States (hereinafter the "government") hereby responds to Jane Doe #1 and 
Jane Doe #2's First Request for Admissions to the Government Regarding Questions Relevant to 
Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for 
Admissions"), and states as follows:*
1. The government admits that the FBI and the U.S. Attorney's Office for the Southern 
District of Florida ("USAO") conducted an investigation into Jeffrey Epstein 
("Epstein") and developed evidence and information in contemplation of a potential 
federal prosecution against Epstein for many federal sex offenses. 
Except as 
otherwise admitted above, the government denies Request No. 1. 
• The government's response is confined to Request No. 1 through Request No. 26 in the 
"Discovery Requested" section of the Request for Admissions and does not intend to respond to 
assertions in any other section of the Request for Admissions (including the "Background" 
section), none of which appear to separately state any matter calling for an admission. 
Nonetheless, the government denies the assertion that the government has declined the request of 
Jane Doe #1 and Jane Doe #2 to stipulate to undisputed facts in this case. 
1 
EFTA00184443