EFTA01107189

Case 9:09-cv-80656-KAM Document 1 
Entered on FLSD Docket 05/04/2009 Page 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 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 
21 
Podhurst Orseck, PA. 
25 West Flagler Street Suite 800, Miami, FL 33130, Miami 305.158.2800 Fax 305358.2182 • Fort Lauderdale 954.463.4346 
www.podMirst.com 
EFTA01107209

Case 9:09-cv-80656-KAM Document 1 
Entered on FLSD Docket 05/04/2009 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 Pornoeraphv pursuant to 18 U.S.C. & 2255 in 
Violation of 18 U.S.C. 4 2252Ma)(1)1 
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(a)(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 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 
22 
Podhurst Orseck, P.A. 
25 West Flagkr Street, Suite 800, Miami, FL 33130, Miami 305358.2800 Fax 305358.2382 • Fort Lauderdale 951.463.4346 
www.poclhurstcom 
EFTA01107210

Case 9:09-cv-80656-KAM Document 1 
Entered on FLSD Docket 05/0412009 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 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 NINE 
(Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to 18 U.S.C. 
2255 in Violation of 18 U.S.C. & 2252M2)1 
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(gX2), 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(AXaX1)), and Chapter 117 (transportation for illegal 
sexual activity in violation of 18 U.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 Orseck, P.A. 
25 West Hagler Street Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 3053582382 • Fort Lauderdale 954.163.4346 
www.podhursteom 
EFTA01107211

Case 9:09-cv-80656-KAM Document 1 
Entered on FLSD Docket 05/04/2009 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 1, 2009 
ktta 
Pirs44—art,-.6. _12 
Kul E 
Robert C. Josefsbferg, Bar No. 0408503
Katherine W. Ezell, Bar No. 114771 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 800 
Miami, Florida 33130 
(305) 358-2800 
(305) 358-2382 (fax) 
riosefsberia,podhurst.com 
24 
Podhurst Orseck, P.A. 
25 West Flagler Street Suite SOO, Miami. FL 33130, Miami 305358.2300 Fax 305358.2382 • Fort Lauderdale 954.463.4346 I 
www.podlutratcont 
EFTA01107212

Case 9:09-cv-80656-KAM Document 1 
Entered on FLSD Docket 05/04/2009 Page 25 of 27 
[email protected] 
Attorneys for Plaintiff 
DEMAND FOR JURY TRIAL 
Plaintiff demands to have her case tried before a jury. 
lioLtA 
i,•_14‘41C' 
Robert C. Joseftherg, Bar No. 040856 
Katherine W. Ezell, Bar No. 114771 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 800 
Miami, Florida 33130 
(305) 358-2800 
(305) 358-2382 (fax) 
rjosefsbergla.podhurst.com 
kezellapodhurst.com 
Attorneys for Plaintiff 
25 
Podhurst Ors. eck, P.A. 
25 West Flagler Street. Suite 800, Miami, FL 33130, Miami 305358.2800 Fax 305.3582382 • Fort Lauderdale 954.463.4346 
www.podhurst.com 
EFTA01107213

Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 0504.-2009 Page 26 of 27 
*US 44 (Rev. 11/05) 
CIVIL COVER SHEET 
The JS 44 civil cover Shed and the information contained herein neither replace nor supplement the filing and Service of pleadinp. or dher papersas required by law, except as provided 
by load ivies of coun. This lona, approved by the Judicial Conference of the United States i Seotanber 1974. is reamed for the use of the Ckrk of Court for the corneae of initiating 
the civil docket shed. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM,) 
NOTICE: Attorneys MUST Indicate All Re-Bled Cases Below. 
I. (a) PLAINTIFFS 
Jane Doe No. 102 
(b) County of Residence of First Listed Plaintiff 
West Palm Beach 
(EXCEPT IN US. PLAINTIFF CASES) 
(C) Attorney's (Elm Name. Address. std Telephone Noreen 
Robert C. Josefsberg, Esq./Katherine W. Ezell, Esq. 
Podhurst Orseck, P.A. 
25 W. Flagler St., Suite 800 
Miami FI nun 
OR— C/ — 806S (0 
Id) Check County Where Action Arose 
MI 5511 Dal)) 
Mon ROI 
II. BASIS OF JURISDICTION 
disc Jo 
(kit Box only 
1-1 I IrS. Ginertunent 
rfl I 
Federal Question 
Plateau 
ICS Gosemment Not a Party) 
0 2 U.S. lientounent 
Mien/Sim 
Sta
1 V)) 
73 4 
Dreamy 
(Inform Citizenship of Panics in hem III) 
• 
DEFENDANTS 
Jeffrey Epstein 
County of Residence of First Listed Defendant 
West Palm Beach 
(IN U.S. PLAINTIFECAS" CedLul  
 
