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m. He also received perverse sexual gratification from directing others (e.g., Marcinkova) to sexually abuse and prostitute minor girls. 11. While Jane Doe's civil action alleges violations of the Florida Civil RICO statute rather than violations of the federal civil RICO statute, it should be noted that
e 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 Jane Doe's complaint. 3. The other wrongdoers included Sarah Kellen and Nadia Marcinkova. (Jane Doe is uncertain as to the precise spelling of their names and
t 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. While others (including Kellen and Marcinkova) were involved in the plan, scheme, and enterprise, the sole defendant alleged i
y to enjoy life. These injuries are permanent in nature and the Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe, demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, punitive damages as specifically allowed by this and other stat
t 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 II. criminally sexually abused and prost
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 Jane Doe's complaint. 3. The other wrongdoers included and (Jane Doe is uncertain as to the precise spelling of their names and their full legal names.) Th
t 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. While others (including and were involved in the plan, scheme, and enterprise, the sole defendant alleged in this complaint
Entities connected to both Jane Doe and the "Florida Civil