EFTA01089193

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
August 15, 2008 
DELIVERY BY ELECTRONIC MAIL 
Jay P. Lefkowitz, Esq. 
Kirkland & Ellis LLP 
Roy Black, Esq. 
Black Srebnick Komspan & Stumpf P.A. 
Re: 
Jeffrey Epstein 
Dear Jay and Roy: 
Thank you for your response to my earlier e-mail. Our communications with Mr. 
Black and later with Mr. Leflcowitz were solely to determine what Mr. Epstein considered 
to be the terms of the Non-Prosecution Agreement. We appreciate your answering our 
question with finality. You have now made clear that Mr. Epstein did not accept the 
December modification, and accordingly, the offer to make that modification is a nullity. 
Pursuant to our Agreement, I will prepare an AmendedNotification that contains the 
names of additional identified victims. As you know, 
had selected the Podhurst 
firm to serve as the attorney representative for the victims. Assuming that Mr. Josefsberg is 
still amenable to the appointment, we will provide him with the victim list so that he may 
begin his service. 
Finally, as you are aware, the United States has been ordered to produce the 
Non-Prosecution Agreement. In accordance with that Order, we will produce the September 
Agreement with the October Addendum signed by your client. We understand that Mr. 
EFTA01089333

JAY P. LEFKOWITZ, ESQ. 
ROY BLACK, ESQ. 
AUGUST 15, 2008 
PAGE 2 OF 2 
Goldberger did not provide the state court with a true copy of the complete Agreement, and 
he should take steps to correct that error. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: 
Assistant United States Attorney 
cc: 
Northern Division 
EFTA01089334

Exhibit 24 
EFTA01089335

pur,CJGC2V1 
P:2 
r 
.f.d1cWiltams, Shannon R. 
From: 
Sant: 
To: 
Cc: 
Subject 
Attachments: 
Dear 
Epstein Agrmt Portion.pdt 
Thant you for taking the time to meet with us on Tuesday. As we discussed, I have attached the pertinent portion of 
Mr. Epsteirt's agreement with the U.S. Attorney's Office. 
«Epstein Agnnt Portion.pdf%. 
I also wanted to call to your attention a couple of items regarding the issue of Week Release. Dwi 
thee 
e of 
plea, Mr. Epstein stated that he would be working at the Florida Science Foundation, located at 
, that the Foundation had been /0 existence for a "couple of years," and that he had been working there 
"every day" prior to the plea. The Division of Corporations' documents show that the Florida Seta:ice Foundation was 
incorporated inNovember 2007, not a "couple of years ago." The address provided for the "office" of the Florida 
Scicues Foundation is Jack Goldberger'a office suite, and neither the eace building directory nor the officio suite door 
reflects that such a business is located there, and neither the security guard nor any building tenant that FBI questioned 
knows of the existence of such a business. Mr. Epsteinalso could not have boon working thexe "every thy" when be 
hadn't been in Palm beach County in the past six months. 
I would apprecfart the opportunity to review the work release regulations. If Mr, Epstein truly is eligible for the 
program, we have no objection to him being treated like any other similarly situated prisoner, but sitting in his 
attorney's ofEcesuite making telephone calls, web-surfing, and having food delivered to him is probably not in 
accordant= with the objectives of imprisonment. Obviously, the decision is left entirely within your discretion, but I 
warred to make sure that you had a complete picture before you made that decision. 
Thank you again, and have a wonderful 4th of July. 
Assistant U.S. Attorney 
EFTA01089336

Exhibit 25 
EFTA01089337

0 
1. 
' • 
r 
2OO8croosAtyin 
-• 
immunity PERSON thumitsms•of fib 
tqapipetelisleklbrunted, BOgleapgites:.:13 
Aft 
441.04,101,5184..:. 
c. 
4$0146fri 
Ageiiikedarteeit**-• 
V6144retelOR,It'. 
441. 
keggteinitesi 
11 t e 
. •••"" 
. • • 
•r: 
 
litiklattr t.CITC &Sr e 
s 
:44 •••;r 
 -`er
• 
. . • 
witiormr? 
wv,saixioacist.4ecormi crbt:-1- 
• . 
• 
• 
5.1ffergr.,, 
: . 
 f,r..
;:•74-1 
.... 
tioa-141e
—,- 
. 
— .p .•:;>-.;`474.......: • :2 ••-• •:. : ' ' ' 
. , 
• 
. ..:e..:-71 
,.:•.. • ' ... - . .. z.. •;'.c, - - -:- . .4.1,‘•  Eav: t •I ty.42zn.-_,
,•:.10
.,
-..4 e.....,^ '  
f,e,„:..... • ....n.A:pligstnegee . 
. 
.,
. .• • ' -: it • ...; ....:i. :fr:fA7 .1 .7 1  ....... 0.. i r" ... 
, c.:: 0
.1.1.4." :..5.4e•.*: , : ": 
• 
.. 
' 
M 
:I,: • • 
• 
• 
"4  
• 
4%."
Ailiclucity,e, • 
. 
••• 
. • 
 
