EFTA00621400

Case 9:o9-c&gon-63-41.1 -WcturnERfil6Wrtiwenencata86101cheragabe6i8Page 20 of 27 
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 SEVEN 
(Cause of Action for Transport of Visual Depiction of Minor Enduing_ is Sexually Explicit 
Conduct pursuant to 18 U.S.C. 6 2255 In Violation of 18 U.S.C. 2252(2)(1)1 
57. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, =lieges, and incorporates by 
reference the allegations contained in paragraphs 1 through 32 above. 
58. 
Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via 
computer and/or facsimile in or affecting interstate and/or foreign commerce at least one visual 
depiction of the minor Plaintiff engaging in sexually explicit conduct, in violation of 18 U.S.C. § 
2252(a)( I). As previously stated in paragraphs 14, 24, and 25, Defendant 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 as a minor at Defendant's home in Palm Beach. As previously stated in paragraph 
24, Defendant told Plaintiff that he had photographs of her naked in all of his homes. Upon 
information and belief, many 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 nude photographs of underage girls on a computer in Defendant's 
home. 
Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd 
20 
Podhurst Orseck, 
lc 
CI sear c•••••• C. ' 
WWI IC sun; CT 11•1(1 Mann. LK IN -AM C,. 'a; llA 11AI • ten* I •t•Aerel +le lICA 
•••••••••• eet.ntly..••• 
EFTA00621420

Case 9:099aVOR63-4KAVttcurne 'RE116`WeregibendaS
8OcickeVanZ86 8Page 21 of 27 
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. 
59. 
As previously stated in paragraph 23, any assertions by Defendant that he was 
unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by 
the provision of applicable federal and state 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's preference for underage girls 
was well-known to those who regularly procured them for him. 
60. 
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. 
61. 
As a direct and proximate result of the offenses enumerated in I8 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 
21 
Podhurst Orseck, 
25 West Hagler Street, Suite 800, Miami, FL 33130, Wand 305.358 2800 Fat 305 358.2382 • Fort Lauderdale 954.461.4346 
www.podhuntcom 
EFTA00621421

09a . :9
7 J:RBR 
Doc 1603-1 
Filed 04/08/11 
Page 23 of 28 
Case 9:0Q-EaUbb64-KAm Document 1 Entered on FLSD Docket 0/04/2009 Page 22 of 27 
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 EIGHT 
'Cause of Action for Transport of Child Pornography pursuant to 18 U.S.C. 6 2255 iq 
Violation of IS U.S.C. 6 2252/Valli)) 
62. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 32 above. 
63. 
Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via 
computer and/or facsimile in or affecting interstate and/or foreign commerce child pornography 
in violation of 18 U.S.C. § 2252A(aX 1). 
64. 
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. 
65. 
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 andior 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 
22 
Podhurst Orseck, 
25 West Flatter Stmt., Suite 800, Abaft, FL 33130, Miami 305358 MOO Fax 305358.2382 • Fort Lauderdale 954.463.4346 
www.podhurst.com 
EFTA00621422

Case 9:0Q-2033806elaktiRBFoicurRA 160i-dtereFdled Q4/
/ 1 
Papte 24 of 28 
on i-LSU Docket Ub/04/2009 Page 23 of 27 
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 cant 
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 funze. 
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 NINE 
(Cause of Action for Flinfirlff in a Child Exploitation Enterprise pursuant to 18 U.S.C. § 
2255 in Violation of IS U.S.C. d 2252Mall 
66. 
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by 
reference the allegations contained in paragraphs 1 through 32 above and Counts One through 
Eight above. 
67. 
Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, 
as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 U.S.C. § 2252A(gX1). As more fully 
set forth above, Defendant engaged in actions that constitute countless violations of 18 U.S.C. § 
1591 (sex trafficking of children), Chapter 110 (sexual exploitation of children in violation of 18 
U.S.C. §§ 2251, 2252(a)(1), and 2252(A)(a)(1)), and Chapter 117 (transportation for illegal 
sexual activity in violation of 18 G.S.C. §§ 2421, 2422, and 2423). As more fully set forth above 
in paragraphs 9 through 32, Defendant's actions involved countless victims and countless 
separate incidents of sexual abuse, which he committed against minors, including Plaintiff, in 
concert with at least three other persons. 
23 
Podhurst Orsecic, 
25 West Flasks Street, Suite ROM Miami, FL 3300. M4m11053S12900 Fax X5.358.2382 • Fort Lauderdale 954.463 4346 1 
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Case 9:016, 86612 ,41/4441 68Lralif 116(1ti‘reEiM#S9Alcickel'ogtb
8638 Page 24 of 27 
68. 
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. 
69. 
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. 
Date: May I, 2009 
24 
Podhurst Orseck, ■ 
aLadaC, 
12.1_ FtadE 
Robert C. JosefsWerg, ar No.6408563
Katherine W. Ezell Bar No. 114771 
Podhurst Orseck, 
25 West Flagler Street, Suite 800 
Miami, Florida 33130 
(305) 358-2800 
(305) 358-2382 fax 
rjosefsber&
25 West Flag* Street, Suite 806 %third, FL 33130, Miami 305.358 2800 Fas 305358 2782 • Fort Lauderdak 954 463 4146 
EFTA00621424

