EFTA00175214

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 89 of 91 
at
vs. Epstein, et al. 
o.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
self-esteem, loss of dignity, invasion of personal privacy and other damages associated 
with JEFFREY EPSTEIN'S controlling , manipulating, and coercing MI 
into a 
perverse and unconventional way of life for a minor. The then minor Plaintiff incurred 
medical and psychological expenses and the Plaintiff, MB, will in the future suffer 
additional 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, MB, 
will continue to suffer these losses in the future. 
WHEREFORE, the Plaintiff, a, 
demands judgment against the Defendant, 
EMIfor compensatory damages of at least the minimum amount provided 
by law, punitive damages, 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. 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on the 9th day of February, 2009, I electronically filed 
the foregoing with the Clerk of the Court by using CM/ECF system, which will send a 
notice of electronic filing to all counsel of record on the attached service list. 
89 
EFTA00175414

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 91 of 91 
vs. Epstein, et al. 
08-CV-80811-CIV-MARRAJJOHNSON 
First Amended Complaint 
Page 91 of 91 
COUNSEL LIST 
Richard H. Willits, Esquire 
Richard H. Willits, P.A. 
2290 10th Avenue North, Suite 404 
Lake Worth, FL 33461 
Phone: 
Fax: 
Robert Critton, Esquire 
Burman Critton Luttier & Coleman LLP 
515 North Flagler Drive, Suite 400 
West Palm Beach FL 33414 
Phone: 
Fax: 
Jack A. Goldberger, Esquire 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue South 
West Palm Beach FL 33401 
Phone: 
Bruce E. Reinhart, Esquire 
Bruce E. Reinhart, P.A. 
250 South Australian Avenue 
Suite 1400 
West Palm B ch FL 33401 
Phone: 
Fax: 
91 
EFTA00175415

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LRJ, MEDREQ, REF_DISCOV 
U.S. District Court 
Southern District of Florida (West Palm Beach) 
CIVIL DOCKET FOR CASE #: 9:08-cv-80893-KAM 
Doe v. Epstein 
Assigned to: Judge Kenneth A. Marra 
Referred to: Magistrate Judge Linnea R. Johnson 
Lead case: 9:08-cv-80119-KAM 
Member case: (View Member Case) 
Case: 9:09-cv-80802-ICAM 
Cause: no cause specified 
Plaintiff 
Jane Doe 
V. 
Defendant 
Jeffrey Epstein 
Date Filed: 08/13/2008 
Jury Demand: Plaintiff 
Nature of Suit: 360 P.I.: Other 
Jurisdiction: Federal Question 
represented by Bradley James Edwards 
Rothstein Rosenfeldt Adler 
401 East Las Olas Blvd 
Suite 1650 
Ft. Lauderdale FL 33301 
Fax: 
Email: 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Paul G. Cassell 
Email: 
PRO HAG
ATTORNEY TO BE NOTICED 
represented by Jack Alan Goldberger 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach , FL 33401-5012 
Fax: 835-8691 
Email: 
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LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Robert Deweese Critton , Jr. 
Burman Critton Luther & Coleman 
515 N Flagler Drive 
Suite 400 
West Palm Beach , FL 33401-2918 
Amicus 
United States of America 
ax: 
Emai 
LEAD 
ATTORNEY TO BE NOTICED 
Michael James Pike 
Burman Critton Luttier & Coleman 
515 N Flagler Drive 
Suite 400 
West Palm Beach , FL 33401-2918 
Fax: 515-314 
ATTORNEl
li
gi'M 
D 
Email: 
represented by mi 
B 
United States Attorney s Office 
500 East Broward Blvd 
7th Floor 
Ft Lauderdale , FL 33394 
ext. 3546 
Fax: 356-7336 
Email: 
LEAD ATT
ATTORNEY TO BE NOTICED 
Date Filed 
# that Docket Text 
08/13/2008 
1 
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COMPLAINT against Jeffrey Epstein Filing fee $ 350. Receipt#: 724605, 
filed by Jane Doe.(rb) (Entered: 08/14/2008) 
08/13/2008 
2 
11 
236.0 
xri 
MOTION to Proceed Anonymously by Jane Doe. (rb) (Entered: 
08/14/2008) 
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08/13/2008 
3 
Fr 
119.3
KB 
MOTION to keep True Name in Sealed Envelope by Jane Doe. (rb) 
(Entered: 08/14/2008) 
08/13/2008 
4 
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Summons Issued as to Jeffrey Epstein. (rb) (Entered: 08/14/2008) 
08/13/2008 
5 
Sealed Document. (rb) (Entered: 08/14/2008) 
08/21/2008 
6 
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MOTION for Limited Appearance, Consent to Designation and Request to 
Electronically Receive Notices of Electronic Filing for Paul G. Cassell, 
Filing Fee $75, Receipt #724636. (cw) (Entered: 08/25/2008) 
08/25/2008 
7 
ENDORSED ORDER granting Paul G. Cassell 6 Motion for Limited 
Appearance, Consent to Designation and Request to Electronically Receive 
Notices of Electronic Filings. Signed by Judge Kenneth A. Marra on 
8/25/08. (ir) (Entered: 08/25/2008) 
09/15/2008 
8 
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NOTICE of Attorney Appearance by Robert Deweese Critton, Jr on behalf 
of Jeffrey Epstein (Critton, Robert) (Entered: 09/15/2008) 
09/30/2008 
9 
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ORDER TO RESPOND re 3 MOTION to keep True Name in Sealed 
Envelope filed by Jane Doe, 2 MOTION to Proceed Anonymously filed by 
Jane Doe. Responses due by 10/15/2008. Signed by Judge Kenneth A. 
