EFTA00175214

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 9 of 91 
vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
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 PlaintiffM., 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 II 
Cause of Action Pursuant to 18 USC §2255 
June 2002- Incident 2 
26. 
The Plaintiff, 
, adopts and realleges paragraphs 1 through 19 
above. 
27. 
Approximately one week after the first incident, 
. received a 
telephone call from JEFFREY EPSTEIN requesting that she return to his residence. On 
this occasion, JEFFREY EPSTEIN directed 
to undress to her brassiere and 
underwear and to provide him with a massage. At the conclusion of the massage, 
JEFFREY EPSTEIN masturbated himself in 
's presence. JEFFREY EPSTEIN 
paid 
$300 for this encounter. 
9 
EFTA00175374

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 11 of 91 
IIIII. vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
30. 
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, Ill.., 
and as such he must effectively admit liability unto the 
Plaintiff, MI. 
31. 
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, 
, 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 
11 
EFTA00175375

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 13 of 91 
It. vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
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." 
35. 
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. 
36. 
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. 
37. 
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, 
13 
EFTA00175376

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 15 of 91 
. vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
38. 
The Plaintiff, IS, 
adopts and realleges paragraphs 1 through 19 
above. 
39. 
For the second time in July of 2002, 
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. 
40. 
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 
15 
EFTA00175377

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 17 of 91 
C.M.A. vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRNJOHNSON 
First Amended Complaint 
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 
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 V 
Cause of Action Pursuant to 18 USC §2255 
August of 2002 — Incident 1 
44. 
The Plaintiff, 
., adopts and realleges paragraphs 1 through 19 
above. 
45. 
In August of 2002, 
. 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. 
17 
EFTA00175378

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 19 of 91 
al . vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
48. 
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,' 
49. 
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, 
at , 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 
19 
EFTA00175379

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 21 of 91 
"
vs. Epstein, et al. 
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." 
53. 
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. 
54. 
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, 
55. 
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 
21 
EFTA00175380

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 23 of 91 
!t
vs. Epstein, et al. 
o.: 08-CV-80811-CIV-MARRAJJOHNSON 
First Amended Complaint 
57. 
In September of 2002, 
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. 
58. 
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, shalt 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." 
23 
EFTA00175381

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 25 of 91 
NB. 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,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 
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 VIII 
Cause of Action Pursuant to 18 USC §2266 
September of 2002 — Incident 2 
62. 
The Plaintiff, IIII., 
adopts and realleges paragraphs 1 through 19 
above. 
63. 
For the second time in September of 2002, 
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. 
25 
EFTA00175382

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 27 of 91 
vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
66. 
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 
67. 
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, al, 
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, IIII., will continue to suffer these losses in the future. 
WHEREFORE, the Plaintiff, IIII., 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 
27 
EFTA00175383

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 29 of 91 
. vs. Epstein, et al. 
ase No.: 08-CV-80811-CIV-MARFtA/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." 
71. 
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. 
72. 
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, 
73. 
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 
29 
EFTA00175384

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 31 of 91 
vs. Epstein, et al. 
08-CV-80811-CIV-MARRAIJOHNSON 
First Amended Complaint 
74. 
The Plaintiff, ea, 
adopts and realleges paragraphs 1 through 19 
above. 
75. 
For the second time in October of 2002, 
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 MI 
At the 
conclusion of the massage, JEFFREY EPSTEIN masturbated himself in is 
presence. JEFFREY EPSTEIN paid III 
in excess of $200 for this encounter. 
76. 
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 
31 
EFTA00175385

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 33 of 91 
Elt. 
vs. Epstein, et at. 
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
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 
will continue to suffer these losses in the future. 
WHEREFORE, the 
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 XI 
Cause of Action Pursuant to 18 USC §2255 
November of 2002 — Incident 1 
80. 
The Plaintiff, In, 
adopts and realleges paragraphs 1 through 19 
above. 
81. 
In November of 2002, 
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. 
33 
EFTA00175386

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 35 of 91 
vs. Epstein, et al. 
08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
84. 
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 
Plaintiff, 
85. 
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 
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, In, 
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, MI, 
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 
35 
EFTA00175387

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 37 of 91 
Mt 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." 
89. 
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. 
90. 
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, 
91. 
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 
37 
EFTA00175388

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 39 of 91 
... 
vs. Epstein, et al. 
Case No.: 08-CV-80811-CIV-MARFtA/JOHNSON 
First Amended Complaint 
93. 
In December of 2002, 
.. 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 C.M.A. in excess of $200 for this encounter. 
94. 
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." 
39 
EFTA00175389

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 41 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, mg, 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 XIV 
Cause of Action Pursuant to 18 USC 42255 
December of 2002 — Incident 2 
98. 
The Plaintiff, 
., adopts and realleges paragraphs 1 through 19 
above. 
99. 
For the second time in December of 2002, 
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 I.M.A.'s 
presence. JEFFREY EPSTEIN paid 
. in excess of $200 for this encounter. 
41 
EFTA00175390

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 43 of 91 
vs. Epstein, et al. 
08-CV-80811-CIV-MARRAIJOHNSON 
First Amended Complaint 
102. 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, 
103. 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, MI, 
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, IN, 
will continue to suffer these losses in the future. 
WHEREFORE, the Plaintiff, IN., 
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 
43 
EFTA00175391

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 45 of 91 
vs. Epstein, et at 
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." 
107. 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. 
108. 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, 
109. 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 
45 
EFTA00175392

Case 9:08-cv-80811-KAM 
Document 39 
Entered on FLSD Docket 02/09/2009 
Page 47 of 91 
vs. Epstein, et al. 
ase No.: 08-CV-80811-CIV-MARRA/JOHNSON 
First Amended Complaint 
111. For the second time In January 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 In.'s 
presence. JEFFREY EPSTEIN paid. 
in excess of $200 for this encounter. 
112, 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." 
47 
EFTA00175393