EFTA01117107.pdf

Case 9:09-mj-08308-LRJ Document 3 Entered on FLSD Dockttsj2/09/2009 P e 1 of 7 AO 91111cv. 5/85) Criminal Complaint Alt VILLAPAAA FILID by United States District Court DEC -1 211U9 SOUTHERN DISTRICT OF FLORIDA STCViN IA /AMUCK a ER% U 5.01SL ct si) or ri.A. • wee. UNITED STATES OF AMERICA CRIMINAL CO LAINT vs. ALFREDO RODRIGUEZ, CASE NUMBER: 09-8308-LRJ Defendant. I, the undersigned complainant, being duly sworn, state the following is true and correct to the best of my knowledge and belief. From at least as early as January 18, 2007, through on or about November 3, 2009, in Palm Beach County, in the Southern District of Florida, and elsewiere, the defendant, ALFREDO RODRIGUEZ, did corruptly conceal a record, document, or other object, with the intent to impair the object's availability for use in an official proceeding and otherwise corruptly obstructed or impeded an official proceeding , in violation of Title 18 , United States Code, Section 1512M . I further state that I am a Special Agent with the Federal Bureau of Investigation , and that this Complaint is based on the following facts: Please see attached Affidavit Continued on the attached and made a part hereof. ChnSfina J. Pryor, Special Federal Bureau of Investiga Sworn to before me, and subscribed in my presence, upon my finding of probable cause. December 2009 at West Palm Beach. Florida Date City and State L1NNEA R. JOHNSON D TES IST' TE Signature of Judie.ia EP-002 EFTA01117107 Case 9:09-mj-08308-LRJ V:ument 3 Entered on FLSD Dockti 2/09/2009 Page 2 of 7 AFFIDAVIT I, Christina J. Pryor, being duly sworn, do state and attest as follows: 1. I am a Special Agent with the Federal Bureau of Investigation (FBI) and have been so employed for three (3) months. I am currently assigned to the Safe Streets Task Force, Miami Field Division, FBI Squad PB-2. Prior to joining the Miami Field Division, I attended the FBI Academy in Quantico, Virginia, for five (5) months where I received training in federal criminal laws and investigation techniques, including the laws related to obstruction of justice. 2. This affidavit is based upon my-own personal knowledge of the facts and circumstances surrounding the investigation, and information provided to me by other law enforcement officers. This affidavit does not purport to contain all the information known to me about this case but addresses only that information necessary to support a finding of probable cause for the issuance of a criminal complaint charging Alfredo Rodriguez with obstruction of official proceedings, in violation of Title 18, United States Code, Section 1512(c). 3. On October 27, 2009, agents of the FBI met with and interviewed a cooperating witness ("CW"). The CW reported that, while conducting discovery in a pending civil case before the United States District Court for the Southern District of Florida, he came into contact with Alfredo Rodriguez ("Rodriguez"), who was a subpoenaed witness in the civil case. 4. Rodriguez had been interviewed by FBI agents on January 18, 2007, in connection with a federal criminal investigation into the sexual exploitation of minors. Prior EP-003 EFTA01117108 Case 9:09-mj-08308-LRJ Zument 3 Entered on FLSD Docket j2/09/2009 Page 3 of 7 to being interviewed by FBI, Rodriguez had also been contacted and interviewed by local police detectives, and had been asked to produce documents related to the criminal investigation. The civil litigation involving the CW related to civil damages claims made by victims of the criminal activity that formed the basis of the state and federal criminal investigations. 5. The CW explained to agents that Rodriguez had been deposed under oath on two occasions. The first deposition occurred on July 27, 2009, and the second deposition was conducted on August 9, 2009. In connection with those depositions, Rodriguez was served with a subpoena duccs tecum that called for the production of several types of documentary evidence. The CW was present for both depositions and Rodriguez testified that he had no documents responsive to the subpoena duces tecum. 6. In August 2009, after the conclusion of the second deposition, the CW received a phone call from Rodriguez. Rodriguez informed the CW that he had additional information that he had not previously disclosed to any law enforcement agency or any of the civil attorneys. Rodriguez described the information as, the Holy Grail or Golden Nugget and explained that he had compiled lists of additional victims in the case and their contact information. Rodriguez explained that the information contained hundreds of additional victims and their phone numbers from diverse geographic locations, including New York, New Mexico, and Paris, France. 7. Rodriguez asked the CW to pay him $50,000.00 and, in return, Rodriguez would turn over the documents relating to the victims. In his initial and subsequent EP-004 EFTA01117109 Case 9:09-mj-08308-LRJ Zument 3 Entered on FLSD Dockti 2/09/2009 Page 4 of 7 communications with Rodriguez, the CW explained to Rodriguez that he was under subpoena to turn over such information and that it would be illegal for Rodriguez to demand money for turning over the information. Rodriguez persisted that he would only turn over the information in his possession in exchange for $50,000.00. 