EFTA00192835

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 7 of 19 
other damages associated with Defendant's controlling and manipulating her into a perverse and 
unhealthy way of life. 
21. 
Any assertions by Defendant that he was unaware of the age of the then minor 
Plaintiff are belied by her telling him her high school graduation year, as well as his own actions, 
and are rendered irrelevant by the provision of applicable federal statutes concerning the sexual 
exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this 
cause of action, knew and should have known of Plaintiff's age of minority. In fact, his 
preference for underage girls was well-known to those who regularly procured them for him. 
22. 
Defendant, Jeffrey Epstein, committed the above-referenced acts upon the then 
minor Plaintiff in violation of federal statutes condemning the coercion and enticement of a 
minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual 
conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual 
depictions of a minor engaging in sexually explicit conduct, transport of child pornography, child 
exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes 
designated in 18 U.S.C. § 2422(b), § 2423(b), § 2423(e), § 2251, § 2252, § 2252A(a)(I), § 
2252A(g)(I), and * 1591. 
23. 
After investigations by the Palm Beach Police Department, the Palm Beach State 
Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's Office 
for the Southern District of Florida, Defendant, Jeffrey Epstein, entered picas of "guilty" to 
various Florida state crimes involving the solicitation of minors for prostitution and the 
procurement of minors for the purposes of prostitution in June 2008 in the Fifteenth Judicial 
Circuit in Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if 
he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such, 
Podhurat °neck, P.A. 
7 
23 Wen Phew Sind, Sults 800, MCI, Pt 33130, Miami 3053581BM Pax 305336.2W • Port Isuderdolo 9544614316 I 
Case No. 08-80736-CV-MARRA 
P-011829 
EFTA00192875

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 8 of 19 
must admit liability unto Plaintiff, Jane Doe. Plaintiff hereby exclusively seeks civil remedies 
pursuant to 18 U.S.C. § 2255. 
COUNT ONE 
fCause of Action for Coercion and Enticement of Minor to Engage in Prostitution or 
Sexual Activity pursuant to 18 U.S.C. ti 2255 in Violation of 18 U.S.C. 2422(bfl 
24. 
Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs I through 23 above. 
25. 
Defendant, Jeffrey Epstein, used a facility or means of interstate commerce to 
knowingly persuade, induce, or entice Jane Doe, when she was under the age of 18 years, to 
engage in prostitution and/or sexual activity for which any person can be charged with a criminal 
offense pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(h). 
26. 
Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. 
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this 
Section of the United States Code. 
27. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and 
other damages associated with Defendant's manipulating and leading her into a perverse and 
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, 
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 
has suffered a loss of income, a toss of the capacity to earn income in the future, and a loss of the 
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to 
suffer these losses in the future. 
Podhurst Orseck, P.A. 
8 
25 wet Malec Sent, suite eao, MbaJ, FL 33130, Miami 305.358.21C0 Fax 303358.2162 • Pert Lauderdale 934.463.4346 
www.podhuroloaat 
Case No. 08-80736-CV-MARRA 
P-011830 
EFTA00192876

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 9 of 19 
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey 
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual 
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this 
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by 
a jury. 
COUNT TWO 
(Cause of Action for Travel with Intent to Engage in Illicit Sexual Conduct pursuant to 18 
U.S.C. & 2255 in Violation of 18 U.S.C. & 2423(bi) 
28. 
Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 23 above. 
29. 
ijpon information and belief, Defendant, Jeffrey Epstein, traveled in interstate 
commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 
2423(f), with minor females, in violation of 18 U.S.C. § 2423(b). 
30. 
Plaintiff. Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. 
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this 
Section of the United States Code. 
31. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and 
other damages associated with Defendant's manipulating and leading her into a perverse and 
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, 
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has 
suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the 
Poclhurst Orseck, R A. 
9 
25 west Meer Street Suite SOO, Miami, PI. 33130. Mead 3053362800 Fax 346358.2M • Poet Lauderdale 954463046 
Case No. 08-80736-CV-MARRA 
P-0[1831 
EFTA00192877

