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+**CIVIL RICO CASE STATEMENT
+PURSUANT TO LOCAL RULE 12.1**
+1. 1. Plaintiff M.J. alleges a violation of Florida Statutes §§ 772.103(3) (participation in an enterprise through a criminal activity) and 772.103(4) (conspiracy to do so). The following information describes both the § 772.103(3) claim and the § 772.103(4) conspiracy claim, with the additional note that the conspiracy was between defendant Jeffrey Epstein, [REDACTED], [REDACTED], Ghislaine Maxwell, Jean Luc Brunel and other persons whose identity is, at this time, unknown to M.J.. Epstein, [REDACTED], [REDACTED] and others all conspired together to violate the provisions of § 772.103(3), doing so willfully and with full knowledge of the criminal activities that were planned as part of the criminal enterprise. For convenience in this statement, Florida Statutes §§ 772.103(3) and (4) will be referred to as the “Florida Civil RICO provisions.”
+2. 2. Epstein served as the leader, boss, and “C.E.O.” of the criminal enterprise. He also criminally sexually abused and prostituted M.J. and other minor girls who were victims of the criminal enterprise. He also paid for [REDACTED] and [REDACTED] and numerous other associates to be a part of the enterprise and conspired with them to commit criminal acts of sexual abuse and prostitution of minors. The basis for Epstein’s liability is also described in M.J.’s complaint.
+3. 3. The other wrongdoers and criminal participants included [REDACTED], Ghislaine Maxwell, and Jean Luc Brunel. (M.J. is uncertain as to the precise spelling of their names and their full legal names.) They assisted defendant Jeffrey Epstein in recruiting and procuring minor girls to satisfy Epstein’s criminal sexual purposes and for prostitution, as described in MJ’s complaint, and to satisfy their own sexual interests. For example, to further the interests of the local Palm Beach chapter of this expansive criminal enterprise they helped to arrange for minor girls to travel to Epstein’s West Palm Beach mansion to satisfy his sexual desires for minor girls. [REDACTED], [REDACTED] and many others also conspired with Epstein to commit acts of sexual abuse and prostitution with minor girls and aided and abetted Epstein in the abuse and prostitution. [REDACTED], [REDACTED] and other members of this criminal organization had full knowledge of the crimes of the enterprise; they knew full well that the girls who were coming to Epstein’s mansion were minors and that Epstein was sexually abusing and prostituting these minors, some of whom were as young as 12. [REDACTED] and [REDACTED] willfully and knowingly participated in the activities of the enterprise and intended to make the criminal activities of the enterprise succeed. Among other things, [REDACTED] helped arrange for recruiters of the minor girls. She also spoke personally to the recruiters as well as to the minor girls who were victims of Epstein’s sexual abuse. At Epstein’s specific direction, [REDACTED] spoke to the recruiters about subjects such as finding more minor girls to satisfy Epstein’s criminal sexual appetite. [REDACTED] also served as Epstein’s scheduler, scheduling appointments for the minor girls to ostensibly do “work” when in fact (as she well knew) she was scheduling them to be sexually abused and prostituted by Epstein. [REDACTED] thus procured minor girls for prostitution and caused them to be prostituted and the term “work” was a code or slang word used by the various criminal enterprise members to avoid detection by law enforcement. [REDACTED], who is known to be Epstein’s bisexual sex slave, also directly participated in the sexual abuse of the minor girls by participating in unlawful sexual activities and prostitution with the girls. Both [REDACTED] and [REDACTED] assisted Epstein in attempting to keep Epstein’s criminal sexual abuse unknown
+to law enforcement and other authorities and in discouraging the minor girls from reporting the crimes to law enforcement and other authorities. Maxwell and Brunel participated by helping to create the impression that the girls would be going to meet with Epstein for legitimate “modeling” purposes. Maxwell and Brunel specifically intended to have Epstein abuse the girls and acted with full awareness of Epstein’s intentions. Both Brunel and Maxwell recruited minor females for Epstein as well as for themselves in an effort to further the goals of the criminal organization – to sexually abuse and molest underage minor females and avoid detection of law enforcement. Brunel used his modeling agency to locate underage girls for Epstein and others to sexually abuse. Maxwell personally brought underage girls to Epstein for him to sexually abuse, she also presented him with underage girls for him to maintain as sex slaves and to travel the globe with him and others, prostituting underage sex slaves to others. Maxwell was also a participant in sexually abusing minor females. Maxwell served many additional purposes for the criminal organization and was highly ranked within the organization, thus she was able to act on her own accord, without needing orders from Epstein. Maxwell’s roles and actions on behalf of the criminal enterprise have included but not been limited to: procuring minor females for her and Epstein and others to sexually abuse, hiring personnel to work for Epstein and for the various positions in the criminal organization, developing relationships with politically connected individuals to protect the organization, managing and organizing the records of the enterprise, maintaining computer records and images of underage minor females with their names and phone numbers, threatening witnesses who have information that could hurt the enterprise, and assisting Epstein and other members of the criminal enterprise to continue the criminal activity of the organization and avoid law enforcement detection or prosecution.
+1. 4. The names of all of the victims are unknown to the plaintiff at this time. However, they include M.J. herself as well as the victims in the multitude of other civil cases, both filed and unfiled, against Epstein. A list of more than 30 such minor female victims was previously provided by the U.S. Attorney’s Office for the Southern District of Florida to Epstein (but not to M.J.). The injuries to those victims resulted from criminal sexual activity and prostitution with Epstein and [REDACTED] and at times Maxwell. The injuries they suffered are like those suffered by M.J. in this action, as described in her complaint. For example, M.J. and the other victims suffered grave emotional distress and financial injury from being forced to engage in unlawful sexual activities with him to which, as minors, they could not lawfully consent, and from being introduced into a deviant sexual lifestyle. They also suffered distress and financial injury from being prostituted by him.
+2. 5. The pattern of racketeering and/or criminal activity is also described in the complaint, which M.J. incorporates by reference into this statement here and at all other points in the statement. The criminal activity included Epstein using paid employees and underlings (including [REDACTED] and [REDACTED]) to repeatedly find, procure, and bring to him minor girls in order for Epstein to solicit, induce, coerce, entice, compel or force these minor girls to engage in unlawful sexual activity and acts of prostitution and Epstein using Ghislaine Maxwell and Jean Luc Brunel and others yet unnamed to create the impression that he was involved in legitimate modeling and other activities.