Marra on 9/30/08. (ir) (Entered: 09/30/2008) 
10/01/2008 
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MOTION FOR EXTENSTION OF TIME TO RESPOND to I Complaint 
Extension to Respond to Complaint and Require Plaintfff to File Rico filed 
by Jeffrey Epstein. (Attachments: # 1 Extension to Respond to Complaint 
and Require Plaintiff to File RicoXCritton, Robert) Modified on 10/2/2008 
(ir). (Entered: 10/01/2008) 
10/02/2008 
Clerks Notice of Docket Correction and Instruction to Filer re 10 
RESPONSE/REPLY for Extension of Time filed by Jeffrey Epstein. Error - 
Wrong Event Selected; Correction - Redocketed by Clerk as MOTION for 
Extension of Time to Answer. Instruction to Filer - In the future, please 
select the proper event. It is not necessary to refile this document. (ir) 
(Entered: 10/02/2008) 
10/02/2008 
1 1 
ENDORSED ORDER granting 10 Motion for Extension of Time to 
Answer Complaint. Jeffrey Epstein response due 10/10/2008. Plaintiff must 
file the Rule 12.1 Civil RICO statement by 10/3/08. Signed by Judge 
Kenneth A. Marra on 10/2/08. (ir) (Entered: 10/02/2008) 
10/02/2008 12 
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RESPONSE to Motion re 2 MOTION to Proceed Anonymously filed by 
Jeffrey Epstein. Replies due by 10/14/2008. (Critton, Robert) (Entered: 
10/02/2008) 
10/03/2008 
13 
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NOTICE of Attorney Appearance by Jack Alan Goldberger on behalf of 
Jeffrey Epstein (Goldberger, Jack) (Entered: 10/03/2008) 
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10/03/2008 
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NOTICE by Jane Doe of Filing Civil RICO Case Statement Pursuant to 
Local Rule 12.1 (Attachments: # 1 Supplement Civil RICO Case Statement 
Pursuant to Local Rule 12.1)(Eclwards, Bradley) (Entered: 10/03/2008) 
10/06/2008 
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ici3 
ORDER granting 2 Motion to Proceed Anonymously ; granting 3 Motion to 
Keep True Name in Sealed Envelope. The Clerk shall SEAL the true name 
affidavit of the Plaintiff. Signed by Judge Kenneth A. Marra on 10/6/08. 
(ir) (Entered: 10/06/2008) 
10/10/2008 
16 r
1.7 
MB
Defendant's MOTION to Dismiss 1 Complaint, MOTION for More 
Definite Statement, MOTION to Strike 1 Complaint by Jeffrey Epstein. 
Responses due by 10/30/2008 (Critton, Robert) (Entered: 10/10/2008) 
10/16/2008 
17 
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RESPONSE to Motion re 16 Defendant's MOTION to Dismiss 1 
Complaint MOTION for More Definite Statement MOTION to Strike i 
Complaint filed by Jane Doe. Replies due by 10/27/2008. (Edwards, 
Bradley) (Entered: 10/16/2008) 
10/27/2008 
18 
r a
Complaint 
REPLY to Response to Motion re 16 Defendant's MOTION to Dismiss 1 
Complaint MOTION for More Definite Statement MOTION to Strike 1 
filed by Jeffrey Epstein. (Attachments: # 1 Order in Jane Does 1 
and 2XCritton, Robert) (Entered: 10/27/2008) 
12/04/2008 
19_ 
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SCHEDULING REPORT - Rule 26(f). (Critton, Robert) (Entered: 
12/04/2008) 
12/10/2008 
20 
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KB
ORDER Setting Trial Date & Discovery Deadlines, Referring Case to 
mediation & Referring Discovery Motions to United States Magistrate 
Judge. SCHEDULING ORDER: ( Jury Trial set for 2/22/2010 in West 
Palm Beach Division before Judge Kenneth A. Marra., Calendar Call set 
for 2/19/2010 10:00 AM in West Palm Beach Division before Judge 
Kenneth A. Marra., Amended Pleadings due by 2/2/2009., Discovery due 
by 10/1/2009., Pretrial Motions due by 10/20/2009.), ORDER 
REFERRING CASE to Mediation. 15 days to appoint mediator., ORDER 
REFERRING CASE to Magistrate Judge Linnea R. Johnson for Discovery 
Proceedings. Signed by Judge Kenneth A. Marra on 12/10/2008. (tas) 
