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74. Additionally, Defendant 
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 
and the 
conspiracy resulted in the various aforementioned crimes being committed against Plaintiff ■ 
as well as many other underage minor females. 
76. As a direct and proximate result of Defendant, 
participation in the 
aforementioned conspiracy, Plaintiff,. 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■ will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff■ demands judgment against Defendant 
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 
PURSUANT 
TO 18 USC 82255 IN VIOLATION OF VARIOUS ENUMERATED OFFENSES 
CONTAINED WITHIN THAT FEDERAL STATUTE 
77. Plaintiff,. 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 
as she played an essential and 
criminal role in the commission of these offenses. 
80. The Plaintiff,■ 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 
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 
(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 18, 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(0, with minor females, including Plaintiff MJ; in 
violation of Title l8, United States Code, Section 2423(b). 
82. As a direct and proximate result of the aforementioned criminal offenses enumerated in 
Title 18, 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 Ewill continue to suffer these losses in the 
future. Plaintiff= 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 
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 XV III 
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, ■ 
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 )O(1V 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, 
Jean Luc Brunel, Ghislaine Maxwell, and 
(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 actii. 'tics 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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organization was 
who served as both his scheduler and a recruiter/procurer of the girls. 
also served as a recruiter and helped Epstein satisfy his criminal sexual desires by, 
on occasion, directly participating in sexual abuse and prostitution of the minor girls. Epstein 
also used otherwise-legitimate business activities to help further the purpose of the criminal 
enterprise. These apparently legitimate activities provided "cover" for Epstein and his associates 
to commit the crimes. Epstein and his associates maintained the appearance of running an 
upstanding investment business, as well as other legitimate businesses with connections to 
modeling agencies and other powerful business and political people, to discourage the minor 
girls from reporting the abuse to law enforcement. Ghislane Maxwell and Jean Luc Brunel 
helped to provide "cover" by creating the impression that legitimate modeling opportunities were 
available for the girls. There are many other known and unknown associates of the criminal 
organization, that worked throughout the country and possibly internationally, who performed 
functions to perpetuate the criminal activities of the organization. 
88. Defendant Jeffrey Epstein participated in this enterprise through a pattern of criminal 
activity in that he engaged in at least two incidents of criminal activity, as defined and required 
in Florida Statute 772.102 and as described below, that have the same or similar intents, results, 
accomplices, victims, or methods of commission and are not isolated incidents. 
89. Defendant Jeffrey Epstein engaged in criminal activity by committing, attempting to 
commit, conspiring to commit or soliciting, coercing or intimidating another person to commit 
one or more of the following predicate acts as outlined and defined in Florida Statute 772.102: 
(a) 
Procuring for prostitution, or causing to be prostituted, any person who is 
under the age of 18 years in violation of Florida Statutes Chapter 796.03; 
(b) 
Acts of battery in violation of Florida Statutes Chapter 784; 
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(c) 
Forcing, compelling or coercing another to become a prostitute in 
violation of Florida Statutes Chapter 796.04; 
(d) 
knowingly recruiting, enticing, harboring, transporting, providing or 
otherwise obtaining by any means a person, knowing that coercion would be used to 
cause that person to engage in prostitution in violation of Florida Statutes Chapter 
796.045; 
(e) 
tampering with a witness in violation of Florida Statutes Chapter 914.22; 
(f) 
altering, destroying, removing, or concealing records or documents or 
other evidence with the purpose to impair its verity or availability in violation of Florida 
Statutes Chapter 918.13; 
(g) 
maintaining a place (or more accurately "places") for the purpose of 
lewdness or prostitution; offering or securing another for the purpose of prostitution or 
for some other lewd or indecent act; receiving persons into his Palm Beach mansion for 
the purpose of prostitution or lewdness; directing, taking or transporting or agreeing to 
direct take or transport persons to his Palm Beach mansion with knowledge or reasonable 
belief that the purpose of such directing, taking or transporting was prostitution or 
lewdness; all in violation of Florida Statutes Chapter 796.07. 
90. The criminal acts of Defendant Epstein occurred repeatedly over a substantial period of 
time and were not isolated events. 
