EFTA00221567

Case 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 1 of 22 
IN THE UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF FLORIDA 
JANE DOE No. 101, 
Civil Action No. 9:09-cv-80591-KAM 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
FIRST AMENDED COMPLAINT AND 
DEMAND FOR JURY TRIAL 
FIRST AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL 
Plaintiff, Jane Doe No. 101, 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. 101, 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. 101, 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. 
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6. 
This Court has jurisdiction of 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, 
approximately 50 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," and 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 in his home 
to countless relatively economically disadvantaged minor girls, 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 children to engage in a systematic 
pattern of sexually exploitative behavior. 
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11. 
Defendant's plan and scheme reflected a particular pattern and method. 
Defendant coerced and enticed impressionable, vulnerable, and relatively economically less 
fortunate minors 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 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 seek out economically disadvantaged and underage girls from 
West Palm Beach and surrounding areas who would be enticed by the money being offered—
generally $200 to $300 per "massage" session—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 
14 years old, were transported to Defendant's Palm Beach county 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 sexually 
explicit photographs and/or videos of the underage girls' for Defendant without their knowledge. 
Defendant would pay the procurer of each girl's "appointment" hundreds of dollars. 
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13. 
Epstein designed the scheme to secure a private place in Defendant's 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 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 
photographs of nude 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 four homes and on his computer. 
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. He would then perform one or more lewd, lascivious, and sexual acts, including 
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in Defendant's 
presence. The exact degree of molestation and frequency with which the sexual crimes took 
place varied and is not yet completely known; however, at least when Defendant was in Palm 
Beach, Florida, such acts occurred usually 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. 
As previously stated in paragraph 14, Defendant displayed photographs of nude 
underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. 
Virgin Islands. Upon information and belief, some of the photographs Defendant's possession of 
Defendant were taken with hidden cameras set up in his home in Palm Beach. On the day of his 
arrest, police found two hidden cameras and photographs of underage girls on a computer in 
Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken 
lewd photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have 
transported lewd photographs of Plaintiff (among many other victims) to his other residences and 
elsewhere using a facility or means of interstate and/or foreign commerce. Upon information 
and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were 
confiscated by the Palm Beach Police Department during its execution of a search warrant of 
Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those 
photographs are still in the custody of law enforcement. 
17. 
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 
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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 11 through the present paragraph occurred at all of Defendant's 
domestic and international residences and/or places of lodging and/or modes of transportation. 
18. 
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. 
Plaintiff, Jane Doe No. 101, was recruited by one of Defendant's agents to give Defendant a 
massage for compensation. Plaintiff was apprehensive, but needed the money and finally agreed 
to go. Plaintiff was first brought to Defendant's mansion in or about the spring of 2003, when 
she was merely 17 years old and in high school. Epstein's procurer drove her to Jeffrey 
Epstein's mansion. Plaintiff was led up a flight of stairs by a blonde woman to a spa room with a 
shower and a massage table, where she was left alone. A woman with dark hair, an accent, and 
naked from the waist up entered and tried to coax Plaintiff to remove her shirt, but Plaintiff 
refused. After the woman showed Plaintiff how to use the lotions that were there, the woman 
left. Defendant walked in wearing only a small towel. He lay down on the massage table still 
wearing the small towel, and Plaintiff began to massage his shoulders and neck. Nervously, she 
asked him what he did for a living. Defendant responded that he was a scientist. Defendant 
asked Plaintiff what year she would graduate high school, to which Plaintiff honestly replied that 
she would graduate in 2004. Plaintiff massaged Defendant's lower back and calves. Defendant 
told her to remove his towel. Defendant told her that he had just worked out and wanted his 
Although disgusted, she was afraid to refuse and did it. At some point, 
Defendant ordered Plaintiff to remove her clothes. In shock, fear, and trepidation, Plaintiff partly 
complied, removing only her shirt and bra. When Defendant turned over, Plaintiff was afraid 
and embarrassed and she wanted to leave. 
Defendant repeatedly told her to relax and 
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complimented her, saying that she had a nice body. Defendant then pulled Plaintiff closer to 
him. He began masturbating and then began 
He asked her to do more and 
mentioned more money, which she adamantly declined. Defendant continued a 
until 
hem 
Plaintiff next recalls that she received $200 and was transported by the procurer, 
whom she later learned received $200 for having brought her to Epstein's mansion. 
19. 
Defendant thereafter lured the then minor Plaintiff to the Epstein mansion on at 
least one and perhaps two other occasions in the spring and/or summer of 2003. The procurer 
made another appointment for her to return, but Plaintiff didn't want to see Defendant. By 
having his assistants continue to contact Plaintiff and attempt to lure her to the mansion for other 
sexual acts, Defendant engaged in a continuous course of conduct that injured Plaintiff upon 
each instance of contact and/or abuse. 
20. 
In addition to the direct sexual abuse and molestation of the then minor Plaintiff, 
Defendant used his money, wealth, and power to unduly and improperly manipulate and 
influence the then minor Plaintiff to bring him another minor girl in a promised exchange for 
money. Rather than go herself, Plaintiff and the procurer took another girl there one time. 