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 10 of 19 
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to 
suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey 
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual 
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this 
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by 
a jury. 
COUNT THREE 
(Cause of Action for Sex Traffickine of Children pursuant to 18 U.S.C. b 2255 in Violation 
of 18 U.S.C. ti 1591(a)) 
32. 
Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs I through 23 above. 
33. 
Defendant, Jeffrey Epstein, knowingly, in or affecting interstate or foreign 
commerce, recruited, enticed, and obtained Plaintiff, Jane Doe, knowing that she had not attained 
the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 
U.S.C. § 1591(0)(1), in violation of 18 U.S.C. § 1591(a)(1). 
34. 
Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. 
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this 
Section of the United States Code. 
35. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and 
other damages associated with Defendant's manipulating and leading her into a perverse and 
Podhurst Once& P.A. 
10 
25 West Plagler Stet. Suite KO, Nand. FL 33130, Kuril 305.3932800 Fax 3053582382 • Fort Lauderede 951.163.4346 I 
inewpodhurstroot 
Case No. 08-80736-CV-MARRA 
P-011832 
EFTA00192878

Case 9:09-Oi-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 11 of 19 
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, 
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the 
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to 
suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey 
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual 
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this 
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by 
a jury. 
COUNT FOUR 
(Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. & 2255 in 
Violation of 18 U.S.C. & 22511 
36. 
Plaintiff, Jane Doc, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 23 above. 
37. 
Defendant, Jeffrey Epstein, knowingly induced, enticed, or coerced then minor 
Plaintiff Jane Doe to engage in sexually explicit conduct for the purpose of producing a visual 
depiction of such conduct in violation of 18 U.S.C. § 2251. As previously stated in paragraphs 
14 and 16, Defendant displayed a myriad of photographs of underage girls throughout his homes 
in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. Upon information and 
belief, many of the photographs in the possession of Defendant were taken with hidden cameras 
set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden 
cameras and photographs of underage girls on a computer in Defendant's home. 
Upon 
information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of 
Plaintiff, Jane Doc, with his hidden cameras and may have transported lewd photographs of 
Podhurst Orseck, P.A. 
11 
13 West Hagler Steen Suite 800. Miami. FL33130, Miami 305358.21X* Fax 301.3582382 • Port Lauderdale 954.463.4346 
.podhuntcozn 
Case No. 08.80736-CV-MARRA 
P-011833 
EFTA00192879

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 12 of 19 
Plaintiff (among many other victims) to his other residences and elsewhere using a facility or 
means of interstate commerce. 
38. 
Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. 
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this 
Section of the United States Code. 
39. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and 
other damages associated with Defendant's manipulating and leading her into a perverse and 
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, 
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the 
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to 
suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey 
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual 
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this 
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by 
a jury. 
Podhurst Orseck, P.A. 
I2 
25 West Rasher Street, SUMP SOO, Maud, FT. 33130, MIanL 3053582880 Fax 3053582382 • Fort Lauderdale 554.463A346 
www.podlutroterom 
Case No. 08-80736-CV-MARRA 
P-011834 
EFTA00192880

