EFTA00183732

Ms. 
June 19, 2009 
Page 7 
Esq. 
Sixth, you raise the issue of a delayed withdrawal of a motion to quash. See Exhibit 1, 
June 15, 2009 Letter at 2-3. There is no motion to quash that still remains pending. The fact that 
the motion was not withdrawn for some time was merely due to an administrative oversight that 
has long been remedied, but at no time did it prejudice the Government in any way. Nor did it 
result from an effort by myself or co-counsel to gain some tactical advantage. Furthermore, no 
effort was made by any counsel to seek a judicial decision on the pending motion. The motion 
had no adverse effect on the Government, and the delay in its withdrawal is legally and factually 
unrelated to the type of material and willful breach that alone could warrant remedies—not least 
of all because Mr. Epstein has suffered irreversible prejudice by complying with the core 
provisions of the NPA. Again, he has been imprisoned, he has pled guilty, he is registered, he 
has paid sums to claimants, all to comply with his obligations under the NPA. 
Seventh, you state that additional issues arose in November regarding the issuance of 
work release to Mr. Epstein. Exhibit 1, June 15, 2009 Letter at 3. We have previously reviewed 
this very matter with you and other individuals in our Office in November 2008. At that time, 
Mr. Roy Black met with you, 
, and 
in Miami to 
review the work release issue. Among other significant documents shown to you, we presented 
you with your own email in which you had previously acknowledged that the sheriff had 
discretion in the matter. See Exhibit 24, July 3, 2008 Email from Assistant U.S. Attorney 
to Michael Gauger ("If Mr. Epstein is truly eligible for the [work release] program, we 
have no objection to him being treated like any other similarly situated prisoner . . ."). 
Furthermore, Mr. Acosta, as already stated, had previously assured me and other counsel that the 
USAO would not interfere in the ordinary implementation of discretionary administrative 
decisions by state or county officials. We believe we were under no obligation (in the NPA or 
anywhere else) to notify you of such discretionary and ordinary state-made decisions, and the 
fact that your Office confirmed that Mr. Epstein was entitled to the same discretionary 
administrative decisions as other similarly situated inmates fundamentally undermines any claim 
that Mr. Epstein breached the NPA in connection with the state and county officials' decision. In 
any event, after thoroughly reviewing and evaluating Mr. Epstein's application, the Palm Beach 
County Sheriff's Office properly exercised its discretion, in full compliance with its stated 
requirements, policies and procedures, to grant Mr. Epstein work release. In addition, after the 
Sheriff's Office received a multi-page letter from you to Captain Sleeth, which recited the very 
allegations of errors on Mr. Epstein's work release application to which you refer in your latest 
letter, each allegation was fully reviewed, and the Sheriff's office found its initial decision 
appropriate. 
Eighth, it is both unreasonable and unjustifiable to hold Mr. Epstein responsible—never 
mind declare him in breach—with regard to Judge McSorley's nunc pro tune order. Exhibit 1, 
June 15, 2009 Letter at 3. Neither Mr. Epstein nor defense counsel had anything to do with and 
certainly no prior knowledge of this order. Defense counsel only learned of it after you brought 
it to our attention. The facts are as follows: the Department of Corrections requires an order 
EFTA00183772