' 
• 
.1.....,),.. . 
04A:i4x,c0: 
,a*Dongi.entrosia0iiii.lidt;:.T. (aTcourtioop)...eciffriii ielituida'i ...7 7***1: 
iiilos*_ 
Pottriench:7::: 
.,..,??44,;•§telStaNti[S.14e'fitadi,..,C.: ..:': .3.2.04k•ae0,10IC•Viateler" 
i 
cisme, teteeiooliceethebieitIoAereeneemsecteelte*Yeeineleinitieramocosrsoneattheisoeskieei 1.- ..1
4:eie
141b
ity
f 
 4‘2"(far tlerEigt4= 140:1414111.4. keiteeteeeeitti:lerwelieeeetellWrztencroevOtimeceAutemeecceermouRn!DusgzeftcoN • 
.9" ; '.. 
• :., 'NW 
' 
1133eleTELEPRONECelpeileyeeileltheNGDAYSOFIQUeleelerbelVIStieteeeritbleallaARINeORy6221MPArefeekli1 
• 
• 
• 
' 
. .. . 
. 
.. ... 
 
, 
 .. 
.. . . 
.: . 
. . 
. • 
• 
— 
• - • 
' 
• 
. 
• .. 
EFTA01089338

0 
I ; :* —• 
-. 
. . 
No1;4- 60?)CF.9t3/W
1-
• Profs/ Sex Off/ Drag Off 
' 
:14 
Donate. vet 
C.C. 1 C.C. IC 
• • • 
. Erisribitieritiineferiedlin• .
.. 
• 
• SPECIAL CONDITIONS:: 
• • 
—' 0 .CoMplete,Originaliy Ordered OpnclitionS ... 
. 
. 
C\ 
... - • • . 
.0 Ourfecir • • 
 p.m., with the
 exception:  
. . 
.
.
 
-
 
Q
 
•
 
DefUto /sport to 'Prob.. Dept. immerdiatEily, sPOn• release. I ' 
... 
.•' 
. 
' Q. Deft. nit have in care, custody; dr control- any. unlawful OFilldgaltiaterial, subst., device, otiOi44 . • ... 
. 
. 
.0 Deft to i , • actiatekt notify Prob. Officer if place of tesidericebrjer changes. - .., L  
- 
..: ;. • r; 'a : 
' 
CI Restitution CRO filed ' 
' 
•, 
• 
• 
• 
. _ 
•• . • 
• • • CI-Sub ea tgailtall-  
loonditr 
• 
y15,5tryse Evat../5!tycho, 41 .,a1../ 13;sychti. .•xtial:cyal.syithiet by.,
...„„,04/4Nr, ..***70490mpetffltoollIgtittEil,'-;
Dootjt - 
:•cIRI4kiiiiistiftweirasorrantiotirig,: ‘.., -,••,a,,a.• q 
: ., . ft I, •:...016: 
a No- Consumption/Possession of Alc0hol Or Drugs or. Intoxicants without a Prescription. " : -• ' .•:•,•.:   . • .' 
. .. aAttend • 
' .• 
• AA andior•NA Meetings per. Week: 
• 
. .- 
' 
_ 
_ .
- - 
• • 
• ...'.3.-fix.44' 
... "Q benottb•freguent•any.filace of busjneas whose primary PUrpose is the sale of aloottoh.tte. -• • — • 
. a •Compl010
1_:1-irecif Cottimuiiity Senate to be done at the rate of .___,_..42. Hrs.. pa' Mr 
• 
,rii!..O .1:109.**E4Yelsie.gegi013.;SAPY._.....:. 
- 
_ . ... ,. .. .rnns it 
• 
• 
• 
• • •-• • -• 
—  WAttdffdiaiiffeuccesstully-completealiticitiii4i.Siadisessiotuaittirsimpact Pitee4.. .. .•7 1....:7 :‘ ,,...1::
• .....0 voco-otct /.No Viole.0 Contact / R ). 
e Plroct ortndirect.contact w/Victits(s)rotheralistest::ii• - .7•••:-
., 
NO•Oontagj wipiihor Children wto,Alu$Stipeirv'Sion.aware ofthiimasittihd the diepeeltiont. .. 
7' ... :a
it
t
ocu
..;;:iOl;•Doeter Orpervislortrt 
• 
- it•I'"". 1  Or•fri 
K
" 
CI Waived
:
 by Court:  
• • 
+" 
• - 
• 
 -' 
' ----' '11
feileriseraSoccetsfally-Oomplete#0e410n- " ... reBed-iztrogram-andAny.fteeomMeildedaftercakt::
la kolcilk0iratody, release only
 DOC Non-SeburesBed.prograrn Officer. 
O :Enter•artd Successful f oomplete SBSO•Long I Shod-Track Drug Farris and'Any Reci.Afteticaret*AtrL4-
O Forteit.Weepon /Id0ney'seized at the tine- of attest to: 
. - 
. • 
• 
• . ..• 
. .. .••:;*•.— 4 
a •Enterandtomplete:. 0 Anger Management ;Program 
• I) Batterers intenteritittp,ogr•am.::•• ::'
. ait Theft Abatement Program: • 
' ' '. ' 
 0 Other 
' 
 
