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i 19. This sexual assault was in violation of Chapter 800 of the Florida Statutes, which " fecognizes a5 2 ctime the lewd and lascivious acts committed by Epstein upon Jane Doe. 20. As 2 direct and proximate result of Epstein's acsaclt on Jane Doe, she has suffered and will continut to suffer severe and permanent waumatiic mjuries, including mental, psychological and emouonal damages. WHEREFORE, Ptaintiff Jane Doe, by and through her Mother, as patent and s2tural guaidian, Scinands judgmenm against Defendant JefMicy Epstein for compensatory damages, costs, attomey"s fees, and such other and further slief as this Court deems just and proper. Further, Plaintiff sezerves the right to amend this Complaint to add a claim for punitive damages pursuant to Florida Law. COUNT tl Civil Conspiracy against Defendants Epsicin, Robson and Kellen : goo 7] Fesmatiede indent: 21. Plaintuff Jane Doe, by and through her Mothes, a9 parent and natural guardian, reprats Lote O°, Feet tree and realleges patagraph: | through 16 above. 22. Defendants Epstein, Robson and Kellen conspited to subject Jane Doe to the sexual "assault of Defendant Epstein. 23. Each of the Defendants commited an ovest act in pursuance of this conspiracy: " Defendant Robson used false pretenses to lure Jane Doe to the home of Defendant Epstein so that Epstein could sexually asszun Jane Doe; Defendant Kellen delivered Jane Doe to Defendant Epstein's bedroom so that Epstein could sexually assault Jane Doc, and Defendant Epsicin actually committed sexual assault against Jane Doe. Page Sof? 07/26/17 Page 78 of 131 Public Records Request No.: 17-295 DOJ-OGR-00030545