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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 
M.J., 
Plaintiff, 
vs. 
JEFFREY EPSTEIN and 
SARAH KELLEN, 
Defendants. 
COMPLAINT 
Plaintiff, M.J., by and through her undersigned counsel, sues the Defendants, Jeffrey 
Epstein and Sarah Kellen, and alleges: 
I. This is an action in an amount in excess of $15,000.00, exclusive of interest and costs and 
is within the jurisdictional limits of this Court. 
2. 
This Complaint is brought under a fictitious name in order to protect the identity of the 
Plaintiff because this Complaint makes allegations of sensitive nature of offenses against a then 
minor child. 
3. 
At all times material to this cause of action, the Plaintiff, M.J. (hereinafter referred to as 
"Plaintiff"), was a resident of Palm Beach County, Florida. 
4. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence 
located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida. 
5. 
Defendant, Jeffrey Epstein, is currently a citizen of the United States Virgin Islands. 
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6. 
At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult 
male born in 1953. 
7. 
Defendant, Sarah Kellen, is currently a citizen of New York, where she currently resides. 
8. 
At all times material, the Defendants Jeffrey Epstein and Sarah Kellen both owed a duty 
unto Plaintiff to treat her in a non-negligent manner and to not commit or conspire to commit 
intentional or tortious illegal acts against her. 
FACTUAL ALLEGATIONS 
9. 
At all times material, Defendant, Jeffrey Epstein, was an adult male, over 50 years old. 
Defendant Epstein is known as a billionaire, yet even those closest to him, including family 
members, long time employees and those that he considers his closest friends have no idea what 
he does or did to earn money to support his lifestyle. 
10. Defendant Epstein owns, directly or through nominee individuals used to conceal his 
interests, a fleet of airplanes, motor vehicles, boats and a helicopter. He owns numerous 
properties and homes, including a 51,000-square-foot mansion in Manhattan, a $30 Million 
7,500-acre ranch in New Mexico, a 70-acre private island formerly known as Little St. James in 
St. Thomas, U.S. Virgin Islands (he is alleged to have renamed this island Little St. Jeff's after 
himself), a mansion in London, England, a home in Paris, France, and a mansion in Palm Beach 
County, FL. The allegations herein primarily concern the defendant's conduct while at his 
mansion in Palm Beach County, FL. 
II. Defendant Epstein has a sexual preference and obsession for underage minor females, 
specifically targeting female children age 12 to 17, and Defendant Epstein acts on that obsession 
by luring underage minor females to him where he attempts to sexually molest and batter these 
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underage minor females on an everyday basis, oftentimes 2 or 3 different underage minor 
females on one day. 
12. Sometime prior to 1998, Defendant Epstein devised a complex plan, scheme and criminal 
enterprise to gain access to countless underage minor females, some as young as 12 years old, for 
the purpose of coercing the minor females into various acts of sexual misconduct that he 
committed upon them. 
His enterprise operated with a definite hierarchal structure with his 
various employees/assistants and associates, including Defendant Sarah Kellen, Jean Luc Brunel, 
Ghislaine Maxwell, Leslie Groff. Adriana Ross. Nadia Marcinkova, various housekeepers, 
butlers and pilots, performing their respective roles to ensure the goals of the enterprise: operate 
an organized and efficient system to maximize the number of underage minor females for 
Defendant Epstein (and others) to sexually abuse and exploit while avoiding law enforcement 
detection. 
