EPSTEIN
page 9 / 129 . OCR, unverified
54.
Defendant, Jeffrey Epstein, 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. As previously stated in paragraphs
14, 24, and 25, Defendant kept and displayed a myriad of nude photographs of underage girls
throughout his homes, including 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
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 19 of 27
Beach. Upon information and belief, many of the photographs in the possession of Defendant
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, Jeffrey Epstein, 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. 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 Sheriffs 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.
55.
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.
56.
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.
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Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 20 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 SEVEN
(Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit
Conduct pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2252(a)(l))
57.
Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by
reference the allegations contained in paragraphs 1 through 32 above.
58.
Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via
computer and/or facsimile in or affecting interstate and/or foreign commerce at least one visual
depiction of the minor Plaintiff engaging in sexually explicit conduct, in violation of 18 U.S.C. §
2252(a)(l). As previously stated in paragraphs 14, 24, and 25, Defendant displayed a myriad of
nude photographs of underage girls throughout his homes, including 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 as a minor at Defendant's home in Palm Beach. As previously stated in paragraph
24, Defendant told Plaintiff that he had photographs of her naked in all of his homes. Upon