Ms. 
Esq. 
June 19, 2009 
Page 8 
placing someone on community control before the Department of Corrections will supervise that 
person. Judge Pucillo, the retired judge that took Mr. Epstein's plea, inadvertently neglected to 
enter the order placing Mr. Epstein on Community Control 1. When Judge McSorley learned of 
this, she properly entered the order nunc pro tune to the date of the plea. See Exhibit 25, Order 
of ConummaySontrol. If you will note on the 3-page court event form, circled at the top of 
page 2, is M.1" (community control 1). Mr. Epstein was properly placed on community 
control 1 on the day of his plea to begin only after he completes his jail sentence, and the nunc 
pro tunc order simply ratifies the oral pronouncement made by the court at the time of the plea. 
Given that the NPA expressly provides that Mr. Epstein is to serve a sentence of 12 months in 
"community control consecutive to his two terms in county jail," Exhibit 2, NPA ¶ 2(b), your 
assertion that the inclusion of community control "directly contradicted the terms of the" NPA is 
incorrect. 
Finally, the motion to dismiss that was the topic of discussion on June 12 has been 
withdrawn. As indicated in the letter I sent you on June 15, we have adopted an internal 
screening process aimed at eliminating future concerns about anything that reasonably could be 
considered a breach of the NPA. See Exhibit 26, June 15, 2009 Letter from J. Lefkowitz to 
Assistant U.S. Attorney 
. Mr. Epstein has directed all counsel to make certain that no 
filing could be construed as a breach of the NPA. Furthermore, we proposed a supplemental new 
process, as stated in my June 15 letter to you, that would have provided you, if you chose, the 
opportunity to review any such filing before it is submitted to the court so that you may 
determine whether or not it constitutes a breach. 
That being said, I wish to reiterate our firm belief that the NPA allowed Mr. Epstein the 
right to contest litigation whenever an express waiver of all other state, federal or common law 
claims or the right to bring contested litigation in the future was not sufficiently or correctly 
pleaded. As you know, we spent several weeks negotiating the language of the NPA with you 
and Mr. Acosta. We firmly believe that the motion to dismiss that was recently filed (and then 
promptly withdrawn) did not constitute a violation. 
First, Paragraph 8 of the NPA clearly limits those who may benefit from any waivers by 
Mr. Epstein to an "identified individual" who "elects to proceed exclusively under 18 USC 2255, 
and aerees to waive any other claim for damages. whether pursuant to state, federal, or 
moron 
law". Exhibit 2, NPA ¶ 8. More is required of a plaintiff than to simply allege, as did 
Doe 
101, that she "exclusively seeks civil remedies pursuant to 18 USC 2255." Exhibit 27, Amended 
Complaint ¶ 24. Such an averment satisfies only the exclusivity portion of the twin conditions 
set forth in the NPA at ¶ 8. The word "and" followed by the requirement of an affirmative 
waiver of any other claims, federal, state, or common law mandates an additional affirmative act 
by the plaintiff. No such waiver was filed or even pled. ■ 
Doe 101 did no more than restate 
that her complaint in civil action no 9:09-cv-80591-ICAM was only for 2255 damages. She 
never affirmatively waived all future claims in state or federal court, as required by the NPA. 
EFTA00183773

Ms. 
Esq. 
June 19, 2009 
Page 9 
Because of this threshold issue, 
Doe 101 did not, though the attorney representative, satisfy 
the NPA 18 requirements.' While Mr. Epstein's counsel still believe for these reasons that the 
motion did not conflict with Mr. Epstein's obligations under the NPA, the motion was in relevant 
part withdrawn at Mr. Epstein's insistence—further demonstrating that Mr. Epstein has 
prioritized his desire to avoid contentious additional litigation with the USAO over this matter. 
In short, our good-faith efforts to raise litigation issues will be more carefully scrutinized 
in the future as to limit the possibility of being construed by your Office as supporting a notice 
that Mr. Epstein is in "willful" breach. Issues regarding the scope of the 1 8 waivers are 
unorthodox and even unprecedented. They result in part from the NPA being executed before 
you identified the individuals listed, see Exhibit 2, NPA 1 7, and, importantly, given the 
evolution of the civil litigation, before any joint statement as required by the terms of the NPA 
was provided to Mr. Josefsberg. Nevertheless, as we stated on June 15, we had intended to 
provide you with future filings in advance so that we could discuss their interaction with the 
NPA before rather than after any filing, However given your rejection of that procedure, in a 
good faith attempt to avoid future conflict, we would nevertheless hope to clarify some of the 
more ambiguous parts of 18 of the agreement with you as soon as possible. To repeat, it is 
Mr. Epstein's overriding intent to fulfill his obligations under the NPA -- an intent we as his 
attorneys will do everything in our power to effectuate. 
The facts demonstrate that Mr. Epstein has clearly not committed any breach of the NPA, 
much less a willful breach. As we have reiterated and as has been proven by Mr. Epstein's own 
actions, Mr. Epstein has no intention of breaching the NPA and has never had any such intention. 
Although you claim that Mr. Epstein received the benefits of the NPA and the Government only 
its burdens, I believe the reality is to the contrary. Mr. Epstein has suffered significant and 
irreversible prejudice: he has been imprisoned in a county jail for almost a year, he has pleaded 
guilty to a state felony that required sex registration and has, in fact, registered as a sex offender, 
he accepted civil burdens in his ongoing litigation that may result in millions of dollars of future 
payments, he has settled cases that could be won, in deference to the NPA and he is paying and 
That U 
Doe 101 did not meet the threshold requirements for ib.pimposition of the waiver of liability portion 
of Paragraph 8 of the NPA is demonstrated by the filings of 
Doe II in 09-80469-C1V-Marra, a federal 
lawsuit filed in March, 2009 seeking "exclusively 2255" damages, while ■ 
Doe II already had a pendin
state court suit filed in July of 2008 seeking damages against Epstein for sexual assault and conspiracy. 
Doe II in her II 
complaint alleged Epstein could "not contest liability for claims brought exclusively 
pursuant to 18 
§2255". Exhibit 27, Amended Complaint 1 24. In her response to Epstein's Motion to 
Dismiss in which Epstein challenged the "exclusivity" claim, she argued at page 7 that "Epstein appeared to be 
violating the agreement . . . [NPA]". However, her attorney withdrew that claim at the June 12, 2009 hearing 
(and in her subsequent Amended Response) agreeing Utile state filing negated the "exclusivity" of the federal 
2255 lawsuit. On the current record, nothing prevents 
Doe 101 from filing a parallel state court claim. 
EFTA00183774