13. Defendant Epstein, with help from his assistants and associates, recruited and procured 
underage minor females, lured them to one of his mansions, had the underage minor female 
taken to a room to be alone with him, then he would appear naked or wearing only a towel and 
sexually batter or otherwise sexually exploit the underage minor female. He would then pay the 
underage minor female for the sex acts he committed against her (typically between $200 and 
$300 per molestation session, or as his criminal enterprise commonly refers to it — per 
"massage"). Prior to leaving, Defendant Epstein's assistant would get the phone number of the 
underage minor female and input it into his computer system or otherwise keep it on file. He 
would then offer the underage minor female to return to his house to make money in exchange 
for him committing sexual acts against her, and he also typically informed her of another option - 
make more money recruiting and procuring other underage minor females for him to sexually 
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abuse. He would tell the underage minor female that he will pay her for each underage minor 
female that she brings to him (again, typically between $200 and $300), and he encouraged, and 
oftentimes forcefully demanded, her to bring him as many underage minor females as she was 
able. Through this general pitch, Defendant Epstein created a vast pyramid of underage minor 
females recruiting and procuring other underage minor females for his purpose of coercing these 
underage females into sexual acts for money. 
14. Defendants Epstein and Kellen and the criminal enterprise specifically targeted 
underprivileged and economically disadvantaged children to sexually exploit and molest and 
otherwise prey upon the vulnerabilities of these young girls. 
15. It is unknown exactly how long Defendant Epstein's aforementioned criminal enterprise 
operated, although information and belief indicates that it was continuously and actively in 
operation from at least 1998 through Defendant Epstein's criminal arrest in 2006. 
16. The complete list of underage minor females that were sexually abused by Defendant 
Epstein over the years is believed to have been kept on a computer system controlled by 
Defendant Epstein and accessible by several of his employees, including Defendant Sarah 
Kellen. It is also known that much of the data regarding the names, addresses and whereabouts 
of each underage minor female was input by one of his assistants, including Defendant Kellen. 
17. Defendant Sarah Kellen was listed in the Federal Non-prosecution Agreement related to 
Defendant Epstein's criminal plea on sex charges against minors as a criminal co-conspirator for 
her role in the criminal activity that was committed by Defendant Epstein against many underage 
minor females. She was employed by Defendant Epstein to maintain his schedule, arrange for 
underage minor females to be with Defendant Epstein, maintain contact with the underage minor 
females, schedule the underage minor females' transportation to and from Defendant Epstein's 
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mansion, and greet the underage minor female at the house before taking her upstairs to be alone 
with Mr. Epstein. 
Upon information and belief, Defendant Kellen remains employed by 
Defendant Epstein and continues to work for Defendant Epstein in furtherance of the goals of the 
criminal enterprise. 
18. Defendant Epstein used his vast wealth and power to lure underprivileged minor females 
to him, and to coerce them into prostitution once he was alone with the underage minor female. 
He sexually battered, molested, committed lewd and lascivious acts upon and otherwise 
exploited numerous underage minor females and then gave them money. So long as the 
underage minor female followed his demands and advances, he assumed the role of a friend or 
mentor or father figure to the minor female in an attempt to groom the minor female; however, if 
any minor female resisted his sexual advances, Defendant Epstein became frustrated, angry and 
threatening towards the underage minor. His intent was to groom each minor female into 
engaging in sexual acts with him as well as to "work" for him, i.c. bring him other underage 
minor females to sexually molest, batter and exploit. He was masterful in his exploitation and 
grooming of these minor females with an additional intent of gaining trust and cooperation from 
these minors to prevent any one of them from reporting his criminal acts to law enforcement. 
Certain of his many co-conspirator associates, including Ghislane Maxwell and Jean Luc Brunel, 
helped in this recruiting process by creating the impression that legitimate modeling 
opportunities were available for the minor females. 
19. Through information and belief, Defendant Epstein has been successful in luring 
hundreds of underage minor girls to him for the purpose of him (and sometimes others) sexually 
abusing them. He intentionally preys upon underage minor females that are middle school or 
high school children who are not working prostitutes, and he takes pleasure in using his power 
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and influence to coerce these minor females into acts of prostitution with him personally and 
sometimes with his friends and associates as well, including but not limited to Ghislaine 
Maxwell and Nadia Marcinkova. 