+   1. a. The criminal activity and specific statutes violated are listed in the complaint and include, but are not necessarily limited to: (i) procuring for prostitution, or causing to be prostituted, minors, in violation of Florida Statutes Chapter 796; (ii) acts of battery in violation of Florida Statutes Chapter 784; (iii) commercial sexual exploitation of a
+child in violation of Florida Statutes § 827.071; and (iv) tampering with a witness in violation of Florida Statutes § 914.22. The criminal activities also include violations of federal criminal statutes, including sexual trafficking of children by fraud, in violation of 18 U.S.C. § 1591, use of a means of interstate commerce to entice a minor to commit prostitution, in violation of 18 U.S.C. § 2422, as well as wire fraud, in violation of 18 U.S.C. § 1343.
+- b. The dates of the events are not fully known to M.J. at this time. However, at a minimum, Epstein obtained minor girls (including M.J.) for sexual purposes of the period of approximately 1998 through November 2005. Epstein could better determine than M.J. the precise dates of his abuse of her by reviewing his schedule or computer records for this period of time and looking for notations of days on which she performed “work” for him. Epstein has pled guilty to two such criminal offenses against minor girls, although the total number of indictable or chargeable offenses would easily number more than 1000. On each of these occasions, as described in the complaint, Epstein would have his underlings, co-conspirators or associates (including [REDACTED]) procure a minor girl to satisfy his sexual desires and then would satisfy his sexual desires through criminal sexual contact with the minor girls. Epstein would also watch [REDACTED] or Maxwell sexually abuse the minor girls to satisfy his sexual desires. Epstein had a particular interest in minor girls, including girls as young as 12. On occasion, he would turn away girls who were 18 or over because of his perverse and unlawful sexual interest in young girls. Epstein recruited and paid the girls for the sexual activities. In doing so, he procured for prostitution, and caused to be prostituted, many young girls under the age of 18, in violation of (among other statutes) Florida Statute § 796.03. The pattern of criminal and unlawful sexual activity extended from at least 1998 through November 2005 and upon information and belief actually existed and operated in a criminal organizational structure for many years prior to 1998. Epstein committed unlawful sexual abuse against M.J. at least 20 times between Summer of 2002 to Spring 2004 while she was a minor. Other criminal activities involving tampering with and harassing witnesses occurred from June 2002 through early 2008 (and perhaps later).
+- c. On many of the occasions, the exact dates of which are not as yet determined by the M.J., Epstein would represent that he was interested in a “massage” or legitimate “work” when in fact he was interested in unlawful sexual activity with the minor girls, including fondling the girls, masturbating in their presence, and vaginally penetrating them or causing them to be penetrated. Epstein and others acting under his direction falsely represented to the minor girls that he was interested in a “massage” or “work” when in fact he was interested in procuring the girls for unlawful sexual activity and acts of prostitution. Epstein and others acting under his direction used means of interstate communications to make these false representations, including cellular telephones. Similar to all known crime families or criminal organizations that operate to commit crimes, this criminal enterprise made use of seemingly innocuous code words such as “message” and “work” to describe the continuous criminal activity of procuring underage girls to sexually molest, abuse and exploit.
+- d. Epstein has pled guilty to two Florida felony criminal offenses against minor girls, as alleged in the complaint and Epstein is a Registered Sexual Offender for life.
+e. The relationship of the criminal activity to the enterprise is also described in the complaint. The Florida offenses to which Epstein pled guilty are but a few of the many instances of his plan succeeding. The acts are all related to each other, are arranged, and are part of common plan for these reasons: they have the same intent (to gratify Epstein's unlawful sexual interest in minor girls as well as to gratify the unlawful sexual interests in minor girls of others at times); the same results (the unlawful sexual abuse and prostitution of minor girls); the same accomplices (including [REDACTED] and frequently [REDACTED], Maxwell, and Brunel); the same victims (M.J. was herself victimized more than 20 times, and many other girls were also victimized repeatedly); the same means (there was a standard payment of several hundred dollars for going to the mansion, and standard escalation feature depending on the nature of the sexual acts that Epstein performed); the same methods of commission (Epstein obtained young, skinny, and attractive girls to satisfy his sexual desires while they were economically disadvantaged and lacked a stable family life and therefore, he perceived, would be interested in obtaining money and unlikely to report his crimes to law enforcement); and the same frequency (remarkably Epstein's criminal enterprise operated constantly to procure underage minor females to be sexually abused by Epstein every single day, oftentimes 2 or 3 different underage females in a single day). The acts were also interrelated by common characteristics, namely the identity of the perpetrator (Epstein and often [REDACTED] or sometimes Maxwell) and the common results of his crimes (sexual abuse and acts of prostitution with minor girls). The acts also constituted a clear pattern of criminal activity, including giving the impression to the girls who were being recruited that they would have legitimate modeling opportunities.
+6. The criminal acts of Epstein occurred repeatedly over a substantial period of time and were not isolated events. In particular, Epstein committed repeated (more than 20) criminal acts of sexual abuse against M.J. from approximately Summer 2002 to Spring 2004. He committed similar criminal acts of unlawful sexual activity and prostitution against other minor girls for a period of time from at least 1998 to November 2005. The acts occurred frequently during this time, so frequently that it is impossible to calculate how many different illegal sexual acts were committed by Epstein and his criminal enterprise, but it is fair to say that serious felonies were committed by this criminal organization on an everyday basis. The acts were part of Epstein's regular way of doing business (e.g., obtaining sexual gratification from minors) during this period of time. Epstein and others acting at his direction (including [REDACTED]) made hundreds of telephone calls in furtherance of these illegal activities. The sexual acts against minors may have temporarily ceased in approximately November 2005 when Epstein learned that law enforcement authorities were investigating his crimes. Given Epstein's long history of sexually abusing minors and the frequency at which he has done so and the fact that despite his arrest and jail sentence his criminal organization remains intact, it is highly likely that he will continue his sexual desires for minor girls. In addition, Epstein committed criminal acts of tampering with witnesses in violation of Florida Statutes § 914.22. For example, Epstein paid the minor girls money not only with the intent to prostitute them but also with the specific intent of causing the minor girls not to communicate to law enforcement officers information about the sexual abuse committed against them. Epstein made bigger payments to the minor girls depending on the degree of force he used towards them, making larger payments when he was more concerned about the
+fact they might report the crimes committed against them. Without specifically detailing acts committed against certain known minors, Epstein has paid \$1000 on occasion after forcibly holding the head of a minor down and pumping his penis inside her against her will. Epstein has also intimidated and reprimanded his co-conspirators and associates for any cooperating with law enforcement and has made it known that his associates must stay loyal to the criminal enterprise above all else. These obstructions may interfere with the ability of law enforcement to discover and prosecute all of Epstein's crimes. They may likewise interfere with the ability of M.J. to discover all of the information supporting her claim. Epstein also selected impoverished girls for his crimes, believing that the payments would be more effective in obtaining their silence and that their economic circumstances might make them less likely to report to law enforcement. If all else failed, after having unlawful sex with the minor girls, Epstein would tell them not to tell anyone about their unlawful encounter or "bad things" would happen. In addition, since November 2005 and through the early part of 2008 (and perhaps later), Epstein and others acting at his direction have attempted to discourage the victims of his crimes from reporting his crimes and cooperating with law enforcement. For example, persons acting at the direction of Epstein have aggressively attempted to "interview" the victims or to "tail" the victims in their cars. They also harassed a victim shortly before she was to testify at a grand jury investigating Epstein and aggressively intimidated a victim to scare her away from proceeding to trial against him. These efforts have been made not for legitimate investigative reasons but rather for the purpose of discouraging the victims from cooperating with law enforcement (and, in at least one case, the investigating grand jury) and from filing civil lawsuits to vindicate their rights.