Ms. IMM
 Esq. 
June 19, 2009 
Page 10 
will pay hundreds of thousands of dollars in legal fees for his adversaries to pursue him in court. 
The Government may have endured some delays and administrative costs due to certain of its 
own its decision — such as to evaluate the Sheriff's exercise of discretionary authority in 
implementing the Sheriff's own work release program —but neither the Government nor any 
civil plaintiff has suffered any harm, any prejudice, or any disadvantage as a result of the events 
you have identified. We signed a contract -- the NPA -- with you in good faith, and in exchange, 
Mr. Epstein gave consideration that cannot be returned (12 months of his freedom and his 
reputation). He is legally entitled to its benefits. He committed no "willful breach." As such, 
we believe it would constitute both a contractual and constitutional error to seek further remedy 
or to in any way withdraw from the NPA. 
We will continue to make our best efforts to communicate with you about any potential 
problems and hope, in the interest of fairness, you will do the same. 
Sincerely, 
9
Itilf1 P 
Jay . Lefkowitz, P.C. 
Enclosures 
EFTA00183775

LEOPOLD-KUVIN A 
CONSUMER JUSTICE ATTORNEYS 
July 6, 2009 
Assistant U.S. Attorney 
Southern District of Florida 
500 E. Broward Blvd, 7th Floor 
Ft. Lauderdale, FL 33394 
Re: 
B.B. I. JEFFREY EPSTEIN 
OUR FILE NO.: 080303 
Dear Ms. 
As you are aware, this firm represents Plaintiff, Jane Doe, a/k/a/ B.B. in the civil litigation 
against Jeffrey Epstein styled 
Jeffiey Epstein. case no.: 502008CA037319 MB AB. We 
are hereby requesting that a copy of the non-prosecution agreement be provided to my office as 
soon as possible. 
If there are any questions or concerns regarding the production of this agreement, please contact 
me at once. 
V1N 
STK/mlb 
2925 PGA Boulevard 
Suite 200 
Palm Beach Gardens 
Florida 33410 
581.615.1400 
fax 561.515.1401 
leopoldkuvin.com 
CRASUIWORTIIINESS • MANAGED CARE ABUSE • CONSUMER CLASS ACTIONS • PERSONAL INJURY • WRONGFUL DEATH 
EFTA00183776

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
DELIVERY BY ELECTRONIC MAIL 
Jay P. Lefkowitz, Esq. 
Kirkland & Ellis LLP 
Citigroup Center 
153 East 53rd Street 
New York, New York 10022-4675 
Re: 
Jeffrey Epstein 
Dear Jay: 
500 E. Broward Boulevard, 7th Floor 
R. Lauderdale, FL 33394 
(954) 356-7255 
July 7, 2009 
Thank you for your letters of June 19th. From your letters, it appears that you have 
misconstrued the Office's past efforts at alleviating Mr. Epstein's unfounded fears of 
disparate treatment. You seem to have interpreted those efforts as either: (I) an 
acknowledgement of the validity of those fears, or (2) an acquiescence to the efforts of Mr. 
Epstein to avoid the full terms of the Non-Prosecution Agreement. So, for example, you 
write that, in an email to Mr. Acosta, you "confirmed that `there were significant 
irregularities with the deferred prosecution agreement,'" and that "Mr. Acosta agreed to 
many of our objections and adopted several of our modifications . . . [and] [t]his fact 
confirms both the good-faith nature of our objections and that neither Mr. Epstein nor his 
counsel could be considered to have violated the NPA by raising those objections in the first 
place." Neither your e-mails nor Mr. Acosta's consistent attempts to maintain a good 
working relationship with you act as modifications to the NPA or indications that the Office 
agreed or acquiesced to your positions. 
While your letter provides great detail regarding all of the objections that you raised' 
'In an effort to terminate the endless "battle of letters" that this case has become, 1 have 
elected not to detail each and every misstatement in your ten-page letter, but please do not mistake 
that for an agreement with those misstatements. One of those misstatements, however, begs for 
ii iiil 
correction. You write: "Indeed, due to a concern we had raised, your Office specifically modified 
the procedure to select an attorney representative and delegated that task to Judge. Again, the 
EFTA00183777

