EFTA00175214

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 49 of 91 
mi. vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
loss of the capacity to enjoy life. These Injuries are permanent in nature and the 
Plaintiff, 
., will continue to suffer these losses in the future. 
WHEREFORE, the Plaintiff, le., 
demands judgment against the Defendant, 
JEFFREY EPSTEIN, for 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. 
COUNT XVII 
Cause of Action Pursuant to 18 USC 42255 
February of 2003 — incident 1 
116. The Plaintiff, 
., adopts and realleges paragraphs 1 through 19 
above. 
117. In February of 2003, 
. again returned to JEFFREY EPSTEIN'S 
residence at his request. On this occasion, JEFFREY EPSTEIN directed 
to fully 
undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled 
the breasts and buttocks of the then minor 
At the conclusion of the massage, 
JEFFREY EPSTEIN masturbated himself in 
.'s presence. JEFFREY EPSTEIN 
paid 
. in excess of $200 for this encounter. 
49 
EFTA00175394

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 51 of 91 
Mt. 
vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRAJJOHNSON 
First Amended Complaint 
120. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the 
same position as if he had been tried and convicted of the sexual offenses committed 
against the Plaintiff, 1.1., and as such he must effectively admit liability unto the 
Plaintiff,. 
121. As a direct and proximate result of the offenses enumerated in Title 18, 
United States Code, Section 2255, being committed against the then minor Plaintiff, 
mi., has in the past suffered, and will In the future suffer, physical injury, pain and 
suffering, emotional distress, psychological trauma, mental anguish, humiliation, 
embarrassment, loss of self-esteem, loss of dignity, Invasion of her privacy and other 
damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and 
coercing her into a perverse and unconventional way of life for a minor. The then minor 
Plaintiff incurred medical and psychological expenses and the Plaintiff, 
M
.
,
 
will in 
the future suffer additional medical and psychological expenses. The 
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, IIII., will continue to suffer these losses in the future. 
WHEREFORE, the Plaintiff, 
., demands judgment against the Defendant, 
JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount 
provided by law, punitive damages, attorney's fees, costs, and such other and further 
51 
EFTA00175395

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 53 of 91 
MI vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
if Mr. Epstein had been tried federally and convicted of an enumerated offense. For 
purposes of implementing this paragraph, the United States shall provide Mr. Epstein's 
attorneys with a list of individuals whom it was prepared to name In an indictment as 
victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this 
provision, including any authority determining evidentiary burdens if any a Plaintiff must 
meet, shall consider that it is the Intent of the parties to place these identified victims in 
the same position as they would have been had Mr. Epstein been convicted at trial. No 
more; no less." 
125. The Plaintiff, 
., was a victim of one or more offenses enumerated In 
Title 18, United States Code, Section 2255, and as such asserts a cause of action 
against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United 
States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the 
United States Government. 
126. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the 
same position as if he had been tried and convicted of the sexual offenses committed 
against the Plaintiff, 
., and as such he must effectively admit liability unto the 
Plaintiff, 
127. As a direct and proximate result of the offenses enumerated in Title 18, 
United States Code, Section 2255, being committed against the then minor Plaintiff, 
C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and 
53 
EFTA00175396

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 55 of 91 
Ilkivs. Epstein, et al. 
Case o.; 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
129. In March of 2003, 
again returned to JEFFREY EPSTEIN'S 
residence at his request. On this occasion, JEFFREY EPSTEIN directed 
to fully 
undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled 
the breasts and buttocks of the then minor 
At the conclusion of the massage, 
JEFFREY EPSTEIN masturbated himself in 
's presence. JEFFREY EPSTEIN 
paid 
. in excess of $200 for this encounter. 
130. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and 
in exchange for the Federal Government not prosecuting the Defendant for numerous 
federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an 
agreement with the Federal Government to the following: "Any person, who while a 
minor, was a victim of an offense enumerated in Title 18, United States Code, Section 
2255, will have the same rights to proceed under section 2255 as she would have had, 
if Mr. Epstein had been tried federally and convicted of an enumerated offense. For 
purposes of implementing this paragraph, the United States shall provide Mr. Epstein's 
attorneys with a list of individuals whom it was prepared to name in an indictment as 
victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this 
provision, including any authority determining evidentiary burdens if any a Plaintiff must 
meet, shall consider that it is the intent of the parties to place these identified victims in 
the same position as they would have been had Mr. Epstein been convicted at trial. No 
more; no less." 
55 
EFTA00175397