8. On October 28, 2009, in a consensually-monitored phone call, the CW telephoned Rodriguez. Rodriguez again indicated that he would not turn over the information relating to the additional victims without monetary compensation. Rodriguez was told that an associate of the CW would be in touch with him regarding the information and exchange. The associate that the CW referred to was, in fact, an undercover employee (UCE) of the FBI. 9. On October 29, 2009, the FBI UCE contacted Rodriguez via telephone. Rodriguez again explained that he would only turn over the information in exchange for monetary compensation. The UCE advised Rodriguez that it would take several days to acquire the funds and that once the funds were obtained, he/she would contact Rodriguez. During the conversation, Rodriguez admitted that he knew that the information was relevant to the FBI's criminal investigation and was called for by the investigation. Rodriguez explained that he had not turned over the information to the FBI because: (1) it was his "property" and he should be compensated for it; and (2) he was afraid that the target of the investigation would make him "disappear" or otherwise harm him, and the information was his "insurance policy." 10. On November 2, 2009, the UCE made contact with Rodriguez via telephone. EP-005 EFTA01117110 Case 9:09-mj-08308-LRJ Zument 3 Entered on FLSD Docket 12/09/2009 Page 5 of 7 In that conversation, Rodriguez and the UCE continued the discussion regarding the purchase of the documents and scheduled a meeting for the following day. 11. On November 3, 2009, Rodriguez met with the UCE at a predetermined location. During the meeting, Rodriguez produced a small bound book and several sheets of legal pad paper containing hand written notes. Rodriguez explained that he had taken the bound book from his former employer's residence while employed there in 2004 to 2005 and that the book had been created by persons working for his former employer. Rodriguez discussed in detail the information contained within the book, and identified important information to the UCE. In addition, Rodriguez admitted he had previously lied to FBI. Rodriguez asked the UCE about the $50,000.00, took possession of the money, and began counting it. 12. Rodriguez was then detained for Obstruction of Official Proceedings, Title 18, U.S. Code, Section 1512(c), and questioned. After Miranda warnings were administered by agents, Rodriguez waived his rights and signed a written waiver of those rights. Rodriguez admitted that he had the documents and book in his possession and had never turned them over to local law enforcement or the FBI. In addition, Rodriguez advised he had witnessed nude girls whom he believed were underage at the pool area of his former employer's home, knew that his former employer was engaging in sexual contact with underage girls, and had viewed pornographic images of underage girls on computers in his employer's home. Rodriguez was then released from custody for further investigation. 13. The items that Rodriguez had attempted to sell to the UC for $50,000.00 EP-006 EFTA01117111 Case 9:09-mj-08308-LRJ Document 3 Entered on FLSD Docket ]2/09/2009 Page 6 of 7 %so were reviewed by an agent familiar with the underlying criminal investigation. As Rodriguez had described, the items contained information material to the underlying investigation that would have been extremely useful in investigating and prosecuting the case, including the names and contact information of material witnesses and additional victims. Had those items been produced in response to the inquiries of the state law enforcement officers or the FBI Special Agents, their contents would have been presented to the federal grand jury. Based upon the foregoing, your affiant believes that probable cause exists to believe that, from at least as early as January 18, 2007 through on or about November 3, 2009, in Palm Beach County, in the Southern District of Florida, and elsewhere, Al€redo Rodriguez did corruptly conceal a record, document, or other object, with the intent to impair the object's availability for use in an official proceeding and otherwise corruptly obstructed or impeded an official proceeding, in violation of Title 18, United States Code, Section 1512(c). FURTHER YOUR AFFIANT SAYETH NAUGHT. A J. PRYO12, ' CI ENT FEDERAL BUREAU OF VES CATION Sworn to and subscribed before me this ( day of December, 2009. R. JOHNSO UNITED STAT GISTRATE JUDGE 5 EP-007 EFTA01117112 Case 9:09-mj-08308-LRJ Iiio:ument 3 Entered on FLSD Docket i2/09/2009 Page 7 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 09-8308-LRJ UNITED STATES OF AMERICA vs. ALFREDO RODRIGUEZ, Defendant. CRIMINAL COVER SHEET 1. Did this matter originate from a matter pending in the Northern Region of the United States Attorney's Office prior to October 14, 2003? Yes X No 2. Did this matter originate from a matter pending in the Central Region of the United States Attorney's Office prior to September 1, 2007? Yes X No Respectfully submitted, JEFFREY H. SLOMAN ACTING UNITED STATES ATTORNEY By: A. MARIE VILLAFA Assistant United States Attorney Florida Bar No. 0018255 500 East 13roward Boulevard, 7th Floor Ft Lauderdale, FL 33394 Telephone: 954-660-5946 Facsimile: 954-356-7230 ann.marie.c.villafana©usdoj.gov EP-008 EFTA01117113 0 Rom Tea arageaaseas SuSjacti Strategy Doter Waktesthrt July Z9, 2001 1: 11:13 PM dank our best bet Is to go after those dose to Er/Stein. 