EFTA00601091

Podhurst Orseck 
TRIAL & APPELLATE LAWYERS 
Aaron S. Podhurst 
Robert C. Josefsberg 
Joel D. Eaton 
Steven C Marks 
Victor M. Diaz, Jr. 
Katherine W. Ezell 
Stephen F. Rosenthal 
Ricardo M. Martinez-Cid 
Ramon A. Rasco 
Alexander T. Rundlet 
John Gravante, III 
Carolina Maharbiz 
April 17, 2009 
VIA FACSIMILE 
David Spicer, Esq. 
11000 Prosperity Farms Road 
Suite 104 
Palm Beach Gardens, FL 33410 
Robert Critton, Esq. 
. 
. 
Burman, Critton, Luttier & Coleman LLP 
515 North Flagler Drive, Suite 400 
West Palm Beach, FL 33401 
Jack Goldberger, Esq. 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, FL 33401 
Gentlemen: 
Robert Orseck (1934-1978) 
Walter H. Beckham, Jr. 
Karen Podhurst Dent 
Of Counsel 
During our recent meeting with Mr. Black, we were told that it is your client's position that 
the no-contact order agreed to during the state plea colloquy does not apply to any of our clients 
except for those victims who were part of Mr. Epstein's state plea. Our understanding is that AUSA 
Villafana and Messrs. Tein and Goldberger entered a verbal agreement at the time that the list of 
victims was provided to those defense counsel that Mr. Epstein, including his agents, would have 
no direct or indirect contact with the victims named on this list. In addiditon, under applicable 
Florida Bar Rules governing contact by attorneys and their agents with persons represented by 
counsel, any contact with any of our clients or their family members by Mr. Epstein, his counsel 
and/or his agents must strictly be through us. Mr. Le&owitz had previously reassured us that Mr. 
Epstein would not contact any of our clients as long as I am "representing them in connection with 
settlement discussions." Due to our differences regarding the retroactivity issue and the "per 
plaintiff' v. per incident/count issue, we have apparently reached a dead end regarding settlement. 
Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800, Miami, FL 33130 
Miami 3053582803 Fax 305.358.2382 • Fort Lauderdale 954A634346 
www.podhurstcom 
EFTA00601091

We are concerned that Mr. Epstein could misconstrue our impasse in conjunction with Mr. 
Lefkowitz' e-mail to mean that now that we are no longer "representing them in connection with 
settlement discussions," he may contact them. Please be assured that it is our position that regardless 
of whether we are representing our clients during settlement discussions and/or trial preparation, we, 
and the rules of professional conduct, prohibit contact. 
In order to be crystal clear as to whom we represent, we have attached a list of our present 
clients. We expect each member of Mr. Epstein's defense team to abide by the applicable rules of 
professional conduct We request written confirmation from Mr. Epstein that neither he nor his 
agents will contact any of the victims represented by us. 
If this correspondence is in any way unclear, please contact us. 
Sincerely, 
Robed C. Josefsberg 
cc: 
Roy Black, Esq. w/ enclosures 
Jay Lefkowitz, Esq. w/ enclosures 
EFTA00601092

List of Clients Represented by Podhurst. Orseck 
as of April 17. 2009' 
' We will supplement this list as necessary. 
EFTA00601093

Podhurst Orseck 
TRIAL 
,Sz APPELLATE 
LAWYERS 
Aaron S. Podhurst 
Robert C. Josefsberg 
Joel D. Eaton 
Steven C. Marks 
Victor M. Diaz, Jr. 
Katherine W. Ezell 
Stephen F. Rosenthal 
Ricardo M. Mart{nez-Cid 
Ramon k Rasco 
Alexander T. Rundlet 
John Gravante, III 
Carolina Maharbiz 
April 17, 2009 
David Spicer, Esq. 
11000 Prosperity Farms Road 
Suite 104 
Palm Beach Gardens, FL 33410 
Robert Critton, Esq. 
Burman, Critton, Luttier & Coleman LLP 
515 North Flagler Drive, Suite 400 
West Palm Beach, FL 33401 
Jack Goldberger, Esq. 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, FL 33401 
Re: 
Jane Doe 101 vs. Jeffrey Epstein 
Case No. 09-80591-Civ-Marra 
Gentlemen: 
Robert Orseck (1934-1978) 
Walter R Beckham, Jr. 
Karen Podhurst Dem 
Of Counsel 
Attached please find the Summons and Complaint filed in U.S. District Court today. Jack 
Goldberger and Bob Critton had previously agreed to accept service of this Complaint via mail. 
Very truly yours, 
Robert C. Josefsberg 
Podhurst Orseck, P.A. 25 West Hagler Street Suite 800, Miami, FL 33130 
Miami 305.358.2800 Fax 305358.2382 • Fort Lauderdale 954.463.4346 
vnew.podhurstoom 
EFTA00601094