JAY P. LEFKOWITZ, ESQ. 
JULY 7, 2009 
PAGE 2 OF 2 
throughout the nine-month delay between the signing of the NPA and Mr. Epstein's 
commencement of performance, you neglect to mention that all of your objections were 
soundly rejected at each and every level of review, from West Palm Beach, to Miami, to the 
Child Exploitation and Obscenity Section, and, finally, to the highest levels of review at the 
Department of Justice. As Senior Associate Deputy Attorney General John Roth stated: 
Even if we were to substitute our judgment for that of the U.S. Attorney, we 
believe that federal prosecution of this case is appropriate. Moreover, having 
reviewed your allegations of prosecutorial misconduct, and the facts 
underlying them, we see nothing in the conduct of the U.S. Attorney's Office 
that gives us any reason to alter our opinion. 
With regard to your proposal to engage in additional discussions regarding the scope 
of the NPA, we respectfully decline. A great deal of time and effort went into the negotiation 
and signing of the NPA, and the Agreement speaks for itself. Contrary to your assertion, 
both the government and the victims have suffered harm and prejudice due to the willful 
breaches of the NPA by Mr. Epstein. The Office will continue to evaluate its position and 
will proceed accordingly. 
Sincerely, 
Jeffrey H. Sloman 
Acting United States Attorney 
By: 
s/A. 
A. 
Villafafia 
Assistant United States Attorney 
cc: 
, Chief, Northern Division 
Jack Goldberger, Esq. 
Roy Black, Esq. 
fact that your Office accommodated our concerns validated their legitimacy ..." As you have been 
told repeatedly, the decision to delegate that task to a Special Master was made independently and 
before any of Mr. Epstein's attorneys voiced a concern about that process. Mr. Lefkowitz, you were 
provided with a list of potential attorney representatives and with information in writing regarding 
the alleged "conflict of interest," and you made the selection that you later claimed was problematic. 
Notwithstanding your agreement on the selection of the attorney-representative, our Office, 
independently, elected to ask an independent third party to make the final decision. 
EFTA00183778

J. MICHAEL BURMAN. PA! 
GREGORY W. COLEMAN. PA. 
ROBERT D. CRITTON. JR.. PA' 
BERNARD LEBEDEKFit 
MARK T. LUTTIIM. PA. 
JEFFREY 
PEPIN 
MICHAEL J. PIKE 
HEATHER MeNAMARA RUDA 
FLORIDA BOARD 
ED 
CIVIL IHIAL LAWYER 
BURMAN, CRITTON, LUTTIER 
& COLEMAN LLP 
A LIMITED LIABILITY PARTNERSHIP 
July 8, 2009 
AL EXPRESS 
, Esq. 
Assistant U.S. Attorney 
Southern District of Florida 
500 East Broward Boulevard, 7th Floor 
Ft. Lauderdale, FL 33394 
Re: 
Doe No. 8'. Jeffrey Epstein 
Case No. 09-CV-80802-Marra/Johnson 
Dear Ms. 
ADELQUI J. BENAVENTE 
PARALEGAL/ INVESTIGATOR 
BARBARA M. McKINNA 
ASHLIE STOKEN-BARING 
BETTY STOKES 
PARALEGALS 
RITA II. BUDNYK 
OP COUNSEL 
As you are aware, I am Mr. Epstein's attorney in the civil cases that have been 
filed against him. While I am certainly familiar with the NPA, it is clear to me that my 
interpretation of it may differ from yours (USAO) or one of the many plaintiffs' attorneys 
as it relates to what I can do or assert in defense of Mr. Epstein. 
As I expressed to Judge Marra, my charge from Mr. Epstein is to take no action 
that could reasonably be considered to be a violation of the NPA. With that in mind, I 
am sending our motion to dismiss in 
Doe #8, along with a copy of her complaint. 
While I know you expressed to Mr. Lefkowitz that you (USAO) were not inclined 
to review pleadings and offer advisory opinions, I would ask that you reconsider and 
review our motion. 
The Plaintiff 
Doe No. 8 is not exclusively asserting a claim p 
ant to 18 
8's counsel, Adam Horowitz, who also is counsel for Plaintiffs 
. §2255, and thus, the terms of the NPA are not implicailln fact, 
Doe No. 
Does Nos. 2 through 
7 in other civil actions against Mr. Epstein, in the June 12, 2009 hearing before U.S. 
District Judge Kenneth Marra (at which you were also present) conceded that — 
The provision (of the NPA) relating to Mr. Epstein being unable to contest 
liability pertains only to those plaintiffs who have chosen as their sole remedy 
L•A•W•Y•E•R•S 
515 N. FLAGLER DRIVE / SUITE 400 / WEST PALM BEACH, FLORIDA 33401 
TELEPHONE (561) 8424820 FAX (561) 8446929 
[email protected] 
EFTA00183779

