EFTA01109281.pdf

Case 9:09-cv-81092-JIC Ldocument 1 Entered on FLSD Docket 07/27/2009 Page 51 of 82 COUNT 31 Cause of Action Pursuant to 18 U.S.C. § 2255 March 2003 — Incident 3 141. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above. 142. On or about March 2003, the exact date being unknown to L.M., 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 143. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 Page 51 of 234 51 of 234 EFTA01109281  Case 9:09-cv-81092-JIC uocument 1 Entered on FLSD Docket 07/27/2009 Page 52 of 82 and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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. 144. Wherefore, the plaintiff, L.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 32 Cause of Action Pursuant to 18 U.S.C. 4 2255 March 2003 — Incident 4 145. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above. 146. On or about March 2003, the exact date being unknown to L.M., 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). Page 52 of 234 52 of 231 EFTA01109282  Case 9:09-cv-81092-JIC vocument 1 Entered on FLSD Docket 07/27/2009 Page 53 of 82 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. 147. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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. 148. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount providild 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 33 Cause of Action Pursuant to 18 U.S.C. § 2255 Page 53 of 234 53 of 214 EFTA01109283  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 54 of 82 April 2003— Incident 1 149. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above. 150. On or about April 2003, the exact date being unknown to L.M., 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. 151. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M 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.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and Page 54 of 234 64 c1334 EFTA01109284  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 55 of 82 psychological expenses. The plaintiff, L.M., 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. 152. Wherefore, the plaintiff, L.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 34 Cause of Action Pursuant to 18 U.S.C. 4 2255 April 2003 — Incident 2 153. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above. 154. On or about April 2003, the exact date being unknown to L.M., 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 Page 55 of 234 $5 of 234 EFTA01109285  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 56 of 82 Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 155. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff. L.M., 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. 156. Wherefore, the plaintiff, L.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 35 Cause of Action Pursuant to 18 U.S.C. 4 2255 April 2003 — Incident 3 157. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above. Page 56 of 234 64 at 234 EFTA01109286  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 57 of 82 158. On or about April 2003, the exact date being unknown to L.M., 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. 159. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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 57 of 234 $7 of 234 EFTA01109287  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 58 of 82 injuries are permanent in nature and the plaintiff, L.M., will continue to suffer these losses in the future. 160. Wherefore, the plaintiff, L.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 36 Cause of Action Pursuant to 18 U.S.C. Q 2265 April 2003 — Incident 4 161. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above. 162. On or about April 2003, the exact date being unknown to L.M., 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. Page 58 of 234 SI of 234 EFTA01109288  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 59 of 82 163. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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. 164. Wherefore, the plaintiff, L.M., demands judgments against the defendant, Jeffrey Epstein, for compensatory damages of at least the minimum amount provided by taw, 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 37 Cause of Action Pursuant to 18 U.S.C. S 2255 May 2003 — Incident 1 165. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above. 166. On or about May 2003, the exact date being unknown to L.M., Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a violation of Page 59 of 234 of 234 EFTA01109289  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 60 of 82 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. 167. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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. Page 60 of 234 CC of 234 EFTA01109290  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 61 of 82 168. Wherefore, the plaintiff, L.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 38 Cause of Action Pursuant to 18 U.S.C. 4 2255 May 2003 — Incident 2 169. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above. 170. On or about Mayl 2003, the exact date being unknown to L.M., 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. 171. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. has in the past Page 61 of 234 $1 of 234 EFTA01109291  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 62 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, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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. 172. Wherefore, the plaintiff, L.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 39 Cause of Action Pursuant to 18 U.S.C. 2255 May 2003 — Incident 3 173. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above. 