EPSTEIN
page 3 / 31 . OCR, unverified
on (date)
I returned the summons unexecuted because
Other (specify):
My fees are$
for travel and $
for services, for a total of$
I declare. under penalty of perjury .that this information is true.
Server's signature
Printed name and title
Server's address
Additional information regarding attempted service, etc:
, who is
; or
; or
, 0.00
==================== END OF Court Records__C.L. v. Epstein, No. 910-cv-80447 (S.D. Fla. 2010)__001-02.txt ====================
==================== DOCUMENT: Court Records__C.L. v. Epstein, No. 910-cv-80447 (S.D. Fla. 2010)__001.txt ====================
METADATA_SOURCE: Court RecordsC.L. v. Epstein, No. 910-cv-80447 (S.D. Fla. 2010)
METADATA_FILENAME: 001.pdf
----------------------------------------
Case 9:10-cv-80447-KAM Document 1 Entered on FLSD Docket 03/31/2010 Page 1 of 12
THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Civil Action No. ----
CASE NO:
C.L.,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
I
------------------
COMPLAINT
Plaintiff, C.L., brings this Complaint against defendant, Jeffery Epstein ("Defendant"),
and states as follows:
PARTIES, JURISDICTION, AND VENUE
l. 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
mmor.
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 sentence which occurred on
Case 9:10-cv-80447-KAM Document 1 Entered on FLSD Docket 03/31/2010 Page 2 of 12
June 30, 2008, Defendant is currently under community control in Palm Beach County,
Florida.
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
u.s.c. § 2255.
7. This Court has venue of this action pursuant to 28 U.S.C. § 1391(b), as a substantial part
of the events giving rise to the claim occurred in this District.
STATEMENT OF THE 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 aircrafts that include 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
Page 2 of 12
Case 9:10-cv-80447-KAM Document 1 Entered on FLSD Docket 03/31/2010 Page 3 of 12
economically disadvantaged minor girls, and sexually assaulted, molested, and/or
exploited these girls, and then gave them money.
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.
11. 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