20. Over time, Defendant Epstein fine-tuned his operation to further his goals of gaining 
access to a greater number and variety of underage girls while avoiding detection by law 
enforcement. 
He also provided the roadmap for his enterprise should the illegal sexual 
exploitation of the enterprise be detected — he or the criminal enterprise would (and did) retain 
legal representation for each criminal enterprise member who would instruct each member to 
invoke his/her S'h amendment rights, they would hide behind the 5th amendment to avoid turning 
over incriminating materials (i.e. computer system that logged information about the underage 
sexual molestation victims, scheduling books, message pads, and tangible items such as vibrators 
and dildos), they would destroy evidence and refuse all cooperation with law enforcement. 
21. The plan and scheme was developed by Defendant Epstein, and he and his assistants and 
associates carried it out with each underage minor female in a well-planned and ritualistic 
manner; Epstein ran this criminal enterprise as an experienced Mob boss would run any 
organized crime family — in a well-planned, organized, arrogant and ruthless manner, with 
complete cooperation from his co-conspirator associates and underlings and an absolute 
dedication to carrying out the illegal operations of the criminal enterprise. 
22. Defendant Epstein frequently traveled between his various mansions and either he or an 
authorized agent would call to inform a recruiter, assistant, or scheduler at his next destination as 
to his arrival time. His scheduler, usually Defendant Sarah Kellen, would then contact an 
underage minor female and schedule her to be at Defendant Epstein's mansion or to bring 
another underage minor female to his mansion at a particular time. Once the minor female was 
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brought to Defendant Epstein's residence, she was greeted at the door of the mansion and lead 
inside by one of Defendant Epstein's employees, oftentimes Defendant Sarah Kellen. 
23. Defendant Sarah Kellen would lead the underage minor female up to Defendant Epstein's 
room and leave the underage minor alone in the room. Defendant, Jeffrey Epstein, himself would 
then appear naked or wearing only a towel. He would then demand a massage and during the 
massage he would attempt, usually successfully, to perform one or more lewd, lascivious, and 
sexual acts, including, but not limited to, masturbation, touching of the underage minor female's 
sexual organs, coercing or forcing the underage minor female to perform sex acts with him, 
using vibrators or sexual toys on the underage minor female, coercing the underage minor female 
into sexual intercourse with himself or others, and digitally penetrating the underage minor 
female. He would then give the Plaintiff money for engaging in this sexual activity. 
24. Consistent with Defendants Epstein and Kellen's foregoing scheme or plan, in or around 
the summer of 2002, Plaintiff, an economically poor and vulnerable child, was told by another 
one of Epstein's underage minor sex abuse victims, that she could make $300 cash by giving an 
old man a massage on Palm Beach. 
25. Plaintiff's then minor acquaintance (also a sexual abuse victim of Epstein) telephoned 
Defendant Epstein and scheduled for Plaintiff to go to Defendant Epstein's house to give him a 
massage. During that call, Defendant Epstein himself got on the phone and spoke with Plaintiff 
MJ and asked her personally to come to his mansion in Palm Beach. 
26. Plaintiff then took a taxicab to Defendant Epstein's mansion and was greeted by 
Epstein's top assistant, Defendant Sarah Kellen. 
27. Defendant Kellen, in furtherance of the scheme to exploit Plaintiff, escorted Plaintiff 
upstairs to Defendant Jeffrey Epstein's large bathroom, where Defendant Kellen set up the 
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massage table and showed Plaintiff different massage lotions to use. Defendant Kellen then left 
Plaintiff alone in the room. Plaintiff was alone in Defendant Epstein's bathroom until Defendant 
Jeffrey Epstein emerged wearing only a towel. 
28. Defendant Epstein then walked to the massage table that was already open in the room. 
He lied face down on the table and told Plaintiff to start massaging him, at which time he 
engaged in a conversation with Plaintiff. During the conversation, Defendant Epstein asked 
Plaintiff her age and she told him she had recently turned 16. 
