EFTA00221614

Case 9:09-cv-80656-KAM 
Document 1 
Entered on FLSD Docket 05/04/2009 
Page 21 of 27 
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 800, Miami, FL 33130, Miami 305.158.2800 Fax 305.358.2182 • Fort Lauderdale 554.463.4346 
www.podhuntozen 
EFTA00221634

Case 9:09-cv-80656-KAM 
Document 1 
Entered on F LSD 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 
ICause of Action for Transport of Child Pornography pursuant to 18 U.S.C. 6 2255 in 
Violation of 18 U.S.C. & 2252A(a)(111 
62. 
Plaintiff, Jane Doe 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 18 U.S.C. § 2252A(aX1). 
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 Hagler Street, Suite 800, Miami, FL 33130, Miami 305358.2800 Fax 305358.2382 • Fort Lauderdale 951.463.4396 
www.podhursuorn 
EFTA00221635

Case 9:09-cv-80656-KAM 
Document 1 
Entered on FLSD Docket 05/04/2009 
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 Engaging in a Child Exploitation Enterprise pursuant to 18 U.S.C. 
2255 in Violation of 18 U.S.C. ti 2252A(2)) 
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(gX2), in violation of 18 U.S.C. § 2252A(gX1). 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(AXaX1)), 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 Hagler Street. Suite 800, Miami, Fl. 33130. Miami sasass.zsoo Fax 305.358.2382 • Fort Lauderdale 954.463.4346 
www.podhurst.cOm 
EFTA00221636

Case 9:09-cv-80656-KAM 
Document 1 
Entered on FLSD Docket 05/04/2009 
Page 24 of 27 
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 1, 2009 
RekttAl 
aL
Robert C. JosefsWerg, Bar No. 0408503
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) 
riosefsbergfa,podhurst.com 
24 
Podhurst Orseck, P.A. 
25 West Fier Street Suite SOO, Miami, FL 33130, Miami 305358.2300 Fax 305358.2382 • Fort Lauderdale 954.463.4346 I 
www.podhuracorn 
EFTA00221637

Case 9:09-cv-80656-KAM 
Document 1 
Entered on FLSD Docket 05(0412009 
Page 25 of 27 
Icezell@podhurst.com 
Attorneys for Plaintiff 
DEMAND FOR JURY TRIAL 
Plaintiff demands to have her case tried before a jury. 
LtAA 
it /A*44C' 
Robert C. Joseftherg, Bar No. 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) 
rjosefsbergla.podhurst.com 
kezellapodhurst.com 
Attorneys for Plaintiff 
25 
Podhurst Orseck, P.A. 
25 West Flagler Street. Suite 800, Miami, FL 33130, Miami 305358.2800 Fax 3053582382 • Fort Lauderdale 954.463.4.346 
www.podhurst.com 
EFTA00221638

. 
Case 9:09-cv-80656-KAM 
Document 1 
Entered on FLSD Docket 05/04/2009 
Page 26 of 27 
NOS 44 (Rm. 1105) 
CIVIL COVER SHEET 
The JS 44 civil cover shod and the information contained herein neither replace nor SOPPleMalt the filing and service of pleadings or other papasas required by law, except as provided 
by load rules of mud. This form, approved by the Judicial Conference of the United States in September 1974. is required for the use of the Cat of Court for the purpose of initiating 
the civil docket shed. (SEE. INSTRUCTIONS ON THE REVERSE OF THE FORM.) 
NOTICE: Attorneys MUST Indicate AD Re-filed Cases Below. 
1. (a) PLAINTIFFS 
Jane Doe No. 102 
(b) County of Residence of First Listed Plaintiff 
West Palm Beach
(EXCEPT IN US. PLAINTIFF CASES) 
(e) Attorntylt (him Name. Adtress. and Telephorc Number) 
Robert C. Josefsberg, Esq./Katherine W. Ezell, Esq. 
Podhurst Orseck, P.A. 
25 W. Flagler St., Suite 800 
Miami FI 
oq- 
- 80(05 - 
Id) Check County Where Action Arosc: 1 M IAM I I) Slit 
I MIN ROE. 6 4. 
• 
tio?)1, 
D 
PALM BEACH 
DEFENDANTS 
Jeffrey Epstein 
County of Residence of First Listed Defendant 
West Palm Beach 
(IN U.S. PLAINTIFF CATPQ OnLYI  
 
