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EXHIBIT A 
Jane Doe 102 v. Jeffrey Epstein 
Complaint 
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IN THE UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF FLORIDA 
JANE DOE No. 102, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
09-80656 
Civil Action No. 
CIV-RYSKAMP 
FILED by  it, 
 D C. 
INTAKE 
MAY - 1 2009 
MAGISTRATE JUDGE 
s vEN 
_Aiomokk 
VITUNAC 
of FLA Miatili 
s DST CT 
COMPLAINT AND 
Defendant. 
DEMAND FOR JURY TRIAL 
COMPLAINT AND DEMAND FOR JURY TRIAL 
Plaintiff, Jane Doe No. 102, brings this Complaint against Defendant, Jeffrey Epstein, 
and states as follows: 
PARTIES. JURISDICTION, AND VENUE 
1. 
At all times material to this cause of action, Plaintiff, Jane Doe No. 102, 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 No. 102, 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 Brillo Way, 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, 
EXHIBIT 
25 West Hagler Street Suite MO. Miami, FL 33130.Mtam 
Fort Lauderdale 951.463.4346 
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6. 
This Court has jurisdiction over 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(b), 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, spanning the 
ages of 45 and 55 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, as well as a fleet of motor vehicles. 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 56.8 million 
mansion in Palm Beach, Florida, a $30 million 7,500-acre ranch in New Mexico he named 
"Zorro," a 70-acre private island known as Little St. James in St. Thomas, U.S. Virgin Islands, a 
mansion in London's Westminster neighborhood, and a home in the Avenue Foch area of Paris. 
The allegations herein concern Defendant's conduct while at his lavish homes and/or numerous 
other locations both nationally and internationally. 
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 to countless 
vulnerable and relatively economically disadvantaged minor girls, and sexually assaulted, 
molested, and/or exploited these girls, and then gave them money. 
10. 
Beginning in or around 1998 through in or around September 2007, Defendant 
used his resources and his influence over vulnerable minor girls to engage in a systematic pattern 
of sexually exploitative behavior. 
7 
Podhurst Orseckal. 
25 West Hagler Street, Suitt 800. Mama FL 33130. Miami 305.358 MD Fax 3093582382 • Fort Lauderdale 954.463.4346 
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II. 
Defendant's plan and scheme reflected a particular pattern and method. 
Defendant coerced and enticed impressionable, vulnerable, and relatively economically less 
fortunate minor girls 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 and/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 call economically disadvantaged and underage girls from West 
Palm Beach and surrounding areas who would be enticed by the money being offered 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 12 years old, were transported to Defendant's Palm Beach 
mansion by Defendant's employees, agents, and/or assistants in order to provide Defendant with 
"massages." 
12. 
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 with andlor without their 
knowledge. Defendant would pay the procurer of each girl's "appointment" hundreds of dollars. 
3 
Podhurst Orseck, 
25 West Plaster Street. Swat 803, Wan FL 33130, Miami 305358.2800 Fax 305.358.2382 • Fort Lauderdale 951463.046 I 
www.padhurstcout 
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13. 
Epstein designed this scheme to secure a private place in Defendant's Palm Beach 
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 
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 Palm Beach 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 six homes and/or on his computers. 
IS. 
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 and/or the other female would direct the girl to massage him, giving the minor girl 
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 minor's vulva, 
vagina, and/or anus with a vibrator and/or back massager and/or his linens) and/or his penis, 
digitally penetrating her vagina, performing intercourse, oral sex, and/or anal sex, and/or 
coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution and/or 
4 
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enticing the then minor girl to engage in sexual acts with another female in Defendant's 
presence. The exact degree of molestation and frequency with which the sexual exploitations 
took place varied and is not yet completely known; however, Defendant committed such acts 
regularly on a daily basis and, in most instances, several times a day. In order to facilitate the 
daily exchanges of money for sexual assault and abuse, Defendant kept U.S. currency readily 
available. 
16. 
