Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 89 of 91 at vs. Epstein, et al. o.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint self-esteem, loss of dignity, invasion of personal privacy and other damages associated with JEFFREY EPSTEIN'S controlling , manipulating, and coercing MI into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, MB, will in the future suffer additional medical and psychological expenses. The Plaintiff, 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, MB, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, a, demands judgment against the Defendant, EMIfor compensatory damages of at least the minimum amount provided by law, punitive damages, 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. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 9th day of February, 2009, I electronically filed the foregoing with the Clerk of the Court by using CM/ECF system, which will send a notice of electronic filing to all counsel of record on the attached service list. 89 EFTA00175414

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 91 of 91 vs. Epstein, et al. 08-CV-80811-CIV-MARRAJJOHNSON First Amended Complaint Page 91 of 91 COUNSEL LIST Richard H. Willits, Esquire Richard H. Willits, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, FL 33461 Phone: Fax: Robert Critton, Esquire Burman Critton Luttier & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach FL 33414 Phone: Fax: Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South West Palm Beach FL 33401 Phone: Bruce E. Reinhart, Esquire Bruce E. Reinhart, P.A. 250 South Australian Avenue Suite 1400 West Palm B ch FL 33401 Phone: Fax: 91 EFTA00175415

CM/ECF Live Database - flsd Page I of 12 LRJ, MEDREQ, REF_DISCOV U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80893-KAM Doe v. Epstein Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson Lead case: 9:08-cv-80119-KAM Member case: (View Member Case) Case: 9:09-cv-80802-ICAM Cause: no cause specified Plaintiff Jane Doe V. Defendant Jeffrey Epstein Date Filed: 08/13/2008 Jury Demand: Plaintiff Nature of Suit: 360 P.I.: Other Jurisdiction: Federal Question represented by Bradley James Edwards Rothstein Rosenfeldt Adler 401 East Las Olas Blvd Suite 1650 Ft. Lauderdale FL 33301 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Paul G. Cassell Email: PRO HAG ATTORNEY TO BE NOTICED represented by Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach , FL 33401-5012 Fax: 835-8691 Email: https://ecf.flsd.uscourts.gov/cgi-bin/DktRptpl?859999798355213-L_801_0-1 6/10/2009 EFTA00175416

CM/ECP -.Live Database - flsd Page 2 of 12 LEAD ATTORNEY ATTORNEY TO BE NOTICED Robert Deweese Critton , Jr. Burman Critton Luther & Coleman 515 N Flagler Drive Suite 400 West Palm Beach , FL 33401-2918 Amicus United States of America ax: Emai LEAD ATTORNEY TO BE NOTICED Michael James Pike Burman Critton Luttier & Coleman 515 N Flagler Drive Suite 400 West Palm Beach , FL 33401-2918 Fax: 515-314 ATTORNEl li gi'M D Email: represented by mi B United States Attorney s Office 500 East Broward Blvd 7th Floor Ft Lauderdale , FL 33394 ext. 3546 Fax: 356-7336 Email: LEAD ATT ATTORNEY TO BE NOTICED Date Filed # that Docket Text 08/13/2008 1 n 0.6 MB COMPLAINT against Jeffrey Epstein Filing fee $ 350. Receipt#: 724605, filed by Jane Doe.(rb) (Entered: 08/14/2008) 08/13/2008 2 11 236.0 xri MOTION to Proceed Anonymously by Jane Doe. (rb) (Entered: 08/14/2008) https://ecf.flsd.uscourts.gov/egi-bin/DktRpt.pl?859999798355213-L 801_0-1 6/10/2009 EFTA00175417

CM/E,CF -Live Database - flsd Page 3 of 12 08/13/2008 3 Fr 119.3 KB MOTION to keep True Name in Sealed Envelope by Jane Doe. (rb) (Entered: 08/14/2008) 08/13/2008 4 r 69.8 KB Summons Issued as to Jeffrey Epstein. (rb) (Entered: 08/14/2008) 08/13/2008 5 Sealed Document. (rb) (Entered: 08/14/2008) 08/21/2008 6 r 96.6 KB MOTION for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filing for Paul G. Cassell, Filing Fee $75, Receipt #724636. (cw) (Entered: 08/25/2008) 08/25/2008 7 ENDORSED ORDER granting Paul G. Cassell 6 Motion for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filings. Signed by Judge Kenneth A. Marra on 8/25/08. (ir) (Entered: 08/25/2008) 09/15/2008 8 r 129.4 KB NOTICE of Attorney Appearance by Robert Deweese Critton, Jr on behalf of Jeffrey Epstein (Critton, Robert) (Entered: 09/15/2008) 09/30/2008 9 r 53.1 KB ORDER TO RESPOND re 3 MOTION to keep True Name in Sealed Envelope filed by Jane Doe, 2 MOTION to Proceed Anonymously filed by Jane Doe. Responses due by 10/15/2008. Signed by Judge Kenneth A. Marra on 9/30/08. (ir) (Entered: 09/30/2008) 10/01/2008 10. r 459.6 KB MOTION FOR EXTENSTION OF TIME TO RESPOND to I Complaint Extension to Respond to Complaint and Require Plaintfff to File Rico filed by Jeffrey Epstein. (Attachments: # 1 Extension to Respond to Complaint and Require Plaintiff to File RicoXCritton, Robert) Modified on 10/2/2008 (ir). (Entered: 10/01/2008) 10/02/2008 Clerks Notice of Docket Correction and Instruction to Filer re 10 RESPONSE/REPLY for Extension of Time filed by Jeffrey Epstein. Error - Wrong Event Selected; Correction - Redocketed by Clerk as MOTION for Extension of Time to Answer. Instruction to Filer - In the future, please select the proper event. It is not necessary to refile this document. (ir) (Entered: 10/02/2008) 10/02/2008 1 1 ENDORSED ORDER granting 10 Motion for Extension of Time to Answer Complaint. Jeffrey Epstein response due 10/10/2008. Plaintiff must file the Rule 12.1 Civil RICO statement by 10/3/08. Signed by Judge Kenneth A. Marra on 10/2/08. (ir) (Entered: 10/02/2008) 10/02/2008 12 r 160.0 KB RESPONSE to Motion re 2 MOTION to Proceed Anonymously filed by Jeffrey Epstein. Replies due by 10/14/2008. (Critton, Robert) (Entered: 10/02/2008) 10/03/2008 13 r 513 NOTICE of Attorney Appearance by Jack Alan Goldberger on behalf of Jeffrey Epstein (Goldberger, Jack) (Entered: 10/03/2008) https://ed.flsd.uscourts.gov/egi-bin/DktRpt.pl?859999798355213-L_801_0-1 6/10t2009 EFTA00175418

CM/ECF • Live Database - flsd Page 4 of 12 KB 10/03/2008 14 r 1.6 MB NOTICE by Jane Doe of Filing Civil RICO Case Statement Pursuant to Local Rule 12.1 (Attachments: # 1 Supplement Civil RICO Case Statement Pursuant to Local Rule 12.1)(Eclwards, Bradley) (Entered: 10/03/2008) 10/06/2008 15 r 603 ici3 ORDER granting 2 Motion to Proceed Anonymously ; granting 3 Motion to Keep True Name in Sealed Envelope. The Clerk shall SEAL the true name affidavit of the Plaintiff. Signed by Judge Kenneth A. Marra on 10/6/08. (ir) (Entered: 10/06/2008) 10/10/2008 16 r 1.7 MB Defendant's MOTION to Dismiss 1 Complaint, MOTION for More Definite Statement, MOTION to Strike 1 Complaint by Jeffrey Epstein. Responses due by 10/30/2008 (Critton, Robert) (Entered: 10/10/2008) 10/16/2008 17 r 4a5 RESPONSE to Motion re 16 Defendant's MOTION to Dismiss 1 Complaint MOTION for More Definite Statement MOTION to Strike i Complaint filed by Jane Doe. Replies due by 10/27/2008. (Edwards, Bradley) (Entered: 10/16/2008) 10/27/2008 18 r a Complaint REPLY to Response to Motion re 16 Defendant's MOTION to Dismiss 1 Complaint MOTION for More Definite Statement MOTION to Strike 1 filed by Jeffrey Epstein. (Attachments: # 1 Order in Jane Does 1 and 2XCritton, Robert) (Entered: 10/27/2008) 12/04/2008 19_ r 4823 KB SCHEDULING REPORT - Rule 26(f). (Critton, Robert) (Entered: 12/04/2008) 12/10/2008 20 r 82.5 KB ORDER Setting Trial Date & Discovery Deadlines, Referring Case to mediation & Referring Discovery Motions to United States Magistrate Judge. SCHEDULING ORDER: ( Jury Trial set for 2/22/2010 in West Palm Beach Division before Judge Kenneth A. Marra., Calendar Call set for 2/19/2010 10:00 AM in West Palm Beach Division before Judge Kenneth A. Marra., Amended Pleadings due by 2/2/2009., Discovery due by 10/1/2009., Pretrial Motions due by 10/20/2009.), ORDER REFERRING CASE to Mediation. 15 days to appoint mediator., ORDER REFERRING CASE to Magistrate Judge Linnea R. Johnson for Discovery Proceedings. Signed by Judge Kenneth A. Marra on 12/10/2008. (tas) (Entered: 12/11/2008) 03/04/2009 21 r, o.s MB Defendant's MOTION for Extension of Time to File Motions to Compel Directed to Plaintiffs Answers and Responses to discovery by Jeffrey Epstein. (Critton, Robert) (Entered: 03/04/2009) 03/12/2009 22 r 42.4 KB ORDER granting 21 Motion for Extension of Time to File Motion to Compel Directed to Plaintiffs Answers to Defendant's First Set of Interrogatories and to Plaintiffs Response to Defendant's First Request for Production to on or before April 3, 2009. Signed by Magistrate Judge Linnea R. Johnson on 3/12/2009. (kza) (Entered: 03/12/2009) https://ectflsd.useourts.gov/egi-bin/DktRpt.p12859999798355213-L 801_0-1 6/10/2009 EFTA00175419