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 57 of 91 
vs. Epstein, et al. 
ase No.: 08-CV-80811-CIV-MARRNJOHNSON 
First Amended Complaint 
loss of the capacity to enjoy life. These injuries are permanent in nature and the 
Plaintiff, 
, will continue to suffer these losses in the future. 
WHEREFORE, the Plaintiff, 
., demands judgment against the Defendant, 
JEFFREY EPSTEIN, for 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. 
COUNT XX 
Cause of Action Pursuant to 18 USC §2265 
March of 2003 — Incident 2 
134. The Plaintiff, 
., adopts and realleges paragraphs 1 through 19 
above. 
135. For the second time in March of 2003, 
again returned to JEFFREY 
EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed 
to fully undress and to provide him with a massage. Defendant, JEFFREY 
EPSTEIN, fondled the breasts and buttocks of the then minor 
At the conclusion 
of the massage, JEFFREY EPSTEIN masturbated himself in 
.'s presence. 
JEFFREY EPSTEIN paid 
in excess of $200 for this encounter. 
57 
EFTA00175398

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 59 of 91 
vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
138. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the 
same position as if he had been tried and convicted of the sexual offenses committed 
against the Plaintiff, III., 
and as such he must effectively admit liability unto the 
139. As a direct and proximate result of the offenses enumerated in Title 18, 
United States Code, Section 2255, being committed against the then minor Plaintiff, 
is., has in the past suffered, and will in the future suffer, physical injury, pain and 
suffering, emotional distress, psychological trauma, mental anguish, humiliation, 
embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other 
damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and 
coercing her into a perverse and unconventional way of life for a minor. The then minor 
Plaintiff Incurred medical and psychological expenses and the Plaintiff, ME., will in 
the future suffer additional medical and psychological expenses. The Plaintiff, Mi
n
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, 
., will continue to suffer these losses in the future. 
WHEREFORE, the Plaintiff, 
, demands judgment against the Defendant, 
JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount 
provided by law, punitive damages, attorney's fees, costs, and such other and further 
59 
EFTA00175399

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 61 of 91 
vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
if Mr. Epstein had been tried federally and convicted of an enumerated offense. For 
purposes of implementing this paragraph, the United States shall provide Mr. Epstein's 
attorneys with a list of individuals whom it was prepared to name in an Indictment as 
victims of an enumerated offense by Mr. Epstein. My judicial authority interpreting this 
provision, including any authority determining evidentiary burdens if any a Plaintiff must 
meet, shall consider that it is the intent of the parties to place these identified victims in 
the same position as they would have been had Mr. Epstein been convicted at trial. No 
more; no less? 
143. The Plaintiff, 
., was a victim of one or more offenses enumerated in 
Title 18, United States Code, Section 2255, and as such asserts a cause of action 
against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United 
States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the 
United States Government. 
144. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is In the 
same position as if he had been tried and convicted of the sexual offenses committed 
against the Plaintiff, 
., and as such he must effectively admit liability unto the 
Plaintiff, 
145. As a direct and proximate result of the offenses enumerated in Title 18, 
United States Code, Section 2255, being committed against the then minor Plaintiff, 
., has in the past suffered, and will in the future suffer, physical injury, pain and 
61 
EFTA00175400

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 63 of 91 
vs. Epstein, et al. 
Case No.: 08-CV-80811-C IV-MARRA/JOH NSON 
First Amended Complaint 
147. For the second time in April of 2003, 
again returned to JEFFREY 
EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed 
to fully undress and to provide him with a massage. Defendant, JEFFREY 
EPSTEIN, fondled the breasts and buttocks of the then minor 
. At the conclusion 
of the massage, JEFFREY EPSTEIN masturbated himself in 
.'s presence. 
JEFFREY EPSTEIN paid 
. in excess of $200 for this encounter. 
148. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and 
in exchange for the Federal Government not prosecuting the Defendant for numerous 
federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an 
agreement with the Federal Government to the following: "Any person, who while a 
minor, was a victim of an offense enumerated in Title 18, United States Code, Section 
2255, will have the same rights to proceed under section 2255 as she would have had, 
If Mr. Epstein had been tried federally and convicted of an enumerated offense. For 
purposes of Implementing this paragraph, the United States shall provide Mr. Epstein's 
attorneys with a list of individuals whom it was prepared to name in an indictment as 
victims of an enumerated offense by Mr. Epstein. Any judicial authority Interpreting this 
provision, Including any authority determining evidentiary burdens if any a Plaintiff must 
meet, shall consider that it is the intent of the parties to place these identified victims in 
the same position as they would have been had Mr. Epstein been convicted at trial. No 
more; no less." 
63 
EFTA00175401