91. Under Defendant, Jeffrey Epstein's plan, scheme, and enterprise, Defendant, Jeffrey 
Epstein. paid employees and underlings, including but not limited to 
to bring him 
minor girls to his Palm Beach mansion in order for the Defendant to solicit, induce, coerce, 
entice, compel or force such girls to engage in acts of prostitution and sexual misconduct with 
22 
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Defendant Epstein and sometimes 
and to otherwise commit acts of sexual 
battery thereon, and further Defendant Epstein worked in concert as part of the enterprise with 
those who were free to act independently and advance their own interests, including Ghislaine 
Maxwell and Jean Luc Brunel, to obtain minor girls for sexual purposes. 
92. Plaintiff,. was the victim of Defendant, Jeffrey Epstein's plan, scheme, and enterprise 
and was so injured by reason of his violations of the provisions of s. 772.104. Plaintiff,. was 
called on the telephone by Defendant Epstein and other employees of his, including 
and transported to the Defendant, Jeffrey Epstein's residence, where she was placed in a 
room along with the Defendant, enticed to commit acts of prostitution, and had acts of sexual 
battery and sexual exploitation committed against her. Defendant, Jeffrey Epstein, conspired 
with his assistants and employees in order to accomplish their common motive or intent of 
seeking out, gaining access to, and exploiting minor children such as the Plaintiff,■ in the 
aforementioned ways, and he further conspired with his employees, assistants and underlings to 
ensure that the crimes of this criminal enterprise were concealed or undetected by law 
enforcement. 
Those who were free to act independently and advance their own interests, 
including Ghislaine Maxwell and Jean Luc Brunel, also worked with the enterprise to conceal 
the activities of the enterprise. 
93. After law enforcement began to detect the criminal activities of Defendant Epstein and 
the other persons involved in the criminal enterprise, the enterprise used resources and 
information to conceal the illegal activities of the enterprise, threaten the victims of the crimes of 
the enterprise if they revealed the scope of the enterprise to law enforcement, and concealed or 
destroyed documents relevant to the prosecution of the various members of the enterprise. The 
enterprise also made various efforts to discourage the victims from cooperating with law 
23 
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enforcement and from filing civil lawsuits to vindicate their rights. Epstein and other members 
of the enterprise made cash payments and gave gifts to the victims of the enterprise in order to 
discourage them from reporting crimes to law enforcement and other authorities. 
94. Through information and belief, this criminal enterprise gained valuable consideration 
from the practice of sex-trafficking underage children and providing underage children to other 
adults and otherwise derived valuable consideration for running a national and oftentimes 
international sex-trafficking and underage prostitution ring, typically by coercing and 
introducing the economically disadvantaged underage minor females into prostitution and 
sometimes into being underage sex slaves for the enterprise. 
95. The evidence clearly and convincingly establishes that Plaintiff MJ was injured by reason 
of violations of the provisions of 772.103, and as such is entitled to threefold the actual damages 
sustained and a minimum of $200, and reasonable attorney's fees and court costs. 
96. In the alternative, and pursuant to s. 772.104, Plaintiff-was injured due to sex 
trafficking committed in violation of s. 772.103 and is thus entitled to threefold the amount 
gained from the sex trafficking and to a minimum amount of damages not less than 5200, 
reasonable attorney's fees and court costs. 
97. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, 
loss to her property and business opportunities and other losses. 
WHEREFORE, under the provisions of Florida Statutes Chapter 772, Plaintiff, MJ, 
demands judgment against Defendant, Jeffrey Epstein, for any minimum damages authorized by 
law, all actual damages sustained (to be trebled as authorized by law), court costs and attorneys' 
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. 
24 
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COUNT XXV 
Cause of Action Pursuant to Florida Statute 796.09 
Against Defendant, Jeffrey Epstein 
98. Plaintiff adopts and realleges paragraphs 1 through 60 above. 
99. The allegations contained herein in Count XXV are a separate and distinct legal remedy. 
100. Defendant, Jeffrey Epstein, was a wealthy and powerful man, and Plaintiff was an 
economically disadvantaged and impressionable minor. 
101. Plaintiff MJ had never engaged in any act of prostitution prior to meeting Epstein or 
being introduced to any of the members of the criminal enterprise of which Defendant Epstein 
was an operating member and leader. 
102. Defendant, Jeffrey Epstein, used his vast wealth and power to coerce Plaintiff into 
prostitution and/or coerced her to remain in prostitution. 
103. Defendant, Jeffrey Epstein, coerced Plaintiff into prostitution in one or more of the 
following ways: 
A. 
Domination of her mind and body through exploitive techniques; 
B. 
