EFTA00222670.pdf

Case 9:08-cv-80119-KAM Document 1 Entered on FLSD Docket 02/06/2008 Pan gto tk 6 FILED by VT D.C. ELECTRONIC ebruary 6, 2008 CLARENCE MADDOX UNITED STATES DISTRICT COURT CLERK U.S. Cat CT. S.D. OF HA. • MIAMI SOUTHERN DISTRICT OF FLORIDA CASE NO.: JANE DOE NO. 2, 08-CV-80119-MARRA-JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. COMPLAINT Plaintiff, Jane Doe No. 2 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey Epstein, as follows: Parties, Jurisdiction and Venue 1. Jane Doe No. 2 is a citizen and resident of the Commonwealth of Virginia, and is sui juris. 2. This Complaint is brought under a fictitious name to protect the identity of the upon a Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of 550 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuant to 28 U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs; and (ii) is between citizens of different states. 6. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial viww.hermanlavccom HERMAN 6 MERMELSTEIN. P. A. -1- Toff EFTA00222670 Case 9:08-cv-80119-KAM Document 1 Entered on FLSD Docket 02/06/2008 Page 2 of 6 occurred in this District. part of the events or omissions giving rise to the claim Factual Allegations was an adult male, 52 7. At all relevant times, Defendant Jeffrey Epstein ("Epstein") a secret clientele limited exclusively to years old. Epstein is a financier and money manager with r and influence. He maintains his billionaires. He is himself a man of tremendous wealth, powe New Mexico, St. Thomas and Palm Beach, principal home in New York and also owns residences in at his lavish estate in Palm Beach. FL. The allegations herein concern Epstein's conduct while ence and obsession for 8. Upon information and belief, Epstein has a sexual prefer in which he gained access to primarily underage minor girls. He engaged in a plan and scheme lly assaulted these girls, and then gave economically disadvantaged minor girls in his home, sexua ximately 16 years old, fell into Epstein's them money. In or about 2004-2005, Jane Doe, then appro trap and became one of his victims. his scheme and assaulted 9. Upon information and belief, Jeffrey Epstein carried out n as Little St. James, in St. Thomas. girls in Florida, New York and on his private island, know t underage girls. (Upon 10. Epstein's scheme involved the use of young girls to recrui to Epstein was herself a minor victim of information and belief, the young girl who brought Jane Doe . Under Epstein's plan, underage girls Epstein, and will therefore not be named in this Complaint) ge for monetary compensation in his Palm were recruited ostensibly to give a wealthy man a massa Epstein was planning to be at his Palm Beach mansion. The recruiter would be contacted when in or someone on his behalf would direct the Beach residence or soon after he had arrived there. Epste nce. The recruiter, upon information and recruiter to bring one or more underage girls to the reside underage girls from western Palm Beach belief, generally sought out economically disadvantaged VYWW.hermanlaw.com HERMAN & MERMELSTEIN. P. A. -2- EFTA00222671 :Case 9:08-cv-80119-KAM Document 1 Entered on FLSD Docket 02/06/2008 Page 3 of 6 County who would be enticed by the money being offered - generally $200 to $300 per "massage" session - and who were perceived as less likely to complain to authorities or have credibility if allegations of improper conduct were made. This was an important element of Epstein's plan. 11. Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at Epstein's mansion, the underage victim would be introduced to Sarah Kellen, Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms. Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition the to other furnishings. There were photographs of nude women lining the stairway hall and in bedroom. The girl would then find herself alone in the room with Epstein, who would be wearing only a towel. He would then remove his towel and lie naked on the massage table, and direct the girl to remove her clothes. Epstein would then perform one or more lewd, lascivious and sexual acts, including masturbation and touching the girl's vagina. 12. Consistent with the foregoing plan and scheme, Jane Doe was recruited to give Epstein a massage for monetary compensation. Jane was brought to Epstein's mansion in Palm Beach. Once at the mansion, Jane was introduced to Sarah Kellen, who led her up the flight of stairs give to the room with the massage table. In this room, Epstein told Jane to take off her clothes and him a massage. Jane kept her panties and bra on and complied with Epstein's instructions. Epstein wore only a towel around his waste. After a short period of time, Epstein removed the towel and rolled over exposing his penis. Epstein began to masturbate and he sexually assaulted Jane. 13. After Epstein had completed the assault, Jane was then able to get dressed, leave the room and go back down the stairs. Jane was paid $200 by Epstein. The young girl who recruited Jane was paid $100 by Epstein for bringing Jane to him. www.hermanlaw.com HERMAN & MERMELSTEIN, P. A. -3- EFTA00222672 .:Case 9:08-cv-80119-KAM Document 1 Entered on FLSD Docket 02/06/2008 Page 4 of 6 14. As a result of this encounter with Epstein, Jane experienced confusion, shame, humiliation and embarrassment, and has suffered severe psychological and emotional injuries. COUNT I Sexual Assault 15. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 16. Epstein tortiously assaulted Jane Doe sexually. Epstein's acts were intentional, unlawful, offensive and harmful. 17. Epstein's plan and scheme in which he committed such acts upon Jane Doe were done willfully and maliciously. 18. This sexual assault was in violation of Chapter 800 of the Florida Statutes, which recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane. 19. As a direct and proximate result of Epstein's assault on Jane, she has suffered and will and continue to suffer severe and permanent traumatic injuries, including mental, psychological emotional damages. WHEREFORE, Plaintiff Jane Doe No. 2 demands judgment against Defendant Jeffrey this Epstein for compensatory damages, punitive damages, costs, and such other and further relief as Court deems just and proper. COUNT II Intentional Infliction of Emotional Distress 20. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 21. Epstein's conduct was intentional or reckless. 22. Epstein's conduct was outrageous, going beyond all bounds of decency. 23. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had www.hermanlaw.com HERMAN & MERMELSTEIN, P. A. -4- EFTA00222673 :Case 9:08-cv-80119-KAM Document 1 Entered on FLSD Docket 02/06/2008 Page 5 of 6 reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe. 24. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe, has suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiff Jane Doe No. 2 demands judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this Court deems just and proper. JURY TRIAL DEMAND Plaintiffs demand a jury trial in this action. Dated: February C2008 Respectfully submitted, HERMAN & MERMELSTEIN, P.A. Attorneysfor Plaintiffs 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931- By: Jeffrey M. Herman jherman@,hermanlaw.com Florida Bar No. 521647 Stuart S. Mcrmelstein [email protected] Florida Bar No. 947245 Adam D. Horowitz Florida Bar No. 376980 [email protected] HERMAN & MERMELSTEIN. P. A. www.hermanlaw.com -5- EFTA00222674  Case 9:08-cv-80119-KAM DocuncsiMik- CCNERealt:IFEITSD Docket 02/06/2008 Page 6 of 6 The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing, and service of pleading or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of the Court for the purpose of Initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) 1(a) PLAINTIFFS DEFENDANTS JANE DOE NO. 2, JEFFREY EPSTEIN (b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT NEW YORK OUT OF STATE (IN U.S. PLAINTIFF CASES ONLY) (EXCEPT IN U.S. PLAINTIFF CASES) (c) ATTORNEYS (FIRM NAME. ADDRESS, AND TELEPHONE NUMBER) ATTORNEYS (IF KNOWN) Herman & Mermelstein, PA.,18205 Biscayne Blvd., Suite 2218, Miami, FL 33160, (305) 931.2200 (d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH q!ely V foul-K/9in- ) 0 4-)/71__ II. BASIS OF JURISDICTION III. CITTZENSHIP OF PRINCIPAL PARTIES PLACE AN X IN ONE BOX FOR PLAINTIFF (PLACE AN X ONE BOX ONLY) (For Diversity Case Only) AND ONE FOR DEFENDANT PTF DEF PTF DEF Incorporated of Principal Place of O 4 04 O 1. U.S. Government O 3 Federal Question Citizen of This State 0 t O 1 Business in This Stale Plaintin (U.S. Government Not a Party) Citizen of Another State X2 x 2 Incorporated and Principal Place of O 5 O 5 O 2 U.S. Government X 4 Diversity Citizen or Subject of s Foreign Country 0 3 03 Business in Another State Defendant (Indicate Citizenship of Parbes in Item III) Foreign Nation O 6 O 6 IV. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE. DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY.) DIVERSITY ACTION UNDER 28 U.S.C. §1332(a) FOR SEXUAL ASSAULT IVa. _5_ days estimated (for both sides) to try entire case V. NATURE OF SUIT (PLACE AN X IN ONE BOX ONLY) A CONTRACT A TORTS B FORFEITURE A BANKRUPTCY A OTHER STATUS PENALTY D I 10Mani PERSONAL INJURY 06i Aran" o 422 *sow a use iss KO Sou Roacoortwn 0 i2,01AWn2 0 133.06•264 0 623 0•4111003 6 Pic a 62$ Om ROSSI Saw* SC rot. 0 423 Wintleampl a 410 430 AnaNI2 Nam ara Maury 0 310 Milano 0 3.32 Plan 140,600 1160403102 Cl Mowry 21 USC 211 450 Conant= 4140,pvtec 6 0 140 4113010016 ireivw.1 0 315 IirgterePadue Umbday 0306 hnovilmerive0alLibitY 13 320 Mat LOW & SW*, °3m M044101POISOatel 0 630 Inge law 420 0424:00101 4 VA:waned 0 Wri" 0 15"."1 """" 0 330 7 23.41102272on' Sat won proem ustyr 0 OW RR 1 Truck A PROPERTY RIGHTS 470 (LWOW 'Murcia ard Jar. 0 34014.41* 0 ASO Ara Rye Camoi Ornalealon o 1511.1,343•0 Ad 0 NO 1303.43okal RIO Sea.. Swot 0 IS?Rams, of Defail“ 0343 *ARM Rona USW, PERSONAL PROPERTY Salelluean 0 WO Coonols •10 S•AttifievConouxlIeW 511,4301Loans Mc. 0 =lax vet* 0 NO One 06$ Pw. Eche., "urn) 6 a 3SS ilabe WO* Proati Liable/ 0370 Ods / rad OM Truienri 1175 Oates 0010.• o iS3Rang 01Oweirroi X 363 ORR 114/ 010011NRY 0 371 Toe, measly 0 I2USC34I0 /Vests Seneca 0360 Caw Plinewl 211 R00^ 121 As o 1035bckroblies a eiricieuore B SOCIAL SECURITY 802 Ewalt 901242812/I AO 0 mow Geese a ass Awry 0,12”032 203 enwoongetal lAseIrs o 126C0,290 040:420 Latity Onnoci a 0162 “PA1130td) RH Erwin mocon" MI tOS Fritts ollrfommion AO 0 862 Mack Lure1923) 920 APPUI Sr.. Delemnson AREAL PROPERTY A CIVIL RIGHTS B PRISONER PETITIONS A LABOR 0 663 CINC.01WW WOW 1.1R3441.41Aceen 0 1054 Silo ler An ate o ma as Noma 0 260 coniseceein et sue CI 210 Lard 030OrnnInn 0 441Vo010 0 5101.1710, 10 VasaSerene id Fat 1.rat Strains 901.42 0 220 