EPSTEIN
page 6 / 129 . OCR, unverified
in 18 U.S.C. § 2421, § 2422(a), § 2422(b), § 2423(a), § 2423(b), § 2423(e), § 2251, § 2252, §
2252A(a)(l), and§ 2252A(g)(l).
32.
In June 2008, after investigations by the Palm Beach Police Department, the Palm
Beach State Attorney's Office, the Federal Bureau of Investigation, and the United States
Attorney's Office for the Southern District of Florida, Defendant, Jeffrey Epstein, entered pleas
of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and
the procurement of minors for the purposes of prostitution in the Fifteenth Judicial Circuit in
Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if he had
been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must
admit liability unto Plaintiff, Jane Doe No. 102. Plaintiff hereby exclusively seeks civil remedies
pursuant to 18 U.S.C. § 2255.
COUNT ONE
(Cause of Action for Coercion and Enticement of Minor to Engage in Prostitution or
Sexual Activity pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2422(b))
33.
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 32 above.
34.
Defendant, Jeffrey Epstein, used a facility or means of interstate and/or foreign
commerce to knowingly persuade, induce, entice, or coerce Jane Doe No. 102, 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 ).
35.
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in
U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein,
pursuant to this Section of the United States Code.
Podhurst Orse~k, 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 13 of 27
36.
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
leading her into a perverse and unhealthy way of life. 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 Plaintiff will continue to suffer these losses in the future.
WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant,
Jeffrey Epstein, 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 of right
by a jury.
COUNT TWO
(Cause of Action for Transportation of Minor with Intent to Engage in Criminal Sexual
Activity pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2423(a))
37.
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 32 above.
38.
Defendant, Jeffrey Epstein, knowingly transported then minor Plaintiff, Jane Doe
No. 102, in interstate and/or foreign commerce, with the intent that Plaintiff engage in
prostitution, or in any sexual activity for which any person can be charged with a criminal
offense, in violation 18 U.S.C. § 2423(a). As previously stated in paragraphs 20, 21, and 27,
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 14 of 27
Defendant transported Plaintiff, Jane Doe No. 102, across state lines and across international
borders numerous times from the time that Plaintiff was merely 15 years old through adulthood
with the primary intent of sexually exploiting her.
39.
Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in
U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein,
pursuant to this Section of the United States Code.