EPSTEIN
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Court Records MJ v. Epstein, No. 910-cv-
==================== DOCUMENT: Court Records__MJ v. Epstein, No. 910-cv-81111 (S.D. Fla. 2010)__001-01.txt ====================
METADATA_SOURCE: Court RecordsMJ v. Epstein, No. 910-cv-81111 (S.D. Fla. 2010)
METADATA_FILENAME: 001-01.pdf
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Case 9:10-cv-81111-WPD Document 1-1 Entered on FLSD Docket 09/17/2010 Page 1 of 10
CIVIL RICO CASE STATEMENT
PURSUANT TO LOCAL RULE 12.1
1. Plaintiff M.J. alleges a violation of Florida Statutes §§ 772.103(3) (participation in an
enterprise through a criminal activity) and 772.103(4) (conspiracy to do so). The following
information describes both the § 772. 103(3) claim and the § 772.103( 4) conspiracy claim,
with the additional note that the conspiracy was between defendant Jeffrey Epstein, Sarah
Kellen, Nadia Marcinkova, Ghislaine Maxwell, Jean Luc Brunel and other persons whose
identity is, at this time, unknown to M.J..
Epstein, Kellen, Marcinkova and others all
conspired together to violate the provisions of § 772 .103(3 ), doing so willfully and with full
knowledge of the criminal activities that were planned as part of the criminal enterprise. For
convenience in this statement, Florida Statutes§§ 772.103(3) and (4) will be referred to as
the "Florida Civil RICO provisions."
2. Epstein served as the leader, boss, and "C.E.O." of the criminal enterprise.
He also
criminally sexually abused and prostituted M.J. and other minor girls who were victims of
the criminal enterprise. He also paid for Kellen and Marcinkova and numerous other
associates to be a part of the enterprise and conspired with them to commit criminal acts of
sexual abuse and prostitution of minors. The basis for Epstein's liability is also described in
M.J. 's complaint.
3. The other wrongdoers and criminal participants included Nadia Marcinkova, Ghislaine
Maxwell, and Jean Luc Brunel. (M.J. is uncertain as to the precise spelling of their names
and their full legal names.)
They assisted defendant Jeffrey Epstein in recruiting and
procuring minor girls to satisfy Epstein's criminal sexual purposes and for prostitution, as
described in MJ's complaint, and to satisfy their own sexual interests. For example, to
further the interests of the local Palm Beach chapter of this expansive criminal enterprise
they helped to arrange for minor girls to travel to Epstein's West Palm Beach mansion to
satisfy his sexual desires for minor girls.
Kellen, Marcinkova and many others also
conspired with Epstein to commit acts of sexual abuse and prostitution with minor girls and
aided and abetted Epstein in the abuse and prostitution.
Kellen, Marcinkova and other
members of this criminal organization had full knowledge of the crimes of the enterprise;
they knew full well that the girls who were coming to Epstein's mansion were minors and
that Epstein was sexually abusing and prostituting these minors, some of whom were as
young as 12. Kellen and Marcinkova willfully and knowingly participated in the activities of
the enterprise and intended to make the criminal activities of the enterprise succeed. Among
other things, Kellen helped arrange for recruiters of the minor girls.
She also spoke
personally to the recruiters as well as to the minor girls who were victims of Epstein's sexual
abuse. At Epstein's specific direction, Kellen spoke to the recruiters about subjects such as
finding more minor girls to satisfy Epstein's criminal sexual appetite. Kellen also served as
Epstein's scheduler, scheduling appointments for the minor girls to ostensibly do "work"
when in fact (as she well knew) she was scheduling them to be sexually abused and
prostituted by Epstein. Kellen thus procured minor girls for prostitution and caused them to
be prostituted and the term "work" was a code or slang word used by the various criminal
enterprise members to avoid detection by law enforcement. Marcinkova, who is known to be
Epstein's bisexual sex slave, also directly participated in the sexual abuse of the minor girls
by participating in unlawful sexual activities and prostitution with the girls. Both Kellen and
Marcinkova assisted Epstein in attempting to keep Epstein's criminal sexual abuse unknown
Case 9:10-cv-81111-WPD Document 1-1 Entered on FLSD Docket 09/17/2010 Page 2 of 10
to law enforcement and other authorities and in discouraging the minor girls from reporting
the crimes to law enforcement and other authorities. Maxwell and Brunel participated by
helping to create the impression that the girls would be going to meet with Epstein for
legitimate "modeling" purposes. Maxwell and Brunel specifically intended to have Epstein
abuse the girls and acted with full awareness of Epstein's intentions. Both Brunel and
Maxwell recruited minor females for Epstein as well as for themselves in an effort to further
the goals of the criminal organization - to sexually abuse and molest underage minor females
and avoid detection of law enforcement.