rombam 6 0 442En62,44401 Kies 0).TM ACI 0 IMO Ors Itiseary Adtee 0230 Rem Waal Law. 0 444w.4, 1,10m1R204:40m4e6skas 0 530Gnat' 0 720 Labor umpires ••ce6 0 240 Teas le Lind 0 444 0 5351140/.Penny Nam% e A FEDERAL TAX SUITS 0 245 Ian Piatlat Leta/ 0 4400104 OR R43111 0 Lao untrue a one- a730 later umwonert Owlantiory NW am mar ie.00M 0 210 Al Onw Ras 1.200/1 0 5930.4 We. Rawer° 1 0601.401 lee 0460r6ton •A ea Ad 0670 Taw NS Mini• or Oardird) 0 740 Rafxry LAW nu a WI 11.9-Thod Poly 26 USC 1600 0 703 00•41.10XU130101 a 791 4,747ne• RN ac SIAMACII a I FILED by D.C.; VI. ORIGIN it 1. Original 0 2. Removed from 0 3. Remanded from 0 4. Refilled 0 6. Multidistrict Litigation 0 7. Appeal to District Judge from Proceeding State Court Appellate Court 0 5. Transferred from another district (Specify) Magistrate Judgment VII. REQUESTED CHECK IF THIS IS A O CLASS ACTION DEMAND $ CI Check YE IN COMPLAINT o UNDER F.R.C.P. 23 complaint: JURY DEMAND: O NO VIII. RELATED (See Instructicos): (SEE ATTACHED) CASE(S) IF ANY JUDGE DOCKET NUMBER DATE pi . -1,0 46t SIGNATURE OF ATTORNEY OF RECORD UNITED STATES DISTRICT COURT FOR OFFICE USE ONLY: Receipt No. Amount S/F 1.2 REV. 9194 Date Paid: Wfp: EFTA00222675 Case 9:08-cv-80119-KAM Document 12 Entered on FLSD Docket 06/20/2008 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. DEFENDANT'S MOTION FOR STAY Defendant Jeffrey Epstein respectfully moves for a mandatory stay of this action under Title 18, United States Code, Section 3509(k). As discussed below, this action is subject to a mandatory stay based on the existence of two pending parallel criminal actions. Introduction This civil action is a private counterpart to two ongoing criminal actions, one in Palm Beach state court, the other in Miami federal court. Both cases purport to arise from the same occurrence: the alleged sexual assault of a minor, Jane Doe No. 2. A federal statute directly on point provides that when an alleged sexual assault involving a child victim results in a "criminal proceeding," a commonly EFTA00222676 Case 9:08-cv-80119-KAM Document 12 Entered on FLSD Docket 06/20/2008 Page 2 of 6 derived civil suit "shall be stayed until the end of all phases of the criminal action." 18 U.S.C. § 3509(k) (emphasis added).' A stay of this case is required until there is no longer a pending criminal action derived from the same underlying allegations. See 18 U.S.C. § 3509(k). Discussion The parallel state criminal action pending in Palm Beach Circuit Court is still in the discovery phase. State of Florida v. Jeffi-ey Epstein, Case No. 2006 CF 09454 AXX (Fifteenth Judicial Circuit, Palm Beach County). Meanwhile, there is also a parallel federal criminal grand jury action pending in the Southern District of Florida. In re Grand Jury, No. FGJ 07-103(WPB) (S.D. Fla.) Both cases arise out of the same occurrence and allege that the minor plaintiff is a victim. The language of section 3509(k) of title 18, United States Code, is clear: a parallel "civil action shall be stayed until the end of all phases of the criminal The full text of the mandatory-stay provision reads: If, at any time that a cause of action for recovery of compensation for damage or injury to the person of a child exists, a criminal action is pending which arises out of the same occurrence and in which the child is the victim, the civil action shall be stayed until the end of all phases of the criminal action and any mention of the civil action during the criminal proceeding is prohibited. As used in this subsection, a criminal action is pending until its final adjudication in the trial court. 