EFTA00594036.pdf

Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 42 of 73 numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 563. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■ has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant. Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The 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 the plaintiff, ■, will continue to suffer these losses in the future. Page 204 of 234 203 ot 234 EFTA00594036 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 43 of 73 564. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right 137 COUNT 137 Cause of Action Pursuant to 18 U.S.C. d 2255 June 2005 — Incident 1 565. Plaintiff,.. adopts and realleges paragraphs 1 through 20 above. 566. On or about June 2005, the exact date being unknown to.., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 567. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■ has in the past Page 205 of 234 204 of 234 EFTA00594037 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 44 of 73 suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The 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 the plaintiff, ■, will continue to suffer these losses in the future. 568. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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 138 Cause of Action Pursuant to 19 U.S.C. § 2255 June 2005 — Incident 2 569. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above. 570. On or about June 2005, the exact date being unknown to.., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to Page 206 of 234 206 of 234 EFTA00594038 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 45 of 73 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■ is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 571. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■ has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff. L M , will in the future suffer medical and psychological expenses. The plaintiff, E., 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 the plaintiff, ■, will continue to suffer these losses in the future. 572. Wherefore, the plaintiff,.., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided Page 207 of 234 206 of IN EFTA00594039 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 46 of 73 by law, attorney's fees, costs, and such other and 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 139 Cause of Action Pursuant to 18 U.S.C. 4 2255 June 2005 — Incident 3 573. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 574. On or about June 2005, the exact date being unknown to.., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). II. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant. Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 575. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of Page 208 of 234 201 0234 EFTA00594040 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 47 of 73 self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The plaintiff, M., 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 the plaintiff, ■, will continue to suffer these losses in the future. 576. Wherefore, the plaintiff, •, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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 140 Cause of Action Pursuant to 18 U.S.C. § 2255 June 2005 — Incident 4 577. Plaintiff, L M. adopts and realleges paragraphs 1 through 20 above. 578. On or about June 2005, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, Page 209 of 234 200 a23+ EFTA00594041 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 48 of 73 child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 579. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■ has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff a incurred medical and psychological expenses and the plaintiff, ■, will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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 the plaintiff, ■, will continue to suffer these losses in the future. 580. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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. Page 210 of 234 1010134 EFTA00594042 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 49 of 73 COUNT 141 Cause of Action Pursuant to 18 U.S.C. 2255 July 2006 — Incident 1 581. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 582. On or about July 2005, the exact date being unknown to ■, Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 583. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse Page 211 of 234 210 0334 EFTA00594043 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 50 of 73 and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The 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 the plaintiff, E, will continue to suffer these losses in the future. 584. Wherefore, the plaintiff, E. demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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 142 Cause of Action Pursuant to 18 U.S.C. 6 2255 July 2005 — Incident 2 585. Plaintiff, i n . adopts and realleges paragraphs 1 through 20 above. 586. On or about July 2005, the exact date being unknown to.., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is Page 212 of 234 2110234 EFTA00594044 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 51 of 73 therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 587. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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 the plaintiff, •, will continue to suffer these losses in the future 588. Wherefore, the plaintiff,.., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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 143 Cause of Action Pursuant to 18 U.S.C. 4 2255 Page 213 of 234 212 of231 EFTA00594045 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 52 of 73 July 2005 — Incident 3 589. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 590. On or about July 2005, the exact date being unknown to E, Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 591. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255. being committed against her, ■ has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■ incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and Page 214 of 234 213.1231 EFTA00594046 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 53 of 73 psychological expenses. The plaintiff, I., 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 the plaintiff, ■, will continue to suffer these losses in the future. 592. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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 144 Cause of Action Pursuant to 18 U.S.C. § 2255 July 2005 — Incident 4 593. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 594. On or about July 2005, the exact date being unknown to in, Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e) is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Page 215 of 234 214 0134 EFTA00594047 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 54 of 73 Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 595. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, • has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The 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 the plaintiff, ■, will continue to suffer these losses in the future. 596. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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 145 Cause of Action Pursuant to 18 U.S.C. 6 2255 August 2005 — Incident 1 597. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. Page 216 of 234 2150234 EFTA00594048 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 55 of 73 598. On or about August 2005, the exact date being unknown to.., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 599. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress. psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The 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 Page 217 of 234 11101334 EFTA00594049 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 56 of 73 injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. 600. Wherefore, the plaintiff, ■, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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 146 Cause of Action Pursuant to 18 U.S.C. L2255 August 2005 — Incident 2 601. Plaintiff,.. adopts and realleges paragraphs 1 through 20 above. 602. On or about August 2005, the exact date being unknown to.., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. Page 218 of 234 2'? of 234 EFTA00594050 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 57 of 73 603. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, ■, will in the future suffer medical and psychological expenses. The 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 the plaintiff, ■, will continue to suffer these losses in the future. 604. Wherefore, the plaintiff,.., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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 147 Cause of Action Pursuant to 18 U.S.C. § 2255 August 2005 — Incident 3 605. Plaintiff,.. adopts and realleges paragraphs 1 through 20 above. 606. On or about August 2005, the exact date being unknown to.., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a Page 219 of 234 21101234 EFTA00594051 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 58 of 73 violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 607. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■ has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein. controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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 the plaintiff, ■, will continue to suffer these losses in the future. Page 220 of 234 119 of 134 EFTA00594052 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 59 of 73 608. Wherefore, the plaintiff, •, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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 148 Cause of Action Pursuant to 18 U.S.C. 4 2255 August 2005 — Incident 4 609. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 610. On or about August 2005, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). El is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 611. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. has in the past Page 221 of 234 220.0124 EFTA00594053 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 60 of 73 suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, a, 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 the plaintiff, ■, will continue to suffer these losses in the future. 612. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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 149 Cause of Action Pursuant to 18 U.S.C. 6 2255 September 2005 — Incident 1 613. Plaintiff, ■ adopts and realleges paragraphs 1 through 20 above. 614. On or about September 2005, the exact date being unknown to.., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to Page 222 of 234 111 a114 EFTA00594054 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 61 of 73 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■ is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 615. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L M . will in the future suffer medical and psychological expenses. The plaintiff, M., 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 the plaintiff, ■, will continue to suffer these losses in the future. 616. Wherefore, the plaintiff, •, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided Page 223 of 234 222 of 234 EFTA00594055 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 62 of 73 by law, attorney's fees, costs, and such other and 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 10 Cause of Action Pursuant to 18 U.S.C. 4 2255 September 2005 - Incident 2 617. Plaintiff,.. adopts and realleges paragraphs 1 through 20 above. 