Inducement; 
C. 
Promise of greater financial rewards; 
D. 
Exploitation of a condition of developmental disability, cognitive 
limitation, affective disorder, and/or substance dependency; 
E. 
Exploitation of human needs for food, shelter or affection; 
F. 
Exploitation of underprivileged and vulnerable economic condition or 
situation; 
G. 
Use of a system of recruiting other similarly situated minor girls to further 
coerce and induce Plaintiff into the lifestyle of prostitution; and 
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H. 
Exploitation through demonstration of abundant wealth and power to 
impress a young and vulnerable then minor Plaintiff and to coerce her into prostitution. 
104. As a direct and proximate result of the offenses committed by Defendant, Jeffrey Epstein, 
against Plaintiff pursuant to Florida Statutes §796.09, the Plaintiff has in the past suffered, and 
will in the future suffer, injury, pain and suffering, emotional distress, psychological trauma, 
mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her 
privacy and other damages associated with Defendant, Jeffrey Epstein, controlling, manipulating 
and coercing her into a perverse and unconventional way of life for a minor. The then minor 
Plaintiff incurred medical and psychological expenses and Plaintiff will in the future suffer 
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 
are permanent in nature and the Plaintiff will continue to suffer these losses in the future. 
WHEREFORE, Plaintiff, Jane Doe, demands judgment against the Defendant, Jeffrey 
Epstein, for compensatory damages, punitive damages as specifically allowed by this and other 
statutes and by law, 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 XXV 
Cause of Action Pursuant to Florida Statute 726.101 
Against Defendant, Jeffrey Epstein 
105. This count alleges an action for redress of fraudulent transfers brought under Florida's 
Uniform Fraudulent Transfer Act, sections 726.101, et seq., Fla.Stats. ("FUFTA"). 
106. Plaintiff adopts and realleges paragraphs I through 60 above. 
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107. M.J. is a creditor of defendant Jeffrey Epstein. She has various claims against him for 
repeated sexual molestation of her when she was a minor, as alleged in the other counts of this 
complaint. 
108. Given the egregious acts of sexual molestation the defendant perpetrated against her, M.J. 
has a claim against defendant, once punitive damages are added, is worth in excess of 
$50,000,000. Therefore, he is facing judgments in excess of $50,000,000 from her. Epstein is 
thus a debtor of M.J., as defined in the FUFTA. 
109. Defendant Jeffrey Epstein has numerous overseas contacts and sophistication in 
international business transactions. He previously served as a trader at Bear Stearns 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, he managed 
the assets of billionaire clients. 
110. Defendant Jeffrey Epstein has transferred, is transferring, and intends to transfer in the 
near future his assets, to locations overseas and elsewhere and/or to nominee individuals who 
conceal Epstein's interest in the assets, with the actual intent to hinder, delay and defraud-
To prevent■ from satisfying any judgment that she might obtain in her pending lawsuit again 
him, Epstein has moved and intends to move his significant financial assets to locations overseas 
(i.e., to Israel) or in other unreachable areas and to title his assets (including real property, 
aircraft, boats, vehicles, and financial instruments) in the names of other persons or entities, even 
though he maintains (directly or indirectly) control over those assets. 
These transfers arc 
designed by Epstein to prevent 
from being able to collect on any judgment she might obtain 
against him, including any punitive damages judgment. 
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111. In recent lawsuits against him very similar to those filed by ■, 
defendant Epstein has 
refused to answer and taken the Fifth when asked whether he intends to conceal assets from 
those with claims against him. 
112. In recent lawsuits against him very similar to those filed by 
defendant Epstein 
refused to answer and took the Fifth Amendment when asked whether he intends to remain in the 
country in the future. 
113. Epstein could currently post a $15 million bond to satisfy a judgment in this case without 
financial or other difficulty. 
WHEREFORE plaintiff-demands judgment against defendant Epstein as follows: 
(a) An accounting by defendant Jeffrey Epstein of all of his significant financial assets, 
whether held in this country or overseas, and all significant transfer of assets in the last three 
years; 
(b) Avoidance of the fraudulent transfers or obligations to the extent necessary to satisfy 
M.J.'s claims; 
(c) An attachment or other provisional remedy against the asset transferred or other 
property of the transferee in accordance with applicable law; 
(d) An injunction against defendant Jeffrey Epstein and such transferees as may be 
appropriate, or both, against further transfers of any assets pending further order of the Court and 
posting of a bond to protect 
(e) Appointment of a receiver to take charge of the assets of defendant Jeffrey Epstein 
until the Court is satisfied that 
interests in having assets available from the defendant to 
satisfy any judgment are fully protected; 
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(t) Posting by defendant Jeffrey Epstein of a S15,000,000 bond to satisfy any judgment 
obtained b). 
in her pending lawsuits; and 
(g) All other relief that the circumstances may require to protect and 
her ability to 
satisfy any judgment she might obtain. 