Defendant, Epstein, traveled to his mansion in Palm Beach for the purpose of' 
luring minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to 
contact these minor girls for the purpose of coercing them into acts of prostitution and to enable 
himself to commit sexual battery against them and/or acts of lewdness in their presence, and he 
conspired with others, including assistants and/or his driver(s) and/or pilot(s), and his socialite 
friend/partner, Ghislaine Maxwell, to further these acts and to avoid police detection. 
Defendant's systematic pattern of sexually exploitative behavior referred to in paragraph 10 and 
described in paragraphs I 1 through the present paragraph occurred in all of Defendant's 
domestic and international residences and/or places of lodging and/or modes of transportation. 
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. 
A vulnerable young girl, Plaintiff was working as a 
Meking approximately S9 an hour when she was first lured into Defendant's 
sexually exploitative world. In or about the summer of 1998, when Plaintiff was merely fifteen 
years old while attending to her duties at 
Plaintiff was recruited by Ghislaine 
Maxwell, who lived, traveled, socialized, and worked with Defendant. Ms. Maxwell asked 
Plaintiff if she was interested in learning massage therapy and earning a great deal of money 
while learning the profession. Plaintiff's father, who 
5 
Podhurst Orseck, 
25 West Flatlet Sind, Suite 800, Miaow FL 33130, Miami 305358.2800 Fax 305358.2382 • Fat Lauderdale 9544534346 
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was not apprehensive because he felt comforted that an older woman had approached 
Plaintiff with this opportunity. As a result, Plaintiff's father dropped off Plaintiff at Defendant's 
mansion that same day. Ms. Maxwell met Plaintiff and her father outside of Defendant's Palm 
Beach mansion, where Ms. Maxwell assured the minor girl's father that Ms. Maxwell would 
provide transportation home for his teenaged daughter. Ghislaine Maxwell led Plaintiff up a 
flight of stairs to a spa room with a shower and a massage table. Defendant was lying naked on 
the massage table. Plaintiff was shocked, but, with no experience with massages, thought this 
could be massage therapy protocol. Ms. Maxwell then took off her own shirt and left on her 
underwear and started rubbing her breasts across Defendant's body, impliedly showing Plaintiff 
what she was expected to do. Ms. Maxwell then told Plaintiff to take off her clothes. The minor 
girl was apprehensive about doing this, but, in fear, proceeded to follow Ms. Maxwell by 
;he was then ordered to 
The encounter escalated, with Defendant and Ms. Maxwell sexually 
assaulting, battering, exploiting, and abusing Plaintiff in various ways and in various locations, 
including the steam room and shower. At the end of this sexually exploitive abuse, Defendant 
and Ms. Maxwell giddily told Plaintiff to return the following day and told her she had "lots of 
potential." Defendant paid Plaintiff hundreds of dollars, told her it was for two hours of work, 
and directed one of his employees to drive her home. 
18. 
Defendant and/or his procurers thereafter lured the then minor Plaintiff to his 
Palm Beach mansion every day for the next two weeks in order to engage in a similar pattern of 
sexual exploitation. Defendant and/or his procurers arranged at the end of each incident the 
transportation and scheduling for the following day's appointment. Additionally, Defendant 
telephoned the minor Plaintiff himself and/or had Ms. Maxwell telephone Plaintiff to make 
arrangements. Plaintiff was often times driven to and from Epstein's mansion by Epstein 
6 
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himself or his driver. Alternatively, Defendant or Ms. Maxwell would arrange and pay for 
Plaintiff's transportation home by taxicab. 
19. 
During Plaintiff's second incident of being sexually exploited and assaulted by 
Defendant at Defendant's Palm Beach mansion, Defendant asked Plaintiff to quit her job a= 
and travel with him to earn much more money while learning the massage 
profession. Thus. Plaintiff, an impressionable and vulnerable young girl of modest means, quit 
her job as a 
vas lured by Defendant, and continued to be victimized by 
Defendant, who immersed the minor Plaintiff into Defendant's lewd and abusive lifestyle. 