(Entered: 12/11/2008) 
03/04/2009 21 r, 
o.s 
MB
Defendant's MOTION for Extension of Time to File Motions to Compel 
Directed to Plaintiffs Answers and Responses to discovery by Jeffrey 
Epstein. (Critton, Robert) (Entered: 03/04/2009) 
03/12/2009 
22 
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KB
ORDER granting 21 Motion for Extension of Time to File Motion to 
Compel Directed to Plaintiffs Answers to Defendant's First Set of 
Interrogatories and to Plaintiffs Response to Defendant's First Request for 
Production to on or before April 3, 2009. Signed by Magistrate Judge 
Linnea R. Johnson on 3/12/2009. (kza) (Entered: 03/12/2009) 
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03/19/2009 
23 r
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ORDER Setting Hearing on Motion 16 Defendant's MOTION to Dismiss 1 
Complaint MOTION for More Definite Statement MOTION to Strike 1 
Complaint : Motion Hearing set for 4/1/2009 01:00 PM in West Palm 
Beach Division before Judge Kenneth A. Marra. Signed by Judge Kenneth 
A. Marra on 3/19/2009. (ir) (Entered: 03/19/2009) 
03/26/2009 
24 
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MB 
Defendant's MOTION to Stay re 1 Complaint by Jeffrey Epstein. 
Responses due by 4/13/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit B) 
(Pike, Michael) (Entered: 03/26/2009) 
03/30/2009 
25 
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KB 
Notice of Supplemental Authority re 16. Defendant's MOTION to Dismiss 1 
Complaint MOTION for More Definite Statement MOTION to Strike 1 
Complaint by Jeffrey Epstein (Pike, Michael) (Entered: 03/30/2009) 
04/01/2009 
29 
Minute Entry for proceedings held before Judge Kenneth A. Marra: Motion 
Hearing held on 4/1/2009 re 16 Defendant's MOTION to Dismiss 1 
Complaint MOTION for More Definite Statement MOTION to Strike 1 
Complaint filed b Jeffrey Epstein. Court Reporter: Stephen Franklin, 
Phone: 
(ir) (Entered: 04/08/2009) 
04/02/2009 26 
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ORDER granting 16 Motion to Dismiss; granting 16 Motion for More 
Definite Statement; terminating 16 Motion to Strike. Signed by Judge 
Kenneth A. Marra on 4/2/2009. (ir) (Entered: 04/02/2009) 
04/02/2009 
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Defendant's MOTION to Compel Response to 1st RTP by Jeffrey Epstein. 
Responses due by 4/20/2009 (Attachments: # 1 Exhibit A)(Pike, Michael) 
(Entered: 04/02/2009) 
04/02/2009 a 
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210.0 
KB 
Defendant's MOTION to Compel Response to 1st Interrogs by Jeffrey 
Epstein. Responses due by 4/20/2009 (Pike, Michael) (Entered: 
04/02/2009) 
04/09/2009 
30 r
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KB 
"WRONG EVENT USED, RE-DOCKETED AS ENTRY 34 " NOTICE by 
Jane Doe of Change of Firm Affiliation (Edwards, Bradley) Modified on 
4/13/2009 (Is). (Entered: 04/09/2009) 
04/09/2009 
31 r 
39.6
Ka 
RESPONSE in Opposition re 24 Defendant's MOTION to Stay re 1 
Complaint filed by Jane Doe. (Edwards, Bradley) (Entered: 04/09/2009) 
04/09/2009 
32 r 
20.8 
KB 
MOTION to Strike Reference to Non Prosecution Agreement by Jane Doe. 
Responses due by 4/27/2009 (Edwards, Bradley) (Entered: 04/09/2009) 
04/09/2009 
34 
NOTICE of Change of Address and Firm Affiliation by Bradley James 
Edwards [See Image at DE #30] (Is) (Entered: 04/13/2009) 
04/13/2009 
33 
Clerks Notice of Docket Correction and Instruction to Filer re 30 Notice 
(Other) filed by Jane Doe. Error - Wrong Event Selected; Correction - 
Redocketed by Clerk as Notice of Change of Address. Instruction to Filer -
In the future, please select the proper event. It is not necessary to refile this 
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document. (Is) (Entered: 04/13/2009) 
04/15/2009 
35. 