AO 440 (Rev. 10/2002) Summate in a Civil Case 
UNITED STATES DISTRICT C OURT 
Southern District of Florida 
Case Number: 
v. 
JANE DCE 101, 
a 
EPSTEIN, 
Plaintiff 
Defendant 
09-80591 
CIV-IVIARRA 
SUMMONS IN A CIVIL CASE 
TO: (Name and adds, of defendant) 
MAGISTRATE 'Gnu 
JOHnen 
Jeffrey Epstein, Palm Beach Bounty Stockade, West Palm Beach, FL 
and/or by serving his counsel: David W. Spicer, Esq., 11000 Prosperity Farms 
Pc1,.Snite 104, Palm Beath Ca±dens, FL 33410 or Jack A. Goldberger, Esg., 250 S. 
Australia[ Ave., Suite 1400, West Palm Beach, FL 33401, or Robert D. 
Critton, Jr., Esq:, 515 N. Flagler Drive, Suite 400, West Palm Beach, FL 33401 
YOU ARE HEREBY SUMMONED and required to serve upon PLAINTIFF'S ATTORNEY (name and adten) 
Robert C. Josefsberg, Esq/Katherine W. Ezell, Esq. 
PODHUPST OPSECK, P.A. 
25 W. Flagler St., Suite 800 
Miami, FL 33130 
an answer to the complaint which is herewith served upon you, within  
20 
 days after service of 
this summons upon you, exclusive of the day of service. If you fail to do so, judgment by default will be taken against 
you for the relief demanded in the complaint. You must also file your answer with the Clerk of this Court within a 
reasonable period of time after service. 
Steven M. Larlmore 
CLERK OF COURT 
DATE 
APR 1 7 2009 
ia://n4
4 1 
(BY) DEPUTY CLERK 
EFTA00601095

IN THE UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF FLORIDA 
JANE DOE No. 101, 
09-80591 
CH-MARRA 
Civil Action No. 
Plaintiff, 
MAGISTRATE JUDGE 
JOHNSON 
vs. 
JEFFREY EPSTEIN, 
FILED by 
D.C. 
inn AKE 
APR 17 2009 
STEVEN M. LARIMORE 
MERV US. DIST. CT. 
S.D. OF FLA. MIAMI 
COMPLAINT AND 
Defendant. 
DEMAND FOR JURY TRIAL 
COMPLAINT AND DEMAND FOR JURY TRIAL 
Plaintiff Jane Doe No. 101 ("Jane Doe"), brings this Complaint against Defendant, 
Jeffrey Epstein, and states as follows: 
PARTIES, JUIUSDICTIOLAND VENUE 
I. 
At all times material to this cause of action, Plaintiff, Jane Doe, 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, 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, bad a 
residence located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida. 
4. 
Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is 
currently incarcerated in the Palm Beach County Stockade. 
5. 
At all times material to this cause of action, Defendant, Jeffrey Epstein, was an 
adult male born in 1953. 
Podhurst Orseck, P.A. 
24 Wnt Metier street, Suite 800, Mime, FL 33130, Mime 3053582800 Fax 305358.2382 • Fat Lauderdale 954463.4346 
wmc.pocihttnttcom 
EFTA00601096

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(a), 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. 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. The allegations herein concern 
Defendant's conduct while at his lavish estate in Palm Beach. 
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 or molested 
these girls, and then gave them money. 
10. 
Beginning in or around 2001 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. 
11. 
Defendant's plan and scheme reflected a particular pattern and method. 
Defendant coerced and enticed impressionable, vulnerable, and relatively economically less 
Podhurst Orsec.k, P.A. 
2 
25 West Hagler Street Suite 803, Miami, FL 33130, Miami 3053582800 Fax 306358/382 • Fort Lauderdale 954463.4346 
www.podhurstcom 
EFTA00601097

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. 
Defendant would pay the procurer of each girl's "appointment" approximately 
$200. Many of the instances of illegal sexual conduct committed by Defendant were perpetrated 
with the assistance, support, and facilitation of at least three assistants who helped him 
orchestrate this child exploitation enterprise. These assistants would often arrange times for 
underage girls to come to Defendant's residence, transport or cause the transportation of 
underage girls to Defendant's residence, escort the underage girls to the massage room where 
Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove 
their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the 
conclusion of each "massage appointment," and, upon information and belief, take nude 
photographs and/or videos of the underage girls' for Defendant without their knowledge. 
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 
Podhurst Orsecic, P.A. 
3 
8 West Fla ear Street, Suite 800, Miami, FL 33130, Miami 3053582800 Fax 305.3542382 • Fat Lauderdale 95&463.4346 
I 
vraw.podlturat.com 
EFTA00601098

