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. seserves the right to amend this Complaint to 26d 2 ctatmn for punitive damages parvusnt to Florida Law. COUNT IV Civil Remedy for Violation of Florida Statute Section 772.103 against Defendants Epstein, Robson aad Kellen 30. Plaintiff Jane Doe, by and through her Mother, as parent and naturdl guardian, repeats’ (at Fa tre | and realleges paragraphs 1 through 16 above. 31. Defendants participated in an enterprise, or conspired or endeavored to so participate, " through a pattem of criminal activity in violation of Florida Statute section 772.103(3)-(4). 32, Defendants engaged in this pattem of criminal activay by engaging in at least two of the following incidents of criminal activity with the same or similar intents, results, accomplices, victims, and methods of commission within a5 year period: 2 Procuring for prostitution, ot causing to be prostituted, any person who is under the age of 18 years in violation of Flotida Statute section 796.03, b. Soliciting, inducing, enticing, or procuring another to commit prostitotion, lewdness, or assignation in violation of Florida Statute section 796.07(2)(1), or aiding, abetting ox participating in such acts in violation of Florida Statute section 796.97(2)h), ¢ Knowingly recruiting, enticing, harboring, transporting, providing, or obtaining by any means a person, knowing that force, fraud, or coercion will be used to CaUSe that person to engage in prostitution in violation of Florida Stalute section 796.045; of 4. Forcing, compelling, or coercing another 1o become a prostitute in violation of Florida Statute section 796.04. Page 7 of 9 07/26/17 Page 80 of 131 Public Records Request No.: 17-295 DOJ-OGR-00030547