EFTA00234729.pdf

Case 9:08-cv-80893-KAM Document 1 Entered on FLSD DocIJ 08/14/2008 Flam*1 8f812 D.C. ELECTRONIC \Br AUGUST 13, 2008 UNITED STATES DISTRICT COURT STEVE M. LARIMORE SOUTHERN DISTRICT OF FLORIDA U CLERK N.S. DIS T.CT. t2093 ornren-- S.D. OF FLA. • MIAMI Case No.: OgCr JANE DOE, 08-80893-Civ-MARRA/JOHNSON Plaintiff vs. JEFFREY EPSTEIN, Defendant COMPLAINT Parties, Jurisdiction and Venue COMES NOW the Plaintiff, Jane Doe, and brings this Complaint against the Defendant, Jeffrey Epstein, and states as follows: 1. This is an action for damages in an amount in excess of $50,000,000.00, exclusive of interest and costs. 2. This Complaint is brought under a fictitious name in order to protect the identity of the Plaintiff, Jane Doe, because this Complaint makes allegations of sexual assault and child abuse of a then minor. 3. At all times material to this cause of action, the Plaintiff, Jane Doe, was a resident of Palm Beach County, Florida. 4. At all times material to this cause of action, the Defendant, Jeffrey Epstein, was a resident of the State of New York. 5. At all times material to this cause of action, the Defendant, Jeffrey Epstein, had a residence located in Palm Beach County, Florida. Page 1 of II 10110 EFTA00234729 08-808893sCavetAARRAMOHNSON _.tered on FLSD Docket 08/14/2008 Page 2 of 12 .80 6. At all times material to this cause of action, the Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. This Court has jurisdiction of this action and the claim set forth herein pursuant to 28 U.S.C. §1332(a) as the matter in controversy exceeds $75,000.00, exclusive of interest and costs and is between citizens of different states. 8. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial part of the events or omissions giving rise to the claim occurred in this district. 9. At all times material, the Defendant, Jeffrey Epstein, owed a duty unto Plaintiff, Jane Doe, to treat her in a non-negligent manner and to not commit intentional or tortious or illegal acts against her. Factual Allegations 10. Upon information and belief, the Defendant, Jeffrey Epstein, has demonstrated a sexual preference and obsession for minor girls. He engaged in a plan, scheme, and enterprise in which he gained access to economically disadvantaged and other minor girls, such as the Plaintiff, Jane Doe, sexually assaulted these girls, and/or coerced them to engage in prostitution, and in return gave these minor girls money. 11. The Defendant's plan, scheme, and enterprise included an elaborate system wherein the then minor Plaintiff and other minor girls were brought to the Defendant, Jeffrey Epstein's residence by the Defendant's employees and assistants. When the assistants and employees left the then minor Plaintiff and 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 Plaintiff to remove her clothing. He would then perform one or more lewd, Page 2 of 11 20112 EFTA00234730 08-811893aCavetAARRAMOHNSON _tered on FLSD Docket 08/14/2008 Page 3 of 12 NE/ lascivious, and sexual acts, including, but not limited to, masturbation, touching of the then minor Plaintiffs sexual organs, using vibrators or sexual toys on the then minor Plaintiff, and digitally penetrating the then minor Plaintiff. 12. The Plaintiff, Jane Doe, was first brought to the Defendant, Jeffrey Epstein's mansion in early 2003, when she was a fourteen-year old in middle school. 13. 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. 