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 65 of 91 
I
vs. Epstein, et al. 
PNo.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
loss of the capacity to enjoy life. These injuries are permanent in nature and the 
Plaintiff, 
will continue to suffer these losses in the future. 
WHEREFORE, the Plaintiff, MB, demands judgment against the Defendant, 
JEFFREY EPSTEIN, for 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. 
COUNT XXIII 
Cause of Action Pursuant to 18 USC 82255 
May of 2003 — Incident 1 
152. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 
abovb. 
153. In May of 2003, 
again returned to JEFFREY EPSTEIN'S residence 
at his request. On this occasion, JEFFREY EPSTEIN directed 
to fully undress 
and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the 
breasts and buttocks of the then minor 
At the conclusion of the massage, 
JEFFREY EPSTEIN masturbated himself in all's 
presence. JEFFREY EPSTEIN 
paid 
in excess of $200 for this encounter. 
65 
EFTA00175402

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 67 of 91 
la
ys. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
156. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the 
same position as if he had been tried and convicted of the sexual offenses committed 
against the Plaintiff, MI., 
and as such he must effectively admit liability unto the 
157. As a direct and proximate result of the offenses enumerated in Title 18, 
United States Code, Section 2255, being committed against the then minor Plaintiff, 
mi., has in the past suffered, and will in the future suffer, physical injury, pain and 
suffering, emotional distress, psychological trauma, mental anguish, humiliation, 
embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other 
damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and 
coercing her into a perverse and unconventional way of life for a minor. The then minor 
Plaintiff incurred medical and psychological expenses and the Plaintiff, 
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, 
., will continue to suffer these losses in the future. 
WHEREFORE, the Plaintiff, 
, demands judgment against the Defendant, 
JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount 
provided by law, punitive damages, attorney's fees, costs, and such other and further 
67 
EFTA00175403

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 69 of 91 
. vs. Epstein, et al 
ase No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
if Mr. Epstein had been tried federally and convicted of an enumerated offense. For 
purposes of implementing this paragraph, the United States shall provide Mr. Epstein's 
attorneys with a list of individuals whom It was prepared to name in an indictment as 
victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this 
provision, including any authority determining evidentiary burdens if any a Plaintiff must 
meet, shall consider that it is the intent of the parties to place these identified victims in 
the same position as they would have been had Mr. Epstein been convicted at trial. No 
more; no less." 
161. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in 
Title 18, United States Code, Section 2255, and as such asserts a cause of action 
against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United 
States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the 
United States Government. 
162. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the 
same position as if he had been tried and convicted of the sexual offenses committed 
against the Plaintiff, 
., and as such he must effectively admit liability unto the 
Plaintiff, 
163. As a direct and proximate result of the offenses enumerated in Title 18, 
United States Code, Section 2255, being committed against the then minor Plaintiff, 
., has in the past suffered, and will in the future suffer, physical injury, pain and 
69 
EFTA00175404

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 71 of 91 
vs. Epstein, et al. 
08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
165. In June of 2003, 
again returned to JEFFREY EPSTEIN'S 
residence at his request. On this occasion, JEFFREY EPSTEIN directed 
to fully 
undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled 
the breasts and buttocks of the then minor IN 
At the conclusion of the massage, 
JEFFREY EPSTEIN masturbated himself in 
's presence. JEFFREY EPSTEIN 
paid 
in excess of $200 for this encounter. 
166. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and 
in exchange for the Federal Government not prosecuting the Defendant for numerous 
federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an 
agreement with the Federal Government to the following: "Any person, who while a 
minor, was a victim of an offense enumerated in Title 18, United States Code, Section 
2255, will have the same rights to proceed under section 2255 as she would have had, 
if Mr. Epstein had been tried federally and convicted of an enumerated offense. For 
purposes of implementing this paragraph, the United States shall provide Mr. Epstein's 
attorneys with a list of individuals whom it was prepared to name in an indictment as 
victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this 
provision, including any authority determining evidentiary burdens if any a Plaintiff must 
meet, shall consider that it is the intent of the parties to place these identified victims in 
the same position as they would have been had Mr. Epstein been convicted at trial. No 
more; no less." 
71 
EFTA00175405

