EFTA00183732

ROY BLACK 
HOWARD M. SREBNICK 
Scan A. KORNSPAN 
LARRY A. STUMPF 
MARIA NEYRA 
JACKIE PERCZEK 
MARK A.J. SHAPIRO 
JARED 
Jeff Sloman, Esq. 
United States Attorney 
99 N.E. 4°  Street 
Miami, FL 33132 
BLACK 
SREBNICK 
KORNSPAN 
&STUMPF 
=PA.= 
March 5, 2010 
, Esq. 
Assistant United States Attorney 
99 N.E. 4i° Street 
Miami, FL 33132 
RE: 
Jeffrey Epstein 
Dear Counsel: 
JESSICA FONSECA-NADER 
KATHLEEN P. PHILUPS 
AARON ANTHON 
MARCOS BEATON, JR. 
MATTHEW P. O'BRIEN 
JENIPER J. SOUUKIAS 
NOAH Fox 
E-Mail: Rrnack®RoyBlack.com 
Esq. 
Assistant United States Attorney 
99 N.E. 4th Street 
Miami, FL 33132 
We write this letter to renew our request that the United States Attorney's 
Office provide us, as Mr. Epstein's counsel in the federal NPA matter, with clarity 
as to what legal issues we can advise his civil counsel can be litigated without 
causing you to consider the raising of legal issues to be in breach of Mr. Epstein's 
obligations under paragraph 8 of the NPA. A letter from civil counsel Robert 
Critton is attached. On February 11, 2010, you advised us that for reasons 
including the fact that at the time there were "no currently pending cases arising 
exclusively under 18 USC §2255 as to any of the victims on the identified list" you 
would "decline to provide any advisory opinions" in response to our requests 
during our meeting of February 3. 
Since February 11, 2010, a lawsuit has been filed by the attorney 
representative on behalf of 
Doe 103. 
Her identity is known by us and she 
is on the "identified list." Her lawsuit raises only §2255 claims. Although she has 
not waived her right to file any other state or federal or common law claim so as 
to fit squarely within the letter of 18 of the NPA, she does, in her lawsuit, quote 
18 and claim rights as a beneficiary of that agreement, see Case No. 10-80309 
(S.D. Fla.), Complaint, 1125-26, thus requiring that civil counsel consider 
201 S. Biscayne Boulevard, Suite 1300 • Miami. Florida 33131 • Phone: 30S-371.6421 • Fax: 305-358-2006 • suww.RoyBlack.com 
EFTA00183812

Jeff Sloman, Esq. 
Esq. 
, Esq. 
March 5, 2010 
Page 2 
responsive motions that relate to the scope of waiver of liability that is 
memorialized in the NPA. 
Additionally, Mr. Epstein and his counsel have 
scheduled a meeting to review the attorney representatives outstanding bills but 
have been told that if there is no settlement agreement, then the attorney 
representative intends to initiate litigation rather than adopt the Special Master 
procedure that we referred to in our February 18, 2010 correspondence to you. 
It is the intention of Mr. Epstein's civil counsel to not contest that at least 
one predicate §2255 offense was committed believing that such a "waiver" 
satisfies, facially, Mr. Epstein's obligations under the NPA, see attached letter from 
Mr. Critton. As we said during our meeting on February 3, we have an obligation 
to provide advice to Mr. Epstein's civil counsel, Robert Critton, whether his raising 
of certain legal challenges to the Complaint will be perceived as being in conflict 
with Mr. Epstein's NPA obligations. These issues include: 
1. 
Whether Mr. Epstein can contend that any waiver of liability is 
satisfied by his not contesting the occurrence of a single rather than 
multi 
edicate offenses as to each claimant? This issue is pertinent 
since 
Doe 103 has brought six separate claims for §2255 relief each 
implicating the statutory minimum damage recovery. 
Amongst the 
predicates alleged include a predicate offense allegation of a statute that 
was not even enacted until 2006, i.e., over a year after 
Doe 103 turned 
18, and substantially after her last alleged contact with Mr. Epstein. Any 
requirement that Mr. Epstein not contest liability for that predicate would 
violate the ex post facto laws. Two other predicates are not supported by 
trustworthy evidence. It is our contention that Mr. Epstein satisfies his 
NPA obligations by not contesting that he committed at least one predicate 
offense. Prior correspondence from your office is not inconsistent with our 
belief that the required scope of waiver was to a predicate offense in the 
singular, see, e.g., Mr.Acosta's letter to Ken Starr, December 4, 2007, p.2 
("were Mr. Epstein convicted at trial, the plaintiff-victims would not have to 
show that a violation of an enumeration section of Title 18 took place")? 
2. 
Whether Mr. Epstein can contend that the statutory provisions of 
§2255 in effect at the time of the offense (e.g., 2004-5) govern the minimum 
statutory damage amount ( 50,000 rather than $150,000) under ex post 
facto laws, see United States 
Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010) 
(indicating that the statute in effect at the time of the violation governs the 
minimum damage remedy)? 
Black. SrebnIck, Kornspan & Stumpf. P.A. 
EFTA00183813