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 13 of 19 
COUNT FIVE 
(Cause of Action for Transport of Visual Depiction of Minor Eneanine in Sexually Explicit 
Conduct pursuant to 18 U.S.C. 4 2255 in Violation of 18 U.S.C. & 2252(a)(1)1 
40. 
Plaintiff, Jane Doe, hereby adopts, repeats, =lieges, and incorporates by 
reference the allegations contained in paragraphs I through 23 above. 
41. 
Defendant, Jeffrey Epstein, knowingly mailed, transported, or shipped in 
interstate or foreign commerce child pornography in violation of 18 U.S.C. § 2252(1). As 
previously stated in paragraphs 14, 16, and 37, upon information and belief, Defendant displayed 
a myriad of photographs of underage girls throughout his homes in New York, Palm Beach, New 
Mexico, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in 
the possession of Defendant were taken with hidden cameras set up throughout his home in Palm 
Beach. On the day of his arrest, police found two hidden cameras and photographs of underage 
girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey 
Epstein, may have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and 
may have transported lewd photographs of Plaintiff (among many other victims) to his other 
residences and elsewhere using a facility or means of interstate commerce. 
42. 
As previously stated in paragraph 21, any assertions by Defendant that he was 
unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by 
the provision of applicable federal and state statutes concerning the sexual exploitation and abuse 
of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew 
and should have known of Plaintiff's age of minority. In fact, his preference for underage girls 
was well-known to those who regularly procured them for him. 
43. 
Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. 
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this 
Section of the United States Code. 
Podhurst Orseck, P.A. 
13 
25 Wed Meer Sued. Suite 800. Mlwt FL03130. Mang 3(5.158.2800 Fax 305358.2382 • Foci Lauderdale 954.461.4346 I 
www.podlwtteasn 
Case No. 08-80736-CV-MARRA 
PA11835 
EFTA00192881

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 14 of 19 
44. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and 
other damages associated with Defendant's manipulating and leading her into a perverse and 
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, 
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the 
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to 
suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey 
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual 
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this 
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by 
a jury. 
COUNT SIX 
(Cause of Action for Transport of Child Pornography pursuant to 18 U.S.C. & 2255 in 
Violation of 18 U,S.C. ti 2252A(a)(1)1 
45. 
Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs I through 23 above. 
46. 
Defendant, Jeffrey Epstein, knowingly mailed, transported, or shipped in 
interstate or foreign commerce child pornography in violation of 18 U.S.C. § 2252A(a)(1). 
Podhurst Orsecic, P.A. 
14 
ZS West Meer Street. Suite 800, MWµ P1.13130. Ittlen0 305.1582800 Pax 305358.2382 • Port Lauderdale 951.463.8346 
.podhuntcom 
Case No. 08.80736-CV-MARRA 
P-011836 
EFTA00192882

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 15 of 19 
47. 
Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. 
§ 2255, and, as such asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this 
Section of the United States Code. 
48. 
Defendant, Jeffrey Epstein, is in the same position as if he had been tried and 
convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability 
unto Plaintiff, Jane Doe. 
49. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and 
other damages associated with Defendant's manipulating and leading her into a perverse and 
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, 
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the 
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to 
suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey 
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual 
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this 
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by 
a jury. 
Podhurst Orseck, P.A. 
25 Wag FlalJer Street Suite SOO, Wan* FL 33130. Miura 305358.2800 Fax 305358.2382 • Rift Lauderdale 958463.4346 
I 
www.podhuntaxm 
15 
Case No. 08.80736-CV-MARRA 
P-011837 
EFTA00192883

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 16 of 19 
COUNT SEVEN 
(Cause of Action for Envie.Ina in a Child Exploitation Enterprise pursuant to 18 U.S.C. § 
2255 in Violation of 18 U.S.C. 6 2252Alafi 
50. 
Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs I through 23 above. 
51. 
Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, 
as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 USC § 2252A(g)(1). As more fully set 
forth above in paragraphs 9 through 19, Defendant's actions involved countless victims and 
countless incidents of abuse, and he committed those offenses against minors in concert with at 
least three other persons. 
52. 
Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. 
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this 
Section of the United States Code. 
53. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and 
other damages associated with Defendant's manipulating and leading her into a perverse and 
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, 
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the 
capacity to enjoy life. These injuries arc permanent in nature, and Plaintiff will continue to 
suffer these losses in the future. 
Podhurst Orseck, P.A. 
16 
23 West Hagler Week Suite 800, Ma, FL 33130, Miami 3053582900 Fax 3053581242 • Fort Lauderdale 954.463.4346 
twatcom 
Case No. 08.80736-CV-MARRA 
P-011838 
EFTA00192884

