EPSTEIN
page 5 / 129 . OCR, unverified
naked in different sexually explicit positions.
Ms. Maxwell then presented these nude
photographs of Plaintiff to Defendant as a birthday present for Defendant from Ms. Maxwell.
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.podhurstcom
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 10 of 27
Upon information and belief, one or more nude photographs of Plaintiff that were taken when
she was a minor were confiscated by the Palm Beach Sheriff's Office during its execution of a
search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information
and belief, those photographs are still in the custody of law enforcement.
26.
It is virtually impossible to calculate the exact number of times that Defendant
sexually exploited and abused Plaintiff. From the age of 15, Plaintiff was sexually exploited and
abused by Defendant on a daily basis and, most often, multiple times each day. While some of
the precise dates these acts occurred are unknown to Plaintiff, these dates are known to
Defendant, as he is reported to have kept a written log of each instance in which he engaged in
these lewd acts with then minor Plaintiff and others. Upon information and belief, these logs are
also in the custody of law enforcement.
27.
In or around September 2002, Defendant purchased a commercial round-trip
airline ticket, and provided a passport, U.S. currency, and accommodations for Plaintiff to fly to
Thailand. While thousands of miles away from Defendant on this extended trip alone for the
first time in more than four years, Plaintiff met, fell in love, and married a young man. She
escaped from Defendant's abuse with the help and insistence of her new husband and, instead of
returning to Defendant, boarded a plane to Australia with one suitcase.
28.
Since November 2002, Plaintiff has lived a modest life in Australia, while
maintaining lines of communication with her family and without contact with Defendant or any
of the people in his entourage. However, suddenly, in 2008, Plaintiff received numerous phone
calls from one of Defendant's agents. During these phone calls to Plaintiff, he repeatedly asked
whether she knew anything about the civil cases against Defendant, whether she knew any of the
females who were proceeding with the civil suits, whether she was planning on filing suit,
whether she was communicating and/or cooperating with anyone against Defendant, and whether
Podhurst Orseck, P.A.
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 11 of 27
she would return to the United States to testify. Terrified by Defendant's demonstrated ability to
track her down on her changed cell phone number halfway across the world, Plaintiff attempted
to reassure Defendant's agent that she would remain quiet. During the course of one of these
phone calls from Defendant's agents, Defendant himself spoke on the phone, continued to
question her intentions, and, upon being reassured by Plaintiff, thanked her for not getting
involved.
29.
Around January 2009, Plaintiff received a letter from the United States Attorney's
Office for the Southern District of Florida, informing her of her potential civil claims against
Defendant under 18 U.S.C. § 2255. Plaintiff contacted undersigned counsel within days and
diligently and repeatedly pursued a good faith viable settlement of her claims against Defendant.
Unable to reach a settlement, this lawsuit followed.
30.
As a result of these encounters with Defendant, Plaintiff, Jane Doe No. 102, 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 controlling and manipulating her on a daily basis for years into a perverse and
unhealthy way of life.
31.
Defendant, Jeffrey Epstein, committed the above-referenced acts upon Plaintiff in
violation of federal statutes condemning the coercion and enticement of a minor to engage in
prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex
trafficking of children, sexual exploitation of minor children, transport of visual depictions of a
minor engaging in sexually explicit conduct, transport of child pornography, child exploitation
enterprises, and other crimes, specifically including, but not limited to, those crimes designated
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 12 of 27