Jeff Sloman, Esq. 
Esq. 
, Esq. 
March 5, 2010 
Page 3 
3. 
Whether personal injury is a separate §2255 element from the 
predicate offense element so that Mr. Epstein could "agree" to the occurrence 
of a predicate pursuant to his NPA obligations but still contest that the 
plaintiff was injured, see United States,. Scheidt, supra (finding each to be 
a separate element) and the letter from Mr. Acosta to Mr. Star, supra 
December 4, 2007 letter at p.2 which agrees that Mr. Epstein can contest the 
injury element under the NPA ("were Mr. Epstein convicted at trial, the 
plaintiff-victims in a subsequent Section 2255 suit would still have had some 
burden to prove that they were `victims"? 
4. 
Whether the 6-year civil statute of limitations contained in 18 USC 
§2255 could be raised as an affirmative defense if the facts or allegations 
demonstrate a greater than 6-year period between the accruing of the cause 
of action and the complaint, i.e., whether Mr. Epstein can "agree" (for civil 
§2255 purposes) to the occurrence of a predicate offense and still claim it 
occurred greater than 6 years before the filing of a Complaint? 
5. 
Whether Mr. Epstein can contest certain claims that are unsupported 
by trustworthy proof (or in certain cases by any proof at all) so long as he has 
waives his right to deny the occurrence of at least one predicate offense as 
required by ¶8 of the NPA? 
6. 
Whether damages are to be awarded based on injury to a plaintiff or 
based on the number of separately proven claims, see United States'. 
Raker, 2009 WL 4572785 (E.D.Tex., 2009) where the Court rejected the 
contention that damages were to be allocated per violation? 
We are not asking the government to adopt our legal positions; instead we 
are simply seeking the right for Mr. Epstein's civil counsel to raise principled good 
faith legal issues without fear of the irreparable collateral consequences that 
would result from any notice by you that you believed that a litigation position 
adopted by Mr. Epstein's civil counsel constituted a willful breach. Paragraph 8 
and its waiver provisions are not clear (or as stated by Mr. Acosta are "far from 
simple," see Mr. Acosta letter to Ms. Sanchez, December 19, 2007). Paragraph 8 
does not "speak for itself." That the provisions of ¶8 are "far from simple" is 
illustrated in the construction of those paragraphs by Mr. Epstein's prior counsel, 
Jay Lefkovvitz, who repeatedly advised Mr. Acosta, by letter, that he considered the 
waiver of liability to be limited to those who agreed to damages, and was 
inapplicable to those who chose to litigate, see, e.g., letters from Jay Lefkowitz to 
Black. Srebnick. Kornspan & Stumpf, P.A 
EFTA00183814

Jeff Sloman, Esq. 
Esq. 
, Esq. 
March 5, 2010 
Page 4 
Alex Acosta October 10, 2007, p.4 and November 29, 2007, p.2. Again, we are 
only requesting that you inform us whether in the event Mr. Epstein did not 
contest the commission of at least one predicate - the statutory precondition for 
the filing of a §2255 lawsuit - you would nevertheless believe that the raising of 
any of the legal arguments outlined above would violate the NPA 
Respectfully submitted, 
MARTIN W 
BERG, ESQ. 
ROY B 
CK, SQ. 
/wg 
By 
Black. Srebnick, Kornspan & Stumpf. PA 
EFTA00183815

