📄 Extracted Text (9,801 words)
Case 9:09-cv-81092-JIC Document 1-3 Entered on FLSD Docket 07/27/2009 Page 42 of 73
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.
563. 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.
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564. 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 137
COUNT 137
Cause of Action Pursuant to 18 U.S.C. d 2255
June 2005 — Incident 1
565. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
566. On or about June 2005, 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.
567. 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
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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.
568. 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 138
Cause of Action Pursuant to 19 U.S.C. § 2255
June 2005 — Incident 2
569. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
570. On or about June 2005, 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
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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.
571. 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.
572. Wherefore, the plaintiff, L.M., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
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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 139
Cause of Action Pursuant to 18 U.S.C. 4 2255
June 2005 — Incident 3
573. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
574. On or about June 2005, 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.
575. 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
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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.
576. 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 140
Cause of Action Pursuant to 18 U.S.C. § 2255
June 2005 — Incident 4
577. Plaintiff, L M. adopts and realleges paragraphs 1 through 20 above.
578. On or about June 2005, 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,
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EFTA01109438
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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.
579. 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.
580. 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.
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COUNT 141
Cause of Action Pursuant to 18 U.S.C. 2255
July 2006 — Incident 1
581. Plaintiff, L.M. adopts and realleges paragraphs 1 throu
gh 20 above.
582. On or about July 2005, 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, Jeffre
y Epstein, pursuant to this
Section of the United States Code and the agreement betwe
en the Defendant, Jeffrey
Epstein, and the United States Government.
583. As a direct and proximate result of the offenses
enum erated in Title 18,
United States Code, Section 2255, being committed again
st 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
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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.
584. 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 142
Cause of Action Pursuant to 18 U.S.C. 6 2255
July 2005 — Incident 2
585. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
586. On or about July 2005, 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
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EFTA01109441
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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.
587. 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
588. 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 143
Cause of Action Pursuant to 18 U.S.C. 4 2255
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July 2005 — Incident 3
589. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
590. On or about July 2005, 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.
591. 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
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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.
592. 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 144
Cause of Action Pursuant to 18 U.S.C. § 2255
July 2005 — Incident 4
593. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
594. On or about July 2005, 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
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Section of the United States Code and the agreement between the Defendant, Jeffrey
Epstein, and the United States Government.
595. 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.
596. 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 145
Cause of Action Pursuant to 18 U.S.C. 6 2255
August 2005 — Incident 1
597. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
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598. On or about August 2005, 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.
599. 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
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injuries are permanent in nature and the plaintiff, L.M., will continue to suffer these
losses in the future.
600. 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 146
Cause of Action Pursuant to 18 U.S.C. L2255
August 2005 — Incident 2
601. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
602. On or about August 2005, 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.
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2'? of 234
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603. 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.
604. 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 147
Cause of Action Pursuant to 18 U.S.C. § 2255
August 2005 — Incident 3
605. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
606. On or about August 2005, the exact date being unknown to L.M.,
Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a
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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.
607. 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.
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119 of 134
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608. 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 148
Cause of Action Pursuant to 18 U.S.C. 4 2255
August 2005 — Incident 4
609. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
610. On or about August 2005, 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.
611. 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 221 of 234
220.0124
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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.
612. 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 149
Cause of Action Pursuant to 18 U.S.C. 6 2255
September 2005 — Incident 1
613. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
614. On or about September 2005, 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
Page 222 of 234
111 a114
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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.
615. 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.
616. Wherefore, the plaintiff, L.M., demands judgments against the defendant,
Jeffrey Epstein, for compensatory damages of at least the minimum amount provided
Page 223 of 234
222 of 234
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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 10
Cause of Action Pursuant to 18 U.S.C. 4 2255
September 2005 - Incident 2
617. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.
618. On or about September 2005, the exact date being unknown to L.M.,
Defendant, Jeffrey Epstein, com
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