Plaintiff also demands a jury trial on all issues so triable by jury. 
Dated: 
Respectfully submitted, 
FARMER, JAFFE, WEISSING, 
EDWARDS, FISTOS & LEHRMAN, PL 
Attorneys for Plaintiff(s) 
425 North Andrews Avenue, Suite 2 
Fort Lauderdale, Fl 33301 
(954)524-2820 TELEPHONE 
954 524-2822
BY: 
Bradley J. Edwards 
Florida Bar No. 542075 
29 
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CIVIL RICO CASE STATEMENT 
PURSUANT TO LOCAL RULE 12.1 
1. Plaintiffs alleges a violation of Florida Statutes §§ 772.103(3) (participation in an 
enterprise through a criminal activity) and 772.103(4) (conspiracy to do so). The following 
information describes both the § 772.103(3) claim and the § 772.103(4) conspiracy claim 
with the additional note that the conspiracy was between defendant Jeffrey Epstein, MI 
ME 
a 
Ghislaine Maxwell, Jean Luc Brunel and other persons whose 
identity is, at this time, unknown to M.J.. Epstein, ME 
and others all 
conspired together to violate the provisions of § 772.103(3), doing so willfully and with Ml 
knowledge of the criminal activities that were planned as part of the criminal enterprise. For 
convenience in this statement, Florida Statutes §§ 772.103(3) and (4) will be referred to as 
the "Florida Civil RICO provisions." 
2. Epstein served as the leader, boss. and "C.E.O." of the criminal enterprise. 
He also 
II.
criminally sexually abused and prostituted 
and other minor A
were 
s who 
 victims of 
the criminal enterprise. He also paid for 
and 
and numerous other 
associates to be a part of the enterprise and conspired with them to commit criminal acts of 
sexual abuse and prostitution of minors. The basis for Epstein's liability is also described in 
complaint. 
3. The other wrongdoers and criaarticipants included 
MOM 
Ghislaine 
Maxwell, and Jean Luc Brunel. 
's uncertain as to the precise spelling of their names 
and their full legal names.) They assisted defendant Jeffrey Epstein in recruiting and 
procuring minor girls to satisfy Epstein's criminal sexual purposes and for prostitution, as 
described in Mcomplaint, and to satisfy their own sexual interests. For example, to 
further the interests of the local Palm Beach chapter of this expansive criminal enterprise 
they helped to arrange for minor girls to travel to
 West Palm Beach mansion to 
satisfy his sexual desires for minor girls. 
and many others also 
conspired with Epstein to commit acts of sexual abuse and prostitution with minor girls and 
aided and abetted Epstein in the abuse and prostitution. a 
and other 
members of this criminal organization had full knowledge of the crimes of the enterprise; 
they knew full well that the girls who were coming to Epstein's mansion were minors and 
that Epstein was sexual! abusin and prostituting these minors, some of whom were as 
young as 12. 
and 
willfully and knowingly participated in the activities of 
the enterprise and intended to make the criminal activities of the enterprise succeed. Among 
other things, 
helped arrange for recruiters of the minor girls. She also spoke 
personally to the recruiters as well as to the minor girls who were victims of Epstein's sexual 
abuse. At Epstein's specific direction, 
spoke to the recruiters about subjects such as 
finding more minor girls to satisfy Epstein's criminal sexual appetite. 
also served as 
Epstein's scheduler, scheduling appointments for the minor girls to ostensibly do "work" 
when in fact (as she well knew) she was scheduling them to be sexually abused and 
prostituted by Epstein. 
thus procured minor girls for prostitution and caused them to 
be prostituted and the term "work" was a code or slang word used b the various criminal 
enterprise members to avoid detection by law enforcement. 