29. Consistent with all of Defendant Epstein's known underage minor female victims, 
Plaintiff had no massage experience whatsoever and she informed him of that, and Defendant 
Epstein began instructing Plaintiff on how he liked his massage. 
30. After approximately 15 minutes, Defendant Epstein turned over onto his back, and he 
commanded Plaintiff to massage his chest. 
31. Defendant Epstein then suddenly removed his towel and his penis was already erect. He 
then commanded Plaintiff to remove her shin and bra and to begin "pinching his nipples" as he 
began masturbating with his right hand. 
32. As he was masturbating, Defendant Epstein began fondling Plaintiffs breasts. 
33. Defendant Jeffrey Epstein, while masturbating with his right hand, reached out his left 
hand and grabbed Plaintiff's vagina and butt over her clothes. Plaintiff pushed Defendant's hand 
away and told him repeatedly not to touch her like that. Epstein was persistent in his attempt to 
grab Plaintiff's vagina and continued to grab her vagina and butt on multiple occasions after she 
told him not to. 
34. Defendant Epstein continued to masturbate his exposed penis until he ejaculated in front 
of the then minor Plaintiff. 
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35. Plaintiff was shocked and embarrassed by the events and Defendant Epstein talked to her 
to persuade her that everything he was doing with he was normal. 
36. Epstein paid Plaintiff $300 for allowing him to grope her and masturbate in her presence. 
37. Plaintiff returned to Epstein's home on approximately 20 occasions. On each occasion 
Epstein grabbed Plaintiff's bare breasts, exposed his penis, masturbated and ejaculated in 
Plaintiff's presence, and paid her $300 each time. 
38. Defendant Epstein coerced Plaintiff into acts of prostitution, preying on her low 
economic status and troubled upbringing, complimenting Plaintiff for being "special" to him and 
having a "very pretty body" and making promises to Plaintiff such as — he told Plaintiff that if 
she graduated high school, then he would buy her a computer, something that she wanted yet 
could not afford. 
39. On multiple occasions Defendant Epstein pressured Plaintiff to bring him other underage 
minor females to abuse; he told Plaintiff that he would pay her $300 for each girl she brought 
him, but Plaintiff refused to bring other girls. 
40. Defendant Epstein told Plaintiff that he would pay her more money if she would give him 
oral sex and that he would pay her $600 for actual sexual intercourse. Plaintiff refused. 
41. Defendant Epstein personally called Plaintiff at least five times to tell her when she 
should be at his house to "work" or give him a "massage" (Epstein's criminal enterprise's 
learned code words for paying minors for Epstein and others to interact with them sexually). 
42. Every other time (approximately 15) Defendant Kellen called to inform Plaintiff of the 
date and time when she needed and was expected to be at Epstein's mansion to "work". 
43. The acts referenced above, committed by Defendant, Jeffrey Epstein, against the then 
minor Plaintiff were committed in violation of numerous State and Federal criminal statutes 
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condemning battery, assault and the exploitation of minor children, contributing to the 
delinquency of a minor and other crimes, specifically including, but not limited to, those criminal 
offenses outlined in Chapters 796, 800, and 827 of the Florida Statutes, as well as those 
designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §796.09, §39.01, §450.151, 
and §827.04. 
44. The above-described acts took place in Palm Beach County, Florida at the residence of 
the Defendant, Jeffrey Epstein. Any assertions by Defendants, Jeffrey Epstein and Sarah Kellen, 
that they were unaware of the age of the then minor Plaintiff are belied by their actions and 
rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual 
exploitation and abuse of a minor child. The Defendants, Jeffrey Epstein and Sarah Kellen, at all 
times material to this cause of action, knew and should have known of the Plaintiffs minority as 
Plaintiff specifically told Epstein her age and Defendant Epstein and criminal organization has a 
history of seeking out underage minor children to sexually abuse. In fact, one primary goal of 
the organization is to sexually abuse females who are under the age of 18, and oftentimes 
Defendant Epstein has turned away females (i.e. refused to engage in sexual acts with them) for 
being "too old" once she reaches 18 years of age, and he has reprimanded girls for bringing him 
other girls who are over the age of majority. 
45. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, Defendant 
Epstein entered pleas of "guilty" to various Florida State crimes related to his exploitation of 
minors for sex. 
46. As a condition of that plea and in exchange for the Federal Government entering into a 
Non-Prosecution Agreement with Defendant Epstein, wherein the Federal Government agreed to 
effectively stay any prosecution of Jeffrey Epstein, Sarah Kellen and other criminal co-
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conspirators Nadia Marcinkova and Leslie Groff, Defendant Epstein agreed to admit that 
approximately 40 underage minor females, whose names were provided to Defendant Epstein, 
were his victims. Plaintiff was not included in that list as she moved away from the West Palm 
Beach area in part to escape from Epstein, and she has lived in fear of Epstein and his 
organization and has not yet been contacted by law enforcement. 
47. Beginning in or about June 2008 and continuing to the present time, defendant Epstein 
has been aware he faces significant financial liability for his sexual offenses, both to MJ and to 
many other similarly-situated girls whom he abused. MJ and these other girls are creditors of 
Epstein, in that have filed and can file tort actions against him under both Florida and Federal 
laws. Accordingly, Epstein has conveyed substantial assets and property into the names of other 
persons and into overseas bank accounts and other financial institutions. These assets and 
properties could have been attachable and used to pay the debts owed to MJ and to the other girls 
that Epstein has abused. 
48. As an example of the fraudulent conveyances that Epstein has attempted, in 
approximately October 2009, Epstein placed his personal 727 aircraft up for sale, with the intent 
that the proceeds of that sale would be hidden so that MJ and other creditors of Epstein would 
not be able to secure payment from that substantial asset. 
49. While Epstein is clearly distinct from the criminal enterprise that he oversees that asset, 
as well as his other airplanes and helicopters and other assets, have been used continuously and 
repeatedly to further the interest and endeavors of Epstein and his criminal enterprise. 
50. As another example of the fraudulent transfers that Epstein has made, Epstein has titled a 
Ford F-I50 Truck in the name of Larry Visoki (Epstein's personal pilot). Visoski was unaware 
that the truck was titled in his name when he was questioned under oath in a deposition. 
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51. In approximately 2009, Defendant Epstein purchased a $68,000 Land Rover and 
registered it in Visoski's name with the intent to hide this asset from MJ and other creditors. 
52. In approximately 2009, Defendant Epstein purchased a Mercedes-Benz 2005 by wiring 
funds to Visoski and then placing the car in Visoski's name. 
53. In approximately 2009, Defendant Epstein bought a Jaguar X-Type 2005 so that he 
(Epstein) would have another car around Palm Beach available for his friends to use and then 
placed the car in Visoski's name. 
54. In approximately September 2009, Visoski attempted to sell a Ferrari owned by Epstein 
for $159,000. Epstein intended for the sale to hide the value of this Ferrari and prevent MJ and 
other creditors from recovering from him. 
55. 
Epstein is concealing substantial assets through a new corporation, Shmitka Air, Inc., 
whose representative is Larry Visoski. In September 2010, Epstein attempted to sell a 1999 Bell 
Helicopter for approximately $1,900,000. This sale was an attempt to prevent MJ and other 
creditors from recovering from him. 
56. Epstein is also concealing substantial assets through an entity known at JEGE, Inc. He is 
currently attempting to sell an aircraft for $10,000,000 through that entity in an attempt to 
prevent MJ and other creditors from recovering from him. 
57. Through information and belief, Epstein and/or his criminal enterprise provides the 
financial support for his various employees, co-conspirators, other criminal enterprise members 
and associates. 