18 U.S.C. § 3509(k). 2 EFTA00222677 Case 9:08-cv-80119-KAM Document 12 Entered on FLSD Docket 06/20/2008 Page 3 of 6 action." 18 U.S.C. § 3509(k) (emphasis added). When it comes to statutory construction, the mandatory nature of the word "shall" is well-settled. See, e.g., Lopez v. Davis, 531 U.S. 230, 241 (2001) (noting Congress' use of a mandatory `shall' to impose discretionless obligations") (emphasis added); Lexecon Inc. v. Milberg Weiss Bershad Hynes & Lerach, 523 U.S. 26, 35 (1998) (explaining that "the mandatory `shall' . . . normally creates an obligation impervious to judicial discretion") (emphasis added). Cf. Miller v. French, 530 U.S. 327, 350 (2000) ("Through the PLRA [Prison Litigation Reform Act], Congress clearly intended to make operation of the automatic stay mandatory, precluding courts from exercising their equitable powers to enjoin the stay. And we conclude that this provision does not violate separation of powers principles.") (emphasis added). One district court within the Eleventh Circuit, facing the identical issue with a pending state prosecution, recently construed "the plain language of § 3509(k)" as "requirfing] a stay in a case . . . where . . . a parallel criminal action [is] pending." Doe v. Francis, No. 5:03 CV 260 MCR/WCS, 2005 WL 950623, at *2 (N.D. Fla. Apr. 20, 2005) (Francis I.1) (emphasis added). Accord Doe v. Francis, No. 5:03 CV 260 MCR/WCS, 2005 WL 517847, at *1-2 (N.D. Fla. Feb. 10, 2005) (Francis I) (staying federal civil action in favor of "a criminal case currently pending in state court in Bay County, Florida, arising from the same facts and involving the same parties as the Instant action," noting that "the language of 18 3 EFTA00222678 Case 9:08-cv-80119-KAM Document 12 Entered on FLSD Docket 06/20/2008 Page 4 of 6 U.S.C. § 3509(k) is clear that a stay is required in a case such as this where a parallel criminal action is pending which arises from the same occurrence involving minor victims") (emphasis added). There is no contrary opinion from any court. In determining that the federal stay provision is mandatory, the Francis II court expressed that there was apparently no case law supporting, or even "discussing the [avoidance] of a stay [under the command of] § 3509(k)." Francis H, 2005 WL 950623, at *2. Deferring to the statute as written, the Francis H court rejected the plaintiffs' argument that some of the alleged victims had already reached their majority. See id. The court similarly rejected the plaintiffs' argument that it would be in the victims' best interests to avoid a stay so as to counteract the victims' "ongoing and increasing mental harm due to the `frustrating delay in both the criminal case and [the civil] case.'" Id. The Francis II court, in adhering to the plain language of the statute, also adhered to the "well established priority of criminal proceedings over civil proceedings." Cf. United States v. Hanhardt, 156 F. Supp. 2d 988, 1000 (N.D. I11. 2001) (citing Fed. R. Crim. P. 50(a)). Conclusion Because this civil action arises from the same allegations as two pending criminal actions, § 3509(k) mandates a stay of this civil action. • 4 EFTA00222679 Case 9:08-cv-80119-KAM Document 12 Entered on FLSD Docket 06/20/2008 Page 5 of 6 WHEREFORE, Defendant Jeffrey Epstein respectfully requests that the Court enter a stay under 18 U.S.C. § 3509(k), coextensive with the state and federal criminal actions. Respectfully submitted, ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, Florida 33401 Tel: 561 659 8300 Fax: 561 835 8691 By: /s/ Jack A. Goldberger Jack