DOJ-OGR-00015188.tif

COUNT I 5. Plaintiff incorporates into this count the allegations of paragraphs | through 3. 6. On numerous occasions while the Plaintiff was a minor, beginning when she was fourteen, the defendant, JEFFREY EPSTEIN intentionally induced and/or seduced the Plaintiff into performing various acts of lewd and lascivious conduct and/or sexual performances in his presence. These acts all took place at the mansion owned by the defendant JEFFREY EPSTEIN which was located in Palm Beach, Florida. 7. On numerous occasions while the Plaintiff was a minor, the defendant, JEFFREY EPSTEIN performed various acts of lewd and lascivious conduct in the presence of the Plaintiff. These acts all took place at the mansion owned by the defendant JEFFREY EPSTEIN which was located in Palm Beach, Florida. 8. On numerous occasions while the Plaintiff was a minor, the defendant, JEFFREY EPSTEIN touched the Plaintiff's breasts and genitilia. These acts all took place at the mansion owned by the defendant JEFFREY EPSTEIN which was located in Palm Beach, Florida 9. As a result, the Plaintiff suffered mental anguish, mental pain and suffering, psychic trauma, and a loss of the capacity for the enjoyment of life. WHEREFORE, THE PLAINTIFF DEMANDS JUDGMENT FOR DAMAGES AGAINST JEFFREY EPSTEIN, IN AN AMOUNT IN EXCESS OF FIFTEEN THOUSAND DOLLARS, EXCLUSIVE OF COSTS AND INTEREST, AND FURTHER DEMANDS TRIAL BY JURY. COUNT II 10. _ Plaintiff incorporates into this count the allegations of paragraphs | through 4, and paragraphs 6 through 9. 2 DOJ-OGR-00015188