14. Beginning in approximately February 2003 and continuing until approximately June 2005, the Defendant coerced and enticed the impressionable, vulnerable, and economically deprived then minor Plaintiff to commit various acts of sexual misconduct. These acts included, but were not limited to, fondling and inappropriate and illegal sexual touching of the then minor Plaintiff, sexual misconduct and masturbation of the Defendant, Jeffrey Epstein, in the presence of the then minor Plaintiff, and encouraging the then minor Plaintiff to become involved in prostitution; Defendant, Jeffrey Epstein, committed numerous criminal sexual offenses against the then minor Plaintiff including, but not limited to, sexual battery, solicitation of prostitution, procurement of a minor for the purposes of prostitution, and lewd and lascivious assaults upon the person of the then minor Plaintiff. 15. Defendant, Jeffrey Epstein, used his money, wealth and power to unduly and improperly manipulate and influence the then minor Plaintiff 16. The acts referenced above in paragraphs 10 and 15, committed by Defendant, Jeffrey Epstein, against the then minor Plaintiff, Jane Doe, were committed in violation of Page 3 of 11 30t12 EFTA00234731 Case 9:08-cv-80893-KAM Document 1 Entered on FLSD Docket 08/14/2008 Page 4 of 12 numerous criminal State and Federal statutes condemning the sexual exploitation of minor children, prostitution, 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 crimes designated in 18 USC §2241, §2242, §2243, §2421, and §2423, criminal offenses outlined in Chapter 800 of the Florida Statutes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §39.01, and §827.04. 17. The above-described acts took place in Palm Beach County, Florida at the residence of the Defendant, Jeffrey Epstein. Any assertions by the Defendant, Jeffrey Epstein, that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual exploitation and abuse of a minor child. The Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of the Plaintiff, Jane Doe's minority. 18. The above-described acts were perpetrated upon the person of the then minor Plaintiff regularly and on dozens of occasions. 19. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, the 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. 20. As a condition of that 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 Page 4 of 11 EFTA00234732 Case 9:08-cv-80893-KAM Document 1 Entered on FLSD Docket 08/14/2008 Page 5 of 12 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 had Mr. Epstein been convicted at trial. No more; no less". 21. 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, Jane Doe. COUNT I Sexual Exploitation, Sexual Abuse and/or Sexual Assault of a Minor 22. The Plaintiff, Jane Doe, repeats and realleges paragraphs 1 through 21 above. 23. Defendant, Jeffrey Epstein, tortiously assaulted Plaintiff, Jane Doe, sexually on dozens of occasions between approximately February 2003 and approximately June 2005, and further sexually exploited her and contributed to her delinquency during that time. Defendant's acts were outrageous, egregious, intentional, unlawful, offensive and harmful. 24. The sexual assaults were in violation of the numerous state and federal statutes described in paragraph 16 above, and the assaults and acts of exploitation were committed by Defendant, Jeffrey Epstein, willfully and maliciously. 25. As a direct and proximate result of Defendant, Jeffrey Epstein's assaults on the Plaintiff, Jane Doe, the Plaintiff has in the past suffered, and will in the future suffer, physical Page 5 of 11 EFTA00234733 Case 9:08-cv-80893-KAM Document 1 Entered on FLSD Docket 08/14/2008 Page 6 of 12 Sow 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 unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, Jane Doe, will in the future suffer additional medical and psychological expenses. The Plaintiff, Jane Doe, 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, Jane Doe, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, Jane Doe, demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, punitive damages, attorney's fees, 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 H Cause of Action Pursuant to 18 USC 82255 26. The Plaintiff, Jane Doe, adopts and realleges paragraphs 1 through 25 above. 