58. In addition to Epstein's various houses, he owns or controls other condominiums, 
including approximately 8 to 10 units at 301 East 66 Street, in New York City, where certain of 
his or his Criminal Enterprise associates live or reside, including Jean Luc Brunel, Nadia 
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Marcinkova, Sarah Kellen, and at times various underage minor girls are stashed at this location 
as well. 
59. Defendant Epstein has numerous overseas contacts and accounts and sophistication in 
international business transactions. He previously served as a trader at Bcar Steams and founded 
his own financial management firm, J. Epstein and Col. (later called Financial Trust Co.) located 
on his private island in the U.S. Virgin Islands where, until his recent incarceration, according to 
him he allegedly managed the assets of billionaire clients. 
60. After extensive investigation into Epstein's employment history, including questioning of 
Epstein's family, those whom Epstein considers friends and longtime employees of Epstein, the 
only known client of Epstein was Limited, Inc. Founder Leslie Wexner, although it is believed 
that even that relationship has been severed. No other legitimate means of income have been 
reported. 
COUNT I 
BATTERY AGAINST DEFENDANT EPSTEIN 
61. Plaintiff M.J. adopts and =lieges paragraphs I through 60 above. 
62. In the summer of 2002, just after Plaintiff turned 16 years old, Defendant Epstein 
committed battery against Plaintiff when he intentionally touched intimate areas of her body and 
person in an offensive manner while she was a minor child. 
63. Defendant Epstein intentionally touched Plaintiff MJ's private areas multiple times 
against the will of MJ. 
64. Defendant Epstein's tortious commission of battery upon Plaintiff was done willfully. 
65. As a direct and proximate result of the offenses committed by Defendant Epstein against 
the then minor Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain 
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and suffering, emotional distress, psychological and psychiatric trauma, mental anguish, 
humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of 
life, invasion of her privacy and other damages associated with Defendant's manipulation and 
leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and 
psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 
income in the future, and loss of proper and complete education. These injuries are permanent in 
nature and Plaintiff MJ will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff MJ demands judgment against Defendant Epstein for 
compensatory damages, punitive damages and such other relief as this Court deems proper and 
hereby demands trial by jury on all issues triable as of right by a jury. 
COUNT II 
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 
AGAINST DEFENDANT EPSTEIN 
66. The Plaintiff adopts and realleges paragraphs 1 through 60 above. 
67. Defendant Epstein's extreme and outrageous conduct towards the then minor Plaintiff 
was intentional and reckless. 
68. Defendant Epstein acted with the intent to cause severe emotional distress or with 
reckless disregard for the high probability of causing severe emotional distress. 
69. As a direct and proximate result of the offenses committed by Defendant Epstein against 
the then minor Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain 
and suffering, emotional distress, psychological and psychiatric trauma, mental anguish, 
humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of 
life, invasion of her privacy and other damages associated with Defendant's manipulation and 
leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and 
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psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 
income in the future, loss of proper and complete education. These injuries are permanent in 
nature and Plaintiff MJ will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff M.J. demands judgment against Defendant Epstein for 
compensatory damages, punitive damages and such other relief as this Court deems proper and 
hereby demands trial by jury on all issues triable as of right by a jury. 
COUNT III 
CONSPIRACY TO COMMIT TORTIOUS ASSAULT OR BATTERY AGAINST 
DEFENDANT SARAH KELLEN 
70. The Plaintiff adopts and realleges paragraphs I through 60 above. 
71. Defendant Kellen is one of Defendant Epstein's top assistants, as referenced previously 
in this Complaint. Defendant Epstein, Defendant Kellen and others reached an agreement 
amongst and between them and otherwise conspired for the purpose of allowing Defendant 
Epstein and others to commit the tortious and illegal acts described above against Plaintiff MJ. 
