EPSTEIN
page 2 / 178 . OCR, unverified
there were as many as 10 to 20 other occasions during this time frame that Defendant
EPSTEIN solicited her and procured her to perform prostitution services, all during the time
that she was a minor.
Case 9:09-cv-80469-KAM Document 1 Entered on FLSD Docket 03/25/2009 Page 4 of 5
14.
Plaintiff seeks damages for personal injury in accordance with 18 U.S.C.
§2255(a) for each of the acts of prostitution set forth above for which Defendants solicited
her, $150,000 for each violation, for a total range of damages between $1.5 million dollars
to $4.5 million dollars, jointly and severally, and a reasonable attorney's fees and costs, as
permitted by the statute.
15.
Defendant EPSTEIN has made an agreement with the United States
Attorney's Office to not contest liability for claims brought exclusively pursuant to 18 U .S.C.
§2255, in exchange for avoiding federal prosecution under 18 U.S.C. §2422(b), which
provides a sentence of 10 years for each violation of the law.
WHEREFORE, Plaintiff demands judgment in her favor, and a jury trial on all issues
so triable as of right.
Date: ~ I "l.:> °
BY: 1cs1i'itl>~~~~:---
Flo • a
No. 437883
GA CIA LAW FIRM, P.A.
224 Datura Street, Suite 900
West Palm Beach, FL 33401
Telephone:(561) 832-7732
Telecopier: (561) 832-7137
e-mail: isidrogarcia@bellsouth.net
Mar. 24, 2009
09-80469-Civ-RYSKAMP/VITUNAC
Case 9:09-cv-80469-KAM Document 1 Entered on FLSD Docket 03/25/2009 Page 5 of 5
FILED by
RB
D.C.
ELECTRONIC
.._JS 44~ (Rev. 2/08)
CIVIL COVER SHEET
The JS 44 civil cover.sheet and the information contained herein neither rc(tla"e IJOr sy~plcment the filing and service of pleadings or other hapcrs as
by local rures of court. This form, approved by the Judicial Conference o the United tates in September 1974, is required for the use oft e Clerk
the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
NOTICE: Attorneys MUST Indicate All Re-filed ,
STEVEN M. LARIMORE
I. (a) PLAINTIFFS
DEFENDANTS
C LERK U.S. DIST. CT,
s. O. Of FLA. · MIAMI
JANE DOE II
JEFFREY EPSTEIN AND SARAH KELL.c.1~
(b) County of Residence of First Listed Plaintiff PALM BEACH
County of Residence of First Listed Defendant
PALM BEACH
(EXCEPT IN U.S. PLAINTIFF CASES)
(IN U.S. PLAINTIFF CASES ONLY)
(c) Attorney's (Firm Na.me, Address, and Telephone Number)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT
ARCIA LAW FIRM, P.A.
G
w
DA TURA STREETM SUITE 900
EST PALM BEACH, FL 33401
LANO INVOLVED.
Attorneys (If Known)
ROBERT D. CRITTON, ESQ.
JACK A. GOLDBERGER, ESQ.
(d) Check County Where Action Arose:
MIAMI- DADE
:J MONROE
:J BROW ARO /J PALM BEACH
O MARTIN
:J ST. LUCIE
:J INDIAN RIVER
:, OK EEC HOB EE
HIGHLANDS
a
II. BASIS OF JURISDICTION
(Place an "X" in One Box Only)
III. CITIZENSHIP OF PRINCIPAL PARTIES(Place an "X" in One Box for Plaintiff
I
U.S. Government
Plaintiff
2
U.S. Government
Defendant
C
CJ 110 Insurance
120 Marine
□ 130 Miller Act
:J 140 Negotiable Instrument
□ I SO Recovery of Overpayment
& Enforcement of Judgment
□ 151 Medicare Act
'.J 152 Recovery of Defaulted
Student Loans
(Exel. Veterans)
:, 153 Recovery of Overpayment
of Veteran ' s Benefits
□ 160 Stockholders' Suits
CJ 190 Other Con1ract
□ 195 Contract Product Liability
:J 196 Franchise
REAL PROPERTY
:J 210 Land Condemnation
□ 220 Foreclosure
:, 230 Rent Lease & Ejectmcnl
240 Torts to land
245 Torr Product Liability
:J 290 All Other Real Property
./0 3
Federal Question
(U .S. Government Not a Party)
U 4
Diversity
PERSONAL INJURY
PERSONAL INJURY
310 Airplane
362 Personal Injury -
:J 315 Airplane Product
Med. Malpractice
Liability
365 Personal Injury -
320 Assault, Libel &
Product Liability
Slander
368 Asbestos Personal
□ 330 Federal Employers'
Injury Product
Liability
Liability
□ 340 Marine
PERSONAL PROPERTY
Cl 345 Marine Product
370 Other Fraud
Liability
371 Truth in Lending
:, 350 Motor Vehicle
□
380 Other Personal
□ 355 Motor Vehicle
Property Damage
Product Liability
385 Property Damage
■ 360 Other Personal
Product liability
lnjur
CIVIL RIGHTS
PRISONER PETITIONS
441 Voting
□
510 Motions to Vacate
□ 442 Employment
Sentence
443 Housing/
Habtu Corpus:
Accommodations
530 General
444 Welfare
535 Death Penalty
445 Amer. w/Disabilities
Employment
540 Mandamus & Other
446 Amer. w/Disabilities
Other
:,
550 Civil Rights
□ 440 Other Civil Rights
□
555 Prison Condition
(Place an '"X" in One Box Only)
(For Diversity Cases Only)
and One Box for Defendant)
PTF
DEF
I
PTF
DEF
Citizen of This State
D
Citizen of Another State
Citizen or Subject of a
Forei n Countr
FORFEIT RE/
610 Agriculture
CJ
y
620 Other Food & Drug
625 Drug Related Seizure
of Property 21 USC 881
630 Liquor Laws
640 R.R. & Truck
650 Airline Regs.
660 Occupational
Safety/Health
Incorporated or Principal Place
O
□ 4
of Business ln This State