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 17 of 19 
WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey 
Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual 
and compensatory damages, attorney's fees, costs of suit, and such other further relief as this 
Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by 
a jury. 
Date: April 17, 2009 
C. 
6-1 
Robert C. Jose s 
re gt1tIo. 040856 
Katherine W. Ezell, Bar No. 114771 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 800 
Miami, Florida 33130 
(305) 358-2800 
(305)358-2382 (fax) 
riosefsberg@podhurst.com 
kezell@podhurst.com 
Attorneys for Plaintiff 
REMAND FOR JURY TRIAL 
Plaintiff demands to have her case tried before a jury. 
Podhurst Orseck, P.A. 
17 
Robert C. Josefstrreei
r No. 04\0-;. -6 
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) 
riosefsbenaoodhurst.com 
kezell@podhurst.com 
Attorneys for Plaintiff 
C • 
i•Ln 
25 Wat Hagler Stmt.Sat SOO, 1,41sent FI, 33130. Pallid 3053%2903 Fax 305.3567382 • Fort Lauderdale 954463.4346 
www.padhurst coen 
Case No. 08-80736-CV-MARRA 
P-0 I I 819 
EFTA00192885

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 18 of 19 
J544 (Rev. I103) 
CIVIL COVER SHEET 
• 
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the civil dada shed. (SEE INSTRUCTIONS ON THE RE VERSE OF THE FOAM I 
NOTICE: Attoroeys MUST ladkate All Re-filed Cones Below. 
I. (R) PLAINTIFFS 
Jane Doe No. 101 
(b) COunly Of Reddest* of Eitel Lime, Plaintiff 
Weal Palm Beach 
(EXCEPT NUS. PLAINTS'S CASES) 
(C) Anomeys Sinn Nana. Addrem, endTelephone Asti 
Robert C. losefsberg, EsqACatherine W. Ezell, Esq. 
Podhurst Orseck, P.A. 
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UNDER F.R.C.P. 23 
Case No. 08-80736-CV-MARRA 
P-011840 
EFTA00192886

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 19 of 19 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
WEST PALM BEACH DIVISION 
ATTACHMENT TO CIVIL COVER SHEET 
FOR: Jane Doe No. 101'. Jeffrey Epstein 
VI. 
RELATED/RE-FILED CASE(S): 
08.80069 
08-80119 
08-80232 
08-80380 
08-80381 
08-08804 
08-80811 
08-80893 
08-80993 
08-80994 
08.80469 
Case No. 08-80736-CV-MARRA 
P411841 
EFTA00192887

Case 9:09-cv-80591 -KAM 
Document 29 
Entered on FLSD Docket 05/26/2009 
Page 1 of 36 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
JANE DOE No. 101, 
Plaintiff, 
I 
JEFFREY EPSTEIN, 
Defendant. 
Case No.: 9:09-CV-80591-KAM 
DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED 
COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT 
Defendant JEFFREY EPSTEIN, by and through his undersigned counsel, moves to 
dismiss or, alternatively, for a more definite statement of, the First Amended Complaint. Fed. R. 
Civ. RR. 12(b)(6) & 12(e) (2009); Loc. Rule 7.1 (S.D. Fla. 2009). In support, Defendant states: 
Pleadine Standard & Summary of Areument 
The First Amended Complaint ("FAC") alleges claims under 18 U.S.C. § 2255 that 
explicitly incorporate, and thus necessarily require Plaintiff to prove that Defendant is guilty of 
violating, specific criminal prohibitions set forth in Title 18 of the U.S. Code. While the 
Supreme Court has held that every complaint "'must contain something more than a statement of 
facts that merely creates a suspicion of a legally cognizable right of action,'" Hell Atlantic Corn. 
1 Twomblv, 550 U.S. 544, 555 (2007), and just last week made clear that "Twombly expounded 
the pleading standard for 'all civil actions' and not just pleadings made in the context of an 
antitrust dispute," Ashcroft'. Iqbal No. 07-1015 (U.S. May 18, 2009) (slip op. at 20) (quoting 
Fed. R. Civ. P. 1), the need to enforce these pleading requirements is especially acute in this 
context. After all, the defendant in a § 2255 action is essentially being put on trial for violating 
criminal laws, and the statutory penalty is obviously and intentionally punitive. 
As a result, it not only is appropriate to require "more than an unadorned, the-defendant-
Case No. 08-80736-CV-MARRA 
P-011842 
EFTA00192888