08420 EP-001 EFTA01117114  La, Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docmd 07/27/2009 Page 1 of 82 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO: 09-CV-81092-Cohn-Seltzer Plaintiff FILED by VT D.C. BECTRCNIC vs. JEFFREY EPSTEIN, July 24, 2009 STEETN M. LARIMORE Defendant CLERIC U.S. DIST. CT. S.O. or FLA. • MIAMI COMPLAINT AND DEMAND FOR JURY TRIAL Plaintiff, hereby sues the Defendant, Jeffrey Epstein, and states as follows: 1. At all times material to this cause of action, M.., was a resident of Palm Beach County, Florida. 2. This Complaint is brought under a fictitious name to protect the identity of M., 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 mansion located at 358 El Brillo Way, Palm Beach, Palm Beach County, Florida. 4. At all times materials to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. 5. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida. This is substantiated by the residence that he maintains at 358 El Brillo Way, West Palm Beach, Florida where he spends the majority of his time, and intentions to remain at that address permanently are further evidenced by his statements to the Court during Page 1 of 234 I of EP-081 EFTA01117115  Case 9:09-cv-81092-JIC .iocument 1 Entered on FLSD Dock..., 07/27/2009 Page 2 of 82 his State Plea colloquy on June 30, 2008, case number 06CF009454AMB, taken before the Honorable Judge Dale Pudic, wherein he indicated that after his release from the Palm Beach County Jail he intends to reside permanently at his home at 358 El Brillo Way, West Palm Beach, Florida, and he plans to work in West Palm Beach, Florida as well. 6. This Court has jurisdiction of this action and the claims set forth herein pursuant to 18 U.S.C. § 2255.11. seeks damages in excess of 1 million dollars. 7. This Court has venue of this action pursuant to 28 U.S.C. § 1391(b), as a substantial part of the events giving rise to the claims occurred in this District. STATEMENT OF FACTS 8. Upon information and belief, the Defendant, Jeffrey Epstein, has demonstrated a sexual preference and obsession for minor girls. 9. The Defendant, Jeffrey Epstein, developed a plan, scheme, and criminal enterprise that included an elaborate system wherein the then-minor. was brought to the Defendant, Jeffrey Epstein's residence by the Defendant's employees, recruiters, and assistants. When the assistants and employees left the then-minor ■. (and, on some occasions, other minor girls) alone in a room at the Defendant's mansion, the Defendant, Jeffrey Epstein, himself would appear, remove his clothing, and direct the then-minor ■. to remove her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including, but not limited to, masturbation, touching of the then minor Plaintiffs sexual organs, coercing or forcing the then-minor. to perform oral sex on him, using vibrators or sexual toys on the then-minor .., coercing the Page 2 of 234 2 et 234 EP-082 EFTA01117116  Case 9:09-cv-81092-JIC document 1 Entered on FLSD Doctmat 07/27/2009 Page 3 of 82 then-minors into sexual acts with himself or others, and digitally penetrating the then-minor M.. He would then pay M. for engaging in this sexual activity. 10. M. was first brought to the Defendant, Jeffrey Epstein's mansion in 2002 when she was a fourteen-year old in middle school. 11. The then-minor M. was a vulnerable child without adequate parental support at all times material to this Complaint. The Defendant, Jeffrey Epstein, a wealthy financier with a lavish home, significant wealth, and a network of assistants and employees, used his resources and his influence over a vulnerable minor child to engage in a systematic pattern of sexually exploitive behavior. 12. Beginning in approximately August 2002 and continuing until approximately the end of October 2005, the Defendant, Jeffrey Epstein, repeatedly coerced, induced and/or enticed the impressionable, vulnerable, and economically deprived then-minor ■. to commit various acts of sexual misconduct and sexually abused ■. These acts included, but were not limited to, fondling and inappropriate and illegal sexual touching of the then-minor M., forcing the then-minor M. into oral sex, sexual misconduct and masturbation of the Defendant, Jeffrey Epstein, in the presence of the then-minor ■., handling and fondling of the then-minor M.'s sexual organs for the purpose of masturbation, and encouraging the then-minor M. to become involved in prostitution; Defendant, Jeffrey Epstein, committed, and conspired with others to commit, numerous criminal sexual offenses against the then minor Plaintiff including, but not limited to, sexual battery, solicitation of prostitution, coercing a minor into a life of prostitution, and lewd and lascivious assaults upon the person of the then-minor ■. Defendant Jeffrey Page 3 of 234 30234 EP-083 EFTA01117117  Case 9:09-cv-81092-JIC :Jocument 1 Entered on FLSD Docker 07/27/2009 Page 4 of 82 Epstein knowingly transported III and other minors in interstate commerce with the intent that the engage in prostitution and in other sexual activity for which he and others could be charged with criminal offenses. Defendant Jeffrey Epstein also knowingly used means of interstate commerce to knowing persuade and induce minors, including 5, to engage In prostitution and other sexual activity for which he and others could be charged with criminal offenses. 