NOTE: IN LAND CONDEMNATION (Vaal*JJ2 
11'k 
LAND INVOLVED. 
! INTAKE. 
+A TC
Jack A. Goldberger, Esq., AtterburX Goldberger, et al.. 250 S. 
MAY 
1 2009 
, 
Australian Ave., 81400. West PalmiBeaeh
eixp
EFE0140.
,to rnobett 
D.0 
O MARTIN O ST. LUCIE 
INDISCRTWF LAI EITIMICHCA 
HIGHLANDS 
Atlorneya of Known) 
D IS PALM BEACH 
dt.# 
III. CITIZENSHIP OF PRINCIPAL PARTIEStowe an -X-  M Om Box for Plaintiff 
tFor DiserfflY OM" (k0 21
PTF 
DEE 
and One Box for Defatlant) 
PTF 
DEF.
Cilium of ibis Star 
rr 
I 
Iniorporated oe Principal Fire 
of Badness In This State 
1 
4 
14 
Citizen of. nother Stale 
0 
2 
O 2 
Innumerated and Principal Place 
of BUSITC13 In Another State 
O 
5 
0 
S 
Citizen or Subject of a 
1 
3 
0 
3 
Foreissi Nation 
0 
6 
0 6 
Foreign Country 
I 
coAlAwri 
TO
FORFEJTURE/PFNAITY 
imMatunrY 
OTHER STATUTES 
I 
110 trauma 
120 Marine 
130 Milk, Act 
140 Negotiable rostrums-Ili 
150 Roar. try of Os dwayment 
a Enforcement of luddnent 
151 Medicare Act 
132 Recovery of Defaulted 
Student Loans 
(Excl. %terrain) 
0 133 Recovery of Ovaparnero 
of %Mena &oaks 
0 160 Stockholders' Stab 
0 190 Other Contract 
0 195 Contract Product Liability 
O 196 Franchise 
PERSONAL INJURY 
PERSONAL INJURY 
0 310 Airplay 
0 
362 Personal Injury • 
0 315 Abram* Prague, 
Med. Malpradiee 
Liability 
O 365 Personal Ingo - 
0 320 Assault. Lad a 
Prod*, Liability 
Slander 
O 368 Asbestos PCISONI 
71 Ile federal lintpdoyas* 
Inbay Padua 
Liability 
Ideality 
0 340 Marine 
PERSONAL PROPERTY 
0345 Maine Product 
0 
370 011er Fnm1 
Liability 
3 
371 Taub in Leaded 
0 350 Motor Vehick 
rt ISO Other Personal 
0 153 Motor Vdticle 
Property Damage 
Product liability 
0 
385 Property Damage 
O 360 OtIrr Personal 
Product liability 
intact' 
0 
610 Agriculture 
0 
620 Other Runt R Drug 
3 
623 Drug Related Scirum 
of Property 21 IrSC 88 I 
0 630 Liquor Laws 
0 640 R R. & Truck 
0 630 Airline Rep. 
0 660 Occupational 
SafayiNealtb 
3 690 Other 
0 422 Appal U USC 158 
fll 423 Withdrawal 
28 USC 137 
400 Slate Rappanionmem 
410 ArdlINSI 
430 Banks and Banking 
430 Cotrantme 
460 Detonation 
470 Racketeer Influenced and 
Comp Organizations 
480 Consumer Credit 
4900'2:MS6i TV 
810 Sekctive Service 
850 Seaga iesCommoditiew 
Exchanr 
875 Customer Chilkmir 
12 USE 3410 
Maher Statutory Actions 
891 Agricultural Acts 
892 Economic Stabilisation ACI 
893 Emironmental Manus 
894 Energy Allocation Ad 
895 Freedom of Infonnaneo 
Act 
91)0Appeal of Foe Dmenntremon 
Lida Equal ACcess 
toJustice 
0 
