EPSTEIN
page 8 / 129 . OCR, unverified
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.
48.
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
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 17 of 27
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 FIVE
(Cause of Action for Transportation with Intent to Engage in Criminal Sexual Activity
pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2421)
49.
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 32 above.
50.
Defendant, Jeffrey Epstein, knowingly transported, or attempted to transport,
Plaintiff, Jane Doe No. 102, in interstate and/or foreign commerce, with the intent that Plaintiff
engage in prostitution and/or in any sexual activity for which any person can be charged with a
criminal offense, in violation of 18 U.S.C. § 2421. As previously stated in paragraphs 20, 21,
and 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.
51.
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.
52.
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,
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 18 of 27
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 for a minor. 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 SIX
(Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. § 2255 in
Violation of 18 U.S.C. § 2251)
53.
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 32 above.
54.
Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, or coerced the