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 73 of 91 
Mt vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
loss of the capacity to enjoy life. These injuries are permanent in nature and the 
Plaintiff..., will continue to suffer these losses in the future. 
WHEREFORE, the Plaintiff, lilt, 
demands judgment against the Defendant, 
JEFFREY EPSTEIN, for 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. 
COUNT XXVI 
Cause of Action Pursuant to 18 USC 
June of 2003 — Incident 2 
170. The Plaintiff, 
., adopts and realleges paragraphs 1 through 19 
above. 
171. For the second time in June of 2003, 
again returned to JEFFREY 
EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed 
to fully undress and to provide him with a massage. Defendant, JEFFREY 
EPSTEIN, fondled the breasts and buttocks of the then minor 
At the conclusion 
of the massage, JEFFREY EPSTEIN masturbated himself in 
.'s presence. 
JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter. 
73 
EFTA00175406

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 75 of 91 
vs. Epstein, et al. 
08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
174. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the 
same position as if he had been tried and convicted of the sexual offenses committed 
against the Plaintiff, 
,
 
and as such he must effectively admit liability unto the 
Plaintiff, MI 
175. As a direct and proximate result of the offenses enumerated in Title 18, 
United States Code, Section 2255, being committed against the then minor Plaintiff, 
I IIII, has in the past suffered, and will in the future suffer, physical injury, pain and 
suffering, emotional distress, psychological trauma, mental anguish, humiliation, 
embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other 
damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and 
coercing her into a perverse and unconventional way of life for a minor. The then minor 
Plaintiff incurred medical and psychological expenses and the Plaintiff, 
will in 
the future suffer additional medical and psychological expenses. The Plaintiff, MI, 
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, 
will continue to suffer these losses in the future. 
WHEREFORE, the Plaintiff, IS, 
demands judgment against the Defendant, 
JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount 
provided by law, punitive damages, attorney's fees, costs, and such other and further 
75 
EFTA00175407

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 77 of 91 
MIvs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
if Mr. Epstein had been tried federally and convicted of an enumerated offense. For 
purposes of implementing this paragraph, the United States shall provide Mr. Epstein's 
attorneys with a list of individuals whom it was prepared to name in an indictment as 
victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this 
provision, including any authority determining evidentiary burdens if any a Plaintiff must 
meet, shall consider that it is the intent of the parties to place these identified victims in 
the same position as they would have been had Mr. Epstein been convicted at trial. No 
more; no less." 
179. The Plaintiff, 
, was a victim of one or more offenses enumerated in 
Title 18, United States Code, Section 2255, and as such asserts a cause of action 
against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United 
States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the 
United States Government. 
180. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the 
same position as if he had been tried and convicted of the sexual offenses committed 
against the Plaintiff, 
., and as such he must effectively admit liability unto the 
Plaintiff, 
181. As a direct and proximate result of the offenses enumerated in Title 18, 
United States Code, Section 2255, being committed against the then minor Plaintiff, 
., has in the past suffered, and will in the future suffer, physical injury, pain and 
77 
EFTA00175408

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 79 of 91 
vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
183. For the second time in July of 2003,... again returned to JEFFREY 
EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed 
a
to fully undress and to provide him with a massage. Defendant, JEFFREY 
EPSTEIN, fondled the breasts and buttocks of the then minor... 
At the conclusion 
of the massage, JEFFREY EPSTEIN masturbated himself in 
presence. 
JEFFREY EPSTEIN paid. 
in excess of $200 for this encounter. 
184. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and 
in exchange for the Federal Government not prosecuting the Defendant for numerous 
federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an 
agreement with the Federal Government to the following: "Any person, who while a 
minor, was a victim of an offense enumerated in Title 18, United States Code, Section 
2255, will have the same rights to proceed under section 2255 as she would have had, 
if Mr. Epstein had been tried federally and convicted of an enumerated offense. For 
purposes of implementing this paragraph, the United States shall provide Mr. Epstein's 
attorneys with a list of individuals whom it was prepared to name in an Indictment as 
victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this 
provision, including any authority determining evidentiary burdens if any a Plaintiff must 
meet, shall consider that it is the intent of the parties to place these identified victims in 
the same position as they would have been had Mr. Epstein been convicted at trial. No 
more; no less." 
79 
EFTA00175409