27. The allegations contained herein in Count II are a separate and distinct legal remedy. 28. As a condition of the Defendant, Jeffrey Epstein's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the 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 Page 6 of II EFTA00234734 Case 9:08-cv-80893-KAM Document 1 Entered on FLSD Docket 08/14/2008 Page 7 of 12 %eir 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 had Mr. Epstein been convicted at trial. No more; no less". 29. The Plaintiff, Jane Doe, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 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. 30. Pursuant to the agreement, the Defendant, Jeffrey Epstein, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, Jane Doe, and as such he must effectively admit liability unto the Plaintiff, Jane Doe. 31. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, the Plaintiff, Jane Doe, 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 unconventional way of life for a minor. The then minor Plaintiff incurred medical and Page 7 of 11 EFTA00234735 Case 9:08-cv-80893-KAM Document 1 Entered on FLSD Docket 08/14/2008 Page 8 of 12 %No psychological expenses and the Plaintiff, Jane Doe, will in the future suffer additional medical and psychological expenses. The Plaintiff, Jane Doe, 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, Jane Doe, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, Jane Doe, demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, punitive damages, attorney's fees, 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 III Intentional Infliction of Emotional Distress 32. The Plaintiff, Jane Doe, adopts and realleges paragraphs I through 25 above. 33. The Defendant, Jeffrey Epstein's conduct towards the then minor Plaintiff was intentional and reckless. 34. The Defendant, Jeffrey Epstein, deliberately and recklessly inflicted mental suffering upon the then minor Plaintiff. 35. The Defendant, Jeffrey Epstein's conduct was outrageous in character, and so extreme in degree, going beyond all bounds of decency. 36. The Defendant, Jeffrey Epstein's intentional, deliberate and reckless conduct caused severe emotional distress to the Plaintiff, Jane Doe. Defendant, at the time he committed these numerous sexual assaults on Plaintiff, Jane Doe, had a specific intent to harm the then minor Plaintiff and his conduct did so harm the Plaintiff. Page 8 of II EFTA00234736 Case 9:08-cv-80893-KAM Document 1 Entered on FLSD Docket 08/14/2008 Page 9 of 12 %WV Nid 37. As a direct and proximate result of the Defendant, Jeffrey Epstein's intentional and reckless conduct, the Plaintiff, Jane Doe, has in the past suffered and in the future will continue to 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 unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, Jane Doe, will in the future suffer additional medical and psychological expenses. The Plaintiff, Jane Doe, 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, Jane Doe, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, Jane Doe, demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, punitive damages, attorney's fees, 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 IV Civil Remedy for Criminal Practices 38. The Plaintiff realleges paragraphs I through 25 above. 