Case 9:09-cv-80591-KAM 
Document 29 
Entered on FLSD Docket 05/26/2009 
Page 2 of 36 
unlawfully-harmed-me accusation" before allowing plaintiffs to launch a fishing expedition for 
evidence of possible crimes, label, slip op. at 14 (citing Thyombly, 550 U.S. at 555), but essential 
that the accused be given "'such a statement of the facts and circumstances as will inform [him] 
of the specific offense ... with which he is charged," including a "specific identification of 
fact[s)" required to establish "fully, directly, and expressly, without any uncertainty or 
ambiguity, ... all the elements necessary to constitute the offence." Russell'. United States, 369 
U.S. 749, 764-65 (1962) (quoting United States 
Hess 124 U.S. 483, 487 (1888); United States 
Carl[, 105 U.S. 611, 612 (1881)). The FAC does not come close to discharging that burden. 
& The applicable version of § 2255 only permits "minors" to sue: "Any minor who is a 
victim of a violation of [certain criminal statutes] and who suffers personal injury as a result of 
such violation may sue." 18 U.S.C. § 2255(a) (2003) (emphasis added). 
Yet the FAC 
affirmatively admits that Plaintiff is over the age of 18. See FAC ¶ 18 ("Plaintiff was first 
brought to Defendant's mansion in or about the spring of 2003, when she was merely 17 years 
old."). Plaintiff is bound by that admission, and the FAC must be dismissed with prejudice. 
Best Canvas Prods. & Supplies, Inc.'. Ploof Truck Lines, Inc., 713 F.2d 618, 621 (11th Cir. 
1983) ("[A] party is bound by the admissions in his pleadings."). 
L. Nor is Plaintiff the "victim of a violation" of a predicate criminal statute within the 
meaning of § 2255. 18 U.S.C. § 2255(a). In our system of justice, those accused of "violating" a 
criminal statute are innocent until proven guilty beyond a reasonable doubt in a criminal court. 
With due respect to the courts that have concluded otherwise, it defies common sense to think 
that Congress intended to invert that fundamental legal norm, and the legislative history of 
§ 2255 expressly confirms that Congress intended to condition § 2255 actions on an antecedent 
criminal conviction. The FAC therefore must be dismissed because it does not—and cannot—
allege that Defendant has been convicted of a predicate criminal offense. 
c z Even if the applicable version of § 2255 were construed to allow adults to sue in the 
Case No. 08-80736-CV•MARRA 
P-011843 
EFTA00192889