. , 
•..•   .•4 
O Defendant may apply lor.Eady Termination after  . 
) 
 , provided ail cents, are satisfied.
- • '0 Seritse ' 
. , • days /month irtf, 
wittrcredit for • 
-days /*ninths. • .  I 
•-04 'fl'Y 
ertp0,91 
• 
I 
Kii i k  0 
•ptyr
.
 ieer - 
— .
., 
• • -, I 
o 41) . --.).4 1-1Si bee44€?s- 8 F 
e i.s. _se... • 
 
I 
O 
i 
• • 
0 
il••••••••• ray ...ash,. 
. 1
EFTA01089339

I 
fete
feemb 
ppied 'a With rithout Prejndic 
 ••
Warrt61 lOttuittred O Recalled 0 Bo 
BoodForf 
OoltbisaiiiRevoke'd/Reibistated 
Bodd Fore Vacated ••Crik,Mdous fond Reinstated, if 
Deft _ Jolliet\ 0 PE) Apb 
0 Erg only' 
aluation rem 
Dvig Fault 0 DOC'Npn-Sea 
• 
O Pre*Plea 1ST ordered by/wi 
Referred to: PT! / SAAPi/P 
Case plgr
ENTERED A 
afurd-cts 
• Sat &Test 
OP 0 NOT GUILTY 
:WaivedPSI 
ADIGUILTY.as (lugged as to 
I UMD
as
AYMBLD
GUiln 
at: C"Cts 
3 !tom ANDADJUDIC.ATED 
110LARRIS 
947 
Pith iCoinitt C.Moot 
0 
sr 
7 Stip/Pound: (Molest 
.131.GimEt 
PBCJ 
ii S 
PBCP 
Ntvocroit for  
.,one / ConseeiCo-Thrm whcosel 
771084 
Cm: 
IT P6OSTITM,TIO14 
isr drawn 
ser 
3 Execution of Sentence Stayed 0 Sentence Su 
3 Youthful Off 0 Habitat& Oft .0 Alin /Mand: 
. 
AliftithfEEPNIENCEIOB! POI-.OWED By: 0 Probation 
a
z DRIVERS LICBNSB Td BE SJSPONDED/ RE °KED 
Set/ 
&n., 
Set/ Renck., 
affey
---
. 
• 
&Pres. 
•
. 
• 
dteserves Rohn 
01 'triton Orkr to Poll9w. • 
O SeeBel‘w VALsoCovels • OtpOond 
OSOR:DischAlleyoked/Reinstated 
' 
. 
O, stai fad to inp diarg4s OfbeleasalaR./ &pa' 
••  • atatthiAppur:. • • 
0
 