NOTE: IN LAND CONDEMNATION C/441,60119, so 
iQIIR 
LAND INVOLVED. 
I `WAKE. 
4tArr 
I 
I 
1Cnount) 
i 
MAY 
1 2009 
1
0 
Jack A. Goldberger, Esq., AtterburX Gold
ger, et al., 250 S. I 
Australian Ave., #1400, West Palm'Beatths.FEN31340.11011.obett D. is 
0 MARTIN O ST. LUCIE 
3 INDISIOILHEIELRI LIMMCIICkg 
CLEF"( a ' S. Csts'T 
HIGHLANDS 
II. BASIS OF JURISDICTION 
(Place an IC in One Box Only1 
Cl I 
US. Lantana 
/7 3 Federal Quedka 
Plaintiff 
(US. Cowman Not a Party) 
0 2 U.S. liacnunent 
0 4 
Diversity 
Defendant 
(Indicate Covens/up of Plirnel in hem Ill) 
III. CITIZENSHIP OF PRINCIPAL PARTIES:risss arr MOM Box for Plair4iff 
ffor Diversity Cara Ocly) 
and One Boa for DeRriclars0 
PTE 
Cilia-nor This State 
7
I 
Citizen of. nother State 
0 
2 
Citizen or Subject of a 
0 
3 
Forei 
Country 
DEE 
PTF 
DEF 
t 
Incorporated or Principal Flax 
of Business In This Stale 
1 
4 
O 4 
O 2 
Incorporated and Pink:oat Place 
of BUSITC13 In Another State 
O 
5 
0 
5 
0 
3 
Foreign Nation 
0 
6 
0 6 
I 
cdIlial 
TO
FORFEITURE/PENALTY 
BANKRUPTCY 
OTHER s-rAints 
I 
110 Insurance 
120 Marine 
130 Milk, Act 
140 Nepotist* instrument 
150 Recovery of Os anayment 
& Enforcement of Judgment 
151 Medicate Act 
152 Recovery of Dcfaubcd 
Student Leans 
(Excl. Veterans) 
0 153 Recovery of Ovapiameat 
of Veterans &oaks 
0 160 Siockholders' Suits 
0 190 Other Contract 
0 195 Comma Product Liability 
O 196 Emnehise 
PERSONAL INJURY 
PERSONAL INJURY 
0 310 Milan 
0 
362 Personal Injury • 
0 315 Aiffilane Product 
Ma Malpractice 
Liability 
O 365 Personal Injury- 
0 320 Astault. Ltd @ 
Product Liability 
Slander 
O 
368 Ashestiza Personal 
1 DO Federal Employers* 
Injury ProSuci 
Liability 
Liability 
0 340 Marine 
PERSONAL PROPERTY 
0 345 Marine Product 
1 
370 Other Saud 
LIMED 
0 
171 That in Ladies 
0 350 Motor Vehicle 
0 
MO Other Personal 
O 355 Motor Vehicle 
Property Damage 
Ptoduct liability 
Cl 
385 Pmpeny Denude 
8 360 Other Perscal 
Product liability 
Injury 
0 
610 Agriculture 
0 
620 Other Food & Drug 
3 
623 Drug Related Mame 
of Property 21 USC MI 
0 630 Liquor Lens 
Cl 610 R R. & Truck 
0 630 Mane Rep. 
0 660 Occupational 
SafayiHealth 
3 690 Other 
0 422 Appeal 28 USC 158 
il 423 Withdrithil 
28 USC 137 
400 Slate ReaPPollicfacellt 
410 Ammo 
430 Banks and Mankind 
430 Continent 
460 Detonation 
470 Racketeer Influenced and 
Comp Organizations 
480 Consumer Credit 
490 Cable/Sat TV 
810 Selective Service 
830 SeanitiesiCorarnodines. 
Exchange 
873 Custom Challenge 
12 USC 3410 
890 Other Statutory Actions 
891 Agrieultund Ads 
892 Economic Subilirmion Act 
893 Emirontnental !damn 