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MB 
Defendant's MOTION to Compel Response to Defendant's First Set of 
Interrogatories by Jeffrey Epstein. Responses due by 5/4/2009 
(Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit I)(Pike, Michael) 
(Entered: 04/15/2009) 
04/15/2009 
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KR 
RESPONSE in Opposition re 21 Defendant's MOTION to Compel 
Response to 1st RTP filed by Jane Doe. (Edwards, Bradley) (Entered: 
04/15/2009) 
04/15/2009 
37 
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RESPONSE in Opposition re 28 Defendant's MOTION to Compel 
Response to 1st Interrogs filed by Jane Doe. (Edwards, Bradley) (Entered: 
04/15/2009) 
04/17/2009 aa 
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863
to 
First AMENDED COMPLAINT, filed by Jane Doe. (Attachments: # 1 
Exhibit A)(Edwards, Bradley) (Entered: 04/17/2009) 
04/22/2009 32 
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KB 
Defendant's MOTION for Extension of Time to File Reply as to 31 
Response in Opposition to Motion to Defendant's Motion to Stay by Jeffrey 
Epstein. (Pike, Michael) (Entered: 04/22/2009) 
04/23/2009 
40 
ENDORSED ORDER granting 32 Motion for Extension of Time to Reply 
re 24 Defendant's MOTION to Stay re 1 Complaint. Replies due by 
5/12/2009. Signed by Judge Kenneth A. Marra on 4/23/2009. (ir) (Entered: 
04/23/2009) 
04/27/2009 .11. 
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Defendant's MOTION for Extension of Time to File Reply as to 36 
Response in Opposition to Motion to Compel Production of Tax Returns by 
Jeffrey Epstein. (Pike, Michael) (Entered: 04/27/2009) 
04/27/2009 
42 
n 
1:14
Defendant's MOTION for Extension of Time to File Reply as to 37 
Response in Opposition to Motion to Compel Plaintiff to Respond to First 
Set Interrogatories by Jeffrey Epstein. (Pike, Michael) (Entered: 
04/27/2009) 
04/28/2009 
43 
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Ks 
ORDER TO SHOW CAUSE why cases should not be consolidated for 
discovery purposes Show Cause Response due by 5/5/2009.. Signed by 
Judge Kenneth A. Marra on 4/28/2009. (cqs) (Entered: 04/29/2009) 
04/29/2009 
44 
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KB
Defendant's MOTION for Extension of Time to File Response as to 32 
MOTION to Strike Reference to Non Prosecution Agreement or, in the 
alternative, to Lift Protective Order Barring Jane Doe's Attorney's from 
Revealing Provision in the Agreement by Jeffrey Epstein. (Pike, Michael) 
(Entered: 04/29/2009) 
05/01/2009 
45 
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ORDER Granting 41 Motion for Extension of Time in which to file reply in 
support of Motion to Compel Tax Records ; Granting 42 Motion for 
Extension of Time to file reply in support of Motion to Compel Response 
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to First set of Interrogatories ; Granting 44 Motion for Extension of Time to 
Respond to Motion to Strike References to Non-Prosecution Agreement. 
Signed by Magistrate Judge Linnea R. Johnson on 5/1/2009. (sa) (Entered: 
05/01/2009) 
05/04/2009 
46 
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REPLY to Response to Motion re 27 Defendant's MOTION to Compel 
Response to 1st RTP, Il. Defendant's MOTION for Extension of Time to 
File Reply as to 36 Response in Opposition to Motion to Compel 
Production of Tax Returns filed by Jeffrey Epstein. (Attachments: # 1 
Exhibit Exhibit AXPike, Michael) (Entered: 05/04/2009) 
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RESPONSE TO ORDER TO SHOW CAUSE by Jane Doe. (Edwards, 
Bradley) (Entered: 05/04/2009) 
05/04/2009 
48 
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REPLY to Response to Motion 37 Response in Opposition to Motion to 
Compel Plaintiff to Respond to First Set Interrogatories, 35 Defendant's 
MOTION to Compel Response to Defendant's First Set of Interrogatories 
filed by Jeffrey Epstein. (Attachments: # 1 Exhibit Exhibit AXPike, 
Michael) Modified link on 5/5/2009 (1k). (Entered: 05/04/2009) 
05/04/2009 
49 
ri 
" 3B3
MEMORANDUM in Opposition re la Order to Show Cause by Jeffrey 
Epstein. (Pike, Michael) (Entered: 05/04/2009) 
05/04/2009 
50 
RESPONSE TO ORDER TO SHOW CAUSE by Jeffrey Epstein. See 
image DE 49 (1k) (Entered: 05/05/2009) 
05/05/2009 
51 
Clerks Notice of Docket Correction and Instruction to Filer re 49 
Memorandum in Opposition filed by Jeffrey Epstein. ERROR - Wrong 
Event Selected; Correction - Redocketed by Clerk as 50 RESPONSE TO 
ORDER TO SHOW CAUSE. Instruction to Filer - In the future, please 
select the proper event, UNDER OTHER 
ANSWERS/RESPONSES/REPLIES. It is not necessary to refile this 
document. (1k) (Entered: 05/05/2009) 
05/05/2009 
52 
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Defendant's MOTION for Extension of Time to File Response as to 38 
Amended Complaint by Jeffrey Epstein. (Critton, Robert) (Entered: 
05/05/2009) 
05/06/2009 
53 
ENDORSED ORDER granting 52 Motion for Extension of Time to 
Answer Amended Complaint. Jeffrey Epstein response due 5/18/2009. 
