📄 Extracted Text (21,775 words)
Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 1 of 91
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80811-CIV-MARRNJOHNSON
C.M.A.,
Plaintiff(s),
vs.
JEFFREY EPSTEIN and
Defendant(s).
FIRST AMENDED COMPLAINT
Parties, Jurisdiction and Venue
COMES NOW the Plaintiff, C.M.A., and brings this First Amended Complaint
against the Defendants, JEFFREY EPSTEIN and SARAH KELLEN, and states as
follows:
1. This is an action for damages in excess of $75,000.00, exclusive of
interest and costs.
2. This Complaint is brought under a fictitious name in order to protect the
identity of the Plaintiff, C.M.A., because this Complaint makes allegation of sexual
assault and child abuse of a then minor.
3. At all times material to this cause of action, the Plaintiff, C.M.A., was a
resident of Palm Beach County, Florida.
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
4. At all times material to this cause of action, the Defendant, JEFFREY
EPSTEIN, had a residence located in Palm Beach County, Florida.
5. At all times material to this cause of action, the Defendant, JEFFREY
EPSTEIN, was an adult male, born in 1953.
6. This Court has jurisdiction of this action and the claim set forth herein
pursuant to 18 U.S.C. §2255.
7. 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.
8. At all times material, the Defendant, JEFFREY EPSTEIN, owed a duty
unto Plaintiff, C.M.A., to treat her in a non-negligent manner and to not commit
intentional or tortious illegal acts against her.
Factual Allegations
9. 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
minor girls, such as Plaintiff, C.M.A., sexually assaulted these girls, and/or coerced
them to engage in prostitution, and in return gave these girls money.
10. The Defendant's plan, scheme and enterprise included an elaborate
system wherein the then minor Plaintiff and other minor girls were brought to the
2
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
Defendant, JEFFREY EPSTEIN'S, residence by the Defendant's employees and
assistants. When the employees and assistants 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
He would then perform one or more lewd, lascivious, and
sexual acts, including, but not limited to, touching of the then minor
Plaintiff's and solicitation and enticement of the then minor Plaintiff
to engage in MEIMII MMII in JEFFREY EPSTEIN'S presence.
11. The Plaintiff, C.M.A., was the first brought to the Defendant, JEFFREY
EPSTEIN'S, mansion in late May or early June of 2002, when she was fifteen-years old
and in middle school.
12. The Defendant, JEFFREY EPSTEIN, a wealthy financier with a lavish
home, significant wealth, 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.
13. Beginning in approximately late May or early June of 2002, and continuing
until approximately August of 2003, the Defendant coerced and enticed the
impressionable, vulnerable, and economically deprived then minor Plaintiff to commit
various acts of sexual misconduct. These acts occurred, on average, one to three times
per week from late May or early June of 2002 until August of 2003. At a bare minimum,
3
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
these acts occurred twice a month from June 2002 until August of 2003. While the
precise dates these acts occurred are unknown to Plaintiff, including those weeks in
which no acts occurred, these dates are known by Defendant, JEFFREY EPSTEIN, as
he is reported to have kept a written log of each and every instance in which he
engaged in these illegal acts with the then minor Plaintiff, C.M.A. and others. These
acts included, but were not limited to, fondling and inappropriate and illegal sexual
touching of the then minor Plaintiff, sexual misconduct and of the
Defendant, JEFFREY EPSTEIN, in the presence of the then minor Plaintiff,
he then minor Plaintiff to n
JEFFREY EPSTEIN'S presence, 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 purpose of
prostitution, and lewd and lascivious assaults upon the person of the then minor
Plaintiff.
14. Defendant, JEFFREY EPSTEIN, used his money, wealth and power to
unduly and improperly manipulate and influence the then minor Plaintiff.
15. The acts referenced in paragraphs 9 through 14, committed by Defendant,
JEFFREY EPSTEIN, against the then minor Plaintiff, C.M.A., were committed in
violation of numerous criminal State and Federal statutes condemning the sexual
4
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
exploitation of minor children, prostitution, sexual performance by a child, lewd and
lascivious assaults, sexual battery, contributing 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 Federal Codes, as well as those designated in Florida Statutes §796.03, §796.07,
§796.045, §796.04, §39.01; and §827.04.
16. 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, C.M.A.'s minority.
17. 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 purpose of prostitution.
18. 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
5
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
Federal Government to the following: "Any person, who while a minor, was a victim of
an offense enumerated in Title 18, United States Code, Section 2255, will have the
same rights to proceed under section 2255 as she would have had, if Mr. Epstein had
been tried federally and convicted of an enumerated offense. For purposes of
implementing this paragraph, the United States shall provide Mr. Epstein's attorneys
with a list of individuals whom it was prepared to name in an indictment as victims of an
enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision,
including any authority determining evidentiary burdens if any a Plaintiff must meet,
shall consider that it is the intent of the parties to place these identified victims in the
same position as they would have been had Mr. Epstein been convicted at trial. No
more; no less".