NO 
•
 
*finputfroftiDThiftadfing 
ks
O. psr pre.. trio
Lesser clitage' " 
r•i• 
Lesser Charge  
. 
• 
C .Daft sign  
De/ Co 
0 
'bob 0 Jail 
0 DJJ 
0 GAL: Notified by 
by: 
. -Ifexez tt." 
 :r. t 
lificeessfolly / rthisti 
Lys 
Predator 
Piv 
• RID_,___ at __f.'sRI/PS 
. • • 
. 
.. 
1 )
• 
_...t
. 
• - • • 
County Courthouse 
- 0 Comb 
 Criminal Justice B 
. -: 
II Couriroot _nsn*
ustice .Complex. 
205 N. Dixie, West Palm Beach 
38844 S 
Road, 80, Belie Glade: '-;: 
' 32T8. Gun Club f(07*eat Piddi,Beach 
OF:100.436 A POISON WIN A OSABUTY IMO NEEOSNNY ACO010.03DAMMI CO* ID PANTS!, IN TILS-PROOLEENCAMMEENTO124 At NO eorrotiiitsti-rerimtastitiOK 
74rnatcsotuicti itas!catoccr sutszJAMADA COCTINATON It TtbrISITtAlVI (
Uf 
TEE 
OP NTIgEncTLPAI.: iBri 
tjaO1.= COURTHOUSE. 20* OCIOE litft'all fa 
.. 
. 
• 
pro,-. ,,n 
EFTA01089340

Exhibit 26 
EFTA01089341

KIRKLAND & ELLIS LLP 
AND ATUATED IMINUAIIPS 
Ciagroup Center 
Jay P. Lelkowitz. P.C. 
To Call Writer Directly: 
June 15, 2009 
VIA FACSIMILE 
United States Attorney's Office 
Southern District of Florida 
Re: Jeffrey Epstein 
Dear MEI 
Facsimile: 
I am attaching a letter authored by my co-counsel, Robert Critton, on today's date. It 
represents our agreement with a proposal that Kathy Ezell indicated in a letter dated June 8, 2009 
would be fully acceptable to her and Bob Josefsberg as a means to resolve expeditiously all 
outstanding fee issues regarding the attorney representative. Mr. Epstein has directed his counsel 
to take immediate steps to address and resolve the attorney representative's outstanding fee-
related issues and we are doing so without delay. The suggestion of a Special Master, agreed to 
by both parties, to resolve the issues in the immediate future, will assure all parties that there will 
be no delay and no need for adversarial litigation regarding fees. 
More generally, I want to assure you that Mr. Epstein has directed all counsel to make 
sure that there is no filing that could constitute a breach of the NPA. Accordingly, anew internal 
screening process has been established to provide focused decision-making on each filing. To 
the extent we believe any filing may be perceived as implicating any of the issues generically 
addressed in the NPA (a document including sentences within paragraph 8 that even Mr. Acosta 
agreed were "far from simple"), we intend to address such issues with you prior to any filing and 
hope that you will agree to review the draft filing and inform us whether or not from your 
perspective it would, if filed, constitute a "breach". This will be especially important regarding 
issues that we believe fall at the intersection of Section 2255 and the civil litigation. We reserve 
our right, if you believe a proposed filing to conflict with the NPA or if you wish not to address 
these issues with us, thereafter to address such substantive issues with the Court. 
Chicago 
Hong Kong 
London 
Los Angeles 
Munich 
San Francisco 
Washington, D.C. 
EFTA01089342

KIRKLAND & ELLIS LLP 
June 15, 2009 
Page 2 
We hope that these proposals—in combination with our immediate withdrawal of the 
previously filed Motion to Dismiss—resolve all outstanding issues at the intersection of the NPA 
and 2255. Please advise if any remain. 
Sincerely, 
a P. Lefkowitz 
Enclosure 
cc: 
EFTA01089343

Exhibit 27 
EFTA01089344

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, 
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. 
EFTA01089345

Case 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 2 of 22 
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. 
STATENENT 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. 
2 
EFTA01089346

Case 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 3 of 22 
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. 
3 
EFTA01089347

Case 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 4 of 22 
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 
masturbation, fondling the minor's breasts and/or sexual organs, touching the minor's vulva, 
vagina, and/or anus with a vibrator and/or back massager and/or his finger(s) and/or his penis, 
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 and/or 
4 
EFTA01089348

Case 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 5 of 22 
enticing the then minor girl to engage in sexual acts with another female 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 
5 
EFTA01089349

Case 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 6 of 22 
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. Ile 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 
buttocks massaged. 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 
6 
EFTA01089350

Case 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 7 of 22 
complimented her, saying that she had a nice body. Defendant then pulled Plaintiff closer to 
him. He began masturbating and then began fondling her breasts. He asked her to do more and 
mentioned more money, which she adamantly declined. Defendant continued masturbating until 
he ejaculated. 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 ancVor 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 
7 
EFTA01089351

Case 9:09-cv-80591-KAM 
Document 9 
Entered on FLSD Docket 05/01/2009 
Page 8, of 22 
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 Engage in Prostitution or 
Sexual Activity pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. @ 2422(b)) 
25. 
Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs I through 24 above. 
8 
EFTA01089352