Under Defendant's dominion and control, Defendant continuously "groomed" the minor 
adolescent. 
Defendant's daily routine required the minor Plaintiff to 
Plaintiff had absolutely no say as to when, how many times, or what was done during each 
sexual encounter. Often, Plaintiff was joined by Ms. Maxwell, Ms. Maxwell's assistant, and/or a 
countless army of young women who would be brought to one of Defendant's homes for the 
sexual trysts and then be sexually exploited by Defendant. 
20. 
The first time that Defendant transported Plaintiff to another state in order to 
engage in sexual acts with her occurred when she was merely fifteen years old and after only two 
weeks of daily sexually abusive encounters with Defendant. Defendant used his private jet to 
transport the minor Plaintiff to Manhattan, where he provided her with spending money and 
accommodations with him at his mansion. From the time that Plaintiff was 15 years old, 
Defendant abused her to serve his every sexual whim, obtaining and purchasing passports and 
whatever was needed for her to travel with him and/or for him. Defendant transported Plaintiff 
in his private jet to locations that included Palm Beach, New York City, Santa Fe, Los Angeles, 
San Francisco, St. Louis, and numerous other domestic destinations, as well as international 
7 
Podhurst Orseck, ■ 
25 Wen Hasler Sent, Suite 800, MIMS, FL 33130. Muni 305.3%2800 Fax 305.358.2382 • Fat Lauderdale 954.463.4346 
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destinations, including Europe, the Caribbean, and Africa. He provided accommodations with 
him in order to have her available to him at all times wherever he went, including while 
transporting the minor Plaintiff on his private jet. Each time they would travel to one of these 
destinations, the same pattern of sexual abuse would occur, often with a vast array of aspiring 
models, actresses, celebrities, and/or other females, including minors, from all over the world. 
Upon information and belief, Defendant transported minor girls from Turkey, the Czech 
Republic, Asia, and numerous other countries, many of whom spoke no English. To Plaintiff's 
knowledge, the only females specifically excluded from Defendant's sexual escapades were 
African-Americans. 
21. 
In addition to being continually exploited to satisfy Defendant's every sexual 
whim, Plaintiff was also required to he sexually exploited by Defendant's adult male peers, 
including royalty, politicians, academicians, businessmen, and/or other professional and personal 
acquaintances. Whenever Defendant transported Plaintiff with him in his private jet to any 
destination, Defendant would pay Plaintiff a flat rate per day while he and/or his above-
mentioned associates would sexually exploit and abuse minor Plaintiff. 
22. 
Most of these acts of abuse occurred during a time when Defendant knew that 
Plaintiff was approximately 1$, 16, and 17 years old, and, after years of daily sexual exploitation, 
continued into her adulthood. Despite Defendant's stating shortly before Plaintiff's sixteenth 
birthday that he soon would have to trade her in because she was getting too old, Defendant 
continued to sexually exploit Plaintiff until she fled at age 19. Defendant's predilection for 
young girls was well known to those who regularly procured them for him and to his circle of 
friends. On one of Defendant's birthdays, a friend of Defendant sent him three I2-year-old girls 
from France who spoke no English for Defendant to sexually exploit and abuse. After doing so, 
they were sent back to France the next day. 
8 
Podhurst Orseck, E. 
25 West aisle Street. Suite 800, Miami. FL 33130, Manta 305358 2800 Fax 305358 2382 • Fort Lauderdale 954163.4316 
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23. 
Any assertions by Defendant that he was unaware of the age of the then minor 
Plaintiff are belied by his own actions, and are rendered irrelevant by the provision of applicable 
federal statutes concerning the sexual exploitation and abuse of a minor child. Defendant, 
Jeffrey Epstein, at all times material to this cause of action, knew and should have known of 
Plaintiff's age of minority. Defendant and Ms. Maxwell acknowledged and celebrated Plaintiff's 
lot" birthday. Defendant's preference for underage girls was well-known to those who regularly 
procured them for him. 
24. 
As previously stated in paragraph 14, Defendant displayed nude photographs of 
underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. 