Case 9:4-R-73806RiakiRgeuri4-5 i6°LitereFdlgg PI4Igtdlektta0S)2492%foV Page 25 of 27 
Kcal= 
.4ttorneys for Plaintiff 
DEMAND FOR JURY TRIAL 
Plaintiff demands to have her case tried before a jury. 
Rod Ixttit e Ir-t-44 4"S Ity-L-R444 
Robert C. Josettberg, Bar No. 040856 
Katherine W. Ezell, Bar No. 114771 
Podhurst Orseck, 
25 West Flagler Street, Suite 800 
Miami, Florida 33130 
(305) 358-2800 
(305 358-2382 (fax) 
Attorneys for Plaintiff 
25 
Podhurst Orseck, 
ZS West Plaster Street, Suite 800, Miami, FL 33130, Miami 305.358 28C0 Fax 305.358.1382 • Fort Lauderdale 054.463.4346 
EFTA00621425

Case 9:0
% I 
• ifia lf Ra RcurRini 160gnierecitg PLIE6OckeVOW/2110i8 Page 26 of 27 
441544 Mo. MOS/ 
CIVIL COVER SHEET 
The IS 44 ci• el covet shag addle information contused how neitherMOWaer SI“lernele the Mal Ind Serviceof plaidinctot tithes papers as inquired by law, except es provided 
by local Soot coon. This km approved by the/41dgC Conference of the United SW= in Seotonker I 974. Is mann& leer the use pulseClete of COun 10( the ourpose of mamma 
the civil docket sheet (SEE INSTRUCTIONSON THE REVERSE OF THE FORMS 
NOTICE: Ana-lien MUST ladkate All Re-filed Can Below. 
I. (a) PLAINTIFFS 
Jane Doe No. 102 
(b) County onteadence of Fen LOS Plaintiff 
West Palm Beach 
(EXCEPT IN OS PLAINTIFF CASES) 
(1) Allorney's (Fa Nam lam 
and Telephone tearben 
Robert C. Josef 
Esq./Katherine W. Ezell, Esq. 
Podhurst Ossetic, M. 
25 W. Elegies St., Suite 800 
Miami FT vim 
OAS ea/ Sans 
(d)Check County Where Action Arose. 7MIAMI. DAM 
1 o ON ROE ^I OR 
DEFENDANTS 
Jeffrey Epstein 
County of Resadence of El* Lined Defendant 
West Palm Beach 
042 US PLAINTIFF f• 
•ors. 
LANDCONOEMNATION 
WikaglIQ 
ACT 
LAND INVOLVED. 
Al77010 0111(sana 
lack A. Goldberger. Esq., Atterburi Goldberger, et al.. 250 S. 
ti 
1 2009 
• 
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PAW BEACH 
MARTIN 0 Sr. LUCIE I, INTVERDWIELA 110111111043E• 
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(knee,Orizemage
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III. C TIZENSHIP OF PRINCIPAL PARTIESPlace al 04" vs One Boa rot PemenIT 
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PERSONAL INJURY 
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0 370 Moon Vebak 
0 
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O 412 Aimee 21 USC 158 
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0 160 Sic/Midas' Suits 
0 190 Other Cessna 
0 195 Coronet Product 1 stony 
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191 Fotedmn of Infonnumn 
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CIVIL RIGHTS 
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V. ORIGIN 
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Transferral from 
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1 
2 
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0 
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06 
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Uwe VI Morn 
Reopened 
DPOCID) 
I thorium 
Appeal to Diu at 
7 
Judge from 
M3.sincc 
ludernent 
VI. RELATED/RE-FILED 
CASE(S). 
(See 
,ease pp' 
a) Re-filed Case Cl YES 0 NO 
JUDGE Kenneth A. Marra 
b) Related Cases OYES 0 NO 
DOCKET See Attached 
NUMBER ' 
VII. CAUSE OF 
ACTION 
Ctie the LI S. Civa Statute under whsh you are filing and Write a Doe( Stumm of Cause (Do sot Ole jot( id k 'Joe el I te fu «I seem 
dhenky): 
18 U.S.C. 2255 (Predicate Statutes 18 U.S.C. 2422(b), 2423(b). 242.3(e). 2231. 2232, 2252A(aX 
2252A(g)( I ) 
LENGTH OF TRIAL .Bs4 
days estimated (for both odes lo ley ewe case) 
VIII. REQUESTED IN 
O CHE.CKIF 
11 IS A CLASS ACTION 
DEMANDS 
CHECK YESunlytfdenndcd in complaint 
COMPLAINT: 
UNDER F. 
23 
JL'RY DEMAND: 
RI Yes r No 
ABOVE INFORMATION IS TREE & CORRECT TO 
THE. BEST OF MV KNOWLEDGE. 
Ski( TI
{ 
RI Ot ‘TTORNLY 
Pir( 
LA) • 
DAB 
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AMOV4T1:1 
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2) 
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ovle /or/ 
EFTA00621426

B.Ft 
Doc 1603-1 
Filed 04/08/11 
Page 28 of 28 
Case 9:0Wliagaita R uocument I 
Entered on FLSD Docket 05/04/2009 Page 27 of 27 
• 
• 
• 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
WEST PALM BEACH DIVISION 
ATTACHMENT TO CIVIL COVER SHEET 
FOR: Jane Doe HYL.v. Jeffrey Epstein 
VI: 
RELATED/RE-FIELD CASE(S): 
08-80069 
08-80119 
08-80232 
08-80380 
08-80381 
08-08804 
08-80811 
08-80893 
08-80993 
08-80994 
08-80469 
09-80591 
EFTA00621427