July 8, 2009 
Page 2 
the federal statute. My clients, 
Doe 2 through 7, have elected to bring 
additional causes of action, and it's for that reason we were silent when you 
said does anyone here find Mr. Epstein to be in breach of the non-
prosecution agreement. This provision, as we understand it, it does not 
relate to our clients. 
June 12, 2009, Transcript of hearing in IF Doe, et al 
Epstein, Case No. 08- 
80119-Civ-Marra, U.S. District Ct., S.D. IF
p. 29, line 19-25, p. 30, line 1. A 
copy of the relevant portions of the hearing transcript is enclosed. 
I agree with his comments as they relate to all of his clients, including 
Doe 8. 
I believe that nothing in this motion involves any aspect of the NPA. If yo.sagree, 
would you please contact me as soon as possible. I must file this motion by July 14th as 
per my extension agreement with Mr. Horowitz. However, I stand ready to have a 
discussion or meeting with you regarding this motion or any other civil related pleadings 
or matter that may implicate the NPA. I look forward to your response. 
RDC/clz 
cc by pdf: 
Jack A. Goldberger, Esq. 
Martin G. Weinberg, Esq. 
Roy Black, Esq. 
Jay Lefkowitz, Esq. 
Cordially y r , 
Rob D. Critton, Jr. 
EFTA00183780

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 09-CV-80802-MARRA-JOHNSON 
DOE NO. 8 
1. 
JEFFREY EPSTEIN, 
Plaintiff, 
Defendant. 
DEFENDANT EPSTEIN'S MOTION TO DISMISS PLAINTIFF'S COMPLAINT 
Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his attorneys, moves 
to dismiss Counts I and III of Plaintiffs Complaint as the causes of action are barred by 
the applicable statute of limitations.' Rule 12(b)(6); Local Gen. Rule 7.1 (S.D. Fla. 
2009). In support of dismissal, Defendant states: 
Plaintiff's Complaint attempts to allege three Counts; the first two counts are 
pursuant to state common law, and the third count is brought pursuant to 18 
§2255. Civil remedy for personal injuries. Count I attempts to allege a cause of action 
for "Sexual Assault and Battery," Count II for "Intentional Infliction of Emotional 
Distress;" and Count III for "Coercion and Enticement to Sexual Activity in Violation of 
18 
§2422," pursuant to 18 
§2255. 
P 
s Complaint att 
to assert both state common law claims and a claim pursuant to 
18 
. §2255. Since 
Doe 8 did not relinquish her state claims and correspondingly did 
not file her complaint relying, exclusively, on 18 USC 2255, she is not entitled to the litigation 
benefits including certain waivers that directly or indirectly accrue to other civil plaintiffs from the 
defendant's fulfilling obligations resulting from his separate confidential agreement with the 
United Staes Attorney's Office. Plaintiff's counsel conceded that the provisions of the NPA are 
not implicated where a plaintiff brings additional causes of acti
d does n 
proceed 
exclusively under §2255. See June 12, 2009, Hearing Transcript in MI Doe, et all. Epstein, 
Case No. 08-80119-Civ-Marra, p. 29, line 19-25, p. 30, line 1. 
EFTA00183781

Doe No. 8'. Epstein 
Page 2 
Pursuant to the allegations on the face of Plaintiff's complaint, Count I, based on 
Florida's common law of assault and battery, and Count III, brought pursuant to 18 
§2255, are barred by the applicable statute of limitations. Although a statute of 
limitations bar to a claim is an affirmative defense, and a plaintiff is not required to 
negate an affirmative defense in her complaint, a Rule 12(b)(6) dismissal on statute of 
limitations grounds is appropriate where, as here, "it is 'apparent from the face of the 
complaint' that the claim is time-barred." See generally, La Grasta I. First Union 
Securities, Inc., 358 F.3d 840, 845 -846 (11th Cir. 2004). 
Count I Is barred by the applicable statute of limitations. 
As to Count I, which is plead pursuant to state law, it is well settled that this Court 
is to apply Florida law. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to 
Florida law, the statute of limitations for assault and battery is four years, §95.11(3)(o)., 
Fla. Stat. §95.11(3)(o), Fla. Stat., provides — 
Actions other than for recovery of real property shall be commenced as 
follows: 
(3) Within four years.—
* 
(o) An action for assault, battery, false arrest, malicious prosecution, 
malicious interference, false imprisonment, or any other intentional tort, 
except as provided in subsections (4), (5), and (7). 
In her Complaint, Plaintiff alleges in relevant part that — 
9. ... In or about 2001, 
Doe, then approximately 16 years old, fell 
into Epstein's trap and became one of his victims. 
According to the allegations of the Complaint, 
Doe had one encounter with 
Defendant at his Palm Beach mansion in or about 2001 when 
was approximately 
EFTA00183782