19. 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, C.M.A.
COUNT I
Cause of Action Pursuant to 18 USC 42255
May/June 2002
20. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
above.
6
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRNJOHNSON
First Amended Complaint
21. In late May or early June of 2002, C.M.A. was first introduced to
Defendant, JEFFREY EPSTEIN. C.M.A. was brought to JEFFREY EPSTEIN'S
residence by a female friend of hers. C.M.A. sat on the couch while the female friend
took off her own clothes, mounted JEFFREY EPSTEIN who was wearing only a towel
and lying on a table, and performed a sexual act upon JEFFREY EPSTEIN in the
presence of C.M.A. In exchange for her participation as an observer of JEFFREY
EPSTEIN'S lewd and lascivious conduct, C.M.A. was paid $300 by JEFFREY
EPSTEIN.
22. 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 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
7
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
the same position as they would have been had Mr. Epstein been convicted at trial. No
more; no less."
23. The Plaintiff, C.M.A., 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.
24. 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, C.M.A., and as such he must effectively admit liability unto the
Plaintiff, C.M.A.
25. 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,
C.M.A., 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 psychological expenses and the Plaintiff, C.M.A., will in
the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
8
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARFtA/JOHNSON
First Amended Complaint
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, C.M.A., will continue to suffer these losses in the future.
WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
provided by law, punitive damages, 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 II
Cause of Action Pursuant to 18 USC 42255
June 2002- Incident 2
26. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
above.
27. Approximately one week after the first incident, C.M.A. received a
telephone call from JEFFREY EPSTEIN requesting that she return to his residence. On
this occasion, JEFFREY EPSTEIN directed C.M.A to and
Nand to provide him with a massage. At the conclusion of the massage,
JEFFREY EPSTEIN IIIIIIIIIIIIIIIIIhimself in C.M.A.'s presence. JEFFREY EPSTEIN
paid C.M.A. $300 for this encounter.
9
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
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 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, C.M.A., 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.
10
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
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, C.M.A., and as such he must effectively admit liability unto the
Plaintiff, C.M.A.
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,
C.M.A., 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 psychological expenses and the Plaintiff, C.M.A., will in
the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
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, C.M.A., will continue to suffer these losses in the future.
WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
provided by law, punitive damages, attorney's fees, costs, and such other and further
11
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
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
Cause of Action Pursuant to 18 USC ✓12255
July. 2002 — Incident 1
32. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
above.
33. In July of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence
at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to undress to her
underwear and to provide him with a massage. At the conclusion of the massage,
JEFFREY EPSTEIN himself in C.M.A.'s presence. JEFFREY EPSTEIN
paid C.M.A. in excess of $200 for this encounter.
34. 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 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
12
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
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."
35. The Plaintiff, C.M.A., 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.
36. 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, C.M.A., and as such he must effectively admit liability unto the
Plaintiff, C.M.A.
37. 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,
C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
suffering, emotional distress, psychological trauma, mental anguish, humiliation,
13
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
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, C.M.A., will in
the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
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, C.M.A., will continue to suffer these losses in the future.
WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
provided by law, punitive damages, 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 IV
Cause of Action Pursuant to 18 USC 42255
July 2002 — Incident 2
14
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
38. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
above.
39. For the second time in July of 2002, C.M.A. again returned to JEFFREY
EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed
C.M.A to a and to provide him with a massage. Defendant, JEFFREY
EPSTEIN, of the then minor C.M.A. At the conclusion
of the massage, JEFFREY EPSTEIN himself in C.M.A.'s presence.
JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
40. 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 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
15
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
the same position as they would have been had Mr. Epstein been convicted at trial. No
more; no less."
41. The Plaintiff, C.M.A., 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.
42. 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, C.M.A., and as such he must effectively admit liability unto the
Plaintiff, C.M.A.
43. 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,
C.M.A., 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 psychological expenses and the Plaintiff, C.M.A., will in
the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
16
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
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, C.M.A., will continue to suffer these losses in the future.
WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
provided by law, punitive damages, 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 V
Cause of Action Pursuant to 18 USC 42255
August of 2002 — Incident 1
44. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
above.
45. In August of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S
residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to ■
end to provide him with a massage. Defendant, JEFFREY EPSTEIN,
of the then minor C.M.A. At the conclusion of the massage,
JEFFREY EPSTEIN himself in C.M.A.'s presence. JEFFREY EPSTEIN
paid C.M.A. in excess of $200 for this encounter.