BURMAN, CRITTON 
LUTTIER&COLEMAN, LLP 
YOUR TRUSTED 
ADVOCATES 
A LIMITED LIABILITY PARTNERSHIP 
J. MICHAEL BURMAN. P.A22
GREGORY W. COLEMAN. P.A. 
ROBERT D. CRITTON. JP-. PA ' 
BERNARD A. LEBEDEKER 
MARKT. LuTTIER. PA. 
MICHAEL J. PIKE 
DAVID A. YAREMA 
RONDA BOARD CERTIFIED CIVIL TRIAL LAWYER 
2ADRUTTED TO PRACTICE IN FLORIDA AND COLORADO 
Roy Black, Esq. 
Black, Srebnick, Kornspan & Ptumpf 
201 S. Biscayne Boulevard, Suite 1300 
Miami, FL 33131 
March 4, 2010 
Martin G. Weinberg, Esq. 
Martin G. Weinberg, PC 
20 Park Plaza, Suite 1000 
Boston, MA 02116 
ADELCW I J. BENAVENTE 
PARATEGAViNVESSIGATOR 
JESSICA CADWELL 
BOBBIE M. MCKENNA 
ASHLIE STOKEN-BARING 
BETTY STOKES 
PARALLOALS 
RITA H. BUONYK 
OF COUNSEL 
EDWARD M. RICCI 
OF COUNSEL 
Re: 
Jeffrey Epstein 
Dear Roy and Marty: 
This letter represents my thoughts on issues concerning the NPA and my ability to 
fully defend Mr. Epstein in the civil case recently filed by Mr. Josefsberg. 
Based on a State criminal court ruling last summer, the Non-Prosecution Agreement 
("NPA") was made available to the public. With regard to the civil aspect of the NPA, 
specifically paragraphs 7 and 8 (including the Addendum), our interpretation has been 
substantially different from that of the attorney representative, Mr. Josefsberg, and other 
attorneys representing alleged victims. They have interpreted those civil portions of the 
agreement to assist them in their civil cases in a manner which we believe is inconsistent 
with both the written word and the intent of the NPA.' 
Mr. Epstein has continued to fulfill his responsibilities under all aspects of the NPA. 
Mr. Josefsberg has represented or currently represents twelve individuals. Of those 
twelve individuals, eleven have resat their claims..athose eleven claims, only two 
individuals filed contested litigation, 
Doe 101 and 
E
l
 
Doe 102. 
Mr. Epstein and Mr. Josefsberg have attempted to resolve the issue associated with 
attorneys fees and costs. Mr. Epstein has, as you know, paid an excess of $500,000.00 
toward the claimed outstanding fees and costs. It is the belief of all attorneys who 
represent Mr. Epstein that the fees and costs incurred by the attorney representative (for 
many attorneys and consultants) are excessive and duplicative. Mr. Epstein provided Mr. 
Josefsberg a signed Special Master Agreement for resolving the fees/costs issues In 
February 2010, in substantially the same format which was agreed upon as of December 
of 2009. The only significant change was use of an out-of-state special master. We were 
advised by Mr. Josefsberg and Mr. Podhurst that they no longer agree with using that 
process. 
303 BANYAN BOULEVARD • SUITE 400 • WEST PALM BEACH. FL 33401 • PHONE: 561-842-2820 • Fax: 561-844-6929 • [email protected] 
WWW.BCLCLAWMOM 
EFTA00183816

March 4, 2010 
Page 2 
Doe 103 now has been filed. While Mr. Epstein clearly recognizes his 
obligation under the NPA to waive liability to a single predicate offense, Mr. Josefsberg 
has filed an action asserting multiple counts against Mr. Epstein based on multiple 
predicate acts, including one wherein the statute was not even in effect at the time of the 
alleged violation. Mr. Josefsberg is also aware and agreed that Mr. Epstein could file a 
declaratory action related to the interpretation of the NPA. Mr. Josefsberg reserved the 
right to contest issues that might be raised in such an action. 
It is facially unfair, unjust and inconsistent with the spirit and Intent of the NPA that 
Mr. Epstein be precluded from fully defending himself (except for the waiver of liability as 
to a single act) especially where no facts exist to support the claim, a statute was not in 
effect at the time of the alleged incident, etc. 
It is my understanding that you are sending a letter to the USAO. I have no 
objection to your Including my letter which expresses some of my concerns with which Mr. 
Epstein Is now confronted based on Mr. Josefsberg's interpretation of the NPA. While I 
am not asking the USAO to confirm Mr. Epstein and his attorneys' Interpretation of the 
NPA and/or its spirit and intent, I would request that the USAO give Mr. Epstein the 
opportunity to fully defend himself, In the civil suit, except for that which is specifically 
required of him under the NPA. 
Cordially you 
Robe D. Critton, Jr. 
RDC/clz 
EFTA00183817