+7. The enterprise is also described in the complaint, which allegations M.J. expressly incorporates into this statement as part of the description of the enterprise. The enterprise included, at a minimum, a group of individuals associated in fact to assist Epstein in recruiting and procuring minor girls and obtaining criminal gratification of his illegal sexual interest in minor girls and at least two individuals (Ghislaine Maxwell and Jean Luc Brunel) who were free to act independently and advance their own interests, including their own sexual interests.
+1. a. The persons constituting the enterprise included a group of individuals associated in fact. These individuals include Epstein, [REDACTED], [REDACTED], Ghislaine Maxwell, and Jean Luc Brunel, as well as other yet unnamed persons whose names M.J. intends to identify during the discovery phase of this case.
+2. b. The criminal enterprise had a definite hierarchal structure, although all the details of that structure are not completely known to M.J.. Through discovery, M.J. intends to ascertain the precise structure of the enterprise that enabled Epstein to commit sexual crimes against here. While M.J. does not currently know all of the details of the structure, she does know that the enterprise operated together on a continuing basis, in an extremely efficient and organized manner, with largely the same personnel for a common purpose. The shared purpose of the enterprise was to satisfy Epstein's, as well as certain other individual's, illegal interest in having sexual activities with minor girls as well. The enterprise was not a mere informal conspiracy, but had a definite clear structure. Epstein served effectively as the leader, C.E.O. or "Boss" of this organization, directing his various levels of underlings how to recruit and procure young girls for his sexual activities and when to bring the girls to his mansion as well as how to avoid law enforcement
+detection. Epstein's key "lieutenant" in the Palm Beach branch of this national and possibly international organization was [REDACTED], who served as both his scheduler and a recruiter/procurer of the girls. This was an important function, as the recruiting was necessary to satisfy Epstein's desire to abuse a large number of different minor girls with different (albeit similar) physical attributes and the scheduling was necessary to insure that the minor girls would be brought to Epstein's mansion to be sexually abused and prostituted at a time when Epstein was there (but not at the same time, when they might learn of other girls' identities and possibly become emboldened to report his activities to law enforcement.) Scheduling was also necessary to ensure secrecy, so that as few persons as possible were aware that minor girls were coming at unusual hours to Epstein's mansion. [REDACTED] also needed (directly or indirectly) to make transportation arrangements for many of the girls, as they were often too young to drive themselves to and from the mansion. [REDACTED] also served as a recruiter and helped Epstein satisfy his criminal sexual desires by, on occasion, directly participating in sexual abuse and prostitution of the minor girls. Epstein, [REDACTED], and [REDACTED] all took steps to conceal the existence of the enterprise and to discourage the girls from reporting the sexual abuse and prostitution to law enforcement or other authority figures. Epstein also used otherwise-legitimate business activities to help further the purpose of the criminal enterprise. These apparently legitimate activities provided "cover" for Epstein and his associates to commit the crimes. Ghislaine Maxwell and Jean Luc Brunel also helped to provide "cover" for the enterprise by creating the impression that there were legitimate modeling opportunities and other legitimate opportunities available for the girls if they went to see Epstein. Epstein also maintained the appearance of an extremely wealthy, upstanding and prominent figure to discourage the minor girls from reporting the abuse to law enforcement. To further impress the underage minor victims, he would tell them that he was a famous scientist, a brain surgeon, an inventor of various products including a state of the art liposuction device. He would also brag about the famous people with whom he was good friends. By projecting an image of financial power (and, relatedly, strong political connections to prominent politicians and current and former government officials and personal connections to prominent scientists), Epstein hoped to discourage the minor girls from reporting what he was doing to them by making it appear that they would not be believed. These business activities helped Epstein secure the financial resources to commit the crimes against the minor girls and to pay for prostituting them. For example, the activities paid for maintaining the mansion where the girls were abused and paid for the cellular telephones and other means of communications that were used to recruit and procure the girls. The business activities also helped to provide the funds to pay [REDACTED] and [REDACTED] large sums of money to participate in the illegal enterprise and make payments to the girls for performing sexual acts. In sum, Epstein and the persons under his direction associated in fact and functioned as a continuing unit. This enterprise produced a course of conduct that lead to a pattern of criminal activity involving more than 100 instances of sexual abuse and prostitution of minor girls. This enterprise was the vehicle for Epstein to commit his crimes against M.J. and other
+minor girls and operated on a continuing basis from June 2002 to November 2005 (and, in regard to witness tampering and harassment, through at least early 2008). The enterprise enabled Epstein to sexually abuse and prostitute M.J. in particular on more than 20 occasions from February 2003 through June 2005.
+- c. Epstein served as the effective leader or "C.E.O." of the enterprise.
+- d. Epstein was associated with the enterprise as its effective leader or "C.E.O."
+- e. Epstein directed the affairs of the enterprise and the others in the enterprise responded to his commands, although Ghislaine Maxwell and Jean Luc Brunel acted independently to advance their own interests (including sexual interests) along with the interests of Epstein.
+- f. Based on the facts that she currently possesses, M.J. specifically alleges and intends to prove both that (i) Epstein was an individual separate and disctinct from the enterprise and (ii) the defendant was a member of the enterprise, namely that he served as the effective leader of the enterprise. With regard to point (i), the illegal enterprise had a definite structure and operational function apart from Epstein. The structure is described in greater detail in this statement in answer 5.b above. With regard to point (ii), the defendant was a member of the enterprise and served to execute many of the decisions and activities of the enterprise and to command the execution of others. Epstein personally engaged in sexual abuse of minor girls, including M.J.. Epstein also directed others to engage in sexual abuse of minor girls, including [REDACTED]. Epstein also procured girls for prostitution and caused these girls to be prostituted. Epstein also served as the leader of the enterprise.
