EPSTEIN
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transport the minor Plaintiff to Manhattan, where he provided her with spending money and
accommodations with him at his mansion.
From the time that Plaintiff was 15 years old,
Defendant abused her to serve his every sexual whim, obtaining and purchasing passports and
whatever was needed for her to travel with him and/or for him. Defendant transported Plaintiff
in his private jet to locations that included Palm Beach, New York City, Santa Fe, Los Angeles,
San Francisco, St. Louis, and numerous other domestic destinations, as well as international
Podhurst Orseck, P.A.
West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
www.podhurst.com
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 8 of 27
destinations, including Europe, the Caribbean, and Africa. He provided accommodations with
him in order to have her available to him at all times wherever he went, including while
transporting the minor Plaintiff on his private jet. Each time they would travel to one of these
destinations, the same pattern of sexual abuse would occur, often with a vast array of aspiring
models, actresses, celebrities, and/or other females, including minors, from all over the world.
Upon information and belief, Defendant transported minor girls from Turkey, the Czech
Republic, Asia, and numerous other countries, many of whom spoke no English. To Plaintiffs
knowledge, the only females specifically excluded from Defendant's sexual escapades were
African-Americans.
21.
In addition to being continually exploited to satisfy Defendant's every sexual
whim, Plaintiff was also required to be sexually exploited by Defendant's adult male peers,
including royalty, politicians, academicians, businessmen, and/or other professional and personal
acquaintances. Whenever Defendant transported Plaintiff with him in his private jet to any
destination, Defendant would pay Plaintiff a flat rate per day while he and/or his above-
mentioned associates would sexually exploit and abuse minor Plaintiff.
22.
Most of these acts of abuse occurred during a time when Defendant knew that
Plaintiff was approximately 15, 16, and 17 years old, and, after years of daily sexual exploitation,
continued into her adulthood. Despite Defendant's stating shortly before Plaintiffs sixteenth
birthday that he soon would have to trade her in because she was getting too old, Defendant
continued to sexually exploit Plaintiff until she fled at age 19. Defendant's predilection for
young girls was well known to those who regularly procured them for him and to his circle of
friends. On one of Defendant's birthdays, a friend of Defendant sent him three 12-year-old girls
from France who spoke no English for Defendant to sexually exploit and abuse. After doing so,
they were sent back to France the next day.
Podhurst Orseck, P.A.
West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
www.podhurst.com
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 9 of 27
23.
Any assertions by Defendant that he was unaware of the age of the then minor
Plaintiff are belied by his own actions, and are rendered irrelevant by the provision of applicable
federal statutes concerning the sexual exploitation and abuse of a minor child. Defendant,
Jeffrey Epstein, at all times material to this cause of action, knew and should have known of
Plaintiffs age of minority. Defendant and Ms. Maxwell acknowledged and celebrated Plaintiffs
16th birthday. Defendant's preference for underage girls was well-known to those who regularly
procured them for him.
24.
As previously stated in paragraph 14, Defendant displayed nude photographs of
underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S.
Virgin Islands. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each of
Defendant's homes, including a photograph of herself naked at Defendant's home in Palm
Beach. When she asked Defendant about it, he stated dismissively that he had naked photographs
of her in all of his homes.
25.
Upon information and belief, some of the photographs in Defendant's possession
were taken with hidden cameras set up in his home in Palm Beach. On the day of his arrest,
police found two hidden cameras and photographs of underage girls on a computer in
Defendant's home. Upon information and belief, Defendant may have taken lewd photographs
of Plaintiff, Jane Doe No. 102, with his hidden cameras and may have transported lewd
photographs of Plaintiff ( among many other victims) to his other residences and elsewhere using
a facility or means of interstate and/or foreign commerce. In addition, while Plaintiff was a
minor teenager and upon Ms. Maxwell's insistence after Ms. Maxwell rejected as inappropriate
photographs that Plaintiff presented of herself fully clothed, Ms. Maxwell photographed Plaintiff