EFTA00601091

COUNT SEVEN 
(Cause of Action for Engazina in a Child Exploitation Enterprise pursuant to 18 U.S.C. 
2255 in Violation of 18 U.S.C. & 2252A(g)) 
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 are permanent in nature, and Plaintiff will continue to 
suffer these losses in the future. 
Podhurst Orsecic, P.A. 
16 
25 West Fielder Street, Sulle 800, Nand FL 33130, Miami 30535821300 Fax 305358 tut, . Fart Lauderdale 954.463.4346 t 
www.podbutet.ccon 
EFTA00601111

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,„ KuJE 
Robert C. Josefgberg, Bar No. 04656 
'Catherine 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) 
dosefsbenapodhurst.com 
kezellecodhurst.com 
Attorneys for Plaintiff 
DEMAND FOR JURY TRIAL 
Plaintiff demands to have her case tried before a jury. 
C • 
+.4d)t 
Robert C. Josefstg,t3::1:14
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) 
riosefsberstapodhurstcom 
kezellapodhurst.com 
Attorneys for Plaintiff 
Podhurst Orseck, P.A. 
17 
25 Weal Nagler Street, Suite SOO, Miami. FL 33130, Miami 305.358/S00 Fax 305 ma "in 
• Fee Lauderdale 954.463.4346 
woortv.podltunst.tota 
EFTA00601112