+- g. Epstein was a direct perpetrator of the racketeering activity. In particular, Epstein engaged in criminal acts of sexual abuse and prostitution with minor girls, as well as procuring girls for prostitution. He also directed others (i.e., [REDACTED]) to engage in such criminal acts and served as the leader of the criminal enterprise.
+8. The relationship between the pattern of criminal activity and the enterprise is not completely known to M.J. at this time, and it is not known how much money or other consideration was generated by the enterprise through these illegal means. Through discovery, she intends to understand the relationship more fully. At this time, however, as described in addition in the complaint and parts 5, 6 and 7 in this statement, there was a criminal entity separate and apart from the pattern of activity in which it engaged. The pattern of criminal activity was the series of crimes committed by Epstein and others, and includes the specific crimes identified in part 5.a. above. These offenses were closely related and formed a clear pattern, as described in part 5.b above. These acts included acts of sexual abuse and procuring the prostitution of minors by Epstein personally and by [REDACTED] acting at Epstein's direction. In contrast, the enterprise was the group of persons who associated together for the common purpose of engaging in the criminal course of conduct described at greater length elsewhere in this statement, including part 5.e above. The group of persons included Epstein, [REDACTED], [REDACTED], Maxwell, and Brunel and others whose identity is, at this time, unknown to M.J..
+9. In this part of the statement, M.J. will provide a description of the relationship between the otherwise-lawful activities of the enterprise and the criminal activities of the enterprise. The lawful and unlawful activities of the enterprise have been described in addition in paragraphs 10 through 18 and 42 through 43 of the complaint and previous answers found in parts 5, 6
+and 7 above (which M.J. expressly incorporates into her answer here). The usual and daily activities of the criminal enterprise included scheduling meetings, activities, and other events for Epstein – including scheduling “private time” in his mansion for Epstein to commit sexual crimes against minor girls. ██████ served as Epstein’s scheduler, scheduling both otherwise-lawful activities to provide “cover” for Epstein as well as the illegal sexual activities. The exact frequency with which the sexual crimes took place varied and is not known, at this time, to M.J.. However, when Epstein was in West Palm Beach, it often occurred on a weekly or daily basis (and, in some instances, took place on several times during a single day). The scheduling was designed to secure a private place in Epstein’s mansion when few other persons would be present at the mansion, so as to reduce the chance of detection of Epstein’s sexual abuse and prostitution as well as to make it more difficult for the minor girls to report his actions to law enforcement or other authorities. The usual activities of the enterprise also included maintaining the mansion and securing means of communication (i.e., cellular telephones) to recruit minor girls and procure them for prostitution. The activities further included arranging transportation for the girls to and from the mansion if it was necessary. The enterprise also attempted to make Epstein appear to be an upstanding and law-abiding member of community and a successful businessperson, for reasons described in paragraph 6.b above. The enterprise served as the usual way in which Epstein would obtain sexual gratification.
+1. 10. Through his criminal enterprise, Epstein received perverse and unlawful sexual gratification from sexually abusing minor girls and engaging in acts of prostitution with them. He also received perverse sexual gratification from directing others (e.g., ██████) to sexually abuse and prostitute minor girls.
+2. 11. While M.J.’s civil action alleges violations of the Florida Civil RICO statute rather than violations of the federal civil RICO statute, it should be noted that means of interstate communications were used to perpetrate the crimes against minor girls (including M.J.), including cellular and other telephones that Epstein used, or caused to be used, to arrange his illegal sexual activities and to recruit additional minor girls to participate in these activities. Through his recruitment and procuring of young girls, Epstein’s activities directly affected interstate commerce.
+3. 12. Based on the information currently known to her, M.J. does not allege that Epstein, who is a billionaire banker, used the enterprise to personally make a financial profit or to obtain the collection of an unlawful debt, only because that information has not yet been made available to MJ. Epstein did, however, make payments to and prostitute the minor girls for the sexual gratification that he obtained from them and to discourage them from reporting his crimes to law enforcement and other authorities. Epstein also has, through his criminal organization, prostitutes underage girls to others, and Epstein and the criminal organization gained valuable consideration from that activity, although it is unknown the type and amount of remuneration at this time.
+4. 13. Based on the information currently known to her, M.J. does not allege that Epstein, who is a billionaire banker, used the enterprise to obtain or maintain control of a business enterprise or real property. Epstein did, however, use his West Palm Beach mansion (and his various other properties including his personal island) to perpetrate the crimes against the then-minor girls. He also used his financial success to provide “cover” for his crimes, as described in part 6.b above.
+5. 14. The criminal enterprise is described in the complaint and part 6 of this statement above,
+which description M.J. incorporates here.
+a. The enterprise including persons unknown to M.J., but at least included Epstein and his paid assistants [REDACTED] and [REDACTED] as well as associates of Epstein (who were free to act independently and to advance their own interests) Ghislaine Maxwell and Jean Luc Brunel
+b. Under the direction of Epstein, [REDACTED], [REDACTED] and others whose names are unknown to M.J. arranged for minor girls to come to Epstein's mansion where he could sexual abuse them and prostitute them to satisfy his perverse sexual desires, as well as the perverse sexual desires of Ghislaine Maxwell and Jean Luc Brunel. [REDACTED] and [REDACTED] were responsible for recruiting the girls and procuring them for prostitution. [REDACTED] was also responsible for scheduling a time when both Epstein and the minor girl could meet together at Epstein's mansion for the sexual abuse and for making travel arrangements (if necessary) for the girls. [REDACTED] was also responsible for ensuring the privacy of the room in Epstein's mansion where Epstein would sexually abuse the girls. [REDACTED] would participate in abusing and prostituting the girls for Epstein's sexual gratification. [REDACTED] and [REDACTED] received payments and other forms of compensation from Epstein for performing these illegal activities and for participating in the enterprise. Epstein, [REDACTED], and [REDACTED] also all took steps to discourage the girls from reporting these crimes to law enforcement, including making cash payments to the girls. Ghislaine Maxwell and Jean Luc Brunel helped to persuade the girls that legitimate modeling opportunities could be had if they went to see Epstein.