930 Coaninutonality of 
State Statutes 
Miii:Itle All irtliti: In 
3 730 Coppices 
1 830 Patent 
CI 840 Trademark 
LADOR 
SOCIAL SECURITY 
0 
710 Fanlab& Standards 
Act 
0 
720 Labor Mgmt Relations 
0 
730 LaborMgmLitcponing 
St Disclosure Act 
0 
740 Rahway Labor Act 
0 
790 Onlyr Lahr Litigation 
0 
791 Tirpt Refine 
Securn) Act 
0 861 DIA11393M 
0 862 Black Lune (923) 
0 863 DIWCIDIWW (405(p)) 
0 864 SSW Title Zvi 
0 865 RSI (405(g1) 
FEDERAL TAX SUITS 
I 
REAL PROPERTY 
CIVIL RIGHTS 
PRISONER PETITIONS 
0 870 fates (VS. Plaintiff 
or Delon:Ural 
O 871 IRS-third Party 
26 USC 7600 
0 210 lad Coulcinnation 
0 220 Foreclosure 
0 230 Rent Lose tb ESMIllai 
0 240 Tons to I amt 
O 245 Ton Product Liability 
O 290 All Other Real Property 
0 441 Voting 
0 442 Employment 
0 443 Housing,
A0:01111110611005 
0 444 Welfart 
3 445 Amer. wiDitabilitits - 
Earoyinem 
3 446 Amer. *Inabilities - 
Other 
3 440 Other Civil Rights 
1 
510 /dm ion to Vacate 
Sentence 
Habeas Corpus:. 
1 
530 General 
1 
535 Death Penalty 
1 
340 Mandamus & Other 
0 
550 Civil Rights 
0 
353 Prism Condition 
V. ORIGIN 
vi 
I Original
P
(Place a -X" in One Boa Only) 
0 
2 Removed from 
CI 3 
Ro-filed- 
0 
4 Reinstated or O 5 amour 
Trans errdiaseiaed from 
0 6 Multidistrict 
St to Court 
,see VI below) 
(namesy) 
Litigation 
Appeal to District 
CI 
JiAge from 
' 
Magistrate 
lodgment 
VI. RELATED/RE-FILED 
CASE(S). 
(See isubvaions 
leCeel Pate): 
a) Re-filed Case 0 YES 0 NO 
JUDGE Kenneth A. Marta 
b) Related Cases OYES CI NO 
DOCKET See Attached 
NUMBER 
VII. CAUSE OF 
ACTION 
Cie the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do Dot cite jurisdictional statutes 13 IlltS1 
amenity): 
18 U.S.C. 2255 (Predicate Statutes 18 U.S.C. 2422(b). 2423(b). 2423(e), 2251, 2252. 2252A(a)( I), 2252A(g)( 1) 
LENGTH OF TRIAL via 4 
days estimated (for both sides to try entire rase/ 
O 
CHECK IF THIS IS A CLASS ACTION 
UNDER ER.C.F. 23 
VIII. REQUESTED IN 
COMPLAINT: 
DEMAND S 
CHECK YES only if demanded n complaint 
JURY DEMAND: 
Pi Yea IS No 
ABOVE INFORMATION IS TRUE & CORRECT TO 
TIIE BEST OF MY KNOWLEDGE 
SIO
TUREOIAITORNET OF RICO 
FtEriLt_ 
DATE 
R OIFICE USE my, 
&moue 
Si) 
RECEIPTSrizetk32)
DC1O I /4.3(7 
EFTA01107214

Case 9:09-cv-80656-KAM Document 1 
Entered on FLSD Docket 05/04/2009 Page 27 of 27 
UNITED STATES DISTRICT COURT 
SOUTIIERN DISTRICT OF FLORIDA 
WEST PALM BEACH DIVISION 
ATTACHMENT TO CIVIL COVER SHEET 
FOR: Jane Doe 10tv. 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 
EFTA01107215