who is known to be 
Epstein's bisexual sex slave, also directly participated in the sexual abuse of the minor irls 
b 
artici ting in unlawful sexual activities and prostitution with the girls. Both 
and 
assisted Epstein in attempting to keep Epstein's criminal sexual abuse unknown 
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to law enforcement and other authorities and in discouraging the minor girls from reporting 
the crimes to law enforcement and other authorities. Maxwell and Brunel participated by 
helping to create the impression that the girls would be going to meet with Epstein for 
legitimate "modeling" purposes. Maxwell and Brunel specifically intended to have Epstein 
abuse the girls and acted with full awareness of Epstein's intentions. Both Brunel and 
Maxwell recruited minor females for Epstein as well as for themselves in an effort to further 
the goals of the criminal organization — to sexually abuse and molest underage minor females 
and avoid detection of law enforcement. 
Brunel used his modeling agency to locate 
underage girls for Epstein and others to sexually abuse. 
Maxwell personally brought 
underage girls to Epstein for him to sexually abuse, she also presented him with underage 
girls for him to maintain as sex slaves and to travel the globe with him and others, 
prostituting underage sex slaves to others. Maxwell was also a participant in sexually 
abusing minor females. 
Maxwell served many additional purposes for the criminal 
organization and was highly ranked within the organization, thus she was able to act on her 
own accord, without needing orders from Epstein. Maxwell's roles and actions on behalf of 
the criminal enterprise have included but not been limited to: procuring minor females for her 
and Epstein and others to sexually abuse, hiring personnel to work for Epstein and for the 
various positions in the criminal organization, developing relationships with politically 
connected individuals to protect the organization, managing and organizing the records of the 
enterprise, maintaining computer records and images of underage minor females with their 
names and phone numbers, threatening witnesses who have information that could hurt the 
enterprise, and assisting Epstein and other members of the criminal enterprise to continue the 
criminal activity of the organization and avoid law enforcement detection or prosecution. 
4. The na 
f all of the victims are unknown to the plaintiff at this time. However, they 
include 
herself as well as the victims in the multitude of other civil cases, both filed and 
unfiled, against Epstein. A list of more than 30 such minor female victims was previously 
providelithe U.S. Attorney's Office for the Southern District of Florida to Epstein (but 
not to 
The injuries to those victims resulted from criminal sexual activity and 
prostitution with Epstein and 
and at times Maxwell. The injuries they suffered 
'N
ike those suffered by 
in this action, as described in her complaint. For example, 
and the other victims suffered grave emotional distress and financial injury from being 
forced to engage in unlawful sexual activities with him to which, as minors, they could not 
lawfully consent, and from being introduced into a deviant sexual lifestyle. 
They also 
suffered distress and financial injury from being prostituted by him. 
5. The pattern of racketeering and/or criminal activity is also described in the complaint, which 
incorporates by reference into this statement here and at all other points in the statement. 
The criminal activit included Epstein using paid employees and underlings (including 
and 
to repeatedly find, procure, and bring to him minor girls in order for 
Epstein to solicit, induce, coerce, entice, compel or force these minor girls to engage in 
unlawful sexual activity and acts of prostitution and Epstein using Ghislaine Maxwell and 
Jean Luc Brunel and others yet unnamed to create the impression that he was involved in 
legitimate modeling and other activities. 
a. The criminal activity and specific statutes violated are listed in the complaint and 
include, but are not necessarily limited to: (i) procuring for prostitution, or causing to 
be prostituted, minors, in violation of Florida Statutes Chapter 796; (ii) acts of battery 
in violation of Florida Statutes Chapter 784; (iii) commercial sexual exploitation of a 
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child in violation of Florida Statues § 827.071; and (iv) tampering with a witness in 
violation of Florida Statutes § 914.22. The criminal activities also include violations 
of federal criminal statutes, including sexual trafficking of children by fraud, in 
violation of 18 U.S.C. § 1591, use of a means of interstate commerce to entice a 
minor to commit prostitution, in violation of 18 U.S.C. § 2422, as well as wire fraud, 
in violation of 18 U.S.C. § 1343. 
b. The dates of the events are not fully known to 
at this time. However, at a 
minimum, Epstein obtained minor girls (including
 for sexual purposes of the 
period of approximately 1998 through November 2005. 