Virgin Islands. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each of 
Defendant's homes, including a photograph of herself naked at Defendant's home in Palm 
Beach. When she asked Defendant about it, he stated dismissively that he had naked photographs 
of her in all of his homes. 
25. 
Upon information and belief, some of the photographs in Defendant's possession 
were taken with hidden cameras set up in 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 may have taken lewd photographs 
of Plaintiff, Jane Doe No. 102, 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 and/or foreign commerce. In addition, while Plaintiff was a 
minor teenager and upon Ms. Maxwell's insistence after Ms. Maxwell rejected as inappropriate 
photographs that Plaintiff presented of herself fully clothed, Ms. Maxwell photographed Plaintiff 
naked in different sexually explicit positions. 
Ms. Maxwell then presented these nude 
photographs of Plaintiff to Defendant as a birthday present for Defendant from Ms. Maxwell. 
9 
Podhurst Orseck, 
25 West Flagler Sweet, Soar 803, Miami. Ft 33130, Miami 305.358./900 Fax 3116 358.2382 • Fort Lauderdale 954.463.4346 I 
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Upon information and belief, one or more nude photographs of Plaintiff that were taken when 
she was a minor were confiscated by the Palm Beach Sheriffs Office during its execution of a 
search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information 
and belief, those photographs are still in the custody of law enforcement. 
26. 
It is virtually impossible to calculate the exact number of times that Defendant 
sexually exploited and abused Plaintiff. From the age of IS. Plaintiff was sexually exploited and 
abused by Defendant on a daily basis and, most often, multiple times each day. While some of 
the precise dates these acts occurred are unknown to Plaintiff, these dates are known to 
Defendant, as he is reported to have kept a written log of each instance in which he engaged in 
these lewd acts with then minor Plaintiff and others. Upon information and belief, these logs are 
also in the custody of law enforcement. 
27. 
In or around September 2002, Defendant purchased a commercial round-trip 
airline ticket, and provided a passport, U.S. currency, and accommodations for Plaintiff to fly to 
Thailand. While thousands of miles away from Defendant on this extended trip alone for the 
first time in more than four years, Plaintiff met, fell in love, and married a young man. She 
escaped from Defendant's abuse with the help and insistence of her new husband and, instead of 
returning to Defendant, boarded a plane to Australia with one suitcase. 
28. 
Since November 2002, Plaintiff has lived a modest life in Australia, while 
maintaining lines of communication with her family and without contact with Defendant or any 
of the people in his entourage. However, suddenly, in 2008, Plaintiff received numerous phone 
calls from one of Defendant's agents. During these phone calls to Plaintiff, he repeatedly asked 
whether she knew anything about the civil cases against Defendant, whether she knew any of the 
females who were proceeding with the civil suits, whether she was planning on filing suit, 
whether she was communicating and/or cooperating with anyone against Defendant, and whether 
I0 
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she would return to the United States to testify. Terrified by Defendant's demonstrated ability to 
track her down on her changed cell phone number halfway across the world, Plaintiff attempted 
to reassure Defendant's agent that she would remain quiet. During the course of one of these 
phone calls from Defendant's agents, Defendant himself spoke on the phone, continued to 
question her intentions, and, upon being reassured by Plaintiff, thanked her for not getting 
involved. 
29. 
Around January 2009, Plaintiff received a letter from the United States Attorney's 
Office for the Southern District of Florida, informing her of her potential civil claims against 
Defendant under 18 U.S.C. § 2255. Plaintiff contacted undersigned counsel within days and 
diligently and repeatedly pursued a good faith viable settlement of her claims against Defendant. 
Unable to reach a settlement, this lawsuit followed. 
30. 
As a result of these encounters with Defendant, Plaintiff, Jane Doe No. 102, has in 
the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, 
emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, 
confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, 
invasion of her privacy, separation from her family, and other damages associated with 
Defendant's controlling and manipulating her on a daily basis for years into a perverse and 
unhealthy way of life. 
31. 