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 81 of 91 
vs. Epstein, et al. 
08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
loss of the capacity to enjoy life. These injuries are permanent in nature and the 
Plaintiff, 
, will continue to suffer these losses in the future. 
WHEREFORE, the Plaintiff, 
demands judgment against the Defendant, 
JEFFREY EPSTEIN, for 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. 
COUNT XXIX 
Cause of Action Pursuant to 18 USC 82255 
August of 2003 — Incident 1 
188. The Plaintiff, MI, 
adopts and realleges paragraphs 1 through 19 
above. 
189. In August of 2003, MI 
again returned to JEFFREY EPSTEIN'S 
residence at his request On this occasion, JEFFREY EPSTEIN directed 
to fully 
undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled 
the breasts and buttocks of the then minor 
At the conclusion of the massage, 
JEFFREY EPSTEIN masturbated himself in 
presence. JEFFREY EPSTEIN 
paid 
in excess of $200 for this encounter. 
81 
EFTA00175410

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 83 of 91 
vs. Epstein, et al. 
08-CV-80811-CIV-MARRAJJOHNSON 
First Amended Complaint 
192. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the 
same position as if he had been tried and convicted of the sexual offenses committed 
against the Plaintiff, 
and as such he must effectively admit liability unto the 
Plaintiff, MI. 
193. As a direct and proximate result of the offenses enumerated in Title 18, 
United States Code, Section 2255, being committed against the then minor Plaintiff, 
has in the past suffered, and will in the future suffer, physical injury, pain and 
suffering, emotional distress, psychological trauma, mental anguish, humiliation, 
embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other 
damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and 
coercing her into a perverse and unconventional way of life for a minor. The then minor 
Plaintiff incurred medical and psychological expenses and the Plaintiff, is , 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, 
, will continue to suffer these losses in the future. 
WHEREFORE, the Plaintiff, 
., demands judgment against the Defendant, 
JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount 
provided by law, punitive damages, attorney's fees, costs, and such other and further 
83 
EFTA00175411

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 85 of 91 
vs. Epstein, et al. 
08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
if Mr. Epstein had been tried federally and convicted of an enumerated offense. For 
purposes of implementing this paragraph, the United States shall provide Mr. Epstein's 
attorneys with a list of individuals whom it was prepared to name in an indictment as 
victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this 
provision, including any authority determining evidentiary burdens if any a Plaintiff must 
meet, shall consider that it is the intent of the parties to place these identified victims in 
the same position as they would have been had Mr. Epstein been convicted at trial. No 
more; no less." 
197. The Plaintiff, 
, was a victim of one or more offenses enumerated in 
Title 18, United States Code, Section 2255, and as such asserts a cause of action 
against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United 
States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the 
United States Government. 
198. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the 
same position as if he had been tried and convicted of the sexual offenses committed 
against the Plaintiff, 
and as such he must effectively admit liability unto the 
Plaintiff, C.M.A. 
199. As a direct and proximate result of the offenses enumerated in Title 18, 
United States Code, Section 2255, being committed against the then minor Plaintiff, 
has in the past suffered, and will in the future suffer, physical injury, pain and 
85 
EFTA00175412

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 87 of 91 
vs. Epstein, et al. 
08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
201. Between late May or early June of 2002 and August of 2003, Defendant, 
JEFFERY EPSTEIN, engaged in dozens of illegal and depraved sexual acts against 
Plaintiff, 
202. 
As described more fully in the above paragraphs, Defendant, JEFFERY 
EPSTEIN, intentionally inflicted harmful and/or offensive sexual contact on the person of 
203. Defendant, JEFFREY EPSTEIN'S, tortuous commission of sexual battery 
upon III 
were done willfully and maliciously. 
204. As a direct and proximate result of JEFFREY EPSTEIN'S battery on 
she has suffered and will continue to suffer severe and permanent traumatic 
injuries, including mental, psychological and emotional damages. 
WHEREFORE, the Plaintiff, 
demands judgment against the Defendant, 
JEFFREY EPSTEIN, for 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. 
COUNT XXXII 
Conspiracy to Commit Tortious Assault Against Defendant, 
205. Plaintiff incorporates into this count the allegations of paragraphs 1 
through 19. 
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