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 S. Australian Ave, Ste 400 
West Palm Beach, FL 3340! 
(561)820-8711 
Facsimile: (56!) 8204777 
April 2, 2010 
DELIVERY BY ELECTRONIC MAIL 
Roy Black, Esq. 
Black Srebnick Kornspan & Stumpf P.A. 
201 S. Biscayne Blvd, Suite 1300 
Miami, FL 33131 
Re: 
Jeffrey Epstein 
Dear Mr. Black: 
The Office is in receipt of your letter of March 29, 2010. We have had a series of 
correspondence, telephone calls, and meetings regarding the issue of Mr. Epstein's obligation to his 
victims. We have repeatedly stated that Mr. Epstein is expected to abide by the letter and spirit of 
the Non-Prosecution Agreement. And we have repeatedly informed you that the U.S. Attorney's 
Office does not intend to provide advisory opinions to Mr. Epstein or his attorneys regarding the 
handling of the civil suits filed against him. Yet again, you have asked us to provide such an 
advisory opinion. The request relates to Mr. Epstein's Motion to Dismiss in toto the suit filed 
against him by Jane Doe 103, whom we understand is one of the victims identified through the 2006 
through 2007 investigation that culminated in the signing of the Non-Prosecution Agreement. 
Jane Doe 103 is represented by Robert Josefsberg, the attorney-representative selected by the 
Special Master in accordance with the Non-Prosecution Agreement, and the Complaint raises claims 
exclusively under 18 
. § 2255. As such, Mr. Epstein has waived his right to contest liability. 
Despite this waiver, Mr. Epstein and his attorneys want the Court to dismiss the Complaint. In a 
word, yes, the Office believes that this is a breach of the Non-Prosecution Agreement. 
Sincerely, 
Jeffrey H. Sloman 
United States A 
By: 
Assistant United States Attorney 
EFTA00183818

ROY BLACK, ESQ. 
APRIL 2, 2010 
PAGE 2 OF 2 
cc: 
Jeffrey H. Sloman, U.S. Attorney 
Robert K. Senior, Acting First Assistant U.S. Attorney 
Chief, Northern Division 
EFTA00183819

' Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 1 of 19 
a3/e4//0 
Seated 
IN THE UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF FLORIDA 
Civil Action No. 
10 - 803 09 
DOE No. 103, 
Plaintiff, 
1. 
JEFFREY EPSTEIN, 
Defendant. 
FILED bytt)....... 
FEB 2 3 20W 
STEVEN M. LARIMORE 
CLERK 
01ST CT 
of ft.A. - MIAMI 
COMPLAINT AND DEMAND FOR JURY TRIAL 
Plaintiff, ■ 
Doe No. 103 ("Plaintiff% brings this Complaint against Defendant, Jeffrey 
Epstein ("Defendant), and states as follows: 
PARTIES. JURISDICTION. AND VENUE 
1. 
At all times material to this cause of action, Plaintiff was a resident of Palm Beach 
County, Florida. 
2. 
This Complaint is brought under a fictitious name to protect the identity of 
Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse of a then 
minor. 
3. 
At all times material to this cause of action, Defendant owned a residence located 
at 358 El Brillo Way, Palm Beach, Palm Beach County, Florida. 
4. 
Defendant is presently a citizen of the United States Virgin Islands. Pursuant to 
the plea agreement entered by the Defendant in state court and the sentencing which occurred on 
June 30, 2008, Defendant is currently under community control in Palm Beach County, Florida. 
Seated 
Podhurst Orseck, PA. 
25 West noisier Street, Suite 800, Miami, FL 33130, Mush305.358.1900 Fax 305.1.58.2382 • Fort Lauderdale 954.463.4346 I 
EFTA00183820

' Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 2 of 19 
5. 
Defendant is an adult male born on January 20, 1953. 
6. 
This Court has jurisdiction over this action and the claims set forth herein 
pursuant to 18 !MI § 2255. 
7. 
This Court has venue of this action pursuant to 28 
1391(b), as a 
substantial part of the events giving rise to the claim occurred in this District. 
STATEMENT OF FACTS 
8. 
At all relevant times, Defendant was an adult male spanning the ages of 45 and 55 
years old. Defendant is known as a billionaire financier and money manager with a secret 
clientele limited exclusively to billionaires. He is a man of tremendous wealth, power, and 
influence. He owns a fleet of aircraft that includes a Gulfstream IV, a helicopter, and a Boeing 
727, as well as a fleet of motor vehicles. Until his incarceration pursuant to the plea entered and 
sentencing, which occurred on June 30, 2008, he maintained his principal place of residence in 
the largest dwelling in Manhattan, a 51,000-square-foot eight-story mansion on the Upper East 
Side. He also owns a $6.8 million mansion in Palm Beach, Florida, a $30 million 7,500-acre 
ranch in New Mexico he named "Zorro," a 70-acre private island known as Little St. James in 
the U.S. Virgin Islands, a mansion in London's Westminster neighborhood, and another 
residence in the Avenue Foch area of Paris. The allegations herein concern Defendant's conduct 
while at his lavish residence in Palm Beach and numerous other locations both nationally and 
internationally. 
9. 
Defendant has a sexual preference for underage minor girls. He engaged in a 
plan, scheme, or enterprise in which he gained access to countless vulnerable and relatively 
economically disadvantaged minor girls, and sexually assaulted, molested, and/or exploited these 
girls, and then gave them money. 
Podhurst Orseck, P.A. 
2 
25 West Hagler Stmt, Suite 800, Miami, Fl. 33130, Warn! 305358.2800 Fax 305.3582382 • Fort Laudetdale 954.4638346 
www.podhurstcom 
EFTA00183821

' Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 3 of 19 
10. 
Beginning in or around 1998 through in or around September 2007, Defendant 
used his resources and his influence over vulnerable minor girls to engage in a systematic pattern 
of sexually exploitative behavior. 
II. 
Defendant's plan and scheme reflected a particular pattern and method. 
Defendant coerced and enticed impressionable, vulnerable, and relatively economically less 
fortunate minor girls to participate in various acts of sexual misconduct that he committed upon 
them. Defendant's scheme involved the use of underage girls, as well as other individuals, to 
recruit underage girls. Defendant and/or an authorized agent would call and alert Defendant's 
assistants shortly before or after he arrived at his Palm Beach residence. His assistants would 
call economically disadvantaged and underage girls from West Palm Beach and surrounding 
areas who would be enticed by the money being offered and who Defendant and/or his assistants 
perceived as less likely to complain to authorities or have credibility issues if allegations of 
improper conduct were made. The then minor Plaintiff and other minor girls, some as young as 
14 years old, were transported to Defendant's Palm Beach mansion by Defendant's employees, 
agents, and/or assistants in order to provide Defendant with "massages." 
12. 
Many of the instances of illegal sexual conduct committed by Defendant were 
perpetrated with the assistance, support, and facilitation of at least three assistants who helped 
him orchestrate this child exploitation enterprise. These assistants would arrange times for 
underage girls to come to Defendant's residence, transport or cause the transportation of 
underage girls to Defendant's residence, escort the underage girls to the massage room where 
Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove 
their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the 
conclusion of each "massage appointment," and assist Defendant in taking nude photographs 
Podhurst Orseck, P.A. 
3 
I
25 West Plaster Street, State 800, Miami, FL 33130, Miami 305.35&2800 Fax 305358.2382 • Fort Lauderdale 95,1463.4346 
www.poclhursteom 
EFTA00183822

Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 4 of 19 
and/or videos of the underage girls with and/or without their knowledge. Defendant would pay 
the procurer of each girl's "appointment" hundreds of dollars. 
13. 
Defendant designed this scheme to secure a private place in Defendant's Palm 
Beach mansion where only persons employed and invited by Defendant would be present, so as 
to reduce the chance of detection of Defendant's sexual abuse and/or exploitation, as well as to 
make it more difficult for the minor girls to flee the premises and/or to credibly report his actions 
to law enforcement or other authorities. The girls were usually transported by his employee(s), 
agcnt(s), and/or assistant(s) and/or by taxicab(s) and/or motor vehicle(s) paid for by Defendant, 
which also made it difficult for the girls to flee his mansion. 
14. 
Upon her initial arrival at Defendant's Palm Beach mansion, each underage 
victim would generally be introduced to one of Defendant's assistants, who would gather the 
girl's personal contact information. The minor girl would be led up a remote flight of stairs to a 
room that contained a massage table and a large shower. 
15. 
At times, if it was the girl's first "massage" appointment, another female would 
be in the room to "lead the way." Generally the other female would leave, or Defendant would 
dismiss her. Often, Defendant would start his massage wearing only a small towel, which 
eventually would be removed. Defendant and/or the other female would direct the girl to 
massage him, giving the minor girl specific instructions as to where and how he wanted to be 
touched, and then direct her to remove her clothing. Defendant would then perform one or more 
lewd, lascivious, and sexual acts, including masturbation; fondling the minor's breasts and/or 
sexual organs; touching the minor's vulva, vagina, and/or anus with a vibrator, back massager, 
his finger(s), and/or his penis; digitally penetrating her vagina; performing intercourse, oral sex, 
and/or anal sex; and/or coercing or attempting to coerce the girl to engage in lewd acts and/or 
Podhurst Orseck, P.A. 
4 
25 West Flagler Street, Suite 800, Maud, FL 33130, Miami 3053581800 Fax 305158.2382 • Port Lauderdale 954.463.4346 
EFTA00183823