39. The allegations contained herein in Count IV are a separate and distinct legal remedy. Page 9 of 11 EFTA00234737 Case 9:08-cv-80893-KAM Document 1 Entered on FLSD Docket 08/14/2008 Page 10 of 12 Not 40. The Defendant, Jeffrey Epstein, participated in an enterprise, or conspired or endeavored to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 41. The Defendant, Jeffrey Epstein, participated in this pattern of criminal activity by engaging in at least two of the following acts of criminal misconduct with the same or similar intents, results, accomplices, victims, and methods of commission within a five year period: (a) Procuring for prostitution, or causing to be prostituted, any person who is under the age of 18 years in violation of Florida Statutes Chapter 796; (b) Acts of battery in violation of Florida Statutes Chapter 784; (c) Commercial sexual exploitation of a child in violation of Florida Statutes §827.071. 42. Under the Defendant, Jeffrey Epstein's plan, scheme, and enterprise, the Defendant, Jeffrey Epstein, paid employees and underlings to repeatedly find and bring him minor girls in order for the Defendant to solicit, induce, coerce, entice, compel or force such girls to engage in acts of prostitution and sexual misconduct. 43. The Plaintiff, Jane Doe, was the victim of the Defendant, Jeffrey Epstein's plan, scheme, and enterprise. The Plaintiff, Jane Doe, was called on the telephone and transported by various individuals to the Defendant, Jeffrey Epstein's residence, where she was placed in a room along with the Defendant, enticed to commit acts of prostitution, battery, and sexual exploitation. The Defendant, Jeffrey Epstein, conspired with his assistants and employees and various adults and minor children in order to accomplish his enterprise of seeking out, gaining access to, and exploiting minor children such as the Plaintiff, Jane Doe. Page 10 of 11 EFTA00234738 Case 9:08-cv-80893-KAM Document 1 Entered on FLSD Docke; 08/14/2008 Page 11 of 12 %.• WHEREFORE, under the provisions of Florida Statutes Chapter 772, the Plaintiff, Jane Doe, demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, treble damages, costs and attorneys' fees, 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. Dated: August 12, 2008 Respectfully submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC Brad Edwards Florida Bar #542075 [email protected] Page 11 of 11 EFTA00234739 084/02,961CIEWMAUFIRMICHNSOLSIteredonFLSDDocket08/14/2008 FebO)421O12 D.C. ELECTRONIC %loy Nod 44J544 (Rn. 2401) CIVIL COVER SHEET ,A1 UGUST 13, 2008 The JS 44 civil cover sheet and the informationcontained herein neither replace nor supplement the filing and service ofpleadings or other papers by local rules of cowl. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Cle the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE or THE FORM.) NOTICE:Attorneys MUST Indicate All Re-ftle STEVEN M. LARIMORE DEFENDANTS CLERK U.S. GIST. CT. I. (a) PLAINTIFFS S• D. OF FLA. . MIAMI DOE, JANE EPSTEIN, JEFFREY (b) County of Residence of First Listed Plaintiff Palm Beach Cowry ofResidence ofFirst Listed Defendant Palth Beach (EXCEPT IN U.S. PLAINTIFF CASES) ON U.S. PLAINTIFF CASES ONLY) NOTE: IN LAND CONDEMN ATION OF THE TRACT (C) Attorney's (Finn Nome. Address. and Telephone Nemberl LAND INVOLVED. Law Office of Brad Edwards & Associates,LLC- AUMIscrOriuse.0 01) Check County What Action Arose CI MIAMI. DADE 0 MONROE 3 BROWARD R PALM BEACH 0 MARTI 0 EECHOBEE OHLANDS II. BASIS OF JURISDICTION /rose s. -sr ob oas Sot tom CITIZENSHIP OF PRINCIPAL se Be. (or Plena( (For Diversity Cams Only) aed Oae Be. lot Dehathini) 3 I U.S.Gorman.. 