72. Defendant Kellen aided, abetted and assisted Defendant Epstein in his organized scheme 
and plan to sexually exploit Plaintiff and commit battery against her and/or commit or attempt to 
commit numerous other crimes against her, including coercing her into prostitution. 
73. Defendant Kellen conspired with Defendant Epstein to commit tortious and illegal 
conduct against Plaintiff, and in furtherance of the conspiracy Kellen specifically engaged in 
overt acts such as contacting Plaintiff MJ on many occasions, scheduling the then minor 
Plaintiffs appointment for a "massage" knowing that Defendant Epstein was going to commit 
battery against Plaintiff, attempt sexual battery against Plaintiff, and force her into prostitution 
and otherwise did everything in her ability to conceal the illegal operation and refuse cooperation 
with law enforcement. 
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74. Additionally, Defendant Kellen greeted Plaintiff on the occasions when Plaintiff arrived 
at Epstein's home and personally lead Plaintiff to Defendant Epstein's bathroom where Epstein 
appeared for the purposes of committing crimes against Plaintiff. 
75. Defendant Epstein's battery against Plaintiff was facilitated by Defendant Kellen and the 
conspiracy resulted in the various aforementioned crimes being committed against Plaintiff MJ 
as well as many other underage minor females. 
76. As a direct and proximate result of Defendant, Sarah Kellen's, participation in the 
aforementioned conspiracy, Plaintiff, MJ, she has in the past suffered and will in the future suffer 
injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental 
anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of 
enjoyment of life, invasion of her privacy and other damages associated with Defendant's 
manipulation and leading her into a perverse and unhealthy way of life. Plaintiff will incur 
medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the 
capacity to earn income in the future, loss of proper and complete education. These injuries are 
permanent in nature and Plaintiff MJ will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff MJ demands judgment against Defendant Sarah Kellen for 
compensatory damages, punitive damages and such other relief as this Court deems proper and 
hereby demands trial by jury on all issues triable as of right by a jury. 
COUNTS IV THROUGH XXIII 
CAUSES OF ACTION AGAINST DEFENDANTS EPSTEIN AND KELLEN PURSUANT 
TO IS USC 42255 IN VIOLATION OF VARIOUS ENUMERATED OFFENSES 
CONTAINED WITHIN THAT FEDERAL STATUTE 
77. Plaintiff, MJ, adopts and realleges paragraphs I through 60 above. 
78. The allegations contained herein in Counts IV through XXIII are separate and distinct 
legal remedies. 
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79. As a condition of 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, entered into a Non-Prosecution Agreement with the Federal 
Government; that agreement governed not only Defendant Epstein's conduct but also the 
conduct of his "co-conspirators" including Defendant Kellen as she played an essential and 
criminal role in the commission of these offenses. 
80. The Plaintiff, MJ, was in fact 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, and against Defendant Kellen pursuant to this Section of the United States Code 
and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 
81. Specifically, Defendants Epstein and Kellen: 
(a) knowingly conspired with others known and unknown to use a facility or 
means of interstate commerce to knowingly persuade, induce, or entice minor females, 
including Plaintiff MJ, to engage in prostitution, in violation of title IS, United States 
Code, Section 2422(b). 
(b) knowingly and willfully conspired with others known and unknown to travel 
in interstate commerce for the purpose of engaging in illicit sexual conduct with minors, 
including Plaintiff MJ, as defined in 18 U.S.C. § 2423(f), with minor females, in violation 
of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United 
States Code, Section 2423(e); 
(c) used a facility or means of interstate or foreign commerce to knowingly 
persuade, induce, or entice minor females, including Plaintiff MJ, to engage in 
prostitution; in violation of Title 18, United States Code, Section 2422(b); 
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(d) traveled in interstate commerce for the purpose of engaging in illicit sexual 
conduct, as defined in 18 U.S.C. § 2423(f), with minor females, including Plaintiff MJ; in 
violation of Title 18, United States Code, Section 2423(b). 