CM/ECF —Live Database - flsd Page 5 of 12 03/19/2009 23 r 56.8 KB ORDER Setting Hearing on Motion 16 Defendant's MOTION to Dismiss 1 Complaint MOTION for More Definite Statement MOTION to Strike 1 Complaint : Motion Hearing set for 4/1/2009 01:00 PM in West Palm Beach Division before Judge Kenneth A. Marra. Signed by Judge Kenneth A. Marra on 3/19/2009. (ir) (Entered: 03/19/2009) 03/26/2009 24 r 2.3 MB Defendant's MOTION to Stay re 1 Complaint by Jeffrey Epstein. Responses due by 4/13/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit B) (Pike, Michael) (Entered: 03/26/2009) 03/30/2009 25 r 161.4 KB Notice of Supplemental Authority re 16. Defendant's MOTION to Dismiss 1 Complaint MOTION for More Definite Statement MOTION to Strike 1 Complaint by Jeffrey Epstein (Pike, Michael) (Entered: 03/30/2009) 04/01/2009 29 Minute Entry for proceedings held before Judge Kenneth A. Marra: Motion Hearing held on 4/1/2009 re 16 Defendant's MOTION to Dismiss 1 Complaint MOTION for More Definite Statement MOTION to Strike 1 Complaint filed b Jeffrey Epstein. Court Reporter: Stephen Franklin, Phone: (ir) (Entered: 04/08/2009) 04/02/2009 26 r 56.2 KB ORDER granting 16 Motion to Dismiss; granting 16 Motion for More Definite Statement; terminating 16 Motion to Strike. Signed by Judge Kenneth A. Marra on 4/2/2009. (ir) (Entered: 04/02/2009) 04/02/2009 27 r 440.3 KB Defendant's MOTION to Compel Response to 1st RTP by Jeffrey Epstein. Responses due by 4/20/2009 (Attachments: # 1 Exhibit A)(Pike, Michael) (Entered: 04/02/2009) 04/02/2009 a r 210.0 KB Defendant's MOTION to Compel Response to 1st Interrogs by Jeffrey Epstein. Responses due by 4/20/2009 (Pike, Michael) (Entered: 04/02/2009) 04/09/2009 30 r 323 KB "WRONG EVENT USED, RE-DOCKETED AS ENTRY 34 " NOTICE by Jane Doe of Change of Firm Affiliation (Edwards, Bradley) Modified on 4/13/2009 (Is). (Entered: 04/09/2009) 04/09/2009 31 r 39.6 Ka RESPONSE in Opposition re 24 Defendant's MOTION to Stay re 1 Complaint filed by Jane Doe. (Edwards, Bradley) (Entered: 04/09/2009) 04/09/2009 32 r 20.8 KB MOTION to Strike Reference to Non Prosecution Agreement by Jane Doe. Responses due by 4/27/2009 (Edwards, Bradley) (Entered: 04/09/2009) 04/09/2009 34 NOTICE of Change of Address and Firm Affiliation by Bradley James Edwards [See Image at DE #30] (Is) (Entered: 04/13/2009) 04/13/2009 33 Clerks Notice of Docket Correction and Instruction to Filer re 30 Notice (Other) filed by Jane Doe. Error - Wrong Event Selected; Correction - Redocketed by Clerk as Notice of Change of Address. Instruction to Filer - In the future, please select the proper event. It is not necessary to refile this httos://ectflsd.useoutts.gov/cgi-bin/DktRpt.p17859999798355213-L 801_0-1 6/10/2009 EFTA00175420

CM/ECE -.Live Database - flsd Page 6 of 12 document. (Is) (Entered: 04/13/2009) 04/15/2009 35. r 1.8 MB Defendant's MOTION to Compel Response to Defendant's First Set of Interrogatories by Jeffrey Epstein. Responses due by 5/4/2009 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit I)(Pike, Michael) (Entered: 04/15/2009) 04/15/2009 3.6 r 13.4 KR RESPONSE in Opposition re 21 Defendant's MOTION to Compel Response to 1st RTP filed by Jane Doe. (Edwards, Bradley) (Entered: 04/15/2009) 04/15/2009 37 r 25.3 KB RESPONSE in Opposition re 28 Defendant's MOTION to Compel Response to 1st Interrogs filed by Jane Doe. (Edwards, Bradley) (Entered: 04/15/2009) 04/17/2009 aa r 863 to First AMENDED COMPLAINT, filed by Jane Doe. (Attachments: # 1 Exhibit A)(Edwards, Bradley) (Entered: 04/17/2009) 04/22/2009 32 r 145.1 KB Defendant's MOTION for Extension of Time to File Reply as to 31 Response in Opposition to Motion to Defendant's Motion to Stay by Jeffrey Epstein. (Pike, Michael) (Entered: 04/22/2009) 04/23/2009 40 ENDORSED ORDER granting 32 Motion for Extension of Time to Reply re 24 Defendant's MOTION to Stay re 1 Complaint. Replies due by 5/12/2009. Signed by Judge Kenneth A. Marra on 4/23/2009. (ir) (Entered: 04/23/2009) 04/27/2009 .11. r 150.6 KB Defendant's MOTION for Extension of Time to File Reply as to 36 Response in Opposition to Motion to Compel Production of Tax Returns by Jeffrey Epstein. (Pike, Michael) (Entered: 04/27/2009) 04/27/2009 42 n 1:14 Defendant's MOTION for Extension of Time to File Reply as to 37 Response in Opposition to Motion to Compel Plaintiff to Respond to First Set Interrogatories by Jeffrey Epstein. (Pike, Michael) (Entered: 04/27/2009) 04/28/2009 43 - n 60.2 Ks ORDER TO SHOW CAUSE why cases should not be consolidated for discovery purposes Show Cause Response due by 5/5/2009.. Signed by Judge Kenneth A. Marra on 4/28/2009. (cqs) (Entered: 04/29/2009) 04/29/2009 44 n 141.6 KB Defendant's MOTION for Extension of Time to File Response as to 32 MOTION to Strike Reference to Non Prosecution Agreement or, in the alternative, to Lift Protective Order Barring Jane Doe's Attorney's from Revealing Provision in the Agreement by Jeffrey Epstein. (Pike, Michael) (Entered: 04/29/2009) 05/01/2009 45 r ORDER Granting 41 Motion for Extension of Time in which to file reply in support of Motion to Compel Tax Records ; Granting 42 Motion for Extension of Time to file reply in support of Motion to Compel Response https://ecf.flsd.useourts.gov/cgi-bin/D1ctRpt.p1T859999798355213-L_801_0-1 6/10/2009 EFTA00175421

CM/ECF -Live Database - flsd Page 7 of 12 822 KB to First set of Interrogatories ; Granting 44 Motion for Extension of Time to Respond to Motion to Strike References to Non-Prosecution Agreement. Signed by Magistrate Judge Linnea R. Johnson on 5/1/2009. (sa) (Entered: 05/01/2009) 05/04/2009 46 r 381.1 KB REPLY to Response to Motion re 27 Defendant's MOTION to Compel Response to 1st RTP, Il. Defendant's MOTION for Extension of Time to File Reply as to 36 Response in Opposition to Motion to Compel Production of Tax Returns filed by Jeffrey Epstein. (Attachments: # 1 Exhibit Exhibit AXPike, Michael) (Entered: 05/04/2009) 05/04/2009 41 r 219.6 KB RESPONSE TO ORDER TO SHOW CAUSE by Jane Doe. (Edwards, Bradley) (Entered: 05/04/2009) 05/04/2009 48 r 0.5 NIB REPLY to Response to Motion 37 Response in Opposition to Motion to Compel Plaintiff to Respond to First Set Interrogatories, 35 Defendant's MOTION to Compel Response to Defendant's First Set of Interrogatories filed by Jeffrey Epstein. (Attachments: # 1 Exhibit Exhibit AXPike, Michael) Modified link on 5/5/2009 (1k). (Entered: 05/04/2009) 05/04/2009 49 ri " 3B3 MEMORANDUM in Opposition re la Order to Show Cause by Jeffrey Epstein. (Pike, Michael) (Entered: 05/04/2009) 05/04/2009 50 RESPONSE TO ORDER TO SHOW CAUSE by Jeffrey Epstein. See image DE 49 (1k) (Entered: 05/05/2009) 05/05/2009 51 Clerks Notice of Docket Correction and Instruction to Filer re 49 Memorandum in Opposition filed by Jeffrey Epstein. ERROR - Wrong Event Selected; Correction - Redocketed by Clerk as 50 RESPONSE TO ORDER TO SHOW CAUSE. Instruction to Filer - In the future, please select the proper event, UNDER OTHER ANSWERS/RESPONSES/REPLIES. It is not necessary to refile this document. (1k) (Entered: 05/05/2009) 05/05/2009 52 r 136.5 KB Defendant's MOTION for Extension of Time to File Response as to 38 Amended Complaint by Jeffrey Epstein. (Critton, Robert) (Entered: 05/05/2009) 05/06/2009 53 ENDORSED ORDER granting 52 Motion for Extension of Time to Answer Amended Complaint. Jeffrey Epstein response due 5/18/2009. Signed by Judge Kenneth A. Marra on 5/5/2009. (ir) (Entered: 05/06/2009) 05/12/2009 54 r 344.8 KB RESPONSE/REPLY to al Response in Opposition to Motion to Stay and/or Continue Action for Time Certain by Jeffrey Epstein. (Pike, Michael) (Entered: 05/12/2009) 05/13/2009 55 r soil K13 SUPPLEMENT to 54 Response/Reply (Other) to Plaintiffs Response in Opposition to Defendant's Motion to Stay and/or Continue Action by Jeffrey Epstein. (Pike, Michael) (Entered: 05/13/2009) httos://ectflsd.uscourts.govicgi-bitilDktRpt.p17859999798355213-L 801_0-1 6/10t2009 EFTA00175422