A. Goldberger Fla. Bar No. 262013 [email protected] Attorneysfor Defendant Jeffiey Epstein 5 EFTA00222680 Case 9:08-cv-80119-KAM Document 12 Entered on FLSD Docket 06/20/2008 Page 6 of 6 CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7 Counsel for defendant has conferred in good faith with counsel for the plaintiff, who opposes the relief requested in this motion. Is/ Jack A. Goldberger Jack A. Goldberger CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 20, 2008, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on counsel of record identified below by facsimile and U.S. Mail. Jeffrey M. Herman, Esq. Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Herman & Mermelstein, P.A. 18205 Biscayne Blvd, Suite 2218 Miami, Florida 33160 Fax: 305 931 0877 /s/ Jack A. Goldberger Jack A. Goldberger 6 EFTA00222681 Case 9:08-cv-80119-KAM Document 16 Entered on FLSD Docket 07/01/2008 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. DEFENDANT'S NOTICE CONCERNING MOTION TO STAY IDE 121 In connection with his motion to stay this action [DE 12], Defendant Jeffrey Epstein hereby notifies the Court that the State Court action, State of Florida' Jeffrey Epstein, Case No. 2006 CF 09454 AXX (Fifteenth Judicial Circuit, Palm Beach County), was resolved on June 30, 2008. See Final Disposition sheets, attached hereto as Exhibit A. The federal criminal proceeding, however, remains pending. Respectfully submitted, ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, Florida 33401 Tel: 561 659 8300 Fax: 561 835 8691 EFTA00222682 Case 9:08-cv-80119-KAM Document 16 Entered on FLSD Docket 07/01/2008 Page 2 of 3 By: /s/ Jack A. Goldberger Jack A. Goldberger Fla. Bar No. 262013 jgoldberger@ agwpa.com Attorneys for Defendant Jeffrey Epstein 2 EFTA00222683 Case 9:08-cv-80119-KAM Document 16 Entered on FLSD Docket 07'01 '2008 Page 3 of 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 1, 2008, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on counsel of record identified below by facsimile and U.S. Mail. Jeffrey M. Herman, Esq. Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Herman & Mermelstein, P.A. 18205 Biscayne Blvd, Suite 2218 Miami, Florida 33160 Fax: 305 931 0877 /s/ Jack A. Goldberger Jack A. Goldberger 3 EFTA00222684 Case 9:08-cv-80119-KAM Document 16-2 Entered on FLSD Docket 07:01:2008 Page 1 of 4 EXHIBIT A EFTA00222685  Case 9:08-cv-80119-KAM Document 16-2 Entered on FLSD Docket 07/01/2008 Page 2 of 4 : tiP • ' CASE PIO ±-122OO.1.:IFO-5 14/ 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"rtnivz•zrt : . • . 7 Date : • -17 vcri J 'Crt. Rep. lun,L__ „Asir )----=-- Deft--Pres of Pres.- W /- /O • S / PD e--P:9fot Pres, Before the Court for. C r O Granted O Denied O With /Without O Withdrawn O Court Reserves Ruling O Written Order to Follow Prejudiced ^- O Warrant O ordered O Recalled O Bort Cl See Belbw DAlso Covers . 04 Cond O Bond Forf OOR: Distil / Revoked /Reinstated /Reuniter O$GR:Disch/Revoked/Reinsmted • - - O Bond Fat Vacated O Previous Bond Reinstated, if B an O State failed to file charges 0 -Released OR /8:O1L O Deft _ Indigent O PD Appt O Erg only . PD Pres • O- Court Appts Evaluation for: O Drug Farm O DOC Non-Secure Bed by • • • O Pre-Plea . O PSI ordered by/within ' .days O wfinput from DU / Staffing O Referred to: FIT / SAAP / PADD O Case p cod on theabsentee docket DEFT ENTERED A LEA OF: O NOT GUILTY GUILTY O NO CONTEST O BEST INTEREST O TO THE COURT Als,Charged-Cts MA.' er Cts Lesser Charge ' 40' Sw & lest dv of Rts Waived PSI Lesser Cts Lesser Charge 17ADJ GUILTY as Charged as to Cu____,21264 Lesstr Cts O FOUND