Case 9:10-cv-80309-WJZ Document 1 
Entered on FLSD Docket 03/09/2010 Page 5 of 19 
' • 
prostitution and/or enticing the then minor girl to engage in sexual acts with another female in 
Defendant's presence. The exact degree of molestation and frequency with which the sexual 
exploitations took place varied and is not yet completely known; however, Defendant committed 
such acts regularly on a daily basis and, in most instances, several times a day. In order to 
facilitate the daily exchanges of money for sexual assault and abuse, Defendant kept U.S. 
currency readily available. 
16. 
Defendant traveled out of Florida to Palm Beach for the purpose of luring 
minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to contact 
these minor girls for the purpose of coercing them into acts of prostitution and to enable himself 
to commit sexual battery against them and/or acts of lewdness in their presence, and he conspired 
with others, including his employee(s), assistant(s), driver(s), pilot(s), and/or agent(s), to 
facilitate these acts and to avoid police detection. Defendant's systematic pattern of sexually 
exploitative behavior described above also occurred in Defendant's other domestic and/or 
international residences, places of lodging, and/or modes of transportation. 
17. 
Consistent with the foregoing plan and scheme, Defendant used his money, 
wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff. 
A vulnerable young girl, Plaintiff was merely a seventeen year old high school student when she 
was first lured into Defendant's sexually exploitative world in or about January 2004. Plaintiff 
was recruited while at work by a co-worker, one of the minor victims Defendant paid to procure 
underage females. Plaintiff went to Defendant's Palm Beach mansion accompanied by this co-
worker. Upon arriving, Plaintiff was led by one of Defendant's assistants up a flight of stairs to a 
spa room with a shower and a massage table. Defendant entered this room wearing only a towel. 
Defendant suddenly removed his towel, exposing his naked body, and then lay on the massage 
Podhurst Orseck, P.A. 
5 
25 West Hagler Street, Suite 800, Miami, FL 33)30, Miami 305.3582800 Pax 305358.2382 • Fort Lauderdale 954.463.4346 I 
www.podburattom 
EFTA00183824

' Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 6 of 19 
table. Defendant told Plaintiff to massage his back and take off her clothing, which she refused 
to do. Defendant then began to try to touch the minor Plaintiff and/or take off her clothing. 
After Defendant's relentless pawing, she reluctantly removed some of her clothing. During this 
encounter, Defendant turned over on his back and fondled Plaintiff's breasts, despite her 
repeatedly telling him not to do so. As Plaintiff massaged Defendant, Defendant proceeded to 
masturbate until ejaculation. Defendant then paid Plaintiff two hundred dollars, and Plaintiff 
was escorted out of Defendant's mansion and left Defendant's property. 
18. 
A similar pattern of grooming continued, and the sexual exploitation 
progressively escalated, over the course of approximately seventeen months during which 
Defendant would often travel to Palm Beach. Prior to arriving and while in Palm Beach, 
Defendant and/or his agent(s) would frequently call Plaintiff at her home telephone number 
and/or other telephone numbers, arranging for encounters with her for Defendant, sometimes 
twice daily. While usually such contacts were made by his assistants, Defendant personally 
called Plaintiff repeatedly, despite being told to leave Plaintiff alone. After the first few 
encounters, Defendant coerced Plaintiff to remove all her clothing, and Defendant penetrated the 
minor Plaintiff's vagina digitally. Defendant sexually abused and/or battered and/or exploited 
Plaintiff at least a hundred times between approximately January 2004 and May 2005. Such 
exploitation included, but was not limited to, Defendant's sexual abuse and battery of Plaintiff 
with vibrator(s), back massager(s), his finger(s), and his penis. At times, Defendant manipulated 
Plaintiff to interact sexually with another female. During one encounter, Defendant penetrated 
the minor Plaintiff's vagina with his penis, all the while narrating and demonstrating his sexual 
battery of Plaintiff to another female present in the room. While some of the precise dates that 
Defendant's acts of sexual exploitation occurred arc unknown to Plaintiff, these dates are known 
Poilhurst Orseck, P.A. 
6 
25 West Flagler Street, Suite 800, MiamiL FL 33130, Miami 305.358.280D Fax 305.358.2382 • Fort Lauderdale 954.4&3A346 l 
www.podhunt.com 
EFTA00183825

• Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 7 of 19 
to Defendant, as he and/or his assistants kept written records, some of which are in the custody 
of law enforcement, of each instance in which he committed lewd acts upon minor girls, 
including the then minor Plaintiff. 
19. 
Defendant's preference for underage girls was well-known to those who regularly 
procured them for him. The above-described acts of abuse began to occur during a time when 
Defendant knew that Plaintiff was a minor. Defendant, at all times material to this cause of 
action, knew and/or should have known of Plaintiff's age of minority. In fact, Defendant 
repeatedly urged the minor Plaintiff to become legally emancipated in order to accompany him 
as he traveled, both nationally and internationally. Additionally, Defendant, knowing that 
Plaintiff was merely seventeen years old, lured her by inviting her to stay with him at his 
mansion in Manhattan and arranging and/or paying for airplane tickets, theater tickets, and a 
personal chauffeur as gifts for her upcoming birthday. 
20. 
As part of Defendant's persistent process of grooming Plaintiff and immersing her 
in his lewd and abusive lifestyle, Defendant regularly showered the ado/. cent Plaintiff with 
gifts, including, but not limited to lingerie, flowers, bikini bathing suit(s), art book(s), purse(s), 
envelopes of U.S. currency, use of a car, and/or othcr accoutrements. 
21. 
Defendant possessed photographs of nude underage girls, some of which may 
have been taken with hidden cameras set up in his residence in Palm Beach. On the day of 
Defendant's arrest, police found two hidden cameras and photographs of underage girls in 
Defendant's mansion. Defendant took lewd photographs of Plaintiff with his hidden cameras 
and transported lewd photographs of Plaintiff and other victims elsewhere using a facility or 
means of interstate and/or foreign commerce. On one occasion, Defendant manipulated the 
minor Plaintiff to pose nude for him and photographed her using several rolls of film. One or 
Podhurst Orseck, P.A. 
7 
25 West Flagler Street Suite 800. taunt P1.33130, Miami 305.358.2800 Fax 305,3582192 • Fun Lauderdale 959.463.4396 
podhurst.com 
EFTA00183826

' Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 8 of 19 
more of those nude photographs of Plaintiff that were taken by the Defendant when she was a 
minor were confiscated by the Palm Beach Police Department during its execution of a search 
warrant of Defendant's Palm Beach mansion on October 20, 2005. 
22. 
Defendant was particularly skillful at discerning his minor victims' respective 
hopes, dreams, and ambitions. As he did with many of his victims, Defendant lured Plaintiff 
early-on with modeling opportunities, impressing her with his modeling business and contacts 
with supermodels, indicating that he could help her with a modeling career. 
23. 
Knowing that the minor Plaintiff was an excellent student and desired to attend 
New York University or Columbia University, Defendant pretended to show great interest in her 
college admission, and offered to help her with her applications and to assist her with her 
tuition. Defendant had told Plaintiff of his substantial connections within the academic 
community, a matter about which he often bragged. Defendant took it upon himself to take 
control of Plaintiffs college application process and led Plaintiff to believe that he was sincere 
about helping her. Even though she had earned a Bright Futures Scholarship to the Florida 
college of her choice, Defendant insisted that she would not need it, and that, with his 
involvement, she would be admitted into one or both of the universities in New York. As a 
result of Defendant's manipulation, Plaintiff did not apply timely for the Bright Futures 
Scholarship or to any college, and therefore missed the fall semester of her freshman year. When 
the Palm Beach Police Department executed the search warrant on Defendant's mansion, among 
the artifacts found and confiscated were Plaintiffs high school transcript. 
24. 
In June 2008, after an investigation by the Palm Beach Police Department, the 
State Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's 
Office, Defendant entered pleas of "guilty" to one count of solicitation of prostitution, in 
Podhurst Orseck, P.A. 
8 
25 West Flagler Street, Suite ea Miami, FL 33130, Miami 305.358.2800 Fax 305359.2382 • Fort Lauderdale 954.4634346 I 
www.;xxlituraleom 
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Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 9 of 19 
•••••••• 
violation of Fla. Stat. § 796.07, and one count of solicitation of a minor to engage in prostitution, 
in violation of Fla. Stat. § 796.03 in the Fifteenth Judicial Circuit in Palm Beach County, Florida. 
25. 
As a condition of that plea, Defendant entered into a Non-Prosecution Agreement, 
Addendum, and Affirmation (collectively, the "NPA") with the United States Attorney's Office 
for the Southern District of Florida on September 24, 2007, October 29, 2007, and December 7, 
2007, respectively. In so doing, Defendant acknowledged that Plaintiff was one of his victims 
and agreed to the following provisions of the NPA : 
8. If any of the [acknowledged victims] elects to file suit pursuant to 18 
§2255, Epstein will not contest the jurisdiction of the United Statcs District Court 
for the Southern District of Florida over his person and/or the subject matter, and 
Epstein waives his right to contest liability and also waives his right to contest 
damages up to an amount agreed to between the identified individual and E stein, 
so long as the identified individual elects to proceed exclusively under 18 
§2255, and agrees to waive any other claim for damages, whether pursuant to 
state, federal or common law. 
II
:wept as to those individuals who elect to proceed exclusively under 18 
§2255, as set forth in paragraph (8), supra, neither Epstein's signature on 
this agreement, nor its terms, nor any resulting waivers or settlements by Epstein 
are to be construed as admissions of evidence or evidence of civil or criminal 
liability or a waive of any jurisdictional or other defense as to any person, whether 
or not her name appears on the list provided by the United States (emphasis 
added). 
26. 
Plaintiff was among the individuals identified by the United States Attorney's 
Office as victims of Defendant upon whose testimony it intended to base its federal prosecution 
of Defendant for his illegal conduct. Consequently, Defendant is estopped by his state court plea 
and the Non-Prosecution Agreement from denying the acts alleged in this Complaint and must 
effectively admit liability to Plaintiff, ■ 
Doe No. 103. 
COUNT ONE 
Podhurst Orseck, P.A. 
9 
75 West Flagler Street, Suite 800, Mint FL 33130, Miami 305.358.2800 Fax 305358.2182 • Fort Lauderdale 954.463.4346 
vnwepoributsLcom 
EFTA00183828

' Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 10 of 19 
ii
i
(Cause of Action for Coercion and Enticement of Minor to En a ,e in Prostitution or 
Sexual Activity pursuant to 18 M. 
& 2255 in Violation of 18 
. & 2422(1)11 
27. 
Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the 
allegations contained in paragraphs 1 through 26 above. 
28. 
Defendant used a facility or means of interstate and/or foreign commerce to 
knowingly persuade, induce, entice, or coerce Plaintiff, when she was under the age of 18 years, 
to engage in prostitution and/or sexual activity for which any person can be charged with a 
criminal offense, or attempted to do so, pursuant to 18 
. § 2255 in violation of 18 
. § 
2422(b). 
29. 
Plaintiff was a victim of one or more offenses enumerated in 18 
. § 2255, 
and, as such, asserts a cause of action against Defendant pursuant to this Section of the United 
States Code. 
30. 
As a direct and proximate result of the offenses enumerated in 18 
. § 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical 
and psychological expenses, and Plaintiff will in the future incur additional medical and 
psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 
income in the future, and a loss of the capacity to enjoy life. These injuries arc permanent in 
nature, and Plaintiff will continue to suffer these losses in the future. 
Pocihurst Orseck, P.A. 
10 
25 West Flagkr Suet, Suite 800, Miami. FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4316 
www.podhurst.com 
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Case 9:10-cv-80309-WJZ Document 1 
Entered on FLSD Docket 03/09/2010 Page 11 of 19 
WHEREFORE, Plaintiff demands judgment against Defendant for all damages available 
under 18 
. § 2255, including, without limitation, actual and compensatory damages, 
attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, 
and hereby demands trial by jury on all issues triable as of right by a jury. 
COUNT TWO 
(Cause of Action for Travel with Intent to Enen/iii Illicit Sexual Conduct pursuant 
to 18 
2255 in Violation of 18 
. & 2423(19) 
31. 
Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the 
allegations contained in paragraphs I through 26 above. 
32. 
Defendant traveled in interstate and/or foreign commerce for the purpose of 
engaging in illicit sexual conduct, as defined in 18 
§ 2423(f), with minor females, 
including the then minor Plaintiff, in violation of 18 
§ 2423(6). 
33. 
Plaintiff was a victim of one or more offenses enumerated in 18 
. § 2255, 
and, as such, asserts a cause of action against Defendant pursuant to this Section of the United 
States Code. 
34. 
As a direct and proximate result of the offenses enumerated in 18 
§ 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical 
and psychological expenses, and Plaintiff will in the future incur additional medical and 
psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 
Podhurst Orseck, P.A. 
11 
I
25 West Flatter Sheet, Suite 800, Miami, FL 33130, Miami 306358.2800 Fax 306.358.2382 • Fort Lauderdale 954.463.4346 
www.podluust.com 
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' Case 9:10-cv-80309-WJZ Document 1 Entered on FLSD Docket 03/09/2010 Page 12 of 19 
income in the future, and a loss of the capacity to enjoy life. These injur;es are permanent in 
nature, and Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff demands judgment against Defendant for all damages available 
under 18 
§ 2255, including, without limitation, actual and compensatory damages, 
attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, 
and hereby demands trial by jury on all issues triable as of right by a jury. 
COUNT THREE 
(Cause of Action for Sexual Exploitation of Children pursuant to 18 
& 2255 in 
Violation of 1S= 
& 22511 
35. 
Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the 
allegations contained in paragraphs 1 through 26 above. 
36. 
Defendant knowingly persuaded, induced, enticed, or coerced the then minor 
Plaintiff to engage in sexually explicit conduct for the purpose of producing a visual depiction of 
such conduct, in violation of 18 
. § 2251. 
37. 
Plaintiff was a victim of one or more offenses enumerated in 18 
§ 2255, 
and, as such, asserts a cause of action against Defendant pursuant to this Section of the United 
States Code. 
38. 
As a direct and proximate result of the offenses enumerated in 18 
§ 2255 
being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, 
and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, 
loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, 
separation from her family, and other damages associated with Defendant's manipulating and 
luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical 
Poclhurst Orseck, P.A. 
12 
25 West Hagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 306358.2382 • rod Lauderdale 954.463.4346 
 
www.podhuracorn 
EFTA00183831