CWECF r Live Database - flsd Page 8 of 12 05/14/2009 Cases associated. (dg) (Entered: 05/14/2009) 05/14/2009 56 r 1063 KB ORDER CONSOLIDATING CASES. Hereinafter all motions and other court filings that relate to discovery and all procedural motions that relate to multiple cases shall be styled with all of the case names and numbers and shall be filed in Case No. 08-80119-CIV-MARRA. Signed by Judge Kenneth A. Marra on 5/14/2009. Associated Cases: 9:08-cv-80119-KAM et al. (ir) (Entered: 05/14/2009) 05/14/2009 57 _ r 1.3 ms ORDER REQUESTING UNITED STATES PROVIDE POSITION TO MOTION TO STAY. Signed by Judge Kenneth A. Marra on 5/14/2009. (Attachments: # 1 Appendix Motion to Stay DE 51) Associated Cases: 9:08-cv-80119-KAM et al. (ir) (Entered: 05/14/2009) 05/14/2009 58 ORDER terminating 24 Motion to Stay. Signed by Judge Kenneth A. Marra on 5/14/2009. (Ic3) (Entered: 05/14/2009) 05/14/2009 59 ORDER denying 32 Motion to Strike, without prejudice to re-file procedural motions relating to multiple cases in case no. 08-80119. See Order consolidating cases.. Signed by Judge Kenneth A. Marra on 5/14/2009. (1c3) (Entered: 05/14/2009) 05/18/2009 60 r 125.9 KB MOTION for Extension of Time to File Response to Plaintiffs First Amended Complaint by Jeffrey Epstein. (Pike, Michael) (Entered: 05/18/2009) 05/19/2009 61 ENDORSED ORDER granting 60 Motion for Extension of Time to Answer Complaint. Jeffrey Epstein response due 6/4/2009. Signed by Judge Kenneth A. Marra on 5/19/2009. (ir) (Entered: 05/19/2009) 05/19/2009 62 17 Me Defendant's MOTION to Strike Cases from Current Trial Docket by Jeffrey Epstein. Responses due by 6/8/2009 (Attachments: # 1 Exhibit A) Associated Cases: 9:08-cv-80119-KAM et al.(Pike, Michael) (Entered: 05/19/2009) 05/20/2009 63 ORDER terminating (93) Motion to Strike ; terminating (94) Motion in case 9:08-cv-80232-ICAM; terminating (110) Motion to Strike ; terminating (111) Motion in case 9:08-cv-80380-KAM; terminating (95) Motion to Strike ; terminating (96) Motion in case 9:08-0v-80381-KAM; terminating (90) Motion to Strike ; terminating (91) Motion in case 9:08-cv-80811- KAM; terminating (62) Motion to Strike in case 9:08-cv-80893-KAM; terminating (62) Motion to Strike in case 9:08-cv-80993-KAM; terminating (50) Motion to Strike in case 9:08-cv-80994-KAM. Signed by Judge Kenneth A. Marra on 5/20/2009. (Ic3) (Entered: 05/20/2009) 05/20/2009 64 Clerks Notice of Docket Correction and Instruction to Filer re 62 MOTION to Strike filed by Jeffrey Epstein. Error - Motion with Multiple Reliefs Filed as One Relief;. Instruction to filer - In the future, please select all applicable reliefs. It is not necessary to refile this document. (Is) (Entered: https://ecf.flsd.uscourts.gov/cgi-biti/DIctRpt.pl?859999798355213-L J01_0-1 6/10/2009 EFTA00175423

CM/ECF —Live Database - flsd Page 9 of 12 05/20/2009) 05/20/2009 65 r 363.1 KB NOTICE by . of Filing Withdrawal of Previously Raised Oils to Defendant, Jeffrey Epstein's Motion to Comp Or Identify in the Style of This Case and Motion to IdenttfrIME in Third-Party Subpoenas for Purposes of Discovery, Or, Alternatively, Motion to Dismiss Sua Sponte, With Inorporated Memorandum of Law Associated Cases: 9:08-cv-80119-KAM et al.(Hill, Jack) (Entered: 05/20/2009) 05/20/2009 66 ORDER ULLLING in all Epstein cases EXCEPT case no. 08-80119: Notice by I.... of Filing Withdrawal of Previously Raised Objections to Epstein's Motion to Compel and/or Identify. This Notice should only be filed in 08-80119, not in all of the Epstein cases.. Signed by Judge Kenneth A. Marra on 5/20/2009. Associated Cases: 9:08-cv-80119-ICAM et al. (Ic3) (Entered: 05/20/2009) 05/22/2009 67 Clerks Notice of Docket Correctimaad Instruction to Filer re 65 Notice (Other), Notice (Other) filed by il..... Error - Incorrect Document Link/No Link;. Instruction to filer - In the future, please link the document to the proper entry. It is not necessary to refile this document. (Is) (Entered: 05/22/2009) 05/27/2009 68 r 52.0 KB NOTICE by Jane Doe re (111 in 9:08-cv-80119-KAM) Plaintiffs MOTION for Extension of Time to File Response as to (91 in 9:08-cv- 80119-1CAM) Defendant's MOTION to Compel Identity of Doe in Style of Case and Third-Party Subpoenas (replaces Docket entry 90)Plaintiffs MOTION for Extension of Time to File Response as to (91 in 9:08-cv- 80119-ICAM) Defendant's MOTION to Compel Identity of Doe in Style of Case and Third-Party Subpoenas (replaces Docket entry 90) (Attachments: # 1 Text of Proposed Order)Associated Cases: 9:08-cv-80119-KAM et al. (Horowitz, Adam) (Entered: 05/27/2009) 05/28/2009 69 ORDER STRIKING Notice by Jane Doe in all Epstein cases EXCEPT in case 08-80119. This Notice should only be filed in 08-80119, not in all of the Epstein cases... Signed by Judge Kenneth A. Marra on 5/28/2009. Associated Cases: 9:08-cv-80119-KAM et al. (1c3) (Entered: 05/28/2009) 05/29/2009 70 r 11.6 KR NOTICE of Attorney Appearance by on behalf of fimica Associated Cases: 9:08-cv-80119-KAM et al. , ) (Entered: 05/29/2009) 05/29/2009 71 E 37.7 RESPONSE to Motion re (72 in 9:08-cv-80380-KAM) Defendant's MOTION to Stay re (62) Amended Complaint, (57 in 9:08-cv-80232- KAM) Defendant's MOTION to Stay re (50) Amended Complaint, (24 in 9:08-cv-80893-KAM) Defendant's MOTION to Stay re (1) Complaint, (23 in 9:08-cv-80994-KAM) Defendant's MOTION to Stay re (18) Amended Complaint, (22 in 9:08-cv-80993-KAM) Defendant's MOTION to Stay re (19) Amended Complaint, (65 in 9:08-cv-80119-ICAM) Defendant's https://ecf.flsd.useourts.gov/egi-bin/DktRpt.p1.7859999798355213-L_801_0-1 6/10/2009 EFTA00175424

CM/ECE -Live Database - flsd Page 10 of 12 KB MOTION to Stay re (56) Amended Complaint, (68 in 9:08-cv-80381- KAM) Defendant's MOTION to Stay re (60) Amended Complaint, (51 in 9:08-cv-80811-KAM) Defendant's MOTION to Stay re (40) Amended Complaint and or Continue Action Filed Pursuant to Court's Order Requesting Government's Position filed by United States of America. /2C 9n ases00:99):08-cv-80119-1CAM et al. Associated 05 Sit )9 (.Entered ) 05/29/2009 72 r 433 fa3 RESPONSE in Opposition re (90 in 9:08-cv-80119-KAM) Defendant's MOTION to Compel Identify Doe in Style of Case and in Third-Party Subpoenas, (91 in 9:08-cv-80119-KAM) Defendant's MOTION to Compel Identity of Doe in Style of Case and Third-Party Subpoenas (replaces Docket entry 90) filed by Jane Doe No. 102, Jane Doe No. 101. Associated Cases: 9:08-cv-80119-KAM et al.(Ezell, Katherine) (Entered: 05/29/2009) 05/29/2009 73 ORDER STRIKING (124 in 9:08-cv-80119-KAM, 105 in 9:08-cv-80811- KAM, 74 in 9:08-cv-80993-KAM, 72 in 9:08-cv-80893-KAM, 106 in 9:08- cv-80232-KAM, 123 in 9:08-cv-80380-KAM, 35 in 9:09-cv-80591-KAM, 25 in 9:09-cv-80469-KAM, 60 in 9:08-cv-80994-KAM, 22 in 9:09-cv- 80656-KAM, 107 in 9:08-cv-80381-KAM) Response in Opposition to Motion, filed by Jane Doe No. 102, Jane Doe No. 101 DO NOT FILE IN EVERY EPSTEIN CASE. SEE ORDER CONSOLIDATING CASES.. Signed by Judge Kenneth A. Marra on 5/29/2009. Associated Cases: 9:08- cv-80119-ICAM et al. (Ic3) (Entered: 05/29/2009) 05/29/2009 74 r 24.5 KB MOTION for Leave to File UNDER SEAL RESPONSE IN OPPOSITION TO DEFENDANTS MOTION TO STAY OR, IN THE ALTERNATIVE, TO UNSEAL THE NONPROSECUTION AGREEMF,KT by Jane Doe No. 102, Jane Doe No. 101. Associated Cases: 9:08-cv-80119-KAM et al.(Ezell, Katherine) (Entered: 05/29/2009) 05/29/2009 75_ r 19.5 KB MOTION for Hearing MOTION TO RESCHEDULE HEARING by Jane Doe No. 102, Jane Doe No. 101. Associated Cases: 9:08-cv-80119-ICAM et al.(Josefsberg, Robert) (Entered: 05/29/2009) 06/01/2009 76 ORDER STRIKING (28 in 9:09-cv-80469-KAM, 126 in 9:08-cv-80380- KAM, 109 in 9:08-cv-80232-KAM, 25 in 9:09-cv-80656-ICAM, 77 in 9:08- cv-80993-ICAM, 38 in 9:09-cv-80591-KAM, 110 in 9:08-cv-80381-KAM, 63 in 9:08-cv-80994-ICAM, 75 in 9:08-cv-80893-KAM, 108 in 9:08-cv- 80811-1CAM) Motion to Continue Hearing filed by Jane Doe No. 102, Jane Doe No. 101, (76 in 9:08-cv-80993-KAM, 109 in 9:08-cv-80381-KAM, 108 in 9:08-cv-80232-KAM, 62 in 9:08-cv-80994-KAM, 125 in 9:08-cv- 80380-KAM, 74 in 9:08-cv-80893-KAM, 24 in 9:09-cv-80656-KAM, 37 in 9:09-cv-80591-ICAM, 107 in 9:08-cv-80811-KAM, 27 in 9:09-cv-80469- KAM) Motion for Leave to File, filed by Jane Doe No. 102, Jane Doe No. 101. THESE DOCUMENTS SHOULD BE FILED ONLY IN 08-80119. SEE CASE MANAGEMENT ORDER.. Signed by Judge Kenneth A. https://e,ef.flsd.useourts.gov/egi-bin/DktRpt.p17859999798355213-L_801_0-1 6/10/2009 EFTA00175425