Signed by Judge Kenneth A. Marra on 5/5/2009. (ir) (Entered: 05/06/2009) 
05/12/2009 
54 
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RESPONSE/REPLY to al Response in Opposition to Motion to Stay 
and/or Continue Action for Time Certain by Jeffrey Epstein. (Pike, 
Michael) (Entered: 05/12/2009) 
05/13/2009 
55 
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SUPPLEMENT to 54 Response/Reply (Other) to Plaintiffs Response in 
Opposition to Defendant's Motion to Stay and/or Continue Action by 
Jeffrey Epstein. (Pike, Michael) (Entered: 05/13/2009) 
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05/14/2009 
Cases associated. (dg) (Entered: 05/14/2009) 
05/14/2009 
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ORDER CONSOLIDATING CASES. Hereinafter all motions and other 
court filings that relate to discovery and all procedural motions that relate to 
multiple cases shall be styled with all of the case names and numbers and 
shall be filed in Case No. 08-80119-CIV-MARRA. Signed by Judge 
Kenneth A. Marra on 5/14/2009. Associated Cases: 9:08-cv-80119-KAM et 
al. (ir) (Entered: 05/14/2009) 
05/14/2009 
57 
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ORDER REQUESTING UNITED STATES PROVIDE POSITION TO 
MOTION TO STAY. Signed by Judge Kenneth A. Marra on 5/14/2009. 
(Attachments: # 1 Appendix Motion to Stay DE 51) Associated Cases: 
9:08-cv-80119-KAM et al. (ir) (Entered: 05/14/2009) 
05/14/2009 
58 
ORDER terminating 24 Motion to Stay. Signed by Judge Kenneth A. Marra 
on 5/14/2009. (Ic3) (Entered: 05/14/2009) 
05/14/2009 
59 
ORDER denying 32 Motion to Strike, without prejudice to re-file 
procedural motions relating to multiple cases in case no. 08-80119. See 
Order consolidating cases.. Signed by Judge Kenneth A. Marra on 
5/14/2009. (1c3) (Entered: 05/14/2009) 
05/18/2009 
60 
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MOTION for Extension of Time to File Response to Plaintiffs First 
Amended Complaint by Jeffrey Epstein. (Pike, Michael) (Entered: 
05/18/2009) 
05/19/2009 
61 
ENDORSED ORDER granting 60 Motion for Extension of Time to 
Answer Complaint. Jeffrey Epstein response due 6/4/2009. Signed by 
Judge Kenneth A. Marra on 5/19/2009. (ir) (Entered: 05/19/2009) 
05/19/2009 
62 
17
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Defendant's MOTION to Strike Cases from Current Trial Docket by 
Jeffrey Epstein. Responses due by 6/8/2009 (Attachments: # 1 Exhibit A) 
Associated Cases: 9:08-cv-80119-KAM et al.(Pike, Michael) (Entered: 
05/19/2009) 
05/20/2009 
63 
ORDER terminating (93) Motion to Strike ; terminating (94) Motion in 
case 9:08-cv-80232-ICAM; terminating (110) Motion to Strike ; terminating 
(111) Motion in case 9:08-cv-80380-KAM; terminating (95) Motion to 
Strike ; terminating (96) Motion in case 9:08-0v-80381-KAM; terminating 
(90) Motion to Strike ; terminating (91) Motion in case 9:08-cv-80811-
KAM; terminating (62) Motion to Strike in case 9:08-cv-80893-KAM; 
terminating (62) Motion to Strike in case 9:08-cv-80993-KAM; terminating 
(50) Motion to Strike in case 9:08-cv-80994-KAM. Signed by Judge 
Kenneth A. Marra on 5/20/2009. (Ic3) (Entered: 05/20/2009) 
05/20/2009 
64 
Clerks Notice of Docket Correction and Instruction to Filer re 62 MOTION 
to Strike filed by Jeffrey Epstein. Error - Motion with Multiple Reliefs 
Filed as One Relief;. Instruction to filer - In the future, please select all 
applicable reliefs. It is not necessary to refile this document. (Is) (Entered: 
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05/20/2009) 
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NOTICE by 
. of Filing Withdrawal of Previously Raised Oils 
to Defendant, Jeffrey Epstein's Motion to Comp 
Or Identify 
in the Style of This Case and Motion to IdenttfrIME in Third-Party 
Subpoenas for Purposes of Discovery, Or, Alternatively, Motion to Dismiss 
Sua Sponte, With Inorporated Memorandum of Law Associated Cases: 
9:08-cv-80119-KAM et al.(Hill, Jack) (Entered: 05/20/2009) 
05/20/2009 
66 
ORDER ULLLING in all Epstein cases EXCEPT case no. 08-80119: 
Notice by I.... 