+c. As a result of the criminal enterprise, M.J. (then a minor) suffered criminal sexual abuse at the hands of Epstein. As alleged in greater detail in the complaint, this abuse lead to significant past and future physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of privacy, and other damages, including consequential damages from Epstein controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. In addition, the time involved in the abuse created lost opportunities to pursue other activities (including economic activities) and lead to past and future financial and proprietary losses to M.J., as well as the need for psychiatric services. M.J. has also suffered a loss of income, a loss of capacity to earn income in the future, and a loss of the capacity to enjoy life. It has also lead to the need to file this civil suit, with consequent attorney's fees. All of these damages were caused by, and proximately caused by, the criminal enterprise and its criminal acts. All of these injuries were inflicted directly on M.J. and occurred by reason of the criminal acts of the enterprise, including the acts of sexual abuse by Epstein.
+d. The defendant "person" in the Florida Civil RICO action is, at this time, only defendant Epstein. Defendant Epstein is associated with a criminal enterprise that conducted and participated, both directly and indirectly, in a pattern of criminal activity in violation of both Florida and federal criminal law. The exact relationship between Epstein and the criminal enterprise is described in greater detail in parts 5 and 6 above.
+15. The criminal conspiracy involving the enterprise is described in the complaint as well as parts 5, 6, and 7 above. M.J. expressly incorporates that information into her statement here. The conspiracy was formed of Epstein, [REDACTED], [REDACTED], and many others, who agreed to arrange for illegal sexual gratification by Epstein through the sexual abuse and prostitution of minor girls both by Epstein personally and by others (i.e., [REDACTED]) while he watched, as
+well as to provide illegal sexual gratification to Ghislaine Maxwell and Jean Luc Brunel. Certain other names of other criminal enterprise members and co-conspirators are known yet currently unnamed, and many other names are currently unknown but Plaintiff intends to learn the names and roles of all involved in the criminal activity of this enterprise. The many enterprise members conspired to commit similar crimes and to conceal those crimes also in furtherance of the criminal enterprise. The object and substance of the conspiracy was to obtain minor girls for Epstein so that he could satisfy his perverse sexual interest in minor girls, to recruit minor girls to be abused and prostituted for his gratification, to keep the existence of the sexual abuse from being learned by law enforcement and other authorities, and to discourage the victims from reporting the abuse to authorities, as well as to provide sexual gratification to Maxwell and Brunel. The conspiracy started in approximately June 2002 in West Palm Beach, Florida, and other locations. The sexual abuse of the minor girls appears to have, at least temporarily, ceased in approximately 2005. The conspiracy extended beyond November 2005 to early 2008 (and perhaps later) in its efforts to keep the criminal conspiracy unknown, as described in part 5.f above. The conspiracy committed numerous overt acts. For example, [REDACTED] and [REDACTED] arranged for minor girls to be brought to Epstein's West Palm Beach mansion so that he could sexually abuse the girls and obtain sexual gratification. Epstein sexually abused minor girls at his mansion and made payments to them and otherwise prostituted them there.
+1. 16. M.J. suffered injuries, including financial and proprietary injuries, as described in part 13.C above.
+2. 17. The enterprise injured M.J. and the other minor girls by enabling Epstein to sexually abuse and prostitute the girls.
+3. 18. Defendant Epstein is liable for all the damages for his criminal activity and the activity of his criminal enterprise. (If additional defendants are added to the complaint, these other defendants may also be jointly and severable liable for the damages.) The damages for which Epstein is liable include compensatory damages (including damages for emotional distress as well as damages for financial and proprietary losses), attorney's fees, and such further relief as the Court deems just and proper. The amount of these damages is significant. These damages are trebled by operation of Florida Statutes 772.104. M.J. is aware of the provision in Florida Statutes 772.104(3) ("In no event shall punitive damages be awarded under this section"), but is nonetheless entitled to punitive damages by virtue of her other counts in her complaint. She is seeking punitive damages for Epstein's outrageous and egregious conduct and crimes under other provisions of law in this lawsuit.
+4. 19. All of the above answers must be read in light of the complaint that has been filed in this case. M.J. expressly incorporates by reference her complaint as part of the answer to each of the above questions. Whenever the word "include" or its variations appears in this statement, the information that follows is not intended to be an exclusive listing.

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marker2/court-redacted-v-epstein-81111/EFTA02821002/EFTA02821002.md ADDED Viewed

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+The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) **NOTICE: Attorneys MUST Indicate All Re-filed Cases Below.**
+**I. (a) PLAINTIFFS**
+M.J.,
+**(b) County of Residence of First Listed Plaintiff Palm Beach County**
+(EXCEPT IN U.S. PLAINTIFF CASES)
+**(c) Attorney's (Firm Name, Address, and Telephone Number)**
+J [REDACTED]
+J. Jaffe, Weissing, [REDACTED]s, Fistos & Lehrman
+425 N. Andrews Avenue, Suite 2
+Fort Landerdale FI 33301
+**DEFENDANTS**
+JEFFREY EPSTEIN and [REDACTED]
+County of Residence of First Listed Defendant
+(IN U.S. PLAINTIFF CASES ONLY)
+NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT LAND INVOLVED.