21. 
As a result of these encounters with Defendant, Plaintiff, Jane Doe No. 101, has in 
the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, 
emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, 
confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, 
invasion of her privacy, and other damages associated with Defendant's controlling and 
manipulating her into a perverse and unhealthy way of life. 
22. 
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 
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exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this 
cause of action, knew and should have known of Plaintiff's age of minority. Defendant's 
preference for underage girls was well-known to those who regularly procured them for him. 
23. 
Defendant, Jeffrey Epstein, committed the above-referenced acts upon the then 
minor Plaintiff in violation of federal statutes condemning the coercion and enticement of a 
minor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual 
conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual 
depictions of a minor engaging in sexually explicit conduct, transport of child pornography, child 
exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes 
designated in 18 U.S.C. § 2422(b), § 2423(b), § 2423(e), § 2251, § 2252, § 2252A(a)(1), and § 
2252A(g)(1). 
24. 
In June 2008, after investigations by the Palm Beach Police Department, the Palm 
Beach State Attorney's Office, the Federal Bureau of Investigation, and the United States 
Attorney's Office for the Southern District of Florida, Defendant, Jeffrey Epstein, entered pleas 
of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and 
the procurement of minors for the purposes of prostitution in the Fifteenth Judicial Circuit in 
Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if he had 
been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must 
admit liability unto Plaintiff, Jane Doe No. 101. Plaintiff hereby exclusively seeks civil remedies 
pursuant to 18 U.S.C. § 2255. 
COUNT ONE 
(Cause of Action for Coercion and Enticement of Minor to &mime in Prostitution or 
Sexual Activity pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2422(1))) 
25. 
Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 24 above. 
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26. 
Defendant, Jeffrey Epstein, used a facility or means of interstate and/or foreign 
commerce to knowingly persuade, induce, entice, or coerce Jane Doe No. 101, when she was 
under the age of 18 years, to engage in prostitution and/or sexual activity for which any person 
can be charged with a criminal offense, or attempted to do so, pursuant to 18 U.S.C. § 2255 in 
violation of 18 U.S.C. § 2422(b). 
27. 
Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
28. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and 
other damages associated with Defendant's manipulating and leading her into a perverse and 
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, 
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the 
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to 
suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as 
this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right 
by a jury. 
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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(b)) 
29. 
Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 24 above. 
30. 
Upon information and belief, Defendant, Jeffrey Epstein, traveled in interstate 
and/or foreign commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 
U.S.C. § 2423(f), with minor females, including the then minor Plaintiff, in violation of 18 
U.S.C. § 2423(6). 
31. 
Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
32. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and 
other damages associated with Defendant's manipulating and leading her into a perverse and 
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, 
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has 
suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the 
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to 
suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
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actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as 
this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right 
by a jury. 
COUNT THREE 
(Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. § 2255 in 
Violation of 18 U.S.C. § 2251) 
33. 
Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 24 above. 
34. 
Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, or coerced the 
then minor Plaintiff, Jane Doe No. 101, to engage in sexually explicit conduct for the purpose of 
producing a visual depiction of such conduct in violation of 18 U.S.C. § 2251. As previously 
stated in paragraphs 14 and 16, Defendant displayed a myriad of photographs of underage girls 
throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. 
Upon information and belief, many of the photographs in the possession of Defendant were 
taken with hidden cameras set up in his home in Palm Beach. On the day of his arrest, police 
found two hidden cameras and photographs of underage girls on a computer in Defendant's 
home. 
Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd 
photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have transported 
lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere 
using a facility or means of interstate and/or foreign commerce. Upon information and belief, 
one or more sexually explicit photographs of Plaintiff that were taken when she was a minor 
were confiscated by the Palm Beach Police Department during its execution of a search warrant 
of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those 
photographs are still in the custody of law enforcement. 
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35. 
Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
36. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and 
other damages associated with Defendant's manipulating and leading her into a perverse and 
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, 
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the 
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to 
suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as 
this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right 
by a jury. 
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COUNT FOUR 
(Cause of Action for Transport of Visual Depiction of Minor Eneaeina in Sexually Explicit 
Conduct pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2252(a)(1)) 
37. 
Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 24 above. 
38. 
Defendant, Jeffrey Epstein, upon information and belief, knowingly mailed, 
transported, shipped, or sent via computer and/or facsimile in or affecting interstate or foreign 
commerce at least one visual depiction of the minor Plaintiff engaging in sexually explicit 
conduct in violation of 18 U.S.C. § 2252(a)(1). As previously stated in paragraphs 14, 16, and 
34, upon information and belief, Defendant displayed a myriad of nude photographs of underage 
girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin 
Islands. Upon information and belief, many of the photographs in the possession of Defendant 
were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his 
arrest, police found two hidden cameras and photographs of underage girls on a computer in 
Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken 
lewd photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have 
transported lewd photographs of Plaintiff (among many other victims) to his other residences and 
elsewhere using a facility or means of interstate and/or foreign commerce. Upon information 
and belief, one or more sexually explicit photographs of Plaintiff that were taken when she was a 
minor were confiscated by the Palm Beach Police Department during its execution of a search 
warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, 
those photographs are still in the custody of law enforcement. 