17
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
criminal plea, and
46. As a condition of the Defendant, JEFFREY EPSTEIN's
g the Defendant for numerous
in exchange for the Federal Government not prosecutin
additionally entered into an
federal offenses, the Defendant, JEFFREY EPSTEIN,
ing: "Any person, who while a
agreement with the Federal Government to the follow
18, United States Code, Section
minor, was a victim of an offense enumerated in Title
n 2255 as she would have had,
2255, will have the same rights to proceed under sectio
of an enumerated offense. For
if Mr. Epstein had been tried federally and convicted
s shall provide Mr. Epstein's
purposes of implementing this paragraph, the United State
red to name in an indictment as
attorneys with a list of individuals whom it was prepa
judicial authority interpreting this
victims of an enumerated offense by Mr. Epstein. Any
burdens if any a Plaintiff must
provision, including any authority determining evidentiary
place these identified victims in
meet, shall consider that it is the intent of the parties to
in been convicted at trial. No
the same position as they would have been had Mr. Epste
more; no less."
ses enumerated in
47. The Plaintiff, C.M.A., was a victim of one or more offen
such asserts a cause of action
Title 18, United States Code, Section 2255, and as
to this Section of the United
against the Defendant, JEFFREY EPSTEIN, pursuant
t, JEFFREY EPSTEIN, and the
States Code and the agreement between the Defendan
United States Government.
18
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C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
48. 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, C.M.A., and as such he must effectively admit liability unto the
Plaintiff, C.M.A.
49. 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,
C.M.A., 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 psychological expenses and the Plaintiff, C.M.A., will in
the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
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, C.M.A., will continue to suffer these losses in the future.
WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
provided by law, punitive damages, attorney's fees, costs, and such other and further
19
EFTA00201316
Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 20 of 91
C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
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 VI
Cause of Action Pursuant to 18 USC §2255
August of 2002 — Incident 2
50. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
above.
51. For the second time in August of 2002, C.M.A. again returned to
JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN
directed C.M.A to . Defendant,
JEFFREY EPSTEIN, of the then minor C.M.A. At the
conclusion of the massage, JEFFREY EPSTEIN allellina himself in C.M.A.'s
presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
52. 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 Title 18, United States Code, Section
2255, will have the same rights to proceed under section 2255 as she would have had,
20
EFTA00201317
Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 21 of 91
C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
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."
53. The Plaintiff, C.M.A., 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.
54. 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, C.M.A., and as such he must effectively admit liability unto the
Plaintiff, C.M.A.
55. 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,
C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and
21
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Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 22 of 91
C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
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, C.M.A., will in
the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
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, C.M.A., will continue to suffer these losses in the future.
WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
provided by law, punitive damages, 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 VII
Cause of Action Pursuant to 18 USC §2255
September of 2002 — Incident 1
56. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
above.
22
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Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 23 of 91
C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
57. In September of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S
residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully
and to provide him with a massage. Defendant, JEFFREY EPSTEIN,
of the then minor C.M.A. At the conclusion of the massage,
JEFFREY EPSTEIN himself in C.M.A.'s presence. JEFFREY EPSTEIN
paid C.M.A. in excess of $200 for this encounter.
58. 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 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."
23
EFTA00201320
Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 24 of 91
C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
59. The Plaintiff, C.M.A., 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.
60. 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, C.M.A., and as such he must effectively admit liability unto the
Plaintiff, C.M.A.
61. 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,
C.M.A., 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 psychological expenses and the Plaintiff, C.M.A., will in
the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A.,
has suffered a loss of income, a loss of the capacity to earn income in the future, and a
24
EFTA00201321
Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 25 of 91
C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
loss of the capacity to enjoy life. These injuries are permanent in nature and the
Plaintiff, C.M.A., will continue to suffer these losses in the future.
WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant,
JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount
provided by law, punitive damages, 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 VIII
Cause of Action Pursuant to 18 USC 42255
September of 2002 — Incident 2
62. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19
above.
63. For the second time in September of 2002, C.M.A. again returned to
JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN
directed C.M.A to and to provide him with a massage. Defendant,
JEFFREY EPSTEIN, of the then minor C.M.A. At the
conclusion of the massage, JEFFREY EPSTEIN himself in C.M.A.'s
presence. JEFFREY EPSTEIN paid C.M.A. in excess of $200 for this encounter.
25
EFTA00201322
Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 26 of 91
C.M.A. vs. Epstein, et al.
Case No.: 08-CV-80811-CIV-MARRA/JOHNSON
First Amended Complaint
64. 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 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 interpretin
ℹ️ Document Details
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bd0670456a727b60de5befd2dbc0923fbf18cf366d4d8216b448eed0db9b22e3
Bates Number
EFTA00201298
Dataset
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document
Pages
91
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