+Attorneys (If Known)
+(4) Check County Where Action Arose:  MIAMI- DADE  MONROE  BROWARD  PALM BEACH  ST. LUCIE  INDIAN RIVER  OKEECHOBEE  HIGHLANDS
+**II. BASIS OF JURISDICTION**
+(Place an "X" in One Box Only)
+- 1 U.S. Government Plaintiff
+- 3 Federal Question (U.S. Government Not a Party)
+- 2 U.S. Government Defendant
+- 4 Diversity (Indicate Citizenship of Parties in Item III)
+**III. CITIZENSHIP OF PRINCIPAL PARTIES** (Place an "X" in One Box for Plaintiff and One Box for Defendant)
+| Citizen of This State | PTF                                 |     | PTF                                                           |                          |   |
+|-----------------------|-------------------------------------|-----|---------------------------------------------------------------|--------------------------|---|
+|                       | 1                                   | DEF | 1                                                             | DEF                      |   |
+|                       | <input checked="" type="checkbox"/> | 1   | Incorporated or Principal Place of Business In This State     | <input type="checkbox"/> | 4 |
+|                       | <input type="checkbox"/>            | 2   | Incorporated and Principal Place of Business In Another State | <input type="checkbox"/> | 5 |
+|                       | <input type="checkbox"/>            | 3   | Foreign Nation                                                | <input type="checkbox"/> | 6 |
+**IV. NATURE OF SUIT** (Place an "X" in One Box Only)
+| CONTRACT                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | TORTS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | PERSONAL INJURY                                                                                                                                                                                                                                                                                                                                                                                                                              | FORFEITURE/PENALTY                                                                                                                                                                                                                                                                                                                                                                                             | BANKRUPTCY                                                                                                                                                                                                                                                                                                                                                                | OTHER STATUTES                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
+|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
+| <input type="checkbox"/> 110 Insurance<br><input type="checkbox"/> 120 Marine<br><input type="checkbox"/> 130 [REDACTED] Act<br><input type="checkbox"/> 140 Negotiable Instrument<br><input type="checkbox"/> 150 Recovery of Overpayment & Enforcement of Judgment<br><input type="checkbox"/> 151 Medicare Act<br><input type="checkbox"/> 152 Recovery of Defaulted Student Loans (Excl. Veterans)<br><input type="checkbox"/> 153 Recovery of Overpayment of Veteran's Benefits<br><input type="checkbox"/> 160 Stockholders' Suits<br><input type="checkbox"/> 190 Other Contract<br><input type="checkbox"/> 195 Contract Product Liability<br><input type="checkbox"/> 196 Franchise | <input type="checkbox"/> 310 Airplane<br><input type="checkbox"/> 315 Airplane Product Liability<br><input type="checkbox"/> 320 Assault, Libel & Slander<br><input type="checkbox"/> 330 Federal Employers' Liability<br><input type="checkbox"/> 340 Marine<br><input type="checkbox"/> 345 Marine Product Liability<br><input type="checkbox"/> 350 Motor Vehicle<br><input type="checkbox"/> 355 Motor Vehicle Product Liability<br><input checked="" type="checkbox"/> 360 Other Personal Injury | <input type="checkbox"/> 362 Personal Injury - Med. Malpractice<br><input type="checkbox"/> 365 Personal Injury - Product Liability<br><input type="checkbox"/> 368 Asbestos Personal Injury Product Liability<br><input type="checkbox"/> 370 Other Fraud<br><input type="checkbox"/> 371 Truth in Lending<br><input type="checkbox"/> 380 Other Personal Property Damage<br><input type="checkbox"/> 385 Property Damage Product Liability | <input type="checkbox"/> 610 Agriculture<br><input type="checkbox"/> 620 Other Food & Drug<br><input type="checkbox"/> 625 Drug Related Seizure of Property 21 USC 881<br><input type="checkbox"/> 630 Liquor Laws<br><input type="checkbox"/> 640 R.R. & Truck<br><input type="checkbox"/> 650 Airline Regs.<br><input type="checkbox"/> 660 Occupational Safety/Health<br><input type="checkbox"/> 690 Other | <input type="checkbox"/> 422 Appeal 2X USC 158<br><input type="checkbox"/> 423 Withdrawal<br>28 USC 157<br><input type="checkbox"/> <b>PROPERTY RIGHTS</b><br><input type="checkbox"/> 820 Copyrights<br><input type="checkbox"/> 830 Patent<br><input type="checkbox"/> 840 Trademark                                                                                    | <input type="checkbox"/> 400 State Reapportionment<br><input type="checkbox"/> 410 Antitrust<br><input type="checkbox"/> 430 Banks and Banking<br><input type="checkbox"/> 450 Commerce<br><input type="checkbox"/> 460 Deportation<br><input type="checkbox"/> 470 Racketeer Influenced and, Corrupt Organizations<br><input type="checkbox"/> 480 Consumer Credit<br><input type="checkbox"/> 490 Cable Sat TV<br><input type="checkbox"/> 810 Selective Service<br><input type="checkbox"/> 850 Securities/Commodities Exchange<br><input type="checkbox"/> 875 Customer Challenge<br><input type="checkbox"/> 12 USC 3410<br><input type="checkbox"/> 890 Other Statutory Actions<br><input type="checkbox"/> 891 Agricultural Acts<br><input type="checkbox"/> 892 Economic Stabilization Act<br><input type="checkbox"/> 893 Environmental Matters<br><input type="checkbox"/> 894 Energy Allocation Act<br><input type="checkbox"/> 895 Freedom of Information Act<br><input type="checkbox"/> 900 Appeal of Fee Determination Under Equal Access to Justice<br><input type="checkbox"/> 950 Constitutionality of State Statutes |
+| REAL PROPERTY                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | CIVIL RIGHTS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | PRISONER PETITIONS                                                                                                                                                                                                                                                                                                                                                                                                                           | LABOR                                                                                                                                                                                                                                                                                                                                                                                                          | SOCIAL SECURITY                                                                                                                                                                                                                                                                                                                                                           | FEDERAL TAX SUITS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |
+| <input type="checkbox"/> 210 Land Condemnation<br><input type="checkbox"/> 220 Foreclosure<br><input type="checkbox"/> 230 Rent Lease & Ejectment<br><input type="checkbox"/> 240 Torts to Land<br><input type="checkbox"/> 245 Tort Product Liability<br><input type="checkbox"/> 290 All Other Real Property                                                                                                                                                                                                                                                                                                                                                                               | <input type="checkbox"/> 441 Voting<br><input type="checkbox"/> 442 Employment<br><input type="checkbox"/> 443 Housing: Accommodations<br><input type="checkbox"/> 444 Welfare<br><input type="checkbox"/> 445 Amer. w/Disabilities Employment<br><input type="checkbox"/> 446 Amer. w Disabilities Other                                                                                                                                                                                             | <input type="checkbox"/> 510 Motions to Vacate Sentence<br><input type="checkbox"/> 530 General<br><input type="checkbox"/> 535 Death Penalty<br><input type="checkbox"/> 540 Mandamus & Other<br><input type="checkbox"/> 550 Civil Rights<br><input type="checkbox"/> 555 Prison Condition                                                                                                                                                 | <input type="checkbox"/> 790 Other Labor Litigation<br><input type="checkbox"/> 791 Empl. Ret. Inc. Security Act<br><input type="checkbox"/> 462 Naturalization Application<br><input type="checkbox"/> 463 Habeas Corpus-Atien Detainee<br><input type="checkbox"/> 465 Other Immigration Actions                                                                                                             | <input type="checkbox"/> 861 HIA (1395ff)<br><input type="checkbox"/> 862 Black Lung (923)<br><input type="checkbox"/> 863 DIWC/DIWW (405(g))<br><input type="checkbox"/> 864 SSID Title XVI<br><input type="checkbox"/> 865 RSI (405(g))<br><input type="checkbox"/> 870 Taxes (U.S. Plaintiff or Defendant)<br><input type="checkbox"/> 871 IRS Third Party 26 USC 7609 | <input type="checkbox"/> 895 Economic Stabilization Act<br><input type="checkbox"/> 893 Environmental Matters<br><input type="checkbox"/> 895 Freedom of Information Act<br><input type="checkbox"/> 950 Constitutionality of State Statutes                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |
+**V. ORIGIN** (Place an "X" in One Box Only)
+ 1 Original Proceeding  2 Removed from State Court  3 Re-filed- (see VI below)  4 Reinstated or Reopened  5 Transferred from another district (specify)  6 Multidistrict Litigation  7 Appeal to District Judge from Magistrate Judgment
+**VI. RELATED/RE-FILED CASE(S).** (See instructions second page):
+ a) Re-filed Case  YES  NO b) Related Cases  YES  NO
+ JUDGE DOCKET NUMBER
+**VII. CAUSE OF ACTION** Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless diversity):
+ 18 USC 2255, Sexual exploitation of a minor
+ LENGTH OF TRIAL via \_\_\_\_ days estimated (for both sides to try entire case)
+**VIII. REQUESTED IN COMPLAINT:**  CHECK IF THIS IS A CLASS ACTION UNDER F.R.C.P. 23 **DEMAND \$** CHECK YES only if demanded in complaint:
+**JURY DEMAND:**  Yes  No
+**ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE** SIGNATURE OF ATTORNEY OF RECORD DATE 9-17-2010

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+At) 440 (Rev. 12/09) Summorts in a tivit Act am
+## UNITED STATES DISTRICT COURT
+for the
+Southent District of Florida
+M.J.
