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esult, Plaintiffs father dropped off Plaintiff at Defendant's mansion that same day. Ms. Maxwell met Plaintiff and her father outside of Defendant's Palm Beach mansion, where Ms. Maxwell assured the minor girl's father that Ms. Maxwell would provide transportation home for his teenaged daughter. Ghislaine M
7, Defendant used his resources and his influence over vulnerable minor girls to engage in a systematic pattern of sexually exploitative behavior. Podhurst Orsecic P.A. EFTA00210922 Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 3 of 27 II. Defendant's plan and scheme reflected a par
esult, Plaintiffs father dropped off Plaintiff at Defendant's mansion that same day. Ms. Maxwell met Plaintiff and her father outside of Defendant's Palm Beach mansion, where Ms. Maxwell assured the minor girl's father that Ms. Maxwell would provide transportation home for his teenaged daughter. Ghislaine M
ill in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn 16 Podhurst Orsecic P.A. 25 West Ragler Street, Suite 800, Miami, FL 33130, Miami 305.3582800 Fax 305.3582382 • Fort Lauderdak 954.463.4346 vnvw.podhurst.com EFTA00221629
ds. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and
wever, at least when Defendant was in Palm Beach, Florida, such acts occurred usually on a daily basis and, in most instances, several times a day. Podhurst Orsecic P.A. 4 23 West Flagler Sate, Suite 800, Miami. FL 33130, Mad X6.35511300 Pax 3(59582342 • Port Lauderdale 954.461.4346 veww.podlturattom Case No. 08-8
uld pay the procurer of each girl's "appointment" hundreds of dollars. 13. Defendant designed this scheme to secure a private place in Defendant's Palm Beach mansion where only persons employed and invited by Defendant would be present, so as to reduce the chance of detection of Defendant's sexual abuse a
osecution Agreement from denying the acts alleged in this Complaint and must effectively admit liability to Plaintiff, Jane Doe No. 103. COUNT ONE Podhurst Orsecic P.A. 9 25 West Plagler Street, Suite 800, Miami, FL 33330, Miami 305.358.2800 Fax 305268.2382 • Fort Lauderdale 954.463.4346 1 www.podhuratcom EFTA001
Entities connected to both Palm Beach and Podhurst Orsecic P.A.

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSONLeon Black
PERSON
United States
LOCATIONJack Goldberger
PERSON
Alan Dershowitz
PERSON
Palm Beach County
LOCATIONJane Doe
PERSON
U.S. Virgin Islands
LOCATIONFBI
ORGANIZATION
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONRoy Black
PERSON
Ken Starr
PERSONthe Upper East Side
LOCATION
Santa Fe
LOCATION
Jay Lefkowitz
PERSON