82. As a direct and proximate result of the aforementioned criminal offenses enumerated in 
Title IS, United States Code, Section 2255, being committed against the then minor Plaintiff, 
Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain and suffering, 
emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, 
confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of life, invasion 
of her privacy and other damages associated with Defendant's manipulation and leading her into 
a perverse and unhealthy way of life. Plaintiff will incur medical and psychological expenses. 
These injuries are permanent in nature and Plaintiff MJ will continue to suffer these losses in the 
future. Plaintiff, M.J., has also incurred attorneys' fees. 
83. With regard to each of the following counts, Plaintiff suffered personal injury, as outlined 
above from the acts above, as a result of the violations of federal criminal law by Defendant 
Epstein enumerated in paragraph 33, on approximately 20 occasions, and while the dates are not 
all precisely documented or diaried by Plaintiff, Defendants Epstein and Kellen committed these 
crimes and inflicted said injuries on or about the following dates: 
COUNT IV 
August 2002 
COUNT V 
September 2002 
COUNT VI 
October 2002 
COUNT VII 
November 2002 
COUNT VIII 
December 2002 
COUNT IX 
January 2003 
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COUNT X 
February 2003 
COUNT XI 
March 2003 
COUNT XII 
April 2003 
COUNT XIII 
May 2003 
COUNT XIV 
June 2003 
COUNT XV 
July 2003 
COUNT XVI 
August 2003 
COUNT XVII 
September 2003 
COUNT XVIII 
October 2003 
COUNT XIX 
November 2003 
COUNT XX 
December 2003 
COUNT XXI 
January 2004 
COUNT XXII 
February 2004 
COUNT XXIII 
March 2004 
WHEREFORE, with regard to each and every one of these counts, Plaintiff, MJ, 
demands judgment against Defendant, Jeffrey Epstein, for compensatory damages, loss of 
income, a loss of the capacity to earn income in the future, attorney's fees, 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 XXIV 
Civil Remedy for Criminal Practices 
84. Plaintiff realleges paragraphs I through 60 above and for the purposes of this count 
incorporates and alleges the RICO Statement that has been filed contemporaneously herewith as 
Exhibit "A." 
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85. The allegations contained herein in Count XXIV are a separate and distinct legal remedy 
brought pursuant to Florida Statute 772.104(1) and (2). 
86. Defendant, Jeffrey Epstein, was associated with an enterprise, a group of individuals 
associated in fact although not a legal entity, which was comprised of at least Defendant Jeffrey 
Epstein, Sarah Kellen, Leslie Groff, Jean Luc Brunel, Ghislaine Maxwell, and Nadia Marcinkova 
(and likely many other yet unknown persons); Defendant Epstein participated in this enterprise, 
or conspired or endeavored to so participate, through a pattern of criminal activity in violation of 
Florida Statutes §772.103(3)-(4), as further outlined in detail in the RICO statement filed with 
this court. 
87. This enterprise was separate and distinct from Epstein himself and had a definite 
hierarchical structure. Epstein served informally but effectively as the leader, C.E.O. or "boss" 
of this organization similar to the way an experienced mob boss runs his organized crime family, 
directing his underlings how to recruit and procure underage girls for his sexual activities and the 
sexual activities of others, developing the use of slang or code words to be used to discuss the 
illegal activities of the organization, designing a plan or scheme to gain the cooperation of 
underage minor females, developing methods and techniques to otherwise avoid detection from 
law enforcement including making large charitable donations to law enforcement agencies, 
powerful politicians, businessmen and world leaders, associating with powerful social people 
and highly influential politicians and attorneys, gathering information to blackmail or extort 
powerful people, devising a plan to attack the credibility and character of anyone that dare unveil 
the illegal operations of the enterprise and to take an oath to remain silent and/or lie when 
confronted by law enforcement about the illegal operations and activities of the criminal 
organization. Epstein's key "lieutenant" in the local Palm Beach branch of the National 
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