+Plaintiff
+v.
+JEFFREY EPSTEIN are
+Defendant
+Civil Action No.
+## SUMMONS IN A CIVIL ACTION
+To: (Defendant's name and address) JEFFREY EPSTEIN 9 East 71st Street New York, NY 10021
+A lawsuit has been filed against you.
+Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (aX2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney, whose name and address are: J.
+, Jaffe, Weissing, . Fistos & Lehrman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301
+If you fail to respond. judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
+Date:
+CLERK OF COURT
+Signature of Clerk or Deputy Clerk
+AO 440 (Rev. I2/09) Summons in a Civil Adig)11 (Page 2)
+Civil Action No.
+## PROOF OF SERVICE
+(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (0)
+This summons for (name of individual and title, if any) JEFFREY EPSTEIN was received by me on (date)
+O I personally served the summons on the individual at (place) on (date) : or
+O I left the summons at the individual's residence or usual place of abode with (name) a person of suitable age and discretion who resides there, on (date) , and mailed a copy to the individual's last known address; or
+Date:
+O I served the summons on (name of individual) designated by law to accept service of process on behalf of manic of organization) on (date) , who is ; Or
+O I returned the summons unexecuted because or
+O Other /\*nth):
+My fees are S for travel and S for services, for a total of S 0.00
+I declare under penalty of perjury that this information is true.
+Server's signature Printed name and title
+Additional information regarding attempted service, etc:
+Server's address

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+AO 440 (Rev. 12/09) Summons in a Civil Action
+## UNITED STATES DISTRICT COURT
+for the
+Southern District of Florida
+M.J.
+Plaintiff
+v.
+JEFFREY EPSTEIN and
+Defendant
+To: (Defendant's name and address) 230 Everglade Avenue. Apt. 102 Palm Beach, FL 33480
+Civil Action No.
+## SUMMONS IN A CIVIL ACTION
+A lawsuit has been filed against you.
+Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: J.
+Jaffe, Weissing, Fistos & Lehrman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301
+If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
+Date:
+CLERK OF COURT
+Signature of Clerk or Deputy Clerk
+AO 440 (Rev. 12/09) Summons in a Civil Aaron (Paso 2)
+Civil Action No.
+## PROOF OF SERVICE
+(This section should not be filed with the court unless required by Felt R. Civ. P. 4 (7))
+This summons for (name of individual and sale. If an)) was received by me on (date)
+O I personally served the summons on the individual at (place) on (date) or
+Date:
+O I left the summons at the individual's residence or usual place of abode with (name) . a person of suitable age and discretion who resides there, on (date) , and mailed a copy to the individual's last known address; or
+O I served the summons on (name of individual) designated by law to accept service of process on behalf of Mame of organization) on (date) , who is or
+O I returned the summons unexecuted because ; or
+O Other awe:
+My fees are S for travel and S for services, fora total of S 0.00
+I declare under penalty of perjury that this information is true.
+Sereer's signature
+Printed name and tide
+Server's address
+Additional information regarding attempted service, etc:

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+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+CASE NO.:
+M.J.,
+Plaintiff,
+vs.
+JEFFREY EPSTEIN and
+Defendants.
+#### COMPLAINT
+Plaintiff, M.J., by and through her undersigned counsel, sues the Defendants, Jeffrey Epstein and and alleges:
+- I. This is an action in an amount in excess of \$15,000.00, exclusive of interest and costs and is within the jurisdictional limits of this Court.
+- 2. This Complaint is brought under a fictitious name in order to protect the identity of the Plaintiff because this Complaint makes allegations of sensitive nature of offenses against a then minor child.
+- 3. At all times material to this cause of action, the Plaintiff, M.J. (hereinafter referred to as "Plaintiff), was a resident of Palm Beach County, Florida.
+- 4. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida.
+  - 5. Defendant, Jeffrey Epstein, is currently a citizen of the United States Virgin Islands.
+6. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953.
+7. Defendant, is currently a citizen of New York, where she currently resides.
+8. At all times material, the Defendants Jeffrey Epstein and both owed a duty unto Plaintiff to treat her in a non-negligent manner and to not commit or conspire to commit intentional or tortious illegal acts against her.
+# FACTUAL ALLEGATIONS
+9. At all times material, Defendant. Jeffrey Epstein, was an adult male, over 50 years old. Defendant Epstein is known as a billionaire, yet even those closest to him, including family members, long time employees and those that he considers his closest friends have no idea what he does or did to earn money to support his lifestyle.
+10. Defendant Epstein owns, directly or through nominee individuals used to conceal his interests, a fleet of airplanes, motor vehicles, boats and a helicopter. He owns numerous properties and homes, including a 51,000-square-foot mansion in Manhattan, a \$30 Million 7,500-acre ranch in New Mexico, a 70-acre private island formerly known as Little St. James in St. , U.S. Virgin Islands (he is alleged to have renamed this island Little St. Jeff's after himself), a mansion in London, England. a home in Paris, France, and a mansion in Palm Beach County, FL. The allegations herein primarily concern the defendant's conduct while at his mansion in Palm Beach County, FL.
