EPSTEIN
page 1 / 128 . OCR, unverified
Court Records L.M. v. Epstein, 909-cv-81
==================== DOCUMENT: Court Records__L.M. v. Epstein, 909-cv-81092 (S.D. Fla. 2009)__001-01.txt ====================
METADATA_SOURCE: Court RecordsL.M. v. Epstein, 909-cv-81092 (S.D. Fla. 2009)
METADATA_FILENAME: 001-01.pdf
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Case 9:09-cv-81092-KAM Document 1-1 Entered on FLSD Docket 07/27/2009 Page 1 of 79
COUNT53
Cause of Action Pursuant to 18 U.S.C. § 2255
September 2003 - Incident 1
229.
Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
230.
On or about September 2003, the exact date being unknown to L.M.,
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and§ 2423(e).
L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
231.
As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, L.M. has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
Page 83 of 234
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Case 9:09-cv-81092-KAM Document 1-1 Entered on FLSD Docket 07/27/2009 Page 2 of 79
and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical
and psychological expenses and the plaintiff, L.M., will in the future suffer medical and
psychological expenses. The plaintiff, L.M., 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 the plaintiff, L.M., will continue to suffer these
losses in the future.
232.
Wherefore, the plaintiff, L.M., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
by law, attorney's fees, costs, and such other and 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 54
Cause of Action Pursuant to 18 U.S.C. § 2255
September 2003 - Incident 2
233.
Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
234.
On or about September 2003, the exact date being unknown to L.M.,
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
violation of numerous federal criminal statutes condemning the coercion and
enticement of a minor to engage in prostitution or sexual activity, travel with intent to
engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor
children, transport of visual depictions of a minor engaging in sexually explicit conduct,
child exploitation enterprises, and other crimes, specifically including, but not limited to,
those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e).
Page 84 of 234
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Case 9:09-cv-81092-KAM Document 1-1 Entered on FLSD Docket 07/27/2009 Page 3 of 79
L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,
as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to
this Section of the United States Code and the agreement between the Defendant,
Jeffrey Epstein, and the United States Government.
235.
As a direct and proximate result of the offenses enumerated in Title 18,
United States Code, Section 2255, being committed against her, L.M. has in the past
suffered, and will in the future suffer, physical injury pain and suffering, emotional
distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of
self-esteem, loss of dignity, invasion of her privacy and other damages associated with
defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse
and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical
and psychological expenses and the plaintiff, L.M., will in the future suffer medical and
psychological expenses. The plaintiff, L.M., has suffered a loss of income, a loss of the