Epstein could better 
determine than 
the precise dates of his abuse of her by reviewing his schedule or 
computer records for this period of time and looking for notations of days on which 
she performed "work" for him. Epstein has pled guilty to two such criminal offenses 
against minor girls, although the total number of indictable or chargeable offenses 
would easily number more than 1000. On each of these occasions, as described in the 
complaint, Epsin would have his underlings, co-conspirators or associates 
(including M) 
procure a minor girl to satisfy his sexual desires and then would 
satisfy his sexual desires throw h criminal sexual contact with the minor girls. 
Epstein would also watch 
or Maxwell sexually abuse the minor girls to 
satisfy his sexual desires. Epstein had a particular interest in minor girls, including 
girls as young as 12. On occasion, he would turn away girls who were 18 or over 
because of his perverse and unlawful sexual interest in young girls. Epstein recruited 
and paid the girls for the sexual activities. In doing so, he procured for prostitution, 
and caused to be prostituted, many young girls under the age of 18, in violation of 
(among other statutes) Florida Statute § 796.03. The pattern of criminal and unlawful 
sexual activity extended from at least 1998 through November 2005 and upon 
information and belief actually existed and operated in a criminal organizational 
strut 
many years prior to 1998. Epstein committed unlawful sexual abuse 
againtislikat least 20 times between Summer of 2002 to Spring 2004 while she was 
a minor. Other criminal activities involving tampering with and harassing witnesses 
occurred from June 2002 through early 2008 (and perhaps later). 
c. 
many of the occasions, the exact dates of which are not as yet determined by the 
Epstein would represent that he was interested in a "massage" or legitimate 
"work" when in fact he was interested in unlawful sexual activity with the minor 
girls, including fondling the girls, masturbating in their presence, and vaginally 
penetrating them or causing them to be penetrated. Epstein and others acting under 
his direction falsely represented to the minor girls that he was interested in a 
"massage" or "work" when in fact he was interested in procuring the girls for 
unlawful sexual activity and acts of prostitution. Epstein and others acting under his 
direction used means of interstate communications to make these false 
representations, including cellular telephones. Similar to all known crime families or 
criminal organizations that operate to commit crimes, this criminal enterprise made 
use of seemingly innocuous code words such as "message" and "work" to describe 
the continuous criminal activity of procuring underage girls to sexually molest, abuse 
and exploit. 
d. Epstein has pled guilty to two Florida felony criminal offenses against minor girls, as 
alleged in the complaint and Epstein is a Registered Sexual Offender for life. 
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e. The relationship of the criminal activity to the enterprise is also described in the 
complaint. The Florida offenses to which Epstein pled guilty are but a few of the 
many instances of his plan succeeding. The acts are all related to each other, are 
arranged, and are part of common plan for these reasons: they have the same intent 
(to gratify Epstein's unlawful sexual interest in minor girls as well as to gratify the 
unlawful sexual interests in minor girls of others at times); the same results (the 
unlawful sexual abuse and prostitution of minor girls); the same accomplices 
(including 
and frequently 
Maxwell, and Brunel); the same 
victim 
was herself victimized more than 20 times, and many other girls were 
also victimized repeatedly); the same means (there was a standard payment of several 
hundred dollars for going to the mansion, and standard escalation feature depending 
on the nature of the sexual acts that Epstein performed); the same methods of 
commission (Epstein obtained young, skinny, and attractive girls to satisfy his sexual 
desires while they were economically disadvantaged and lacked a stable family life 
and therefore, he perceived, would be interested in obtaining money and unlikely to 
report his crimes to law enforcement); and the same frequency (remarkably Epstein's 
criminal enterprise operated constantly to procure underage minor females to be 
sexually abused by Epstein every single day, oftentimes 2 or 3 different underage 
females in a single day). The acts were also interrelated b common characteristics, 
namely the identity of the perpetrator (Epstein and often 
or sometimes 
Maxwell) and the common results of his crimes (sexual abuse and acts of prostitution 
with minor girls). The acts also constituted a clear pattern of criminal activity, 
including giving the impression to the girls who were being recruited that they would 
have legitimate modeling opportunities. 