CM/ECE 'Live Database - flsd Page 11 of 12 Marra on 6/1/2009. (1c3) (Entered: 06/01/2009) 06/03/2009 77 r 160.9 KB Defendant's MOTION for Extension of Time to File Response as to 38 Amended Complaint Unopposed by Jeffrey Epstein. (Attachments: # 1 Text of Proposed Order Order)(Pike, Michael) (Entered: 06/03/2009) 06/04/2009 78 ENDORSED ORDER granting 77 Motion for Extension of Time to Answer First Amended Complaint. Jeffrey Epstein response due 6/10/2009. Signed by Judge Kenneth A. Marra on 6/4/2009. (ir) (Entered: 06/04/2009) 06/04/2009 79 r 349.0 KB REPLY to Response to Motion re (113 in 9:08-cv-80119-ICAM) Plaintiffs MOTION Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No- Contact Order Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Reply to Defendant Jeffrey Epstein's Response to Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Motion for a No-Contact Order filed by Jane Doe No. 101, Jane Doe No. 102. Associated Cases: 9:08-cv-80119-KAM et al. (Ezell, Katherine) (Entered: 06/04/2009) 06/04/2009 80 ORDER STRIKING (112 in 9:08-cv-80381-KAM, Ill in 9:08-cv-80232- KAM, 136 in 9:08-cv-80119-KAM, 111 in 9:08-cv-80811-KAM, 128 in 9:08-cv-80380-KAM, 65 in 9:08-cv-80994-KAM, 79 in 9:08-cv-80893- KAM, 42 in 9:09-cv-80591-ICAM, 27 in 9:09-cv-80656-ICAM, 32 in 9:09- cv-80469-ICAM, 79 in 9:08-cv-80993-KAM) Reply to Response to Motion, filed by Jane Doe No. 102, Jane Doe No. 101 Document stricken for failure to follow Court's orders. DO NOT FILE A DOCUMENT IN EVERY EPSTEIN CASE if it is to be filed only in 08-80119. See Case Management Order and contact CM/ECF Support for assistance in proper filing.. Signed by Judge Kenneth A. Marra on 6/4/2009. Associated Cases: 9:08-cv-80119- KAM et al. (1c3) (Entered: 06/04/2009) 06/08/2009 81 r 161.3 KB Defendant's MOTION for Extension of Time to File Response as to 38 Amended Complaint by Jeffrey Epstein. (Attachments: # 1 Text of Proposed Order)(Pike, Michael) (Entered: 06/08/2009) 06/08/2009 82 r 3.8 MB RESPONSE to Motion re (91 in 9:08-cv-80119-KAM) Defendant's MOTION to Compel Identity of Doe in Style of Case and Third-Party Subpoenas (replaces Docket entry 90) filed by Jane Doe. Replies due by 6/18/2009. (Attachments: # 1 Exhibit A, # 2 Exhibit B)Associated Cases: 9:08-cv-80119-ICAM et al.(Horowitz, Adam) (Entered: 06/08/2009) 06/08/2009 83 r 106.1 KB NOTICE by Jane Doe re (113 in 9:08-cv-80119-KAM) Plaintiffs MOTION Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No- Contact Order -Plaintiffs Jane Does 2-7 Notice of Joinder Associated Cases: 9:08-cv-80119-KAM et al.(Horowitz, Adam) (Entered: 06/08/2009) 06/10/2009 84 ENDORSED ORDER granting .81_ Motion for Extension of Time to Answer Amended Complaint. Jeffrey Epstein response due 6/12/2009. Signed by Judge Kenneth A. Marra on 6/9/2009. (ir) (Entered: 06/10/2009) https://ecf.flsd.useourts.gov/cgi-bin/DictRpt.p17859999798355213-L_801_0-1 6/10/2009 EFTA00175426

CM/ECE -Live Database - flsd Page 12 of 12 06/10/2009 85 Clerks Notice of Docket Correction and Instruction to Filer re 83 Notice (Other), Notice (Other) filed by Jane Doe. Error - Wrong Event Selected;. Instruction to Filer - In the future, please select the proper event, i.e. Notice of Adoption. It is not necessary to refile this document. (ls) (Entered: 06/10/2009) View Selected Total filesize of selected documents (MB): I or Maximum filesize allowed (MB): 10 Download Selected PACER Service Center Transaction Receipt 06/10/2009 13:53:26 PACER Login: du4480 Client Code: Description: Docket ,Report Search Criteria: 9:08-cv-80893- KAM Billable Pages: 7 Cost: 0.56 https://ectilsd.uscourts.gov/cgi-bin/DktRpt.p17859999798355213-L_801_0-1 6/10/2009 EFTA00175427

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Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 1 of 19 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Plaintiff, VS. JEFFREY EPSTEIN, Defendant. 09-80591 Civil Action No. CIV-MARRP MAGISTRATE JUDGE JOHNSON BLED DY INTAKE APR 1 7 2009 STEVEN M. LARIMORE CLERK U.S. DIST. CT. S.O. OF FLA. MIAMI COMPLAINT AND DEMAND FOR JURY TRIAL COMPLAINT AND DEMAND FOR JURY TRIAL Plaintiff, Jane Doe No. 101 ("Jane Doe"), brings this Complaint against Defendant, Jeffrey Epstein, and states as follows: PARTIES, JURISDICTION, AND VENUE I. At all times material to this cause of action, Plaintiff, Jane Doe, was a resident of Palm Beach County, Florida. 2. This Complaint is brought under a fictitious name to protect the identity of Plaintiff, Jane Doe, because this Complaint makes sensitive allegations of sexual assault and abuse of a then minor. 3. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence located at 358 El Grillo Way, West Palm Beach, Palm Beach County, Florida. 4. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is currently incarcerated in the Palm Beach County Stockade. 5. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. Podhurst Orseck, P.A. 25 West Nagler Street, Suite 800, Miami, FL 33130, Miami Fax • Fort Lauderdale www.podhursLcom EFTA00175429

Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 2 of 19 6. This Court has jurisdiction of this action and the claims set forth herein pursuant to 18 U.S.C. § 2255. 7. This Court has venue of this action pursuant to 28 U.S.C. § 1391(a), as a substantial part of the events giving rise to the claim occurred in this District. STATEMENT OF FACTS 8. At all relevant times, Defendant, Jeffrey Epstein, was an adult male, approximately 50 years old. Epstein is known as a billionaire financier and money manager with a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth, power, and influence. He owns a fleet of aircraft that includes a Gulfstream IV, a helicopter, and a Boeing 727. Until his incarceration, he maintained his principal place of residence in the largest home in Manhattan, a 51,000-square-foot eight-story mansion on the Upper East Side. Upon information and belief, he also owns a $6.8 million mansion in Palm Beach, Florida, a $30 million 7,500-acre ranch in New Mexico he named "Zorro," and a 70-acre private island known as Little St. James in St. Thomas, U.S. Virgin Islands. The allegations herein concern Defendant's conduct while at his lavish estate in Palm Beach. 9. Upon information and belief, Defendant has a sexual preference for underage minor girls. He engaged in a plan, scheme, or enterprise in which he gained access in his home to countless relatively economically disadvantaged minor girls, sexually assaulted or molested these girls, and then gave them money. 10. Beginning in or around 2001 through in or around September 2007, Defendant used his resources and his influence over vulnerable minor children to engage in a systematic pattern of sexually exploitative behavior. II. Defendant's plan and scheme reflected a particular pattern and method. Defendant coerced and enticed impressionable, vulnerable, and relatively economically less Podhurst Orseck, P.A. 2 25 West Flagier Street, Sults 800, Miami, FL 33130, Miami Fax • Fort Lauderclak www.podburstcout EFTA00175430

Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 3 of 19 fortunate minors to participate in various acts of sexual misconduct that he committed upon them. Defendant's scheme involved the use of underage girls as well as other individuals to recruit other underage girls. Upon information and belief, Defendant or an authorized agent would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach residence. His assistants would seek out economically disadvantaged and underage girls from West Palm Beach and surrounding areas who would be enticed by the money being offered— generally $200 to $300 per "massage" session—and who Defendant and/or his assistants perceived as less likely to complain to authorities or have credibility issues if allegations of improper conduct were made. The then minor Plaintiff and other minor girls, some as young as 14 years old, were transported to Defendant's Palm Beach county mansion by Defendant's employees, agents, and/or assistants in order to provide Defendant with "massages." 12. Defendant would pay the procurer of each girl's "appointment" approximately $200. Many of the instances of illegal sexual conduct committed by Defendant were perpetrated with the assistance, support, and facilitation of at least three assistants who helped him orchestrate this child exploitation enterprise. These assistants would often arrange times for underage girls to come to Defendant's residence, transport or cause the transportation of underage girls to Defendant's residence, escort the underage girls to the massage room where Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the conclusion of each "massage appointment," and, upon information and belief, take nude photographs and/or videos of the underage girls' for Defendant without their knowledge. 13. Epstein designed the scheme to secure a private place in Defendant's mansion where only persons employed and invited by Epstein would be present, so as to reduce the chance of detection of Defendant's sexual abuse and prostitution as well as to make it more Podhurst Orseck, P.A. 3 25 West Meer Strwt, Suite 800, Miami, FL 33130, Miami Fax • Port Lauderdale vnvw.podhurst.coui EFTA00175431

Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 4 of 19 difficult for the minor girls to flee the premises and/or to credibly report his actions to law enforcement or other authorities. The girls were usually transported by his employees, agents, and/or assistants or by a taxicab paid for by Defendant in order to make it difficult for the girls to flee his mansion. 14. Upon arrival at Defendant's mansion, each underage victim would generally be introduced to one of Defendant's assistants, who would gather the girl's personal contact information. The minor girl would then be led up a flight of stairs to a room that contained a massage table and a large shower. The staircase leading to the room was plastered with nude photographs of young girls, including some photographs depicting two or more young girls engaged in lewd acts. Upon information and belief, Defendant, Jeffrey Epstein, had such photographs in each of his four homes and on his computer. 15. At times, if it was the girl's first "massage" appointment, another female would be in the room to "lead the way" until Defendant would have her leave. Generally, Defendant would start his massage wearing only a small towel, which eventually would be removed. Defendant would direct the girl to massage him, giving her specific instructions as to where and how he wanted to be touched, and then direct her to remove her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including masturbation, fondling the minor's breasts and/or sexual organs, touching the with a IIMM and/or■ her performing and/or coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution. The exact degree of molestation and frequency with which the sexual crimes took place varied and is not yet completely known; however, 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 Orseck, P.A. 4 25 West Flagler Street Suite 800, Nan* FL 33130, tdlaml Fax • Fort Lauderdale EFTA00175432

Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 5 of 19 16. As previously stated in paragraph 14, Defendant displayed nude photographs of underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. Upon information and belief, some 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 belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate commerce. 17. Consistent with the foregoing plan and scheme, Defendant used his money, wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff Plaintiff, Jane Doe, was recruited by one of Defendant's agents to give Defendant a massage for compensation. Plaintiff was apprehensive, but needed the money and finally agreed to go. Plaintiff was first brought to Defendant's mansion in or about the spring of 2003, when she was merely 17 years old and in high school. Epstein's procurer drove her to Jeffrey Epstein's mansion. Plaintiff was led up a flight of stairs by a blonde woman to a spa room with a shower and a massage table, where she was left alone. A woman with dark hair, an accent, and naked from the waist up entered and tried to coax Plaintiff to remove her shirt, but Plaintiff refused. After the woman showed Plaintiff how to use the lotions that were there, the woman left. Defendant walked in wearing only a small towel. He lay down on the massage table still wearing the small towel, and Plaintiff began to massage his shoulders and neck. Nervously, she asked him what he did for a living. Defendant responded that he was a scientist. Defendant asked Plaintiff what year she would graduate high school, to which Plaintiff honestly replied that she would graduate in 2004. Plaintiff massaged Defendant's lower back and calves. Defendant Podhurst Orsecic, P.A. 5 ZS Wet Meer Street Suite 800, Miami, FL 33130, Miami Fax • Fort Lauderdale EFTA00175433

Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 6 of 19 told her to remove his towel. Defendant told her that he had just worked out and wanted his buttocks massaged. Although disgusted, she was afraid to refuse and did it. At some point, Defendant ordered Plaintiff to remove her clothes. In shock, fear, and trepidation, Plaintiff partly complied, removing only her shirt and bra. When Defendant turned over, Plaintiff was afraid and embarrassed and she wanted to leave. Defendant repeatedly told her to relax and complimented her, saying that she had a nice body. Defendant then pulled Plaintiff closer to him. He began masturbating and then began fondling her breasts. He asked her to do more and mentioned more money, which she adamantly declined. Defendant continued masturbating until he ejaculated. Plaintiff next recalls that she received $200 and was transported by the procurer, whom she later learned received $200 for having brought her to Epstein's mansion. IS. Defendant thereafter lured the then minor Plaintiff to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003. The procurer made another appointment for her to return, but Plaintiff didn't want to see Defendant. By having his assistants continue to contact Plaintiff and attempt to lure her to the mansion for other sexual acts, Defendant engaged in a continuous course of conduct that injured Plaintiff upon each instance of contact and/or abuse. 19. In addition to the direct sexual abuse and molestation of the then minor Plaintiff, Defendant used his money, wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff to bring him another minor girl in a promised exchange for money. Rather than go herself, Plaintiff and the procurer took another girl there one time. 20. As a result of these encounters with Defendant, Plaintiff, Jane Doe, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and Podhurst Orseck, P.A. 6 25 West Flatter Street, Suite 800, Miami, FL 33130, Miami Fax • Fott Lauderdale podluustcom EFTA00175434

Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 7 of 19 other damages associated with Defendant's controlling and manipulating her into a perverse and unhealthy way of life. 21. Any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by her telling him her high school graduation year, as well as his own actions, and are rendered irrelevant by the provision of applicable federal statutes concerning the sexual exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of Plaintiff's age of minority. In fact, his preference for underage girls was well-known to those who regularly procured them for him. 22. Defendant, Jeffrey Epstein, committed the above-referenced acts upon the then minor Plaintiff in violation of federal 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, transport of child pornography, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(6), § 2423(b), § 2423(c), § 2251, § 2252, § 2252A(a)(1), § 2252A(g)( I), and § 1591. 23. After investigations by the Palm Beach Police Department, the Palm Beach State Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's Office for the Southern District of Florida, Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution in June 2008 in the Fifteenth Judicial Circuit in Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such, Podhurst Orseck, P.A. 7 25 West Hagler Street, Suite 800, Miami, PL 33130, Miami 386358.2800 Pax • Fort Lauderdale www.podhuzst.com EFTA00175435

Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 8 of 19 must admit liability unto Plaintiff, Jane Doe. Plaintiff hereby exclusively seeks civil remedies pursuant to 18 U.S.C. § 2255. COUNT ONE (Cause of Action for Coercion and Enticement of Minor to Engaae in Prostitution or Sexual Activity pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. & 2422(b)1 24. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above. 25. Defendant, Jeffrey Epstein, used a facility or means of interstate commerce to knowingly persuade, induce, or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution and/or sexual activity for which any person can be charged with a criminal offense pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(b). 26. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 27. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 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 Plaintiff will continue to suffer these losses in the future. Podhurst Orseck, P.A. 8 75 West Meer Street, Suite 800, Wand, FL 33130, Miami Fax • Fort Lauderdale vevnv.pod.hurst.com EFTA00175436

Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 9 of 19 WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other 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 TWO (Cause of Action for Travel with Intent to Engaae in Illicit Sexual Conduct pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. 4 2423(b)) 28. Plaintiff; Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above. 29. Upon information and belief, Defendant, Jeffrey Epstein, traveled in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(0, with minor females, in violation of 18 U.S.C. § 2423(b). 30. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 31. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the Podhurst Orseck, P.A. 9 25 West Flask/ Street, Suite 800, Miami, FL 33130, MIMI 305358.2800 Fax • Fort Lauderdale www.podhurst.com EFTA00175437

Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 10 of 19 capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doc, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other 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 THREE (Cause of Action for Sex Trafficking of Children pursuant to 18 U.S.C. 6 2255 in Violation of 18 U.S.C. & 1591(a)) 32. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above. 33. Defendant, Jeffrey Epstein, knowingly, in or affecting interstate or foreign commerce, recruited, enticed, and obtained Plaintiff, Jane Doe, knowing that she had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1), in violation of 18 U.S.C. § 1591(a)(1). 34. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 35. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, toss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and Podhurst Orseck, P.A. 10 25 West Flagkr Street Suite 800, MWµ FL 33130, Miami Fax • Fort Lauderdale www.podluust.cout EFTA00175438

Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 11 of 19 unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 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 Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other 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 FOUR (Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. 4 2255 in Violation of 18 U.S.C. 4 22511 36. Plaintiff, Jane Doc, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above. 37. Defendant, Jeffrey Epstein, knowingly induced, enticed, or coerced then minor Plaintiff Jane Doe to engage in sexually explicit conduct for the purpose of producing a visual depiction of such conduct in violation of 18 U.S.C. § 2251. As previously stated in paragraphs 14 and 16, Defendant displayed a myriad of photographs of underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. 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 belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and may have transported lewd photographs of Podhurst Orseck, P.A. 11 25 West Flatter Street, Suite 800, Miami, FL 33130, MS=005.358.2800 Fax 305358.2382 • Port Lauderdale unt.corn EFTA00175439

Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 12 of 19 Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate commerce. 38. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 39. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and ►eading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 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 Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other 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. Podhurst Orseck, P.A. 12 25 West Flagler Street, Suite 800, Miami, FL 33130, Miami Fax • Fort Lauderdale envw.podhurst.cont EFTA00175440

Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 13 of 19 COUNT FIVE (Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit Conduct pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. 2252(a)(1)) 40. Plaintiff, Jane Doc, hereby adopts, repeats, =lieges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above. 41. Defendant, Jeffrey Epstein, knowingly mailed, transported, or shipped in interstate or foreign commerce child pornography in violation of 18 U.S.C. § 2252(1). As previously stated in paragraphs 14, 16, and 37, upon information and belief, Defendant displayed a myriad of photographs of underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. 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 belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate commerce. 42. As previously stated in paragraph 21, any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provision of applicable federal and state statutes concerning the sexual exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of Plaintiff's age of minority. In fact, his preference for underage girls was well-known to those who regularly procured them for him. 43. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. Podhurst Orseck, P.A. 13 25 West Flagler Stint, Suite 800, Miami, FL 33130, MIAS Fax • Fort Lauderdale EFTA00175441

Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 14 of 19 44. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 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 Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other 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 SIX (Cause of Action for Transport of Child Pornography pursuant to 18 U.S.C. ti 2255 in Violation of 18 U.S.C. § 2252A(a)(111 45. Plaintiff, Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 23 above. 46. Defendant, Jeffrey Epstein, knowingly mailed, transported, or shipped in interstate or foreign commerce child pornography in violation of 18 U.S.C. § 2252A(a)(1). Podhurst Orseck, P.A. 14 25 West Plaster Street, Suite SOO, Minnie P1.33130, Miami Pax • Port Lauderdale weassaillawrisarn EFTA00175442

Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 15 of 19 47. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 48. Defendant, Jeffrey Epstein, is in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability unto Plaintiff, Jane Doe. 49. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 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 Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other 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. Podhurst Orseck, P.A. 15 25 West Flagler Street. Suite 800, Miami, FL 33130, Miami Fax • Fort Lauderdale www.podhursteom EFTA00175443

Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 16 of 19 COUNT SEVEN (Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to 18 U.S.C. § 2255 in Violation of 18 U.S.C. §2252A(2)1 50. Plaintiff', Jane Doe, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs I through 23 above. 51. Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 USC § 2252A(g)(I). As more fully set forth above in paragraphs 9 through 19, Defendant's actions involved countless victims and countless incidents of abuse, and he committed those offenses against minors in concert with at least three other persons. 52. Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 53. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 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 Plaintiff will continue to suffer these losses in the future. Podhurst Orseck, P.A. 16 25 West Flasks Street Suite 800, Miami, FL 33130, Miami Fax • Fort Lauderdale www.podhuntcom EFTA00175444