13. In addition to the direct sexual abuse and molestation of the then-minor II, Defendant, Jeffrey Epstein, instructed, coerced and otherwise induced the then- minor 5 to bring him numerous other minor girls (some as young at 12 years old) for the purposes of further satisfying his deviant sexual attraction to minors and for purposes of prostitution. On information and belief, Epstein sexually abused hundreds of minor girls through his recruiting system. Defendant, Jeffrey Epstein, used his money, wealth and power to unduly and improperly manipulate and influence the then- minor 5 to bring him these other minor girls for purposes of prostitution and in exchange for money. This influence led the then-minor 5 away from the life of a middle school aged child and into a delinquent lifestyle. This conduct also involved transporting ■. and other minors in interstate commerce and using means of interstate commerce, to persuade and induce 5 and others to engage in prostitution and in other sexual activity for which he and others could be charged with criminal offenses. 14. The Defendant, Jeffrey Epstein, at all times material to this Complaint, knew and should have known of minority. The Defendant, Jeffrey Epstein, at all times Page 4 of 234 4e/234 EP-084 EFTA01117118  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Doch, 07/27/2009 Page 5 of 82 material to this Complaint, knew and should have know of the minority of the other girls he was sexually abusing 15. The acts referenced above in paragraphs 10 through 14, committed by Defendant, Jeffrey Epstein, against the then-minor Plaintiff IN were committed in violation of numerous State criminal statutes condemning the sexual exploitation of minor children, prostitution and prostitution-related offenses, sexual performances by a child, lewd and lascivious assaults, sexual battery, contributing to the delinquency of a minor and other crimes, specifically including, but not limited to, those criminal offenses outlined in Chapters 794, 800, 827 and 847 of the Florida Statutes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §796.09, §39.01, and §827.04. 16. The acts reference above in paragraphs 10 through 15, committed by Defendant, Jeffrey Epstein, against the then-Minor Plaintiff were committed in violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(b), and § 2423(e). 17. The crimes committed against ■. by Epstein were committed, on average, four times per month from the beginning of August 2002 through the end of October 2005, the exact dates being unknown to ■.. Page 5 of 234 eat 234 EP-085 EFTA01117119  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 6 of 82 18. In June 2008, 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 the Fifteenth Judicial Circuit in the 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, must admit liability unto Plaintiff, Jane Doe No. 101. In this action, Plaintiff hereby exclusively seeks civil remedies pursuant to 18 U.S.C. § 2255. 19. As a condition of his plea, and in exchange for the Federal Government not prosecuting the Defendant, Jeffrey Epstein, for numerous federal offenses, Defendant, Jeffrey Epstein, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been Page 6 of 234 Bef234 EP-086 EFTA01117120  Case 9:09-cv-81092-JIC _document 1 Entered on FLSD Dock:. 07/27/2009 Page 7 of 82 had Mr. Epstein been convicted at trial. No more; no less? Plaintiff III is covered by this paragraph and entitled to rights under this paragraph. 20. The defendant, Jeffrey Epstein, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged in this Complaint, and must effectively admit liability to the Plaintiff, im, including admitting liability for all counts enumerated in this Complaint. Plaintiff i is entitled to damages, as further alleged below, including damages as provided in 18 U.S.C. § 2255, as amended by Pub. L. 109-248, Title VII, § 707(b) and (c), 120 Stat. 650. COUNT 1 Cause of Action Pursuant to 18 U.S.C. 6 2255 August 2002 — Incident 1 21. Plaintiff, `adopts and realleges paragraphs 1 through 20 above. 22. On or about August 2002, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated In 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). II is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to Page 7 of 234 75234 EP-087 EFTA01117121  Case 9:09-cv-81092-JIC Jocument 1 Entered on FLSD Doch..:( 07/27/2009 Page 8 of 82 this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 23. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her,El. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff.l. incurred medical and psychological expenses and the plaintiff, will in the future suffer 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, E., will continue to suffer these losses In the future. 