Case 9:09-cv-80591-KAM 
Document 29 
Entered on FLSD Docket 05/26/2009 
Page 3 of 36 
absence of a predicate conviction, the FAC not only fails to meet the modest pleading standards 
elucidated by Twombly and Tribal, but—even taken as true--would not establish a legally 
"plausible" claim that Plaintiff is a victim of any predicate criminal offense giving rise to a 
§ 2255 cause of action. See Iqbal, slip op. at 15 (explaining that every civil complaint must state 
"a plausible claim for relief," and that "where the well-pleaded facts do not permit the court to 
infer more than the mere possibility of misconduct, the complaint has alleged—but it has not 
'shown'—`that the pleader is entitled to relief.") (quoting Fed. R. Civ. P. 8(a)(2)). 
D. Finally, Plaintiff's attempt to multiply the penalties recoverable under § 2255(a) by 
pleading six separate counts is inconsistent with the language and structure of § 2255. The law 
allows for a single action predicated on any and all predicate criminal acts, and entitles the 
plaintiff only to a single recovery of actual damages (subject only to a presumptive minimum). 
I. 
THE COMPLAINT MUST BE DISMISSED BECAUSE PLAINTIFF IS NOT A MINOR. 
A. 
The Version of 18 U.S.C. § 2255 In Effect When The Predicate Acts Allegedly 
Were Committed Allowed Only "Minors" To File Suit. 
The FAC is predicated exclusively on acts that allegedly occurred in 2003. FAC 1 18 
("Plaintiff was first brought to Defendant's mansion in ... the spring of 2003."); id. 119 
("Defendant thereafter lured [Plaintiff] to [his home] on at least one and perhaps two other 
occasions in the spring and/or summer of 2003."). At that time, 18 U.S.C. § 2255(a) provided: 
Any minor who is a victim of a violation of [certain specified federal statutes] and 
who suffers personal injury as a result of such violation may sue in any 
appropriate United States District Court and shall recover the actual damages 
such minor sustains and the cost of the suit, including a reasonable attorney's 
fee. Any minor as described in the preceding sentence shall be deemed to have 
sustained damages of no less than $50,000 in value. 
It is well settled that in interpreting a statute, the court's inquiry begins with the text and 
structure of the law. CBS. Inc... Prime Time 24 Venture 245 F.3d 1217, 1222 (11th Cir. 2001) 
("We begin our construction of [a statutory provision] where courts should always begin the 
process of legislative interpretation, and where they often should end it as well, which is with the 
Case No. 08.80736•CV•MARRA 
P-011844 
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Case 9:09-cv-80591-KAM 
Document 29 
Entered on FLSD Docket 05/26/2009 
Page 4 of 36 
words of the statutory provision.") (quoting Karns I. Garner 216 F.3d 970, 972 (11th Cir. 
2000) (en bane)) (first alteration omitted). In this case, the plain text of the 2003 statute is both 
clear and unmistakable. It allowed only minors (or the representative of a then-minor, see Fed R. 
Civ. P. 17(c)) to initiate suit under § 2255. It provided only that "any minor ... may sue" and 
that "any minor ... shall recover the actual damages such minor sustains" as a result of the 
predicate acts. Id. (emphasis added). The law's use of the present tense further underscored its 
limited scope: It spoke of "any minor who is a victim," provided that "such minor ... shall 
recover" damages arising from the underlying offense, and stated that "any minor ... shall be 
deemed" to have sustained at least $50,000 in damages. Id. (emphasis added). Where the 
statute's words are unambiguous--as the arc here—the "judicial inquiry is complete." Mewl s
Pittard Paver Co 120 F.3d 1181, 1186 (11th Cir. 1997) (citation omitted)). Under the 2003 
version of the statute, only minors could initiate suit. 
To the extent there is any ambiguity in the text—and there is none—the law's legislative 
history further underscores Congress's intent to limit the right of action to minors: "Current law 
provides for a civil remedy for personal injuries resulting from child pornography offenses. This 
section expands the number of sex offenses in which a minor may pursue a civil remedy for 
personal injuries resulting from the offense." H.R. Rep. 105-557, at 23 (1998), as reprinted in 
1998 U.S.C.C.A.N. 678, 692. And perhaps most telling, Congress amended § 2255 in 2006—
three years after the alleged misconduct in this case supposedly took place—to make the civil 
action available to persons who had turned 18 by the time they filed suit: 
(a) In general.—Any person who, while a minor, was a victim of a violation of 
section 2241(c), 2242, 2243, 2251, 2251A, 2252, 2252A, 2260, 2421, 2422, or 
2423 of this title and who suffers personal injury as a result of such violation, 
regardless of whether the injury occurred while such person was a minor, may 
sue in any appropriate United States District Court and shall recover the actual 
damages such person sustains and the cost of the suit, including a reasonable 
attorney's fee. Any person as described in the preceding sentence shall be 
deemed to have sustained damages of no less than $150,000 in value. 
-4-
Case No. 08.80736-CV-MARRA 
P-011845 
EFTA00192891