Case 9:09-cv-80591-1<AM Document 1 Entered on FLSD Docket 04/20/2009 Page 17 of 19 WHEREFORE, Plaintiff, Jane Doe, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other 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. Date: April 17, 2009 Robert C. Jose erg, Bar No. 040856 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, Florida 33130 (fax) Attorneys for Plaintiff DEMAND FOR JURY TRIAL. Plaintiff demands to have her case tried before a jury. Robert . Jose rg, Bar No. 0408 6 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 • Forid 33130 (fax) [email protected] kezellftodhurst.com Attorneys for Plaintiff Podhurst Orseck, P.A. 17 25 West Fielder Street Suite 800, Miami, FL 33130, Miami Fax • Fort Lauderdale www.podhurst.corn EFTA00175445

. . Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 18 of 19 VAN (Rev. II/05) • ThelS 44 civil coves sheet and the information contained herein neither replace nor supplement the filing and service of (shadings or otha papas as required by law, except as proyided .by local rules of cant This font; approved by the Judicial Con femme of the United States in September 1974. is reamed for the use of the Clak of Coun for the oat g initiating thecivil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM) NOTICE: Attorneys MUST Indicate All Re-Med Cues Below. CIVIL. COVER SHEET 1. (a) PLAINTIFFS Jane Doe No. 101 (b) County of Residence of Fins Listed Plaintiff Weat Palm Beach (EXCEPT IN U.S. PLAINTIFF CASES) (C) Attorney's (Firm Name, Address. and Telephone Pianaba) Robert C. Josefsberg, Esq./Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 W. Flagler St., Suite 800 Miami RI 1111A so scf Macre- (d)Cheek County Where Action Arose: 0MIA/M.DADE 0 MONROE 0 BROWARD 9 PALM BEACH 0 MARTIN 0 ST. LUCIE 0 INDIAN RIVER n OKEECHOBEE HIGHLANDS II. BASIS OF JURISDICTION (Place en 'X' in One Bin Onlyl III. CITIZENSHIP OF PRINCIPAL PARTIESeurr scr• in One Dim tot nada Per Divinity Casts Only) NA One Box for Defendant) I US. Ooyenimaa ,of) 3 Federal Question PTV DEP P17 DEF Plaintiff (U.S. Government Not a Parry) Cilium of This State 1 *.0 I Incorporated or Principal Place of Huskiest In This State 4 14 0 2 US. Government Defendant 0 4 Diversity lindicate Citiwnthip of Peak, in hem III) Oaten of nanny: Sine 0 2 0 2 Incorporated and Ponca* Place of Business In Another State 0 S 0 5 Citizen cc Subject of a 0 3 0 3 Foreign Nation O 6 0 6 Foreign Comers. DEFENDANTS Jeffrey Epstein County of Residence of First Listed Defendant F IIN US PLAINTIFF CA Rime NOTE: IN LAND CONDEMNATION CASE USE /II IC LOCA1 ION OF 'f RA LAND INVOLVED. 1m APR 1 Attorneys (If Known) STEVEN Jack A. Goldberger, Esq., Atterbury oldb irefa in E (Australian Ave., 41400, West Palm B art r -• ... ..... _ .... _ . _ _ _ CONTRACT TOR I is PORFKITUREMENALTY BANKRUPTCY DINER STATUTES 0 110 Incur/ince 0 120 Marine 0 130 Miller Act O 140 Negotiable Inurtunem 0 150 Recovery a ()nip:imam & Enfortenant of Judgment 0 IS) Medium Act 0 152 Recovery of Defaulted Student Loam (Fad. %tains) 0 IS) Recovery of Overpaymers of Newman's Aeneas O 160 Stockholden' Suits 0 190 Other Cotermi 0 195 Convect Product Liability 0 196 Franchise PERSONAL INJURY 0 310 Airplane 0 315 Mutant Product Liability 0 320 Assault Libel & Standee 0 330 Federal Employer? Lability 0 MOMenne 0 345 /twine Product Liability CI 350 Motor Vehicle f) 355 Molot Vehick Product Liability 11 360 (kho Personal Injury PERSONAL. INJURY 0 362 Petiond Injury • Med MaBracike 0 365 Penonal Injury- Produce Liability 0 368 Asbestos Personal Injury Prockm liability PERSONAL PROPERTY 0 370 Other Frail 0 371 Tub in tending 0 380 Other Penned PrnPerlY Damage 0 385 Property thorny Product Liability PRISONER PETITIONS 0 610 Aricultwe 0 620 Other Food & Ding 0 625 Drng Related Seizure of Progeny 21 USC It 1 0 630 Liquor Eras 0 610 R.R. & Truck 0 650 Airline Rey. 0 660 °cessations' Salerydkalth 0 690 Odsra 0 422 Appeal 28 USC 158 il 423 Withdramil 28 USC 157 0 400 State RratiPorlionnwel 0 410 Antitnni 0 430 Buds ad Hankins 0 450 Commerce 0 460 Dcganation 0 410 RacLacce laktemed and Comp Organizations 0 480 COlittaixr Credit 0 490 CabkrSat TV 0 MO Selective Strike 0 1.50 SeturitimiCernmedihrst Exchange 0 875 Customer Challenw It USC 3410 0 1190001w Sunder/ Aederat 0 VI AgrkulWral Acts 0 192 Economy° Subiliration Act 0 893 Env imminent& Mitten A 894 Energy Allocation Act 0 895 Frealom of Damnation AN 0 9C0Appeal of Fes Detarninedient (Asks Equal Accent to 'mike 0 950 Comilmikmallty of State susses =7111128:T Id BCH I i6 0 820 Copyrights 0 830 Patent 0 840 Trademark LABOR SOCIAL SECURITY 0 710 Fair Labor Standard. Act 0 720 LabooMgra Relations 0 730 Labotrylpytkeponifts & Din/ovum Am n 740 Railway Labor Act 0 790 Othet Labor Litiplion 0 791 Mora tom Inc. Security AG 0 861111A (B950) 0 162 Black Lung (923) 0 561 DIWC/DIww (a0Sta 0 864 SSIDTitk XVI 0 865 RSI (405(s)) 1 REAL PROPERTY CIVIL. RIGHTS FEDF.FtAL TAX SUITS 0 210 Land Condemnation fl 220 FOP:CIO:a= 0 230 Rent Lease & Ejectment O 240 Torts to Land 0 245Ton Product Liability 0 290 All Other Rea/ Progeny 0 441 Voting 0 44/ Einploymem 0 443 Housing/ Accommodations 0 444 Welfare 0 445 Ansa. wablubilitics • Employment 0 446 Amer. w/Disabilkics - Other 0 440 Other Civil Risks 0 510 klotiora to Vacate Sentence Ilsheas Corpus: 0 530 General 0 535 Death Pawky 0 540 Mandamus & Othry 0 550 Civil RIgNs 0 555 Prison ConditNn 06'70 Tue. (U.S. Finkel& or Defensive) 0 1171 IRS -Teed Pally 26 USC 7609 V. ORIGIN (Mem an "X" in One Box Cary) Appeal to District ,21 I Original n 2 Removed from 0 3 Ro-filed- Proceeding Stale Cowl (see VI Delon) n 4 ReilDaled or Cl 5 Tanoth ranstrffed disur l Reopened (sPocifY) Cl 6 IMituip kiddon sirici CI 7 itr agilfslifromm e Judgment VI. RELATED/RE-FILED (korarsch .o. CASE(S). mood meek a) Ite-Med Case 0 YES (€) NO JUDGE Kenneth A. Marra b) Related Cases GIVES 0 NO K DOCET ER Sec Attached NUMB VII. CAUSE OF ACTION VIII. REQUESTED IN COMPLAINT: ABOVE INFORMATION IS TRUE & CORRECT TO SIGNATURE OP AITORtjEY OF RECORD THE BEST OF MY KNOWLEDGE )AaNewiwas— LA) e the U.S. Chid Statute under which you are filing and Write a Brief Statement of Cause (Do sot cite Judvdleilonal statutes unless dl entity): 18 U.S.C. 2255 (Predicate Statutes 18 U.S.C. 2422(6), 2423(6), 2423(e), 2251, 2252, 2252A(aX1), 2252A(g)( I) and 15911 LENGTH OP TRIAL via 4 days estimated (for both sides to try entire cue) 0 CHECK IP THIS IS A CLASS ACTON DEMANDS CHECK YES only if demended in complaint: JURY DEMAND: Wisfa is No UNDER 23 DATE *Rio 0.1 TOR OFTICEr n AMOUNT?S. Z.> °WM" 7C /RIP? 041/17 EFTA00175446

Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 19 of 19 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION ATTACHMENT TO CIVIL COVER SHEET FOR: Jane Doe No. 101 v. Jeffrey Epstein VI. RELATED/RE-FILED CASE(S): 08-80069 08-80119 08-80232 08-80380 08-80381 08-08804 08-80811 08-80893 08-80993 08-80994 08-80469 EFTA00175447

Case 9:09-cv-80591-KAM Document 9 Entered on FLSD Docket 05/01/2009 Page 1 of 22 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Civil Action No. 9:09-cv-80591-KAM Plaintiff, vs. JEFFREY EPSTEIN, Defendant. FIRST AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL FIRST AMENDED COMPLAINT AND DEMAND FOR JURY TRIAL Plaintiff, Jane Doe No. 101, brings this Complaint against Defendant, Jeffrey Epstein, and states as follows: PARTIES. JURISDICTION. AND VENUE 1. At all times material to this cause of action, Plaintiff, Jane Doe No. 101, was a resident of Palm Beach County, Florida. 2. This Complaint is brought under a fictitious name to protect the identity of Plaintiff, Jane Doe No. 101, because this Complaint makes sensitive allegations of sexual assault and abuse of a then minor. 3. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence located at 358 El Brillo Way, Palm Beach, Palm Beach County, Florida. 4. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is currently incarcerated in the Palm Beach County Stockade. 5. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. EFTA00175448