of Filing Withdrawal of Previously Raised Objections to 
Epstein's Motion to Compel and/or Identify. This Notice should only be 
filed in 08-80119, not in all of the Epstein cases.. Signed by Judge Kenneth 
A. Marra on 5/20/2009. Associated Cases: 9:08-cv-80119-ICAM et al. (Ic3) 
(Entered: 05/20/2009) 
05/22/2009 
67 
Clerks Notice of Docket Correctimaad Instruction to Filer re 65 Notice 
(Other), Notice (Other) filed by il..... Error - Incorrect Document 
Link/No Link;. Instruction to filer - In the future, please link the document 
to the proper entry. It is not necessary to refile this document. (Is) (Entered: 
05/22/2009) 
05/27/2009 
68 
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NOTICE by Jane Doe re (111 in 9:08-cv-80119-KAM) Plaintiffs 
MOTION for Extension of Time to File Response as to (91 in 9:08-cv-
80119-1CAM) Defendant's MOTION to Compel Identity of Doe in Style of 
Case and Third-Party Subpoenas (replaces Docket entry 90)Plaintiffs 
MOTION for Extension of Time to File Response as to (91 in 9:08-cv-
80119-ICAM) Defendant's MOTION to Compel Identity of Doe in Style of 
Case and Third-Party Subpoenas (replaces Docket entry 90) (Attachments: 
# 1 Text of Proposed Order)Associated Cases: 9:08-cv-80119-KAM et al. 
(Horowitz, Adam) (Entered: 05/27/2009) 
05/28/2009 
69 
ORDER STRIKING Notice by Jane Doe in all Epstein cases EXCEPT in 
case 08-80119. This Notice should only be filed in 08-80119, not in all of 
the Epstein cases... Signed by Judge Kenneth A. Marra on 5/28/2009. 
Associated Cases: 9:08-cv-80119-KAM et al. (1c3) (Entered: 05/28/2009) 
05/29/2009 
70 
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NOTICE of Attorney Appearance by 
on behalf of 
fimica Associated Cases: 9:08-cv-80119-KAM et al. 
, 
) (Entered: 05/29/2009) 
05/29/2009 
71 
E 
37.7 
RESPONSE to Motion re (72 in 9:08-cv-80380-KAM) Defendant's 
MOTION to Stay re (62) Amended Complaint, (57 in 9:08-cv-80232-
KAM) Defendant's MOTION to Stay re (50) Amended Complaint, (24 in 
9:08-cv-80893-KAM) Defendant's MOTION to Stay re (1) Complaint, (23 
in 9:08-cv-80994-KAM) Defendant's MOTION to Stay re (18) Amended 
Complaint, (22 in 9:08-cv-80993-KAM) Defendant's MOTION to Stay re 
(19) Amended Complaint, (65 in 9:08-cv-80119-ICAM) Defendant's 
https://ecf.flsd.useourts.gov/egi-bin/DktRpt.p1.7859999798355213-L_801_0-1 
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MOTION to Stay re (56) Amended Complaint, (68 in 9:08-cv-80381-
KAM) Defendant's MOTION to Stay re (60) Amended Complaint, (51 in 
9:08-cv-80811-KAM) Defendant's MOTION to Stay re (40) Amended 
Complaint and or Continue Action Filed Pursuant to Court's Order 
Requesting Government's Position filed by United States of America. 
/2C
9n
ases00:99):08-cv-80119-1CAM et al. 
Associated 
05 
Sit 
)9
(.Entered 
) 
05/29/2009 
72 
r 
433 
fa3 
RESPONSE in Opposition re (90 in 9:08-cv-80119-KAM) Defendant's 
MOTION to Compel Identify Doe in Style of Case and in Third-Party 
Subpoenas, (91 in 9:08-cv-80119-KAM) Defendant's MOTION to Compel 
Identity of Doe in Style of Case and Third-Party Subpoenas (replaces 
Docket entry 90) filed by Jane Doe No. 102, Jane Doe No. 101. Associated 
Cases: 9:08-cv-80119-KAM et al.(Ezell, Katherine) (Entered: 05/29/2009) 
05/29/2009 
73 
ORDER STRIKING (124 in 9:08-cv-80119-KAM, 105 in 9:08-cv-80811-
KAM, 74 in 9:08-cv-80993-KAM, 72 in 9:08-cv-80893-KAM, 106 in 9:08-
cv-80232-KAM, 123 in 9:08-cv-80380-KAM, 35 in 9:09-cv-80591-KAM, 
25 in 9:09-cv-80469-KAM, 60 in 9:08-cv-80994-KAM, 22 in 9:09-cv-
80656-KAM, 107 in 9:08-cv-80381-KAM) Response in Opposition to 
Motion, filed by Jane Doe No. 102, Jane Doe No. 101 DO NOT FILE IN 
EVERY EPSTEIN CASE. SEE ORDER CONSOLIDATING CASES.. 