Case 9:09-cv-80591-KAM 
Document 29 
Entered on FLSD Docket 05/26/2009 
Page 5 of 36 
18 U.S.C. § 2255 (2006) (emphasis added). 
The contrast between the 2003 and 2006 versions of § 2255 is stark. The 2006 law 
replaces each of the 2003 law's uses of the term "minor" with the term "person." Where the 
2006 law does refer to a "minor," it changes the 2003 law's present-tense references ("is") to 
past-tense references ("was"). And the 2006 law's new language now makes clear that, unlike 
the 2003 statute, those victimized while under the age of 18 may sue after they turn 18. Given 
that amendments must be interpreted "to have real and substantial effect," Stone'. I.N.S., 514 
U.S. 386, 397 (1995), there can be no doubt that Congress recognized the prior statute's strict 
limitations and for the first time expanded the tight of action to adults. 
Indeed, the history of the 2006 amendments clearly shows that Congress intended to 
change the law, not merely to clarify it. Those amendments were made by § 707 of the Adam 
Walsh Child Protection and Safety Act, Pub. L. No. 109-248, 120 Stat. 587, 650 (2006), and are 
known as "Masha's Law." As Senator Kerry—the author of Masha's Law—explained: 
What Masha's law does, and what is incorporated in here, is it changes "any 
minor" to "any person," so that if a minor Is depicted in photographs 
pornographically that are distributed over the Internet, but by the time the 
abuser is caught, the minor is an adult, they can still recover. They cannot 
LtqL,v and that is ridiculous. It makes sure that recovery on the part of a minor 
cart take place when they become an adult.... 
Although I don't think there is any price too high to cost an individual who would 
take advantage of a minor, I think it is only appropriate to ... make sure that 
reaching the age of adulthood does not exempt someone from recovery. It is a 
tribute to continuing to do what this bill does, and that is look after the protection 
of minors and ensure that those who violate them are caught and punished and 
have to pay to the maximum extent. 
152 Cong. Rec. S8012-02 at 58016 (July 20, 2006) (statement of Sen. Kerry) (emphasis added). 
Courts typically give special weight to the statements of a bill's sponsor, Corley'. U.S. 129 
-5-
Cast No. 08.80736-CV-MARRA 
P-011846 
EFTA00192892

Case 9:09-cv-80591-KAM 
Document 29 
Entered on FLSD Docket 05/26/2009 
Page 6 of 36 
S.Ct. 1558, 1569 (Apr. 6, 2009) ("[A] sponsor's statement to the MI Senate carries considerable 
weight."),I There is no basis to depart from that rule here. 
It thus is no answer that the 2003 statute's limitations clause provided that "in the case of 
a person under a legal disability, [the complaint may be filed] not later than three years after the 
disability," 18 U.S.C. § 2255(b) (2003), such that the unamended version of the law implicitly 
must have permitted victims to sue even after they turned 18. That interpretation not only would 
render Masha's Law superfluous; it would make Masha's Law's internally redundant, because 
Masha's Law retained the "legal disability" language from the 2003 version of § 2255(b). See 
18 U.S.C. § 2255(b) (2006). In short, the retained "legal disability" language in § 2255(b) of the 
2006 statute would be entirely redundant were it construed to do implicitly what the law 
elsewhere did expressly. In these circumstances, the traditional Ma against surplusage and 
redundancy apply with double force. See, e.g., Duncan'. Walker 533 U.S. 167, 174 (2001). 
The "legal disability" language in § 2255(b) should be interpreted to reference classic legal 
disabilities like insanity, mental disability, or imprisonment—not age. 
Indeed, that is precisely how Congress typically uses the term "legal disability": most 
federal statutes that use the term make clear that it doesn't include age. See, e.g., 25 U.S.C. 
§ 590c CA share or interest payable to enrollees less than eighteen years of age or under legal 
Similarly, the official summary prepared by the Congressional Research Service ("CRS") explained that 
Masha's Law "(devises provisions allowing victims of certain sex-related crimes to seek civil remedies to: (I) 
allow adults as well as minors to sue for injuries; and (2) increase from 550,000 to $150,000 the minimum 
level of damages." 
Official Summary of Pub. Law No. 109-248 (July 27, 2006), as reprinted at 
http://thomas.loc.goviegi-bin/bdquery/z?d109:EiR04472:®@/(gL&summ2amt& (emphasis added) (last visited 
w
ay 10, 2009). Courts have long consulted official CRS summariesto assess legislative intent, see, e.g., &nig 
Pension Ben. Guar. Com. 744 F.2d 133, 145 & n.7 (D.C. Cir. 1984); fIRECI'V Inc. I. Cignarella No. 
I.
Civ.A 03-2384, 2005 W 1252261 at *7 (D.N.J. May 24, 2005); Clokesav 
St. Francis Hoso. & Healthcare 
No. 98-C-4818, 1999 WL 46898 *2-1,3 (ND. III. Jan. 28, 1999), and there is good reason to do so. By design, 
CRS summaries are intended to "objectively describe(] the measure's ... effect upon ... current law" so that 
Congress can make infonned judgments about the impact of proposed bills. See The Library of Congress, 
About CM Summary, available at http://thomaaloc.govrbss/abt_dget.btml (last visited May 10, 2009). 
-6-
Case No. 08-80736-CV-MARRA 
P-011847 
EFTA00192893