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 nude 
photographs of young girls, including some photographs depicting two or more young girls 
engaged in lewd acts. Upon information and belief, Defendant, Jeffrey Epstein, had such 
photographs in each of his 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 would direct the girl to massage him, giving her 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 masturbation, fondling the 
minor's breasts and/or sexual organs, touching the minor's vagina with a vibrator and/or back 
massager, digitally penetrating her vagina, performing intercourse, oral sex, and/or anal sex, 
and/or coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution. 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. 
Podhurst Orsecic, P.A. 
4 
25 west Flatlet' Street, Suite 600, Nan* Ft. 33130, Miami 3053582500 Fax 3052582382 • Fort Lauderdale 954463,4346 I 
www.podhuracom 
EFTA00601099

16. 
As previously stated in paragraph 14, Defendant displayed nude photographs of 
underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S. 
Virgin Islands. Upon information and belief, some 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. 
17. 
Consistent with the foregoing plan and scheme, Defendant used his money, 
wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff. 
Plaintiff, Jane Doe, 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 
Podhurst Orsedc, P.A. 
5 
26 West Bigler Street Suite 800, Mane. FL 33130. Miami 305.3582800 Fax 3053582382 • Fort Lauderdale 9544634346 I 
envw.podhurstccet 
EFTA00601100

told her to remove his towel. Defendant told her that he had just worked out and wanted his 
ROM 
1111111SIMIS 
SINIMMIIIIMINII Main 
MEI 
Ma.
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. 
18. 
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. 
19. 
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. 
20. 
As a result of these encounters with Defendant, Plaintiff, Jane Doe, 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 
Podhurst Orsecic, P.A. 
6 
25 West Flagler Street, Suite KO, leliarni, FL 33130, Miami 3053582800 Fax 3053582382 • Foot Lauderdale 954463.4346 I 
www.podlizust.com 
EFTA00601101

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)(1), § 
2252A(g)(t, 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 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 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 conunitted against Plaintiff and, as such, 
Podhurst Orseck, P.A. 
7 
25 West Flagler Street Suite SCO, Miami, FL 33130, Miami 3053532800 Fax 305.3581382 • Fat Lauderdale 954.463A346 I 
www.podhurstcom 
EFTA00601102

must admit liability unto Plaintiff, Jane Doe. 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 Engage in Prostitution or 
Sexual Activity pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. 4 2422(b)) 
24. 
Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 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(b). 
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 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. 
Podhurst Orsedc, P.A. 
8 
25 West Flagler Street, State 800, Miami, FL 33130, Miami 305358.2800 Fax 301.3582382 • Fort Lauderdale 954A63.4346 l 
w•ww.podhurntcom 
EFTA00601103

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(b)) 
28. 
Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 23 above. 
29. 
Upon 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 
Podhurst Orseck, P.A. 
9 
25 West Fleets Street, Suite BOO, /amt. FL 33130, Wand 3053582903 Fax 305358.2382 • Fort Lauderdale 954463.4346 
EFTA00601104

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 ail 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 Trafficking of Children pursuant to 18 U.S.C. & 2255 In Violation 
of 18 U.S.C. & 1591(a)I 
32. 
Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 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(c)(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 Orseck, P.A. 
10 
25 West Flagler Street, Suite 800, Maud, R. 33130, Miami 3053582800 Fax 305.3582382 • Fat Lauderdale 954.463.4346 
www.podhusstcom 
EFTA00601105

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. 4 2255 in 
Violation of 18 U.S.C. & 2251) 
36. 
Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs I 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 Doe, with his hidden cameras and may have transported lewd photographs of 
Podhurst Orseck, P.A. 
11 
25 West Hagler Street, Suite 800, Miami, FL 33130, Miura 3053582800 Fax 3(63582382 • Fort Lauderdale 954.4634346 I 
vninv.podburatcorn 
EFTA00601106

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. 
12 
25 Wed Meer street Suite 800, iifmmi. FL 33130, Miami 3053582300 Fax 305 I ra n82 • Fat Lauderdale 954.4634346 1 
www.porlhunttom 
EFTA00601107

COUNT FIVE 
(Cause of Action for Transport of Visual Depiction of Minor Enzazine in Sexually Explicit 
Conduct pursuant to 18 U.S.C. 4 2255 In Violation of 18 U.S.C. § 2252(a)(1)) 
40. 
Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 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. 
Podhurat Orsecic P.A. 
13 
25 Wat Plagler Street, 5404e 800, 60axrd. FL 33130, Miami 3053582800 Fax 3053582382 • Fort Lauderdale 954.463.4346 
www.podlauetcom 
EFTA00601108

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. 4 2252A(a)(1)) 
45. 
Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by 
reference the allegation contained in paragraphs 1 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 Orseck, P.A. 
14 
75 West Flar,kr Sant, Suite 800, Kurd, FL 33130,841.mi 305358.2800 Fax 305.3582382 • Fort Lauderdale 95t463.4346 
wwwsodlturstareet 
EFTA00601109

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 Orsecic, P.A. 
15 
25 Welt Flagler Street Suite 800, MLitt* FL 33130, //Rama 305358.2800 Fax 305.350382 • Fort Lauderdale 954.4634346 t 
www.podhurstsrom 
EFTA00601110