618. On or about September 2005, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 619. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■ has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of Page 224 of 234 223 0234 EFTA00594056 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 63 of 73 self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff,.., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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 the plaintiff, MI, will continue to suffer these losses in the future. 620. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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 151 Cause of Action Pursuant to 18 U.S.C. i 2255 September 2006 — Incident 3 621. Plaintiff... adopts and realleges paragraphs 1 through 20 above 622. On or about September 2005, the exact date being unknown to.., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, Page 225 of 234 224 0 224 EFTA00594057 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 64 of 73 child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 623. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■ has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■ incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The 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 the plaintiff, L.M., will continue to suffer these losses in the future. 624. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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. Page 226 of 234 226 a2s4 EFTA00594058 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 65 of 73 COUNT 152 Cause of Action Pursuant to 18 U.S.C. 4 2255 September 2005 — Incident 4 625. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 626. On or about September 2005, the exact date being unknown to.., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 627. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse Page 227 of 234 221 of 234 EFTA00594059 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 66 of 73 and conventional way of life for a minor. The then-minor plaintiff 5 incurred medical and psychological expenses and the plaintiff, ■, will in the future suffer medical and psychological expenses. The 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 the plaintiff, ■, will continue to suffer these losses in the future. 628. Wherefore, the plaintiff, ■, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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 153 Cause of Action Pursuant to 18 U.S.C. 4 2256 October 2005 — Incident 1 629. Plaintiff, 5 adopts and realleges paragraphs 1 through 20 above. 630. On or about October 2005, the exact date being unknown to 5., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). Page 228 of 234 227 el 234 EFTA00594060 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 67 of 73 M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 631. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■ has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiffs incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and psychological expenses. The 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 the plaintiff, ■, will continue to suffer these losses in the future. 632. Wherefore, the plaintiff, ■, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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 154 Cause of Action Pursuant to 18 U.S.C. 4 2255 Page 229 of 234 2at of 2 II EFTA00594061 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 68 of 73 October 2005 — Incident 2 633. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 634. On or about October 2005, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). ■ is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 635. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L M has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer medical and Page 230 of 234 mane EFTA00594062 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 69 of 73 psychological expenses. The plaintiff, E, 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 are permanent in nature and the plaintiff, ■, will continue to suffer these losses in the future. 636. Wherefore, the plaintiff, E, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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 165 Cause of Action Pursuant to 18 U.S.C. 4 2255 October 2005 — Incident 3 637. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 638. On or about October 2005, the exact date being unknown to.., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to Page 231 of 234 2300234 EFTA00594063 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 70 of 73 this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 639. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■ has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. incurred medical and psychological expenses and the plaintiff, •, will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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 the plaintiff, ■, will continue to suffer these losses in the future. 640. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and 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 156 Cause of Action Pursuant to 18 U.S.C. § 2255 October 2006 — Incident 4 641. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. Page 232 of 234 231 at 234 EFTA00594064 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 71 of 73 642. On or about October 2005, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 643. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■ has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, will in the future suffer medical and psychological expenses. The 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 Page 233 of 234 2320132+ EFTA00594065 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 72 of 73 injuries are permanent in nature and the plaintiff, will continue to suffer these losses in the future. 