Case 9:09-cv-80591-KAM 
Document 29 
Entered on FLSD Docket 05/26/2009 
Page 7 of 36 
disability shall be paid ....") (emphasis added); id. § 783 ("Funds payable under sections 781 to 
785 of this title to minors or to persons under legal disability shall be paid....") (emphasis 
added); id. § 1128 ("Sums payable to enrollees ... who are less than eighteen years of age or 
who are under a legal disability shall be paid....") (emphasis added); id. § 1253 ("Sums payable 
... to enrollees ... who are less than eighteen years of age or who are under a legal disability 
shall be paid....") (emphasis added); id. § 1273 (same); id. § 1283 (same); id. § 1295 (same); id. 
§ 1300a-3 (same); id. § 1300c-3 (same); id. § 1300d-7 (same); see also 38 U.S.C. § 3501. 
Needless to say, Congress would not have had to address age expressly in any of these 
statutes if the term "legal disability" necessarily included one's status as a minor; instead, 
Congress's mere use of the term "legal disability" already would account for a would-be 
plaintiff's minority status. Given the rule "against reading a text in a way that makes part of it 
redundant," Nat'l Ass'n of Home BuildersI, Defenders of Wildlife 551 U.S. 644 (2007) (citing 
TRW Inc. 
Andrews 534 U.S. 19, 31 (2001)), and the canon that "where words are employed 
in a statute which had at the time a well-known meaning ... in the law of this country, they are 
presumed to have been used in that sense," $tandard Oil Co. I, United States, 221 U.S. 1, 59 
(1911), § 2255's reference to "legal disability" can only be interpreted as a reference to classic 
disabilities like insanity or mental incapacity, but not age. 
But this Court need not even reach that issue in this case. Regardless of whether 
§ 2255(6) would allow a minor to sue within three years of turning 18, that carve-out would not 
help Plaintiff in this case. After all, she openly admits that she was 17 years-old in 2003. FAC 
11 18, 19. That means that she was either 22 or 23 when she filed this case in April 2009—at 
least a full year beyond the three-year period set forth in § 2255(6), regardless of how the "legal 
disability" language in that subsection of the statute is construed. In shod, and under any 
reasonable interpretation of the law, the version of the statute in effect at the time of the alleged 
criminal conduct giving rise to this suit would preclude Plaintiff from maintaining this action. 
-7-
Case No. 08-80736-CV-MARRA 
P-011848 
EFTA00192894