Doe No. 8'. Epstein 
Page 3 
16 years old. See Complaint, ¶13, endnote 1 hereto.' Based on the allegations of the 
Complaint, it has been at least 8 years since the alleged conduct by EPSTEIN, well past 
the four year statute of limitations, thus requiring dismissal of Count I. Based on the 
allegations, Plaintiff is now at least 24 years old. 
Subsections (4) and (5) referenced in §95.11(3)(o) are not applicable. Plaintiff 
may attempt to argue that subsection (7) of §95.11, Fla. Stat. applies. See endnote 2 
hereto for statutory text of subsection (7), including statutes referenced therein.2
However, a review of Plaintiff's allegations in Count I establish that Plaintiff is attempting 
to assert a cause of action based on the elements of Florida's common law assault and 
battery to which a four year statute of limitation applies. (Compare Count II, ¶24, 
wherein Plaintiff tracks the language §39.01(2), Fla. Stat. (2001), pertaining to "abuse."). 
Pursuant to Florida law, although the term "assault and battery" is most 
commonly referred to as if it were a legal unit, or a single concept, "assault and battery 
are separate and distinct legal concepts, assault being the beginning of an act which, if 
consummated, constitutes battery." 3A FIa.Jur.2d Assault §1. An assault and battery 
are intentional acts. See generally Spivey I. Battaglia, 258 So.2d 815 (Fla. 1972); and 
Travelers Indem. 
PCR, Inc., 889 So.2d 779 (Fla. 2004). 
On the face of the Complaint, the applicable four year statute of limitations has 
expired, and accordingly, Count I is barred an required to be dismissed. 
Count 111 —18 =. 
42255 
EFTA00183783

Doe No. 8'. Epstein 
Page 4 
As to the applicable statute of limitations for Count III which is brought pursuant to 
18 
. §2255, §2255(b), (both the 2001 version, which Defendant asserts is the 
applicable statute, and the amended version, effective July 27, 2006), provides: 
(b) Statute of limitations.—Any action commenced under this section 
shall be barred unless the complaint is filed within six years after the right 
of action first accrues or in the case of a person under a legal disability, 
not later than three years after the disability. 
As noted above, according to the allegations of the Complaint, 
Doe had one 
encounter with Defendant at his Palm Beach mansion in or about 2001 when 
was 
approximately 16 years old. See Complaint, ¶13, endnote 1 hereto. Based on the 
allegations of the Complaint, it has been at least 8 years since the alleged conduct by 
EPSTEIN, well past the six year statute of limitations, thus requiring dismissal of Count 
III. Based on the allegations, Plaintiff is now at least 24 years old, well pass the age of 
majority. (The age of majority under both federal and state law is 18 years old. See 18 
. §2256(1), defining a "minor" as "any person under the age of eighteen years;" 
and §1.01, Definitions, Fla. Stat., defining "minor" to include "any person who has not 
attained the age of 18 years."). Thus, on the face of the Complaint, Count III is timed 
barred and required to be dismissed. 
Conclusion 
Accordingly, Counts I and III of Plaintiff's Complaint are subject to dismissal. On 
the face of the Complaint, the causes of action which Plaintiff attempts to allege are 
barred by the applicable statute of limitations of 4 and 6 years, respectively. 
WHEREFORE, Defendant requests that this Court dismiss Counts I and III of 
Plaintiff's Complaint with prejudice. 
EFTA00183784

Doe No. 8'. Epstein 
Page 5 
Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with 
the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being 
served this day on all counsel of record identified on the following Service List in the 
manner specified by CM/ECF on this 
day of 
, 2009: 
Stuart S. Mermelstein, Esq. 
Adam D. Horowitz, Esq. 
18205 Biscayne Boulevard 
Suite 2218 
Miami, FL 33160 
305-931-2200 
Fax: 305-931-0877 
[email protected] 
[email protected] 
Counsel for Plaintiff = 
Doe #8 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach, FL 33401-5012 
561-659-8300 
Fax: 561-835-8691 
[email protected] 
Counsel for Defendant Jeffrey Epstein 
Respectfully submitted, 
BURMAN, CRITTON, LUTTIER 
& COLEMAN, LLP 
515 N. Flagler Drive, Suite 400 
West Palm Beach, FL 33401 
(561) 842-2820 
By: 
Robert D. Critton, Jr. 
Florida Bar #224162 
Michael J. Pike 
Florida Bar #617296 
Counsel for Defendant Jeffrey Epstein 
rcrit
bciclaw.com 
moikeebciclaw.com 
' Complaint, ¶13 alleges in relevant part — 
Doe was recruited by another girl, who told her that she could make some 
money, buljiil not tell her what was involved. At all relevant times, the glythbo 
recruited 
Doe was acting on behalf of and as an agent for Epstein. 
was 
EFTA00183785