Signed by Judge Kenneth A. Marra on 5/29/2009. Associated Cases: 9:08-
cv-80119-ICAM et al. (Ic3) (Entered: 05/29/2009) 
05/29/2009 74 r
24.5 
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MOTION for Leave to File UNDER SEAL RESPONSE IN OPPOSITION 
TO DEFENDANTS MOTION TO STAY OR, IN THE ALTERNATIVE, TO 
UNSEAL THE NONPROSECUTION AGREEMF,KT by Jane Doe No. 102, 
Jane Doe No. 101. Associated Cases: 9:08-cv-80119-KAM et al.(Ezell, 
Katherine) (Entered: 05/29/2009) 
05/29/2009 
75_ 
r
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MOTION for Hearing MOTION TO RESCHEDULE HEARING by Jane 
Doe No. 102, Jane Doe No. 101. Associated Cases: 9:08-cv-80119-ICAM et 
al.(Josefsberg, Robert) (Entered: 05/29/2009) 
06/01/2009 
76 
ORDER STRIKING (28 in 9:09-cv-80469-KAM, 126 in 9:08-cv-80380-
KAM, 109 in 9:08-cv-80232-KAM, 25 in 9:09-cv-80656-ICAM, 77 in 9:08-
cv-80993-ICAM, 38 in 9:09-cv-80591-KAM, 110 in 9:08-cv-80381-KAM, 
63 in 9:08-cv-80994-ICAM, 75 in 9:08-cv-80893-KAM, 108 in 9:08-cv-
80811-1CAM) Motion to Continue Hearing filed by Jane Doe No. 102, Jane 
Doe No. 101, (76 in 9:08-cv-80993-KAM, 109 in 9:08-cv-80381-KAM, 
108 in 9:08-cv-80232-KAM, 62 in 9:08-cv-80994-KAM, 125 in 9:08-cv-
80380-KAM, 74 in 9:08-cv-80893-KAM, 24 in 9:09-cv-80656-KAM, 37 in 
9:09-cv-80591-ICAM, 107 in 9:08-cv-80811-KAM, 27 in 9:09-cv-80469-
KAM) Motion for Leave to File, filed by Jane Doe No. 102, Jane Doe No. 
101. THESE DOCUMENTS SHOULD BE FILED ONLY IN 08-80119. 
SEE CASE MANAGEMENT ORDER.. Signed by Judge Kenneth A. 
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Marra on 6/1/2009. (1c3) (Entered: 06/01/2009) 
06/03/2009 
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Defendant's MOTION for Extension of Time to File Response as to 38 
Amended Complaint Unopposed by Jeffrey Epstein. (Attachments: # 1 Text 
of Proposed Order Order)(Pike, Michael) (Entered: 06/03/2009) 
06/04/2009 
78 
ENDORSED ORDER granting 77 Motion for Extension of Time to 
Answer First Amended Complaint. Jeffrey Epstein response due 6/10/2009. 
Signed by Judge Kenneth A. Marra on 6/4/2009. (ir) (Entered: 06/04/2009) 
06/04/2009 
79 
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REPLY to Response to Motion re (113 in 9:08-cv-80119-ICAM) Plaintiffs 
MOTION Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No-
Contact Order Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Reply 
to Defendant Jeffrey Epstein's Response to Plaintiffs Jane Doe No. 101 and 
Jane Doe No. 102's Motion for a No-Contact Order filed by Jane Doe No. 
101, Jane Doe No. 102. Associated Cases: 9:08-cv-80119-KAM et al. 
(Ezell, Katherine) (Entered: 06/04/2009) 
06/04/2009 
80 
ORDER STRIKING (112 in 9:08-cv-80381-KAM, Ill in 9:08-cv-80232-
KAM, 136 in 9:08-cv-80119-KAM, 111 in 9:08-cv-80811-KAM, 128 in 
9:08-cv-80380-KAM, 65 in 9:08-cv-80994-KAM, 79 in 9:08-cv-80893-
KAM, 42 in 9:09-cv-80591-ICAM, 27 in 9:09-cv-80656-ICAM, 32 in 9:09-
cv-80469-ICAM, 79 in 9:08-cv-80993-KAM) Reply to Response to Motion, 
filed by Jane Doe No. 102, Jane Doe No. 101 Document stricken for failure 
to follow Court's orders. DO NOT FILE A DOCUMENT IN EVERY 
EPSTEIN CASE if it is to be filed only in 08-80119. See Case Management 
Order and contact CM/ECF Support for assistance in proper filing.. Signed 
by Judge Kenneth A. Marra on 6/4/2009. Associated Cases: 9:08-cv-80119-
KAM et al. (1c3) (Entered: 06/04/2009) 
06/08/2009 
81 r
161.3 
KB 
Defendant's MOTION for Extension of Time to File Response as to 38 
Amended Complaint by Jeffrey Epstein. (Attachments: # 1 Text of 
Proposed Order)(Pike, Michael) (Entered: 06/08/2009) 
06/08/2009 
82 r
3.8 
MB 
RESPONSE to Motion re (91 in 9:08-cv-80119-KAM) Defendant's 
MOTION to Compel Identity of Doe in Style of Case and Third-Party 
Subpoenas (replaces Docket entry 90) filed by Jane Doe. Replies due by 
6/18/2009. (Attachments: # 1 Exhibit A, # 2 Exhibit B)Associated Cases: 
9:08-cv-80119-ICAM et al.(Horowitz, Adam) (Entered: 06/08/2009) 
06/08/2009 
83 r 
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NOTICE by Jane Doe re (113 in 9:08-cv-80119-KAM) Plaintiffs 
MOTION Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No-
Contact Order -Plaintiffs Jane Does 2-7 Notice of Joinder Associated 
Cases: 9:08-cv-80119-KAM et al.(Horowitz, Adam) (Entered: 06/08/2009) 
06/10/2009 
84 
ENDORSED ORDER granting .81_ Motion for Extension of Time to 
Answer Amended Complaint. Jeffrey Epstein response due 6/12/2009. 