GUILTY as Charged as to Cts . Lesser Cts O ADJ WftiELD as to Cts O SENT W/BELD as to Cts O FOUND AND ADJUDICATED DELINQUENT as to Cts ' ODisoOolenofollowflikd O FOUND & AD: NOT GUILTY as to Cts O Dismiss . O Nolte Prase Cts Prob / Comm Control: O Revoked O Reinsta O Modified O Term. Successfully / Unsuccessfully - - . • . e-- - • O Stip/Found: (violent) Habitual Off. 775.084 a o exual Predator O Stip/Found:. P.R.R. SENTENCE: PBCJisilP/15 Cis: / e Os. PBC2- Cts• / DOC. - Os. :meretirlf St W/Credit for an / Consec / Co -'h in w/cases / : / . • . Deft Remanded O Deft to remain on same rel. status pending sent. • O Execution of Sentence Stayed O Sentence Suspended O Time served as ki Cts • O Youthful Off O Habitual Off- O Min/ Maud- as to Cts O ABOVE SENTENCE1O BE FOLLOWED By: O Probation O Drag/Sex OffProb O Comm. Control' .O I . O E - See Pg. 2 O DRIVERS LICENSE TO BE SUSPENDED / REVOKED FOR YEARS AS'A RESULT OF THIS PLEA. , B Set /Remains Set / Reset • Div • Rm— at AM/PM Set / Remains Set / Reset • Div Rm at AM/PM O Deft sign O Def Co O ASA O Bondsman O Prob °Jail ODD O GAL Notified by mail by: on / O County Courthouse O Courtroom, Criminal Justice Bldg. O Courtroom,- Criminal Justice Complex 205 N. Dixie, West Palm Beach 38844 State Road 80, Belle Glade 3228 Gun Club Rd., West Palm Beach IF VON ARE A PERSON VAIN A OISAESUre WHO WEDS MY ACCOVIIKOCS NORDIN TO PARDMIME II TES PECCEEDEC1 YOU AfE 941111114 AT NO CUSP TO YOU.10 THE PROVISION OF • CERTAIN AS9STAhrE Kass CONTACT Lww JAFFE. ADA COORDIVEDE IN TIC ACEANSMATHE awe CHIT COM PAW BEACH MOEN ECWRFICEISM 205 N EWE I'MT, RE SSA WEST PALM MACK FL MEN: TUB:HONE (561)6%.4150, WWI a MENNE ONS Of YOUR Rear OF THE NONCE. IF YOU AM HEARING OR VOCE IMPAIRED, —CALL , 14304554Th. Form 6)1 EDP Ray 11/06 EFTA00222686  Case 9:08-cv-80119-KAM Document 1 6- 2 Entered on FLSD Docket 07/01/2008 Page 3 of 4 Case No.: 20080=ND093Si= W ST of FL vs. JEFFREY'EPSEBIN charges. PROCURE PERSON lla MB GE' 18 FOR PAGSTI5lll-liCN (eater FROM 2006CF009454=kr Assad/ - Bond# Date in n • • - /udge . -• - . Crt. Rep. / • .11 )11017/4'..) ASA _ . 4/..../ j.::..n/tf .4/./.47 DC r- , • - • Int .-Tet--Pres-/,Oot Pres. W i /W/O pa. OS. .1,:in t. . • Esq CP137- res / Not Pros. _....• -Beftliellti Court for: 9.4 A05 f I O Granted 0 Denied .. 0 With / Without Prejudice 0 Withdravin 0 COurt Reserves Ruling a Written Order to Follow O Warrant 0 Ordered 0 Recalled 0 Bond Set at S . Ince Below Also Covers 0 Sp Cond 0 0. Bond Pod 0 OR: Disch / Revoked / Reinstated 0 Bond] Disch /Revoked •cISOR: Discb / Revoked /Reinstated Cl Bond Foil Vacated Cl Previous Bond Reinstated, if Bondsman agrees . Cl State failed to file charges - 0 Released O.R. / S.O.R. . 0 Deft _ Indigent o pp Sppt . CI firg only PD Pres a Court ApPts Evaluation for: 0 Drug PAIR 0 DOC Non-Secure Bed by • 0 Pre-Plea 0 PSI ordered by/within • days. 0 vainput. from DJJ /Staffing 0 Referred to: PTI / SAAP / PADD 0 Case pla on the absentee docket . • ' DEFT ENTERED A PLEA O12: 't3 NOT GUILTY. GUILTY ONO CONTEST Cl BEST INTEREST 0 TO THE COURT Charged-Ctst i ••. I i .<loc. Lesser Cts • -Lesser Charge q At sw & Thu Adv of Rts of gaived PSI ' Lesser Cts • teiserCharge • ADS GUILTY as Charged as to Cts el •1 ••?A• .. y Lesser CG • • • • 0 FOUND GUILTY as Charged as to as Lesser Cts• •• CP ADJ• W/HELD as to Cts 0 -SENTW/1-= astoCts ' CI FOUND AND ADJUDICATED DELINQUENT as to Cts• • ' •• • 0 Dispo Order to follow / Piled 0 POUND & ADI NOT GUILTY as to Cts 0 DisMies : 0 NolleProsseCts Prob / Comm Control: 0 Revoked .0 Reinstated 0 Modified. 0 Term. Successfully / Unsuccessfully . • 0