EPSTEIN
page 5 / 36 . OCR, unverified
COUNT ONE
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 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 10 of 19
(Cause of Action for Coercion and Enticement of Minor to Engag~ in Prostitution or
Sexual Activity pursuant to 18 U.S.C. § 2255 in Violation of 18 U .S.C. § 2422(b))
27.
Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
allegations contained in paragraphs 1 through 26 above.
28.
Defendant used a facility or means of interstate and/or foreign commerce to
knowingly persuade, induce, entice, or coerce Plaintiff, 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).
29.
Plaintiff was a victim of one or more offenses enumerated in 18 U.S.C. § 2255,
and, as such, asserts a cause of action against Defendant pursuant to this Section of the United
States Code.
30.
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
luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
and psychological expenses, and Plaintiff will in the future incur 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.
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 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 11 of 19
WHEREFORE, Plaintiff demands judgment against Defendant 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 Travel with Intent to Engage in Illicit Sexual Conduct pursuant
to 18 U.S.C. § 2255 in Violation of 18 U.S.C. § 2423(bJl
31.
Plaintiff hereby adopts, repeats, realleges, and incorporates by reference the
allegations contained in paragraphs 1 through 26 above.
32.
Defendant traveled in interstate and/or foreign commerce for the purpose of
engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females,
including the then minor Plaintiff, in violation of 18 U .S.C. § 2423(b ).
33.
Plaintiff was a victim of one or more offenses enumerated in 18 U.S.C. § 2255,
and, as such, asserts a cause of action against Defendant pursuant to this Section of the United
States Code.
34.
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 ha~ 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
luring her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical
and psychological expenses, and Plaintiff will in the future incur 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 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 12 of 19
income in the future, and a loss of the capacity to enjoy life. These injrn-: es are permanent in
nature, and Plaintiff will continue to suffer these losses in the future.
WHEREFORE, Plaintiff demands judgment against Defendant 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,