644. Wherefore, the plaintiff, 5, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, attorney's fees, costs, and such other and further relief as this Court deems just and proper. DEMAND FOR JURY TRIAL Plaintiff hereby demands trial by jury on all issues triable as of right by a jury. DATED July 24, 2009 ectfully Submitted, radl y J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Telephone (954) 522-3456 Facsimile (954) 527-8663 Florida Bar No.: 542075 E-mail• bedwards nrr rra-law corn Page 234 of 234 233 of 234 EFTA00594066 Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 73 of 73 %IS 44 (Et.. 2T1) The JS44 civil cover shoat and the infortnation contained herein neither tivtace nor suppkment the filing and smite of pkadinv samba papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the Unikd Swain September 1974, is requiscd for the use of IlseClerk of Court for the putposc of initiating the civil docket sheet (SEE in inner:OHS ON THE REVERSE OF THE FORM) NOTICE: Attorneys MUST.J.DKIcale All Rfratdalistpdow• CIVIL COVER SHEET 1. (a) PLAINTIFFS (b) County o(Residerne of First lined Plaintiff Palm Beach (EXCEPT IN U.S. PLAINTIFF CASES) (C) Alt/411CP (MN Name. neatest. ss4 Tiltpains Mamba° Rothstein Rosenfeldt Adler 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, FL 33301 - Phone 954-522-3456 DEFENDANTS JEFFREY EPSTEIN County of Residence of Fine Listed Deketent Palm Beach ID4 V.S. ILA Dann CASES ONLY) NOTE: IN LAND CONDEMNATION CASES. USE THE LOCATION OF THE TRACT LAND INVOLVED ABOIIICKI (if Rem) Bradley 1. Edwards (10 Check County Where Mho° Arose 0 MIAMI. DADE 0 MONROE 0 IROWARD 4 PALM 'EACH 3 MARTIN 0 ET. LUCIE 0 INDIAN RIVER 0 OKEECHOBEE HIOHLANDS II. BASIS OF JURISDICTION (19.e. la 'X' M Om an OWN O I US. OsIIIMAI vb Fultr)gslloe ANNA (U S. Orson's NMI WO) O 2 U.S00Venal•At 0 4 Dives, Defends Nodes Cs of PAtIti la Ise III) q ie rge V V/ i qfP" C~tnn-.)1i2 ... .,.......„ —. ..... 4 contact .....— _ _ ARTA FORPRITURIOPENALTV namenuercy OTHER STATUTES II a WI Inesoct 0120 Mom 0 130 MIEn Ac' O 140 Negotiable Issaumani O Ise amen., of 0 ..... yams A lielercesal other's 0 lit Silts Ati CI 132 Romeo of Defoltal Ste,44sl Los MS Swan) 0 IS) Ross of Ovens's, of Veleta'. 00401.1 o 160 Siokbeldati Sup4. 0 1900Sr Ce 3 195 Como Ili LIalollsy O 196 tomb's', PERSONAL INJURY PERSONAL INJURY 0 310AM 0 362 04.104iil Isjury • 0 313 Moho Pods.. ■Malsociie• LIalmitity 0 30 PlIrS9nII tajufy • 0 324 ANNA. Lib& a Frahm Lai Moiler aaaaa Ns I 3 361 0 330 isisaal trepLyS bran Prods LIM% Lilbllity 0 140 Miami PERSONAL PROPERTY 0 345 USN Potosi 3 370 Othior Fowl Liabitliy 0 331 Thoth le USN 0 110 4.04•4 Ve blcle 0 31000.' Nasal 0 111 Mew Volta Poona CoNOT Produsi Liabifity 3 OE Pommy Daman 0 34001k,. toms' Prato L Silliy Alm 0 610 AptIt•fruit 0 620 CAS he/ • Os 0 613 Deas It OHO Saws of Press 21 U10111 0 610 Liquor Leal 0 640 R R. A Trick 0 630 ANIS Reµ 0 661 04supiiImal Satcy41•4160 0 OM Oilior 0 422 Ars' 20 USC I SS 0 41) Withdrawal II USC 137 400 Sills Reepp011i 00000 I 410 Aeliimi 430 Inks and Ilszlanp 430 Cesar« 460 Dtpotuars 470 Rotuma. tafimme4 tad Coins CarioN9INal 410 Conan Credit 490 CableSsi TV 110 Salsolve Sinks ISO Ssridta/Cenanothusn' Stamm. 175 Colossi Challenge II USC 3410 190 Olbo Sissy Actions 491 Appicuharsl Adis 192 Eon OM SIC:Malin AM 093 En•konosnasl Mails 494 Meru A MY inas Act $93 eeeee ern col Weiss ma 1 T90 APP.Ii of 44. Den muse*. Undo East Mtn. ii• lona 0 930 Cslevisellly of Sion Status PRO 0 010 Cowl/MR 0 SIG Psis 0 040 1 as LAROA SOCIAL SECURITY 0 MOM. Lobel Sisisrds An 3 7111 LaiMMEmi Realms 5 330 LolsorMont Pennies • Ditclosere Alt 1 740 Ile Sway Lebo. Art 3 116 Oilat Labor Lkiphos 0 191 tapl. Kin In. Usual' AO 0161 NIA (I 39 30) 0 141 aka Leos (92)1 0 SO DIWC/DIWW MO HEN 0 1164 SSII1Tio XVI 0463151(403W) ( REAL PROPERTY CIVIL MONTE PRISONER PETITIONS IIDIRAL TAX MTh 0 Ile Lad Corallosiis 0 220 Fends° 0 210 Rani Least a ESNs' O NC 7 s::. ra t.:-0 3 3 4: T on !rerun i 1 sae) CI 290 All Olhait Rol Promo 3 441 Troin 0 441 Esoliailoo 0 40 HOMO? As, re sac•—• 7a. Menu 441 A abilso c 0 .__- mu Em b oa Y 0 .46 Asa. WOISallelot - O Oilier 0 oft Mbar COB RItly 0 110 Mors a Versa Solon C oo Hato 000 i ". ;1. 4.,4„,1 :I 111 Onin hue. 0 340 M lookout A Oast 350 CS Melo 3 Mt Prls Coedits 0 070 TIM 0I.S Plehauff or OS'S. 0 1 ' 1 IR S. l'on1 .1. Ott aloe I 0 4" " ' tante" Appless 0 461 llotiot Csua.P.11r. Dans fl A462 en. Olbut 'signs III. CITIZENSHIP OF PRINCIPAL PARTIEStru« -x- In OO. en for PAMIR Poe Oremlly Coos Ilaly) and 044 Bo. ill Elaleadasi) PIT OBI PTV OCT Chins of TIM Sob 0 1 0 I horporawl or Inn p.' Plso 0 4 0 4 •f BOAS I. Tki4 Soo Cain •f Asks Sis 3 2 0 1 lacomparsl sad PriocloalPlor 0 $ 011usisass b Asoilto Sista Cabo or SuNrst ors 0 1 0 ) inform Nano. Iona...Coos 0 O 6 0 4 V. ORIGIN (Plaec • 'X' le 0 se So. Only) Trans erred from ,p i Original 0 2 Removed from 0 3 Re-filed- Proceeding State Court 0 4 Reasoned« Reopened 0 5 soother district 0 6 Lltitiligtuttuc n i Et 7 (see VI below) OPecifY) a) Re•filed Case 0 YES O NO b) Related Cases GIVES° NO VI. RELATED/RE-FILED CASE(S). (Mass 'or): JUDGE (S.. lastniclien• Appal CO DittrICI Judge from Maps straw ludameni DOCKET NUMBER 9:08-cv-80119 VII. CAUSE OF ACTION me the U.S. OW Statute under which you are films and Wnto • Bnef Statement of Cause (Do not cite Jurisdictional statutes unless diversity). USC Section 2255 LENGTH OF TRIAL via ys estimated (for both tides to try mire cue) 0 (ECK IT nits is AC . 23 ON DEMAND S /A/ErteS..5 CHECK YES only if demanded in complaint: 1,000,000.00 JURY DEMAND: 0 Yea O No O VIII. REQUESTED IN COMPLAINT: ABOVE INFORMATION IS TRUE & CORRECT TO si THE BEST OF MY KNOWLEDGE 234012M OF ATTORNEY OF OATS FOR evert LY AMOUNT RECEIPT • IF? 546 n7 EFTA00594067