0 3 Federal Deese** PIP DEF ITT REF Plaintiff N.S. Govermatel Not s Party) Cilia. Suit IS I 0 I 1444Mormed or Principal Place 0 4 D. of anima In This Saw 0 2 U.S. Govenneeni gf 4 Diversity Cann of A mils' Sate 0 2 0 2 lateerporated Sae Pnacipal Place O s O5 Defendant of Business le Mather Sate (lotheste Cilia 1$ in It III) S 7 CVCS 9 0 449q3 P 3 4 / .0 2-1C Cream or Subject els Forum Cowan 0 3 0 3 Pettis U.S. 3 6 3 6 I CONTRACT TORTS PORFFITURTJPENALTY BANKRUPTCY OTHER STATUTES I 0 110 Income/ PERSONAL INJURY PERSONALINJURY 0 610 A pieuharr 0 422 APPMI 21 USC 1511 400 Sam Rapponimeieni 0 120 Manse 0 )10 Airplane 0 162 hoarse' Injury • 0 620 Other Food A Drug 0 423 Withdrawal 410 AMAMI O I)* Milky Ael 0 315 Miriam India. Med. Mamma 0 625 Drys Reload Seizure 2$ USC IS7 430 Sakssad Slaking O 140 Neptishls hainimem Liability 0 365 Prisms, Leary • a FroPeny 21 USC MI 450 Cowman 3 ISO Recovery iefOsentraymeet 0 320 Assault. Libel A Paden Liability 0 630 Laser laws PROPERTY RIGHTS 460 bunion & Eisforemant orhelpamt Shade. 0 368 AMMO, Persomil 0 640 R.R. II Track 0 820 Copyrislin 4/0 Redman Istloomed and O IS) Moditere Am 0 330 Fears) Employers' lapin, hada, 0 650 Awhile Rip. 3 830 Patent Comps Orponzawas 0 152 Recovery of Deheilted Lability Liability 0 660 Oseithatimal 0 NO Trademark 410 Commie Credo Steam Leant 3 340 Maras PERSONAL PROPERTY Sideoctlieleh 490 Cablt/Sitt TV (Ent. Vannes) 0 34$ Mane Product 3 370 Other Freed 0 690 Other 110 Stamm Striae 0 IS) Recovery of OwnlisMilim Labatt) 3 371 Trash to Lending J *DOR SOCIAL SEFORITY 850 Sternies/Commeddin4 of Vittersis Ilme(fts 0 350 Moat Vehicle 3 IV/Other Pummel 0 710 Fair Labor Standards 0 $61 NIA (13935) Eschew O 160 Stmliholdtre Setts CI 35$ Moen Vehicle Property Damage Act 0 662 Slack L6081923) $75Careeriter Clalltap O 100 Other Gemmel Predict Lability 0 385 Property Demise 0 720 Laborthlgen Relines 0 $63 DIWCIDIWW (405(1)) 12 USC 3410 3 195 Comma Preston lability If MO Other Fernald Pato lability 0 730 lattotadinn.Repoeting 3 804 5510 Talk XVI $9000... Sammy Anion 0 196 Franchise hoary A Disclosers Act 0 165 RSI mons)) VII A pane& Acts I RFAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 0 740 Ronny Labor Aci FEDERAL TAX SUITS 592 EMMONS Subtheme, AD 3 210 Lead Coodemmties 044, young 0 SIC MMOM Po Tafel* 0 790 Other Labe. Unpins 0170 Tsui (U.S. Plaintiff $91 Eimmementel Memel 0 220 FOrocheleft 0 442 Employment Somme 0 791 Email let. ha. Seceriu or Defordeat) $94 Emmy A Beeson Act 0 230 Rest Lame a Elermem 0 44 3 HousInV Hams Corpus: ACI 0 $71 IRS—Then Pen, $95 Freedom of lathreatien ACI 0 240 Tom eo Lead Amousniecaninse 0 530 Geatnat 26 USC 7609 O 245 Ton Product Liability 044 Welton 0 535 Death ?may I maertAnnw 0 $00 AhmedFee Doiermssum O 290 All Other Real Property 3 445 Anne wiDisabilitin . 0 orninni 540 „.. 4.... 0the, 0 ear Mautrolismoa Ueda Easel Acme ea Imam Apphesism 446 Anal. w/Diesbilities • 44) 11aaaaa Corma.Alim 0 0 550 Coal Rens 0 Other Detainee 465 OtIsti lampoon 950 Commotionialery of Stan 3 440 Other Civil Rights 0 555 Prima Com/nice 3 0 Athens SYMMS V. ORIGIN (Place 'X' .1Om Doe ()sly) to Dimly Trans erred from ei 1 Original O 2 Removed from O 3 Re-filed-O 4 Reinstated cc O 5 another dimly O 6 Multidiaria O 7 Magutrate Judge from Proceeding State Court laet VI below) Reopened (specify) Litigation Judsonent a) Re-filed Cue O YES NO b) Related Cases (2 YES O NO 0840119; 08-80232; VI. RELATED/RE-FILED See wienueticies 0840380; 08.80381; CASE(S). emend MP/ JUDGE Kenneth A. Marra DOCKET NUMBER 08.80804;08-80736 Cie the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do sot cite jurbdietional statutes olden diversity): VII. CAUSE OF ACTION 18 USC 2255 Sexual Exploitation and Other Abuse of Child LENGTH OF TRIAL via 14 . days estimated (for both aides to try entire case) VIII. REQUESTED IN O CHECK IF THIS IS A CLASS ACTION DEMANDS 50,000, 000 CHECK YES only if demanded in employe COMPLAINT: UNDER F.R.C.P. 23 JURY DEMAND: IN Yes 3 No ABOVE INFORMATION IS TRUE ilk CORRECT TO SIGNATURE OF ATTORNEY OF RECORD DATE THE BEST OF MY KNOWLEDGE August 12, 2008 FOR OFFICE USe5iNLY AMOUNT 11360 RECEIPT. lie EFTA00234740