24. Wherefore, the plaintiff, M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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. COUNT 2 Cause of Action Pursuant to 18 U.S.C. 4 2256 August 2002 — Incident Z 25. Plaintiff,M. adopts and realleges paragraphs 1 through 20 above. Page 8 of 234 EP-088 Solis EFTA01117122  Case 9:09-cv-81092-JIC ..socument 1 Entered on FLSD Dock, 07/27/2009 Page 9 of 82 26. On or about August 2002, the exact date being unknown tot Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). S. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Govemment. 27. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against here. has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff S. Incurred medical and psychological expenses and the plaintiff, S., will In the future suffer medical and psychological expenses. The plaintiff, S., 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 Page 9 of 234 OM 214 EP-089 EFTA01117123  Case 9:09-cv-81092-JIC _ocument 1 Entered on FLSD Dock<— 07/27/2009 Page 10 of 82 injuries are permanent in nature and the plaintiff, E., will continue to suffer these losses in the future. 28. Wherefore, the plaintiff. E., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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. COUNT 3 Cause of Action Pursuant to 18 U.S.C. & 2256 August 2002 — Incident 3 29. Plaintiff, ■. adopts and realleges paragraphs 1 through 20 above. 30. On or about August 2002, the exact date being unknown to.., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. Page 10 of 234 10 01214 EP-090 EFTA01117124  Case 9:09-cv-81092-JIC L.ocument 1 Entered on FLSD Docket 07/27/2009 Page 11 of 82 31. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, ■. has In the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein. controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff ■. Incurred medical and psychological expenses and the plaintiff, ■., will in the future suffer 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, L.M., will continue to suffer these losses in the future. 32. Wherefore, the plaintiff, ■., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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. COUNT 4 Cause of Action Pursuant to 18 U.S.C. 4 2255 August 2002 — Incident 4 33. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 34. On or about August 2002, the exact date being unknown to M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a Page 11 of 234 Itee 234 EP-091 EFTA01117125  Case 9:09-cv-81092-JIC _document 1 Entered on FLSD DOChut 07/27/2009 Page 12 of 82 violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 35. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, • has in the past suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein. controlling, manipulating and coercing her Into a perverse and conventional way of life for a minor. The then-minor plaintiff incurred medical and psychological expenses and the plaintiff, will in the future suffer 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, will continue to suffer these losses in the future. Page 12 of 234 $201234 EP-092 EFTA01117126  Case 9:09-cv-81092-JIC _ocument 1 Entered on FLSD Dock-, 07/27/2009 Page 13 of 82 36. Wherefore, the plaintiff, demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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. COUNT 5 Cause of Action Pursuant to 18 U.S.C. 4 2255 September 2002 — Incident 1 37. Plaintiff, M. adopts and realleges paragraphs 1 through 20 above. 38. On or about September 2002, the exact date being unknown to In, Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 39. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, has in the past Page 13 of 234 ti of 234 EP-093 EFTA01117127  Case 9:09-cv-81092-JIC _ ocument 1 Entered on FLSD Dock:. 07/27/2009 Page 14 of 82 suffered, and will in the future suffer, physical injury pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and conventional way of life for a minor. The then-minor plaintiff L.M. Incurred medical and psychological expenses and the plaintiff,S., will in the future suffer medical and psychological expenses. The plaintiff,III., 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, will continue to suffer these losses in the future. 40. Wherefore, .the plaintiff,., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by law, 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. COUNT 6 Cause of Action Pursuant to 18 U.S.C. § 2255 September 2002 — Incident 2 41. Plaintiff, adopts and realleges paragraphs 1 through 20 above. 42. On or about September 2002, the exact date being unknown to Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of numerous federal criminal statutes condemning the coercion and enticement of a minor to engage in prostitution or sexual activity, travel with intent to Page 14 of 234 14 ofIN EP-094 EFTA01117128  Case 9:09-cv-81092-JIC acument 1 Entered on FLSD Dock:: 07/27/2009 Page 15 of 82 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, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and § 2423(e). E. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and, as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 43. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, M. has in the past suffered, and