174. On or about May 2003, the exact date being unknown to L.M., 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 Page 62 of 234 62 e/ 231 EFTA01109292  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 63 of 82 minor children, transport of conduct, sex trafficking of children, sexual exploitation of conduct, child exploitation visual depictions of a minor engaging in sexually explicit not limited to, those crimes enterprises, and other crimes, specifically including, but and § 2423(e). L.M. is designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), 18 U.S.C. § 2255 and, as therefore a victim of one or more offenses enumerated in Jeffrey Epstein, pursuant to this such, asserts a cause of action against the defendant, en the Defendant, Jeffrey Section of the United States Code and the agreement betwe Epstein, and the United States Government. enum erated in Title 18, 175. As a direct and proximate result of the offenses st her, L.M. has in the past United States Code, Section 2255, being committed again and suffering, emotional suffered, and will in the future suffer, physical injury pain , embarrassment, loss of distress, psychological trauma, mental anguish, humiliation other damages associated with self-esteem, loss of dignity, invasion of her privacy and coercing her into a perverse defendant, Jeffrey Epstein, controlling, manipulating and plaintiff L.M. incurred medical and conventional way of life for a minor. The then-minor in the future suffer medical and and psychological expenses and the plaintiff. L M . will a loss of income, a loss of the psychological expenses. The plaintiff, L.M., has suffered ity to enjoy life. These capacity to earn income in the future, and a loss of the capac will continue to suffer these injuries are permanent in nature and the plaintiff, L.M., losses in the future. against the defen dant, 176. Wherefore, the plaintiff, L.M., demands judgments the minimum amount provided Jeffrey Epstein, for compensatory damages of at least Page 63 of 234 63 01 214 EFTA01109293  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 64 of 82 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 40 Cause of Action Pursuant to 18 U.S.C. 4 2255 May 2003 — Incident 4 177. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above. 178. On or about May 2003, the exact date being unknown to L.M., 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. 179. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 Page 64 of 234 640231 EFTA01109294  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 65 of 82 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, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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. 180. Wherefore, the plaintiff, L.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 41 Cause of Action Pursuant to 18 U.S.C. § 2255 June 2003 — Incident 1 181 Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above 182. On or about June 2003, the exact date being unknown to L.M., 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, Page 65 of 234 ti of 234 EFTA01109295  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 66 of 82 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. 183 As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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. 184. Wherefore, the plaintiff, L.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. Page 66 of 234 54 of 234 EFTA01109296  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 67 of 82 COUNT 42 Cause of Action Pursuant to 18 U.S.C. fi 2265 June 2003 — Incident 2 185. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above. 186. On or about June 2003, the exact date being unknown to L.M., 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. 187. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against her, L.M. 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 Page 67 of 234 17 a 234 EFTA01109297  Document 1 Entered on FLSD Docket 07/27/2009 Page 68 of 82 Case 9:09-cv-81092-JIC and conventional way of life for a minor. The then-minor plaintiff L.M. incurred medical and psychological expenses and the plaintiff, L.M., will in the future suffer medical and psychological expenses. The plaintiff, L.M., 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. 188. Wherefore, the plaintiff, L.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 43 Cause of Action Pursuant to 18 U.S.C. 4 2255 June 2003 — Incident 3 189. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above. 190. On or about June 2003, the exact date being unknown to L.M., 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). Page 68 of 234 60 of 234 EFTA01109298  Case 9:09-cv-81092-JIC Document 1 Entered on FLSD Docket 07/27/2009 Page 69 of 82 erated in 18 U.S.C. § 2255 and, L.M. is therefore a victim of one or more offenses enum dant, Jeffrey Epstein, pursuant to as such, asserts a cause of action against the defen ment between the Defendant, this Section of the United States Code and the agree Jeffrey Epstein, and the United States Government. enum erated in Title 18, 191. As a direct and proximate result of the offenses against her, L.M. has in the past United States Code, Section 2255, being committed pain and suffering, emotional suffered, and will in the future suffer, physical injury iation , embarrassment, loss of distress, psychological trauma, mental anguish, humil other damages associated with self-esteem, loss of dignity, invasion of her privacy and coercing her into a perverse defendant, Jeffrey Epstein, controlling, manipulating and r plaintiff L.M. incurred medical and conventional way of life for a minor. The then-mino in the future suffer medical and and psychological expenses and the plaintiff, L.M., will a loss of income, a loss of the psychological expenses. The plaintiff, L.M., has suffered capacity to enjoy life. These capacity to earn income in the future, and a loss of the will continue to suffer these injuries are permanent in nature and the plaintiff, L.M., losses in the future again st the defendant, 192. Wherefore, the plaintiff, L.M., demands judgments the minimum amount provided Jeffrey Epstein, for compensatory damages of at least r relief as this Court deems just by law, attorney's fees, costs, and such other and furthe s triable as of right by a jury. and proper, and hereby demands trial by jury on all issue COUNT 44 Cause of Action Pursuant to 18 U.S.C. 5 2256 Page 69 of 234 0 of 214 EFTA01109299  Case 9:09-cv-81092-JIC Ddcument 1 Entered on FLSD Docket 07/27/2009 Page 70 of 82 June 2003 — Incident 4 193. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above. 194. On or about June 2003, the exact date being unknown to L.M., 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