Doe No. 8'. Epstein 
Page 6 
contacted by this girl by telephone. 
was then picked up and brought to 
Epstein's mansion in Palm Beach. 
nce there, she was lead up a flight of stairs to 
the room with the massage table. Epstein came i t 
the room and directed 
to remove her clothes and give him massage. 
was frightened and felt 
trapped. As directed 
stein, IN removed her clothes. Epstein then during 
the massage touched 
on her breasts and vagina, and he grabbed her hand 
and placed it on his penis. Zulein masturbated himself during the massage. 
Epstein then left money for M. 
2 §95.11(7), Fla. Stat. — 
(7) For intentional torts based on abuse.--An action founded on alleged abuse, 
as defined in s. 39.01, s. 415.102, ors. 984.03, or incest, as defined in s. 826.04, 
may be commenced at any time within 7 years after the age of majority, or within 4 
years after the injured person leaves the dependency of the abuser, or within 4 
years from the time of discovery by the injured party of both the injury and the 
causal relationship between the injury and the abuse, whichever occurs later. 
§39.01(2), Fla. Stat. (2001) —
(2) "Abuse" means any willful act or threatened act that results in any physical, 
mental, or sexual injury or harm that causes or is likely to cause the child's 
physical, mental, or emotional health to be significantly impaired. Abuse of a child 
includes acts or omissions. Corporal discipline of a child by a parent or legal 
custodian for disciplinary purposes does not in itself constitute abuse when it does 
not result in harm to the child. 
§415.102(1), Fla. Stat. (2001) - 
(1) "Abuse" means any willful act or threatened act that causes or is likely to cause 
significant impairment to a vulnerable adult's physical, mental, or emotional 
health. Abuse includes acts and omissions. 
§984.03 (2), Fla. Stat. (2001) —
"Abuse" means any willful act that results in any physical, mental, or sexual injury 
that causes or is likely to cause the child's physical, mental, or emotional health to 
be significantly impaired. Corporal discipline of a child by a parent or guardian for 
disciplinary purposes does not in itself constitute abuse when it does not result in 
harm to the child as defined in s. 39.01. 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 09-CV-80802-Marra-Johnson 
DOE NO. 8, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
FILED by VT 
ELECTRONIC 
May 28, 2009 
STEVEltpl. tARIMORE 
CI.ERK US. MT. CT. 
s. D. or k*.. MIAMI 
COMPLAINT 
Plaintiff, Jane Doe No. 8 ("Jane" or `al Doe"), brings this Complaint against Jeffrey 
Epstein, as follows: 
Parties, Jurisdiction and Venue 
1. 
Jane Doe No. 8 ("Jane Doe") is a citizen and resident of the State of Florida, and is 
sui juris. 
2. 
This Complaint is brought under a fictitious name to protect the identity of the 
Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a 
minor. 
3. 
Defendant Jeffrey Epstein is a citizen and resident of the State of New York, and 
presently serving a prison sentence in Palm Beach County, Florida for, inter alio solicitation of 
prostitution and solicitation of minors to engage in prostitution.. 
4. 
This is an action for damages in excess of $50 million. 
5. 
This Court has jurisdiction of this action and the claims set forth herein pursuant to 28 
§1332(a), as the matter in controversy (i) exceeds $75,000, delusive of interest and costs; 
MERMEL.STEIN & HOROWITZ. P. A. 
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and (ii) is between citizens of different states. 
6. 
Additionally, this Court has jurisdiction pursuant to 28 
§1331 because 
Plaintiff alleges a claim under the laws of the United States. This Court has supplemental 
jurisdiction pursuant to 28... 
§1367(a) over all other claims set forth herein which form part of 
the same case or controversy. 
7. 
This Court has venue of this action pursuant to 28a. 
§§1391(a) and 1391(b) as a 
substantial part of the events or omissions giving rise to the claim occurred in this District. 
Factual Allegations 
8. 
At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male in his 
early 50's. Epstein is a financier and money manager with a secret clientele limited exclusively to 
billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his 
principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach, 
FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach. 
9. 
Upon information and belief, Epstein has a sexual preference and obsession for 
underage minor girls. He engaged in a plan and scheme in which he gained access to primarily 
economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave 
them money. In or about 2001, Jane Doe, then approximately 16 years old, fell into Epstein's trap 
and became one of his victims. 
10. 
Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted 
girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas. 
11. 
Epstein's scheme involved the use of young girls to recruit underage girls. These 
underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation 
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in his Palm Beach mansion. Epstein, upon information and belief, generally sought out economically 