Defendant, Jeffrey Epstein, committed the above-referenced acts upon Plaintiff in 
violation of federal 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, transport of child pornography, child exploitation 
enterprises, and other crimes, specifically including, but not limited to, those crimes designated 
11 
Podhurst Orseck, P.A. 
25 West Flatlet Street. Suite 800, Minor, FL 33130, Miami 305 358 2800 Fax 305358 2382 • Fart Lauderdale 954.463 4346 
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in 18 U.S.C. § 2421, § 2422(a), § 2422(h), § 2423(a), § 2423(b), § 2423(e), § 2251, § 2252, § 
2252A(a)(1), and § 2252A(gX1). 
32. 
In June 2008, after investigations by the Palm Beach Police Department, the Palm 
Beach State Attorney's Office, the Federal Bureau of Investigation, and the United States 
Attorney's Office for the Southern District of Florida, Defendant, Jeffrey Epstein, entered pleas 
of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and 
the procurement of minors for the purposes of prostitution in the Fifteenth Judicial Circuit in 
Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if he had 
been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must 
admit liability unto Plaintiff, Jane Doe No. 102. Plaintiff hereby exclusively seeks civil remedies 
pursuant to 18 U.S.C. § 2255. 
COUNT ONE 
(Cause of Action for Coercion and Enticement of Minor to Engage in Prostitution or 
Sexual Activity pursuant to 18 U.S.C. 4 2255 in Violation of 18 U.S.C.§ 2422(1)11 
33. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, rcalleges, and incorporates by 
reference the allegations contained in paragraphs I through 32 above. 
34. 
Defendant, Jeffrey Epstein, used a facility or means of interstate and/or foreign 
commerce to knowingly persuade, induce, entice, or coerce Jane Doc No. 102, when she was 
under the age of 18 years. to engage in prostitution and/or sexual activity for which any person 
can be charged with a criminal offense, or attempted to do so, pursuant to 18 U.S.C. § 2255 in 
violation of 18 U.S.C. § 2422(b). 
35. 
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein. 
pursuant to this Section of the United States Code. 
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36. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury. pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical 
and psychological expenses, and Plaintiff will in the future suffer additional medical and 
psychological expenses. 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 Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other 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 TWO 
(Cause of Action for Transportation of Minor with Intent to Encase in Criminal Sexual 
Activity pursuant to 1$ U.S.C. 6 2255 in Violation of 18 U.S.C. 6 2423110) 
37. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 32 above. 
38. 
Defendant, Jeffrey Epstein, knowingly transported then minor Plaintiff, Jane Doe 
No. 102, in interstate and/or foreign commerce, with the intent that Plaintiff engage in 
prostitution, or in any sexual activity for which any person can be charged with a criminal 
offense, in violation 18 U.S.C. § 2423(a). As previously stated in paragraphs 20, 21, and 27. 
I3 
Podhurst Orseck, ■ 
25 West Flagler Street, Suite 800, Miami, FL 33130. Alianu 305.358 2800 Fax 305 358 2382 • Fort Ltuderdak 954463.4346 I 
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Defendant transported Plaintiff, Jane Doe No. 102, across state lines and across international 
borders numerous times from the time that Plaintiff was merely 15 years old through adulthood 
with the primary intent of sexually exploiting her. 
39. 
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
40. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
leading her into a perverse and unhealthy way of life for a minor. The then minor Plaintiff 
incurred medical and psychological expenses, and Plaintiff will in the future suffer additional 
medical and psychological expenses. 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 Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, 
Jeffrey Epstein, fbr all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other 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. 
14 
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B West Hagler Street, Suite 800, Miami, Ft 33130, Miami 305.358 2800 Fax 305 358.2382 • Fort Lauderdale 954.463.4316 I 
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COUNT THREE 
!Cause of Action for Travel with Intent to Enna, is Illicit Sexual Conduct pursuant to 18 
U.S.C. 8 2255 in Violation of 18 U.S.C. 6 2423(b11 
41. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs I through 32 above. 
42. 