Case 9:09-cv-80591-KAM Document 9 Entered on FLSD Docket 05/01/2009 Page 3 of 22 II. Defendant's plan and scheme reflected a particular pattern and method. Defendant coerced and enticed impressionable, vulnerable, and relatively economically less fortunate minors to participate in various acts of sexual misconduct that he committed upon them. Defendant's scheme involved the use of underage girls as well as other individuals to recruit other underage girls. Upon information and belief, Defendant or an authorized agent would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach residence. His assistants would seek out economically disadvantaged and underage girls from West Palm Beach and surrounding areas who would be enticed by the money being offered— generally $200 to $300 per "massage" session—and who Defendant and/or his assistants perceived as less likely to complain to authorities or have credibility issues if allegations of improper conduct were made. The then minor Plaintiff and other minor girls, some as young as 14 years old, were transported to Defendant's Palm Beach county mansion by Defendant's employees, agents, and/or assistants in order to provide Defendant with "massages." 12. Many of the instances of illegal sexual conduct committed by Defendant were perpetrated with the assistance, support, and facilitation of at least three assistants who helped him orchestrate this child exploitation enterprise. These assistants would often arrange times for underage girls to come to Defendant's residence, transport or cause the transportation of underage girls to Defendant's residence, escort the underage girls to the massage room where Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the conclusion of each "massage appointment," and, upon information and belief, take sexually explicit photographs and/or videos of the underage girls' for Defendant without their knowledge. Defendant would pay the procurer of each girl's "appointment" hundreds of dollars. 3 EFTA00175449

Case' 9:09-cv-80591-KAM Document 9 Entered on FLSD Docket 05/01/2009 Page 5 of 22 enticing the then minor girl to engage in sexual acts with another female in Defendant's presence. The exact degree of molestation and frequency with which the sexual crimes took place varied and is not yet completely known; however, 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. In order to facilitate the daily exchanges of money for sexual assault and abuse, Defendant kept U.S. currency readily available. 16. As previously stated in paragraph 14, Defendant displayed photographs of nude underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Upon information and belief, some of the photographs Defendant's possession of Defendant were taken with hidden cameras set up in 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 belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. Upon information and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Police Department during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are still in the custody of law enforcement. 17. Defendant, Epstein, traveled to his mansion in Palm Beach for the purpose of luring minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to contact these minor girls for the purpose of coercing them into acts of prostitution and to enable himself to commit sexual battery against them and/or acts of lewdness in their presence, and he conspired with others, including assistants and/or his driver(s) and/or pilot(s), and his socialite 5 EFTA00175450

Case' 9:09-cv-80591-KAM Document 9 Entered on FLSD Docket 05/01/2009 Page 7 of 22 complimented her, saying that she had a nice body. Defendant then pulled Plaintiff closer to him. He began masturbating and then began fondling her breasts. He asked her to do more and mentioned more money, which she adamantly declined. Defendant continued masturbating until he ejaculated. Plaintiff next recalls that she received $200 and was transported by the procurer, whom she later learned received $200 for having brought her to Epstein's mansion. 19. Defendant thereafter lured the then minor Plaintiff to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003. The procurer made another appointment for her to return, but Plaintiff didn't want to see Defendant. By having his assistants continue to contact Plaintiff and attempt to lure her to the mansion for other sexual acts, Defendant engaged in a continuous course of conduct that injured Plaintiff upon each instance of contact and/or abuse. 20. In addition to the direct sexual abuse and molestation of the then minor Plaintiff, Defendant used his money, wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff to bring him another minor girl in a promised exchange for money. Rather than go herself, Plaintiff and the procurer took another girl there one time. 21. As a result of these encounters with Defendant, Plaintiff, Jane Doe No. 101, has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's controlling and manipulating her into a perverse and unhealthy way of life. 22. Any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by her telling him her high school graduation year, as well as his own actions, and are rendered irrelevant by the provision of applicable federal statutes concerning the sexual 7 EFTA00175451

Case 9:09-cv-80591-KAM Document 9 Entered on FLSD Docket 05/01/2009 Page 9 of 22 26. Defendant, Jeffrey Epstein, used a facility or means of interstate and/or foreign commerce to knowingly persuade, induce, entice, or coerce Jane Doc No. 101, when she was under the age of 18 years, to engage in prostitution and/or sexual activity for which any person can be charged with a criminal offense, or attempted to do so, pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(b). 27. Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 28. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 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 Plaintiff will continue to suffer these losses in the future. WHEREFORE, Plaintiff, Jane Doe No. 101, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other 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. 9 EFTA00175452

Casa 9:09-cv-80591-KAM Document 9 Entered on FLSD Docket 05/01/2009 Page 11 of 22 actual and compensatory damages, attorney's fees, costs of suit, and such other 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 THREE (Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. 6 2255 in Violation of 18 U.S.C. 22511 33. Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 24 above. 34. Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, or coerced the then minor Plaintiff, Jane Doe No. 101, to engage in sexually explicit conduct for the purpose of producing a visual depiction of such conduct in violation of 18 U.S.C. § 2251. As previously stated in paragraphs 14 and 16, Defendant displayed a myriad of photographs of underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up in 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 belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. Upon information and belief, one or more sexually explicit photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Police Department during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are still in the custody of law enforcement. 11 EFTA00175453

. Case• 9:09-cv-80591-KAM Document 9 Entered on FLSD Docket 05/01/2009 Page 13 of 22 COUNT FOUR (Cause of Action for Transport of Visual Depiction of Minor Engaging in Sexually Explicit Conduct pursuant to 18 U.S.C. & 2255 in Violation of 18 U.S.C. 2252(a)(1)) 37. Plaintiff, Jane Doe No. 101, hereby adopts, repeats, real leges, and incorporates by reference the allegations contained in paragraphs I through 24 above. 38. Defendant, Jeffrey Epstein, upon information and belief, knowingly mailed, transported, shipped, or sent via computer and/or facsimile in or affecting interstate or foreign commerce at least one visual depiction of the minor Plaintiff engaging in sexually explicit conduct in violation of 18 U.S.C. § 2252(a)( I). As previously stated in paragraphs 14, 16, and 34, upon information and belief, Defendant displayed a myriad of nude photographs of underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. 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 belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe No. 101, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. Upon information and belief, one or more sexually explicit photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Police Department during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are still in the custody of law enforcement. 39. As previously stated in paragraph 22, any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provision of applicable federal and state statutes concerning the sexual exploitation and abuse 13 EFTA00175454

Case,9:09-cv-80591-KAM Document 9 Entered on FLSD Docket 05/01/2009 Page 15 of 22 COUNT FIVE (Cause of Action for Transport of Child Pornography pursuant to 18 U.S.C. 4 2255 in Violation of 18 U.S.C. 4 2252A(a)(1)) 42. Plaintiff, Jane Doe No. 101, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs I through 24 above. 43. Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via computer or facsimile in or affecting interstate and/or foreign commerce child pornography in violation of 18 U.S.C. § 2252A(a)(1). As previously stated in paragraph 16, Defendant displayed a myriad of nude photographs of underage girls throughout his homes, including his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. 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 nude photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doc No. 101, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. Upon information and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Police Department during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are still in the custody of law enforcement. 44. As previously stated in paragraph 22, any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provision of applicable federal and state statutes concerning the sexual exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew 15 EFTA00175455

Cae 9:09-cv-80591-KAM Document 9 Entered on FLSD Docket 05/01/2009 Page 17 of 22 COUNT SIX (Cause of Action for Engaging in a Child Exploitation Enterprise pursuant to 18 U.S.C. 2255 in Violation of 18 U.S.C. S 2252Men 47. Plaintiff, Janc Doe No. 101, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 24 above and Counts One through Five. 48. Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 USC § 2252A(g)(1). As more fully above, Defendant engaged in actions that constitute countless violations of 18 U.S.C. § 1591 (sex trafficking of children), Chapter 110 (sexual exploitation of children in violation of 18 U.S.C. §§ 2251, 2252(a)(1), and 2252(A)(a)(I)), and Chapter 117 (transportation for illegal sexual activity in violation of 18 U.S.C. §§ 2422, and 2423). As more fully set forth above in paragraphs 9 through 19, Defendant's actions involved countless victims and countless separate incidents of abuse, and he committed those offenses against minors in concert with at least three other persons. 49. Plaintiff, Jane Doe No. 101, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. 50. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, 17 EFTA00175456

Case 9:09-cv-80591-KAM Document 9 Entered on FLSD Docket 05/01/2009 Page 19 of 22 DEMAND FOR JURY TRIAL Plaintiff demands to have her case tried before a jury. s/Katherine W. Ezell Robert Josefsberg, Bar No. 040856 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami Florida 33130 fax Attorneys for Plaintiff 19 EFTA00175457

' Cede 19:09-cv-80591-KAM Document 9 Entered on FLSD Docket 05/01/2009 Page 21 of 22 SERVICE LIST JANE DOE NO. 101 v. JEFFREY EPSTEIN Case No. 08-CV-80591-MARRA/JOHNSON United States District Court, Southern District of Florida Robert Critton, Esq. Burman, Critton, Luttier & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401 Jack Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Bruce E. Reinhart, Esq. Bruce E. Reinhart, P.A. 250 South Australian Avenue, Suite 1400 West Palm Beach, FL 33401 Phone: Fax: Co-counsel for Defendant, Jeffrey Epstein Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: [email protected] inh@searcvlaw,com Counsel for Plaintiff... Adam Horowitz, Esq. Stuart Mermelstein, Esq. Herman & Mermelstein 18205 Biscayne Blvd. Suite 2218 Miami, FL 33160 21 EFTA00175458

Case 9:08-cv-80119-KAM Document 151 Entered on FLED Docket 06/10/2009 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 5, Plaintiff, Vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CV-80119-MARRA/JOHNSON CASE NO.: 08-CV-80232-MARRA/JOHNSON CASE NO.: 08-CV-80380-MARRA/JOHNSON CASE NO.: 08-CV-8038I-MARRA/JOHNSON EFTA00175459

Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 2 of 11 Doe 101 v. Epstein Page 2 CASE NO.: 08-80994.CIV-MARRA/JOHNSON JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08.80993-CIV-MARRA/JOHNSON JANE DOE NO. 7, Plaintiff, JBM-/REY EPSTEIN Defendant. CASE NO.: 08-80811-CIV-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN Defendant. JANE DOE, CASE NO.: 08-80893-CIV-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN et al, Defendants. DOE II, CASE NO.: 09-80469-CIV-MARRA-JOHNSON Plaintiff, JEFFREY EPSTEIN et al, Defendants. EFTA00175460

• Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 3 of 11 Doe 101 v. Epstein Page 3 JANE DOE NO. 101, Plaintiff, JEFFREY EPSTEIN Defendant. JANE DOE NO. 102, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 09-80591-CIV-MARRA-JOHNSON CASE NO.: 09-80656-CIV-MARRA/JOHNSON DEFENDANT JEFFREY EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOE NOS. 101 and 102's MOTION FOR AN ORDER FOR THE PRESERVATION OF EVIDENCE & INCORPORATED MEMORANDUM OF LAW (dated 5/26/09, DE 114) Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned attorneys responds to the Plaintiffs' Jane Doe No. 101 and Jane Doe No. 102 ("Plaintiffs") Motion For And Order For The Preservation Of Evidence And Incorporated Memorandum Of Law, [DE 114], and states: 1. Plaintiffs once again mislead and mischaracterize the criminal counts to which EPSTEIN pled guilty. Contrary to Plaintiffs' representations in 111 of their motion and in their memorandum of law, EPSTEIN pled guilty to one count of felony solicitation (which was not related to a minor), under §796.07(2)(f), Fla.Stat., and one count of procuring a minor for prostitution under §796.03, Fla. Stat. Plaintiffs' reference to the "pleas of 'guilty' ... to various Florida state crimes involving the solicitation of minors for the prostitution and procurement of EFTA00175461

Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 4 of 11 Doe 101 v. Epstein Page 4 minors for the purposes of prostitution" mischaracterizes the specific counts to which EPSTEIN pled guilty. 2. As to Plaintiffs' allegations in 11 2 and 3, many of the Plaintiffs' allegations are without any factual basis and know such assertions to be false and untrue. 3. Defendant agrees with Plaintiff's assertion that the Palm Beach Police Department (PBPD) executed a search warrant at EPSTEIN's Palm Beach mansion on October 25, 2005. See 14 Plaintiffs' motion. 4. Defendant's attorneys have no objection to an order to preserve evidence similar to the one entered in the case of Doe v. Epstein, et al, Case No. 08-80804-CIV- MARRA/JOHNSON, (DE 20], and attached hereto as Exhibit A. EPSTEIN's attorneys are unaware of any items referenced in Plaintiffs' motion, ¶5-6, having been returned to EPSTEIN or his attorneys, but will agree to a preservation of such items to the extent such items exist. 5. As to 17 of Plaintiffs' motion, EPSTEIN and his attorneys have no objection to the referenced authorities, (PBPD, FBI, USAO, and PBSAO), preserving items to the extent such items even exist, in a manner that said authorities deem appropriate. 6. As to ¶q8, 9, and 10 of Plaintiffs' motion re: documents, Defendant has asserted in other matters and asserts here, specific legal objections as well as his U.S. constitutional privileges, as follows: My attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would EFTA00175462

Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 5 of 11 Doe 101 v. Epstein Page 5 unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 408, and §90.410, Fla. Stat. Further Defendants objects as the request to preserve evidence is overly broad and includes information that is neither relevant to the subject matter of the pending action nor does it appear to be reasonably calculated to lead to the discovery of admissible evidence. 7. Responding to the grossly overly broad list and categories of documents and items alleged in Plaintiff's motion (j8-10) involves a testimonial component. The Fifth Amendment Privilege extends to the act of production where, as here, it involves a self-incriminating testimonial communication or "a compelled testimonial aspect." United States v, Hubbell, 530 U.S. 27, 120 S.Ct. 2037 (2000)• Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence, Title 6, Chap. 13. The Privilege Against Self-Incrimination, §138 (6th Ed.). See also Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process Clause of the Fourteenth Amendment - "Mt would be incongruous to have different standards determine the validity of a claim of privilege based on the same feared prosecution, depending on whether the claim was asserted in state or federal court.")• Hoffman v. U.S., 71 S.Ct. 814, 818 (1951), and progeny). The Fifth Amendment Privilege may be invoked in a civil action where a litigant or witness is being asked to provide information or respond to a question that may incriminate him in a crime. See generally, DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4h DCA 1983). The privilege against self-incrimination may be asserted during discovery when a litigant EFTA00175463

'Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 6 of 11 Doe 101 v. Epstein Page 6 has "reasonable grounds to believe that the response would furnish a link in the chain of evidence needed to prove a crime against a litigant." A witness, including a civil defendant, is entitled to invoke the Fifth Amendment privilege whenever there is a realistic possibility that the answer to a question could be used in anyway to convict the witness of a crime or could aid in the development of other incriminating evidence that can be used at trial. Id; Pillsbury Company v. Conboy, 495 U.S. 248, 103 S.Ct. 608 (1983). The United States Supreme Court has made clear that the scope of the Fifth Amendment Privilege includes the circumstances as here "the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect." United States v, Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000). In explaining the application of the privilege, the Supreme Court stated: We have held that "the act of production" itself may implicitly communicate "statements of fact." By "producing documents in compliance with a subpoena, the witness would admit that the papers existed, were in his possession or control, and were authentic."all2 Moreover, as was true in this case, when the custodian of documents responds to a subpoena, he may be compelled to take the witness stand and answer questions designed to determine whether he has produced everything demanded by the subpoena. al2g The answers to those questions, as well as the act of production itself, may certainly communicate information about the existence, custody, and authenticity of the documents. Whether the constitutional privilege protects the answers to such questions, or protects the act of production itself, is a question that is distinct from the question whether the unprotected contents of the documents themselves are incriminating. FN19. "The issue presented in those cases was whether the act of producing subpoenaed documents, not itself the making of a statement, might nonetheless have some protected testimonial aspects. The Court concluded that the act of production could constitute protected testimonial communication because it might entail implicit statements of fact: by producing documents in compliance with a subpoena, the witness would admit that the papers existed, were in his possession or control, and were authentic. United States v. Doe. 465 U.S.. at 613. and n. 11, 104 S.Ct. 1237., Fisher, 425 U.S.. at 409-410. 96 S.Ct. 1569., id. at 428. 432. 96 S.Ct. 1569 (concurring opinions). See Braswell v. United States. 1487 U.S.,1 at EFTA00175464

• Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 7 of 11 Doe 101 v. Epstein Page 7 104 108 S.Ct. 2284, J. id.1 at 122, 108 S.Q. 2284 (dissenting opinion). Thus, the Court made clear that the Fifth Amendment privilege against self-incrimination applies to acts that imply assertions of fact."... An examination of the Court's application of these principles in other cases indicates the Court's recognition that, in order to be testimonial, an accused's communication must itself, explicitly or implicitly, relate a factual assertion or disclose information. Only then is a person compelled to be a 'witness' against himself." Poe v. United States. 487 U.S., at 209-210, 108 S.Ct. 2341. (footnote omitted). FN20. See App. 62-70. Thus, for example, after respondent had been duly sworn by the grand jury foreman, the prosecutor called his attention to paragraph A of the Subpoena Rider (reproduced in the Appendix, infra, at 2048-2049) and asked whether he had produced "all those documents." App. 65. Finally, the phrase "in any criminal case" in the text of the Fifth Amendment might have been read to limit its coverage to compelled testimony that is used against the defendant in the trial itself. It has, however, long been settled that its protection encompasses compelled statements that lead to the discovery of incriminating evidence even though the statements themselves are not incriminating and are not introduced into evidence. Thus, a half century ago we held that a trial judge had erroneously rejected a defendant's claim of privilege on the ground that his answer to the pending question would not itself constitute evidence of the charged offense. As we explained: "The privilege afforded not only extends to answers that would in themselves support a conviction under a federal criminal statute but likewise embraces those which would furnish a link in the chain of evidence needed to prosecute the claimant for a federal crime." Hoffman v. United States. 341 U.S. 479, 486, 71 S.Ct. 814, 95 L.Ed. 1118 (1951). Compelled testimony that communicates information that may "lead to incriminating evidence" is privileged even if the information itself is not inculpatory. Doe v. United States, 487 U.S. 201, 208, n. 6. 108 5.O, 2341, 101 L.Ed.2d 184 (1988). It's the Fifth Amendment's protection against the prosecutor's use of incriminating information derived directly or indirectly from the compelled testimony of the respondent that is of primary relevance in this case. In summarizing its holding regarding the application of the Fifth Amendment Privilege to a production request, the Hubbell Court left "no doubt that the constitutional privilege against self incrimination protects" not only "the target of a grand jury investigation from being compelled to answer questions designed to elicit information about the existence of sources of EFTA00175465

Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 8 of 11 Doe 101 v. Epstein Page 8 potentially incriminating evidence," but the privilege also "has the same application to the testimonial aspect of a response to a subpoena seeking discovery of those sources." At 43, and 2047. Here, Plaintiffs' motion to preserve evidence by listing a large inventory of items is in reality no different that propounding a discovery request upon Defendant, and thus, Defendant is afforded the protection of the Constitutional privileges asserted herein. 8. As stated above, Defendant and Defendant's attorneys have no objection to the entry of an order similar to Exhibit A hereto. WHEREFORE, Defendant requests that the Court enter an order similar to that as entered in Exhibit A hereto. Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CMJECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CMIECF on this tday of June , 2009 EFTA00175466

'Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 9 of 11 Doe 101 v. Epstein Page 9 Respectful! By: ROBERT D. R1TTON, JR., ESQ. Florida Bar o. 224162 ESQ. Florida Bar #617296 BUI 1E,N1, LUTHER & COLEMAN 515 N. Hagler Drive, Suite 400 West Palm Beach, FL 33401 Phone Fax (Course or D efendant Jeffrey Epstein) EFTA00175467

Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 10 of 11 Doe 101 v. Epstein Page 10 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami 160 Fax: Counsel for Plaintiffs in Related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08- 80381, 08-80993, 08-80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 33461 Fax: Counsel for Plaintiff in Related Case No. 08- 80811 Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard ach, FL 33409 Counsel for Plaintiff, Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort 3301 Phon Fax: Counsel for Plaintiff in Related Case No. 08- 80893 Paul G. Cassell, Esq. Pro Rae Vice 332 South 1400 E, Room 101 Salt IBke City, LIT 84112 Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 Reach, FL 33401 Counsel for Plaintiff in Related Case No. 08- 80469 Roberti. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 130 Fax: EFTA00175468

Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 11 of 11 Doe 101 v. Epstein Page 11 Bruce Reinhart, Esq. Bruce E. Reinhart, P.A. 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 33401 • Counsel for Defendant Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Fax: Counsel for Plaintiff in Related Case No. 08- t i t ais Counsel for Plaintiffs in Related Cases Nos. 09-80591 and 09-80656 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 ach, FL 33401-5012 Counsel for Defendant Jeffrey Epstein EFTA00175469