disadvantaged underage girls from Palm Beach County who would be enticed by the money being 
offered - generally $200 to $300 per "massage" session - and who were perceived as less likely to 
complain to authorities or have credibility if allegations of improper conduct were made. 
12. 
Epstein's plan and scheme reflected a particular pattern and method. The underage 
victim would be brought or directed to Epstein's mansion, where she would be led up a flight of 
stairs to a room that contained a massage table in addition to other furnishings. The girl would then 
find herself alone in the room with Epstein, who would be wearing only a towel. He would then 
remove his towel and lie naked on the massage table, and direct the girl to remove her clothes. 
Epstein would then perform one or more lewd, lascivious and sexual acts. 
13. 
Consistent with the foregoing plan and scheme, 
Doe was recruited by another 
girl, who told her that she could make some money, but did not tell her what was involved. At all 
relevant times, the girl who recruited. Doe was acting on behalf of and as agent for Epstein. 
was contacted by this girl by telephone. 
was then picked up and brought to Epstein's 
mansion in Palm Beach. Once there, she was led up the flight of stairs to the room with the massage 
table. Epstein came into the room and directed 
to remove her clothes and give him a massage, 
was frightened and felt trapped. As directed by Epstein". removed her clothes. Epstein 
then during the massage touched- on her breasts and vagina, and he grabbed her hand and placed 
it on his penis. Epstein masturbated himself during the massage. Epstein then left money for. 
14. 
As a result of this encounter with Epstein, 
experienced confusion, shame, 
humiliation and embarrassment, and has suffered severe psychological and emotional injuries. 
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24. 
Epstein committed willful acts of child sexual abuse on Woe. These acts resulted 
in mental or sexual injury that caused or were likely to cause IlDoe's mental or emotional health 
to be significantly impaired. 
25. 
Epstein's conduct caused severe emotional distress to .Doe. Epstein knew or had 
reason to know that his intentional and outrageous conduct would cause emotional distress and 
damage to. 
Doe, or Epstein acted with reckless disregard of the high probability of causing 
severe emotional distress to. 
Doe. 
26. 
As a direct and proximate result of Epstein's intentional or reckless conduct, .Doe 
has suffered and will continue to suffer severe mental anguish and pain, psychological and emotional 
injuries and los of enjoyment of life. . 
WHEREFORE, Plaintiff. Doe No. 6 demands judgment against Defendant Jeffrey 
Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this 
Court deems just and proper. 
COUNT III 
Coercion and Enticement to Sexual Activity in Violation of 18 IMI. &2422 
27. 
Plaintiff. Doe repeats and realleges paragraphs 1 through 14 above. 
28. 
Epstein used a facility or means of interstate commerce to knowingly persuade, 
induce or entice In Doe, when she was under the age of 18 years, to engage in prostitution or 
sexual activity for which any person can be charged with a criminal offense. 
29. 
On June 30, 2008, Epstein entered a plea of guilty to violations of Florida H 796.07 
and 796.03, in the 15th Judicial Circuit in and for Palm Beach County (Case nos. 2008-cf-
009381AXXXMI3 and 2006-cf-009454AMMB), for conduct involving the same plan and 
scheme as alleged herein. 
MERMELSTEIN & MoRoWITZ, P. A. 
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30. 
As to Plaintiff Woe, Epstein could have been charged with criminal violations of 
Florida Statute §796.07(2) (including subsections (f (d), (e), (f), (g), and (h) thereof), and other 
criminal offenses including violations of Florida Statutes §§798.02 and 800.04 (including 
subsections (5), (6) and (7) thereof). 
31. 
Epstein's acts and conduct are in violation of 18 MI 
§2422. 
32. 
As a result of Epstein's violation of 18 
§2422, Plaintiff has suffered personal 
injury, including mental, psychological and emotional damages. 
33. 
Plaintiff hired Mermelstein & Horowitz, P.A. (ffIda Herman & Mermelstein, P.A.), in 
this matter and agreed to pay them a reasonable attorneys' fee. • 
WHEREFORE, Plaintiff.. Doe No. 6 demands judgment against Defendant Jeffrey 
Epstein for all damages available under 18 
§2255(a), including without limitation, actual and 
compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as this 
Court deems just and proper. 
JURY TRIAL DEMAND 
Plaintiff demands a jury trial in this action on all claims so triable. 
Dated: May Z-7, 2009 
Respectfully submitted, 
By: 
Stuart S. Mermelstein (FL 
ssm(4sexabuseattorney.co 
Adam D. Horowitz (FL Bar No. 376980) 
[email protected] 
MERMELSTEIN & HOROWITZ, P.A. 
Attorneys for Plaintiff 
18205 Biscayne Blvd., Suite 2218 
Miami, Florida 33160 
Tel: 305-931-2200 
Fax: 305-931-0877 
No. 947245) 
MERMELSTEIN & HOROWITZ, P. A. 
www.sexabuseattorney.com 
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