Upon information and belief, Defendant, Jeffrey Epstein, traveled in interstate 
and/or foreign commerce with the intent to engage in illicit sexual conduct, as defined in 18 
U.S.C. § 2423(0, with minor females, including the then minor Plaintiff, in violation of 18 
U.S.C. § 2423(b). 
43. 
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
44. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical 
and psychological expenses, and Plaintiff will in the future suffer additional medical and 
psychological expenses. 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 Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, 
Jeffrey Epstein. for all damages available under 18 U.S.C. § 2255, including, without limitation, 
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actual and compensatory damages, attorney's fees, costs of suit, and such other 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 FOUR 
(Cause of Action for Coercion and Enticement to Entitle in Prostitution or Sexual Activity 
pursuant to 18 U.S.C. 6 2255 in Violation of 18 U.S.C. 8 2422(411 
45. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs I through 32 above. 
46. 
Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, and/or 
coerced Jane Doe No. 102 to travel in interstate and/or foreign commerce to engage in 
prostitution and/or sexual activity for which any person can be charged with a criminal offense, 
or attempted to do so, pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(a). 
47. 
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 
I8 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
48. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical 
and psychological expenses, and Plaintiff will in the future suffer additional medical and 
psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 
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income in the future, and a loss of the capacity to enjoy lift. These injuries are permanent in 
nature, and Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other 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 FIVE 
(Cause of Action for Transportation with Intent to Entaae in Criminal Sexual Activity 
Pursuant to 18 U.S.C. 6 2255 In Violation of 18 U.S.C. 4 2421) 
49. 
Plaintiff. Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 32 above. 
50. 
Defendant, Jeffrey Epstein, knowingly transported, or attempted to transport, 
Plaintiff, Jane Doe No. 102, in interstate and/or foreign commerce, with the intent that Plaintiff 
engage in prostitution and/or in any sexual activity for which any person can be charged with a 
criminal offense, in violation of 18 U.S.C. § 2421. As previously stated in paragraphs 20, 21, 
and 27, Defendant transported Plaintiff, Jane Doe No. 102, across state lines and across 
international borders numerous times from the time that Plaintiff was merely 15 years old 
through adulthood with the primary intent of sexually exploiting her. 
51. 
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 
18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
52. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered. 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
17 
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psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
leading her into a perverse and unhealthy way of life for a minor. The then minor Plaintiff 
incurred medical and psychological expenses, and Plaintiff will in the future suffer additional 
medical and psychological expenses. 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 Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, 
Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, 
actual and compensatory damages, attorney's fees, costs of suit, and such other 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 SIX 
fiCause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. 5 2255 in 
Violation of 18 U.S.C. & 2251) 
53. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats. realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 32 above. 
54. 
Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, or coerced the 
then minor Plaintiff to engage in sexually explicit conduct for the purpose of producing a visual 
depiction of such conduct, in violation of IS U.S.C. C 2251. As previously stated in paragraphs 
14, 24, and 25. Defendant kept and displayed a myriad of nude photographs of underage girls 
throughout his homes, including his homes in New York City, Palm Beach, Santa Fe, and the 
U.S. Virgin Islands. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each 
of Defendant's homes, including a photograph of herself naked at Defendant's home in Palm 
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Beach. Upon information and belief, many of the photographs in the possession of Defendant 
were taken with hidden cameras set up in 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 No. 102, 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 and/or foreign commerce. Upon information 
and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were 
confiscated by the Palm Beach Sheriff's Office during its execution of a search warrant of 
Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those 
photographs are still in the custody of law enforcement. 
55. 
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 
18 
§ 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, 
pursuant to this Section of the United States Code. 
56. 
As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical 
and psychological expenses, and Plaintiff will in the future suffer additional medical and 
psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 
19 
Podhurst Orseck, 
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Wo•I Paolo., Ghee, Gut. Pal Mimeo R 111111 MiAlTi 111514I 714111 Fa. MC VA 77 
• Fart I auelenble OM 441/144 
www rewIl•mmt eflirIk 
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