6. The criminal acts of Epstein occurred repeatedly over a substantial period of time and were 
not isolated events. Iiiticular, Epstein committed repeated (more than 20) criminal acts of 
sexual abuse against 
from approximately Summer 2002 to Spring 2004. He committed 
similar criminal acts of unlawful sexual activity and prostitution against other minor girls for 
a period of time from at least 1998 to November 2005. The acts occurred frequently during 
this time, so frequently that it is impossible to calculate how many different illegal sexual 
acts were committed by Epstein and his criminal enterprise, but it is fair to say that serious 
felonies were committed by this criminal organization on an everyday basis. The acts were 
part of Epstein's regular way of doing business (e.g., obtaining sexual gratification from 
li
) 
during this period of time. Epstein and others acting at his direction (including 
made hundreds of telephone calls in furtherance of these illegal activities. The 
sexual acts against minors may have temporarily ceased in approximately November 2005 
when Epstein learned that law enforcement authorities were investigating his crimes. Given 
Epstein's long history of sexually abusing minors and the frequency at which he has done so 
and the fact that despite his arrest and jail sentence his criminal organization remains intact, it 
is highly likely that he will continue his sexual desires for minor girls. In addition, Epstein 
committed criminal acts of tampering with witnesses in violation of Florida Statutes § 
914.22. For example, Epstein paid the minor girls money not only with the intent to 
prostitute them but also with the specific intent of causing the minor girls not to 
communicate to law enforcement officers information about the sexual abuse committed 
against them. Epstein made bigger payments to the minor girls depending on the degree of 
force he used towards them, making larger payments when he was more concerned about the 
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Entered on FLSD Docket 09/17/2010 Page 5 of 10 
fact they might report the crimes committed against them. Without specifically detailing acts 
committed against certain known minors, Epstein has paid $1000 on occasion after forcibly 
holding the head of a minor down and pumping his penis inside her against her will. Epstein 
has also intimidated and reprimanded his co-conspirators and associates for any cooperating 
with law enforcement and has made it known that his associates must stay loyal to the 
criminal enterprise above all else. These obstructions may interfere with the ability of law 
enforcement to discover and prosecute all of Epstein's crimes. They may likewise interfere 
with the ability ofM to discover all of the information supporting her claim. Epstein also 
selected impoverished girls for his crimes, believing that the payments would be more 
effective in obtaining their silence and that their economic circumstances might make them 
less likely to report to law enforcement. If all else failed, after having unlawful sex with the 
minor girls, Epstein would tell them not to tell anyone about their unlawful encounter or "bad 
things" would happen. In addition, since November 2005 and through the early part of 2008 
(and perhaps later), Epstein and others acting at his direction have attempted to discourage 
the victims of his crimes from reporting his crimes and cooperating with law enforcement. 
For example, persons acting at the direction of Epstein have aggressively attempted to 
"interview" the victims or to "tail" the victims in their cars. They also harassed a victim 
shortly before she was to testify at a grand jury investigating Epstein and aggressively 
intimidated a victim to scare her away from proceeding to trial against him. These efforts 
have been made not for legitimate investigative reasons but rather for the purpose of 
discouraging the victims from cooperating with law enforcement (and, in at least one case, 
the investigating grand jury) and from filing civil lawsuits to vindicate their rights. 
7. The enterprise is also described in the complaint, which allegations 
expressly 
incorporates into this statement as part of the description of the enterprise. The enterprise 
included, at a minimum, a group of individuals associated in fact to assist Epstein in 
recruiting and procuring minor girls and obtaining criminal gratification of his illegal sexual 
interest in minor girls and at least two individuals (Ghislaine Maxwell and Jean Luc Brunel) 
who were free to act independently and advance their own interests, including their own 
sexual interests. 
a. The persons constituting the enterprise includeciaroirindividuals associated 
in fact. These individuals include Epstein, 
Ghislaine Maxwell, and Jean Luc Brunel, as well as other yet unnamed persons 
whose names M.J. intends to identify during the discovery phase of this case. 
b. The criminal enterprise had a definite hierarchal structure, although all the details 
of that structure are not completely know to 
Through discovery, 
intends to ascertain the precise structure of the enterprise that enabled Epstein to 
commit sexual crimes against here. While 
does not currently know all of the 
details of the structure, she does know that the enterprise operated together on a 
continuing basis, in an extremely efficient and organized manner, with largely the 
same personnel for a common purpose. The shared purpose of the enterprise was 
to satisfy Epstein's, as well as certain other individual's, illegal interest in having 
sexual activities with minor girls as well. The enterprise was not a mere informal 
conspiracy, but had a definite clear structure. Epstein served effectively as the 
leader, C.E.O. or "Boss" of this organization, directing his various levels of 
underlings how to recruit and procure young girls for his sexual activities and 
when to bring the girls to his mansion as well as how to avoid law enforcement 
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