39. 
As previously stated in paragraph 22, any assertions by Defendant that he was 
unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by 
the provision of applicable federal and state statutes concerning the sexual exploitation and abuse 
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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. 
40. 
Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
41. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and 
other damages associated with Defendant's manipulating and leading her into a perverse and 
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, 
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the 
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to 
suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as 
this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right 
by a jury. 
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COUNT FIVE 
(Cause of Action for Transport of Child Pornoeraphy pursuant to 18 U.S.C. § 2255 in 
Violation of 18 U.S.C. § 2252A(a)(1)) 
42. 
Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 24 above. 
43. 
Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via 
computer or facsimile in or affecting interstate and/or foreign commerce child pornography in 
violation of 18 U.S.C. § 2252A(a)(1). As previously stated in paragraph 16, Defendant displayed 
a myriad of nude photographs of underage girls throughout his homes, including his homes in 
New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Upon information and 
belief, many of the photographs in the possession of Defendant were taken with hidden cameras 
set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden 
cameras and nude photographs of underage girls on a computer in Defendant's home. Upon 
information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of 
Plaintiff, Jane Doe No. 101, with his hidden cameras and may have transported lewd 
photographs of Plaintiff (among many other victims) to his other residences and elsewhere using 
a facility or means of interstate and/or foreign commerce. Upon information and belief, one or 
more nude photographs of Plaintiff that were taken when she was a minor were confiscated by 
the Palm Beach Police Department during its execution of a search warrant of Defendant's Palm 
Beach mansion on October 20, 2005. Upon information and belief, those photographs are still 
in the custody of law enforcement. 
44. 
As previously stated in paragraph 22, any assertions by Defendant that he was 
unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by 
the provision of applicable federal and state statutes concerning the sexual exploitation and abuse 
of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew 
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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. 
45. 
Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
46. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and 
other damages associated with Defendant's manipulating and leading her into a perverse and 
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, 
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the 
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to 
suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as 
this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right 
by a jury. 
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COUNT SIX 
(Cause of Action for Eneagins in a Child Exploitation Enterprise pursuant to 18 U.S.C. 
2255 in Violation of 18 U.S.C. § 2252A(g)) 
47. 
Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 24 above and Counts One through 
Five. 
48. 
Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, 
as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 USC § 2252A(g)(1). As more fully 
above, Defendant engaged in actions that constitute countless violations of 18 U.S.C. § 1591 (sex 
trafficking of children), Chapter 110 (sexual exploitation of children in violation of 18 U.S.C. §§ 
2251, 2252(a)(1), and 2252(A)(a)(1)), and Chapter 117 (transportation for illegal sexual activity 
in violation of 18 U.S.C. §§ 2422, and 2423). As more fully set forth above in paragraphs 9 
through 19, Defendant's actions involved countless victims and countless separate incidents of 
abuse, and he committed those offenses against minors in concert with at least three other 
persons. 
49. 
Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
50. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and 
other damages associated with Defendant's manipulating and leading her into a perverse and 
unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, 
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Page 18 of 22 
and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 
has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the 
capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to 
suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as 
this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right 
by a jury. 
Date: May 1, 2009 
s/Katherine W. Ezell 
Robert C. Josefsberg, Bar No. 040856 
Katherine W. Ezell, Bar No. 114771 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 800 
3130 
(305) 358-2382 (fax) 
Attorneys for Plaintiff 
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Case 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05)01:2009 
Page 19 of 22 
DEMAND FOR .11:RY TRIAL 
Plaintiff demands to have her case tried before a jury. 
%/Katherine W. Ezell 
Robert C. Josefsberg, Bar No. 040856 
Katherine W. Ezell, Bar No. 114771 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 800 
Miami, Florida 33130 
(305) 358-2382 (fax) 
Attorneys for Plaintiff 
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Case 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05)01.2009 
Page 20 of 22 
CERTIFICATE OF SERVICE 
WE HEREBY CERTIFY that on this Ist day of May, 2009, we electronically filed the 
foregoing document with the Clerk of the Court using CM/ECF. We also certify that the 
foregoing document is being served this day on all counsel of record identified on the attached 
Service List either via transmission of Notices of Electronic Filing generated by CM/ECF or in 
some other authorized manner for those counsel or parties who are not authorized to receive 
electronically Notices of Electronic Filing. 
Respectfully submitted, 
PODHURST ORSECK, P.A. 
Attorneys for Plaintiff 
By: 
s/Katherine W. Ezell 
Robert C. Josefsberg 
Fla. Br No. 040856 
Katherine W. Ezell 
Fla. Bar No. 114771 
City National Bank Building 
25 W. Flagler Street, Suite 800 
Miami, FL 33130 
Telephone 
Facsimile: (305) 358-2382 
20 
EFTA00221586