894 loan Allocation An 
893 Freedom of [animation 
Act 
91)0Appeal of Eve Dffenntration 
Under Equal ACcess 
toJustice 
0 MO Coanitunornlity of 
State Smiths 
MI a :fil . Ka a:ICH:IC 
3 F20 Copyriptuts 
1 830 Patna 
r) 840 Todeniark 
LABOR 
SOCIAL SECURITY 
0 
710 lair Labor Sander& 
Ad 
0 
720 LabooMgras Reheats 
0 
730 LaborthIgni.Reporting 
dt Diatom= Aar 
0 
740 Railway Libor Act 
O 790Oilter Lake Litiggioe 
0 
791 Encl. Ret. Inc. 
Scarily Act 
1861111A 1139510 
0 862 Black Lung (923) 
0 863 DINX1DIWW NOS(® 
0 864 SSID Title XVI 
0 865 RSI (405(0) 
FEDERAL TAX SUITS 
I 
REAL PROPERTY 
CIVIL RIGHTS 
PRISONER PETITIONS 
O 870 fates (DS. Plaintiff 
or Defendant, 
O 871 IRS— fItird Pany 
26 USC 7609 
0 210 Land Condrinnaam 
0 220 ForecIosure 
0 230 Rem Lae & E,CcIIIICI. 
O 240 Tons to 1 and 
O 245 Ton Product Lability 
O 290 All Other Real Property 
0 441 Voting 
Cl 442 Employment 
0 443 Dousing' 
Accommodations 
0 444 Welfare 
3 443 Artier. wOnabilities . 
Repayment 
3 446 AMT. *tifibilitiCS • 
Other 
3 440 Other Civil Rights 
1 
510 Simian to li'acage 
Manx 
Habeas Corpus: 
1 
510 Gan) 
I 
MS Death Penalty 
1 
540 Mandamus & Other 
0 
550 Civil Rights 
0 
555 Pate Condition 
V. ORIGIN 
vi 1 rul
ing
Waco a 'X" imOne Ha Only) 
Transferred from 
O 2 Removal from 
n 
3 
Ro-fded- 
O 4 Reiman:dm Cl 5 anotherdistaiet 
O 6 M916district 
St to Court 
ate VI below) 
Reopened 
Dina y) 
litigation 
Appeal to District 
CI 
idge from 
' 
Magistrate 
lodgment 
VI. RELATED/RE-FILED 
CASE(S). 
(See atrouctions 
letabl 
a) Re-filed Case OYES 0 NO 
JUDGE Kenneth A. Marra 
b) Related Cases GIYES O NO 
DCICKET See Attached 
NUMBER 
VII. CAUSE OF 
ACTION 
Cie the U.S. ( 
Mange under which you are filing and Write a Brief Statement of Cause (Do Dot cite jurisdklIonal statutes unless 
dIvenhy): 
18 U.S.C. 2255 (Predicate Statutes 18 U.S.C. 2422(b), 2423(b), 2423(e), 2251, 2252, 2252A(a)( 1), 2252A(g)( I) 
LENGM OF TRIAL nth 4 
days estimated (for both sides to try tine ease) 
O CHECK IF THIS IS A CLASS ACTION 
UNDER F.R.C.P. 23 
VIII. REQUESTED IN 
COMPLAINT: 
DEMANDS 
CHECK YES only if demanded 'n complaint: 
JURY DEMAND: is Yes ri 
No 
ABOVE INFORMATION IS TRUE & CORRECT TO 
THE BEST OF MY KNOWLEDGE 
SIG. 
TURE 01:ATTORNEY tr7( 0 
DATE 5) I) 9 
R °MOE USE ON.I.So
AMOIJN4 tce.
)  
RECEIPT/ rinal
14.3(7 
EFTA00221639

Case 9:09-cv-80656-KAM 
Document 1 
Entered on FLSD Docket 05/04/2009 
Page 27 of 27 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
WEST PALM BEACH DIVISION 
ATTACHMENT TO CIVIL COVER SHEET 
FOR: Jane Doe 10Lv. 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 
EFTA00221640