EPSTEIN
page 6 / 31 . OCR, unverified
plea and the Non-Prosecution Agreement in denying the acts alleged in this Complaint
and must effectively admit liability to Plaintiff, Jane Doe No. 104.
COUNTI
Cause Of Action For Coercion And Enticement OfMinor To Engage In Prostitution Or
Sexual Activity Pursuant To 18 U.S.C. § 2255 In Violation Of 18 U.S.C. § 2422(b)
29. Plaintiff hereby adopts, repeats, re-alleges, and incorporates by reference the allegations
r
contained in paragraphs 1 through 22 above.
30. 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 U.S.C. § 2255 in violation of 18
U.S.C. § 2422(b ).
31. Plaintiff was a victim of one or more offenses enumerated in 18 U.S.C § 2255, and, as such,
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asserts a cause of action against Defendant pursuant to this Section of the United States Code.
32. As a direct and proximate result of the offenses enumerated in 18 U.S.C § 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 medjcal 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 Plaintiff will
continue to suffer these losses in the future.
WHEREFORE, Plaintiff demands judgment against Defendant for all damages available
under 18 U.S.C § 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 ofright by a jury.
COUNT TWO
Cause Of Action For Sexual Exploitation Of Children Pursuant To 18 U.S.C. § 2255 In
Violation Of 18 U.S.C. §2251
33. Plaintiff hereby adopts, repeats, re-alleges, and incorporates by reference the allegations
contained in paragraphs 1 through 22 above.
34. 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 U.S.C § 2251.
I
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Case 9:10-cv-80447-KAM Document 1 Entered on FLSD Docket 03/31/2010 Page 10 of 12
35. Plaintiff was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as
such, asserts a cause of action against Defendant pursuant to this Section of the United
States Code.
36. As a direct and prox~mate result of the offenses enumerated in 18 U.S.C. § 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,
j
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 are permanent in nature, and Plaintiff will
continue to suffer these losses in theifuture.
WHEREFORE, Plaintiff demands judgment against Defendant for all damages available
under 18 U.S.C. § 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 ofright by a jury.
COUNT THREE
Cause Of Action For Engaging In ,A Child Exploitation Enterprise Pursuant To 18 U.S.C. §
•
2255 In Violation Of 18 U.S.C. §2252A (g)
•
7. Plaintiff hereby adopts, repeats, re-alleges, and incorporates by reference the allegations
contained in paragraphs 1 through 22 above and Counts One and Two above.