Epstein Secrets

4. The names of all of the victims are unknown to the plaintiff at this time. However, they include Jane Doe herself as well as the victim in E.W. I. Jeffrey Epstein and L.M. Jeffrey Epstein. A list of more than 30 such minor female victims has previously been provided by the U.S. Attorney's Office for the Sout

l note that the conspiracy was between defendant Jeffrey Epstein, nd numerous other persons whose identity is, at this time, unknown to Jane Doe. Epstein, and others all conspired together to violate the provisions of § 772.103(3), doing so willfully and with full knowledge of the criminal activities

the victims are unknown to the plaintiff at this time. However, they include Jane Doe herself as well as the victim in E.W. I. Jeffrey Epstein and L.M. Jeffrey Epstein. A list of more than 30 such minor female victims has previously been provided by the U.S. Attorney's Office for the Southern District of Florida t

luding Epstein also procured girls for prostitution and caused these girls to be prostituted. Epstein also served as the leader of the enterprise. g. Epstein was a direct perpetrator of the racketeering activity. In particular, Epstein engaged in criminal acts of sexual abuse and prostitution with minor g

ne to schedule times for each girl to "work" for Defendant Epstein at his house, and they helped to arrange for mino

FLSD Docket 04/17/2009 Page 1 of 19 JANE DOE'. JEFFREY EPSTEIN Case No.: 08-CIV-80893 - MARRA/JOHNSON

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

ing Kellen and Marcinkova) were involved in the plan, scheme, and enterprise, the sole defendant alleged in this complaint at this time is defendant Jeffrey Epstein. Epstein served as the leader and informal "C.E.O." of the criminal enterprise. He also criminally sexually abused and prostituted Jane Doe and othe

acy was between Defendant, Jeffrey Epstein, Sarah Kellen, Nadia Marcinkova, and other persons whose identity is, at this time, unknown to Jane Doe. 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

and others acting under his direction used means of interstate communications to make these false representations, including cellular telephones. d. Epstein has pled guilty to two Florida criminal offenses against minor girls, as alleged in paragraph 19 of the complaint. e. The relationship of the crimi

Florida Civil RICO action is, at this time, only defendant Epstein. Defendant Epstein is associated with a criminal

HERN DISTRICT OF FLORIDA Jane Doe, Plaintiff vs. Jeffrey Epstein, Defendant CASE NO: 08-CV-80893-MARRA/JO

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

d by Epstein's top assistant, Defendant 27. Defendant in furtherance of the scheme to exploit Plaintiff, escorted Plaintiff upstairs to Defendant Jeffrey Epstein's large bathroom, where Defendant set up the 7 EFTA00729614 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 8 of 29 mas

legal acts against her. FACTUAL ALLEGATIONS 9. At all times material, Defendant, Jeffrey Epstein, was an adult male, over 50 years old. Defendant Epstein is known as a billionaire, yet even those closest to him, including family members, long time employees and those that he considers his closest frie

ouse before taking her upstairs to be alone with Mr. Epstein. Upon information and belief, Defendant remains

y Epstein, was an adult male, over 50 years old. Defendant Epstein is known as a billionaire, yet even those closest

P mg, Civil Action No. CASE NO.: 9:10-cv-81111 JEFFREY EPSTEIN and WM Defendant (If the action is pend

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