Signed by Judge Kenneth A. Marra on 6/9/2009. (ir) (Entered: 06/10/2009) 
https://ecf.flsd.useourts.gov/cgi-bin/DictRpt.p17859999798355213-L_801_0-1 
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85 
Clerks Notice of Docket Correction and Instruction to Filer re 83 Notice 
(Other), Notice (Other) filed by Jane Doe. Error - Wrong Event Selected;. 
Instruction to Filer - In the future, please select the proper event, i.e. Notice 
of Adoption. It is not necessary to refile this document. (ls) (Entered: 
06/10/2009) 
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6/10/2009 
EFTA00175427

I. (\iced a gOetA) rfuCate rmr9 e. or- r:le, [Nader 
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EFTA00175428

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 1 of 19 
IN THE UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF FLORIDA 
JANE DOE No. 101, 
Plaintiff, 
VS. 
JEFFREY EPSTEIN, 
Defendant. 
09-80591 
Civil Action No. 
CIV-MARRP 
MAGISTRATE JUDGE 
JOHNSON 
BLED DY 
INTAKE 
APR 1 7 2009 
STEVEN M. LARIMORE 
CLERK U.S. DIST. CT. 
S.O. OF FLA. MIAMI 
COMPLAINT AND 
DEMAND FOR JURY TRIAL 
COMPLAINT AND DEMAND FOR JURY TRIAL 
Plaintiff, Jane Doe No. 101 ("Jane Doe"), brings this Complaint against Defendant, 
Jeffrey Epstein, and states as follows: 
PARTIES, JURISDICTION, AND VENUE 
I. 
At all times material to this cause of action, Plaintiff, Jane Doe, 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, 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 Grillo Way, West 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. 
Podhurst Orseck, P.A. 
25 West Nagler Street, Suite 800, Miami, FL 33130, Miami 
Fax 
• Fort Lauderdale 
www.podhursLcom 
EFTA00175429

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 2 of 19 
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(a), as a 
substantial part of the events giving rise to the claim occurred in this District. 
STATEMENT 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. 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. The allegations herein concern 
Defendant's conduct while at his lavish estate in Palm Beach. 
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 or molested 
these girls, and then gave them money. 
10. 
Beginning in or around 2001 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. 
II. 
Defendant's plan and scheme reflected a particular pattern and method. 
Defendant coerced and enticed impressionable, vulnerable, and relatively economically less 
Podhurst Orseck, P.A. 
2 
25 West Flagier Street, Sults 800, Miami, FL 33130, Miami 
Fax 
• Fort Lauderclak 
www.podburstcout 
EFTA00175430

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 3 of 19 
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. 
Defendant would pay the procurer of each girl's "appointment" approximately 
$200. 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 nude 
photographs and/or videos of the underage girls' for Defendant without their knowledge. 
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 
Podhurst Orseck, P.A. 
3 
25 West Meer Strwt, Suite 800, Miami, FL 33130, Miami 
Fax 
• Port Lauderdale 
vnvw.podhurst.coui 
EFTA00175431

Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 4 of 19 
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 nude 
photographs of 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 would direct the girl to massage him, giving her 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 
with a IIMM and/or■ 
her 
performing 
and/or coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution. 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. 
Podhurst Orseck, P.A. 
4 
25 West Flagler Street Suite 800, Nan* FL 33130, tdlaml 
Fax 
• Fort Lauderdale 
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Case 9:09-cv-80591-KAM 
Document 1 
Entered on FLSD Docket 04/20/2009 
Page 5 of 19 
16. 
As previously stated in paragraph 14, Defendant displayed nude photographs of 
underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S. 
Virgin Islands. Upon information and belief, some of the photographs in the possession of 
Defendant were taken with hidden cameras set up throughout 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, 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 commerce. 
17. 
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, 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. He 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 
Podhurst Orsecic, P.A. 
5 
ZS Wet Meer Street Suite 800, Miami, FL 33130, Miami 
Fax 
• Fort Lauderdale 
EFTA00175433