+I I. Defendant Epstein has a sexual preference and obsession for underage minor females, specifically targeting female children age 12 to 17, and Defendant Epstein acts on that obsession by luring underage minor females to him where he attempts to sexually molest and batter these underage minor females on an everyday basis, oftentimes 2 or 3 different underage minor females on one day.
+12. Sometime prior to 1998, Defendant Epstein devised a complex plan, scheme and criminal enterprise to gain access to countless underage minor females, some as young as 12 years old, for the purpose of coercing the minor females into various acts of sexual misconduct that he committed upon them. His enterprise operated with a definite hierarchal structure with his various employees/assistants and associates, including Defendant, Jean Luc Brunel, Ghislain Maxwell, Leslie Groff, t, various housekeepers, butlers and pilots, performing their respective roles to ensure the goals of the enterprise: operate an organized and efficient system to maximize the number of underage minor females for Defendant Epstein (and others) to sexually abuse and exploit while avoiding law enforcement detection.
+13. Defendant Epstein, with help from his assistants and associates, recruited and procured underage minor females, lured them to one of his mansions, had the underage minor female taken to a room to be alone with him, then he would appear naked or wearing only a towel and sexually batter or otherwise sexually exploit the underage minor female. He would then pay the underage minor female for the sex acts he committed against her (typically between \$200 and \$300 per molestation session, or as his criminal enterprise commonly refers to it — per "massage"). Prior to leaving, Defendant Epstein's assistant would get the phone number of the underage minor female and input it into his computer system or otherwise keep it on file. He would then offer the underage minor female to return to his house to make money in exchange for him committing sexual acts against her, and he also typically informed her of another option make more money recruiting and procuring other underage minor females for him to sexually
+abuse. He would tell the underage minor female that he will pay her for each underage minor female that she brings to him (again, typically between \$200 and \$300), and he encouraged, and oftentimes forcefully demanded, her to bring him as many underage minor females as she was able. Through this general pitch, Defendant Epstein created a vast pyramid of underage minor females recruiting and procuring other underage minor females for his purpose of coercing these underage females into sexual acts for money.
+14. Defendants Epstein and and the criminal enterprise specifically targeted underprivileged and economically disadvantaged children to sexually exploit and molest and otherwise prey upon the vulnerabilities of these young girls.
+15. It is unknown exactly how long Defendant Epstein's aforementioned criminal enterprise operated, although information and belief indicates that it was continuously and actively in operation from at least 1998 through Defendant Epstein's criminal arrest in 2006.
+16. The complete list of underage minor females that were sexually abused by Defendant Epstein over the years is believed to have been kept on a computer system controlled by Defendant Epstein and accessible by several of his employees, including Defendant . It is also known that much of the data regarding the names, addresses and whereabouts of each underage minor female was input by one of his assistants, including Defendant
+was listed in the Federal Non-prosecution Agreement related to Defendant Epstein's criminal plea on sex charges against minors as a criminal co-conspirator for her role in the criminal activity that was committed by Defendant Epstein against many underage minor females. She was employed by Defendant Epstein to maintain his schedule, arrange for underage minor females to be with Defendant Epstein, maintain contact with the underage minor females, schedule the underage minor females' transportation to and from Defendant Epstein's
+mansion, and greet the underage minor female at the house before taking her upstairs to be alone with Mr. Epstein. Upon information and belief, Defendant remains employed by Defendant Epstein and continues to work for Defendant Epstein in furtherance of the goals of the criminal enterprise.
+18. Defendant Epstein used his vast wealth and power to lure underprivileged minor females to him, and to coerce them into prostitution once he was alone with the underage minor female. He sexually battered, molested, committed lewd and lascivious acts upon and otherwise exploited numerous underage minor females and then gave them money. So long as the underage minor female followed his demands and advances, he assumed the role of a friend or mentor or father figure to the minor female in an attempt to groom the minor female; however, if any minor female resisted his sexual advances, Defendant Epstein became frustrated, angry and threatening towards the underage minor. His intent was to groom each minor female into engaging in sexual acts with him as well as to "work" for him, i.e. bring him other underage minor females to sexually molest, batter and exploit. He was masterful in his exploitation and grooming of these minor females with an additional intent of gaining trust and cooperation from these minors to prevent any one of them from reporting his criminal acts to law enforcement. Certain of his many co-conspirator associates, including Ghislane Maxwell and Jean Luc Brunel, helped in this recruiting process by creating the impression that legitimate modeling opportunities were available for the minor females.
+19. Through information and belief, Defendant Epstein has been successful in luring hundreds of underage minor girls to him for the purpose of him (and sometimes others) sexually abusing them. He intentionally preys upon underage minor females that are middle school or high school children who are not working prostitutes, and he takes pleasure in using his power
+and influence to coerce these minor females into acts of prostitution with him personally and sometimes with his friends and associates as well, including but not limited to Ghislaine Maxwell and
+20. Over time, Defendant Epstein fine-tuned his operation to further his goals of gaining access to a greater number and variety of underage girls while avoiding detection by law enforcement. He also provided the roadtnap for his enterprise should the illegal sexual exploitation of the enterprise be detected — he or the criminal enterprise would (and did) retain legal representation for each criminal enterprise member who would instruct each member to invoke his/her 5th amendment rights, they would hide behind the 5th amendment to avoid turning over incriminating materials (i.e. computer system that logged information about the underage sexual molestation victims, scheduling books, message pads, and tangible items such as vibrators and dildos), they would destroy evidence and refuse all cooperation with law enforcement.
+21. The plan and scheme was developed by Defendant Epstein, and he and his assistants and associates carried it out with each underage minor female in a well-planned and ritualistic manner; Epstein ran this criminal enterprise as an experienced Mob boss would run any organized crime family — in a well-planned, organized, arrogant and ruthless manner, with complete cooperation from his co-conspirator associates and underlings and an absolute dedication to carrying out the illegal operations of the criminal enterprise.
+22. Defendant Epstein frequently traveled between his various mansions and either he or an authorized agent would call to inform a recruiter, assistant, or scheduler at his next destination as to his arrival time. His scheduler, usually Defendant would then contact an underage minor female and schedule her to be at Defendant Epstein's mansion or to bring another underage minor female to his mansion at a particular time. Once the minor female was
+brought to Defendant Epstein's residence, she was greeted at the door of the mansion and lead inside by one of Defendant Epstein's employees, oftentimes Defendant
+would lead the underage minor female up to Defendant Epstein's room and leave the underage minor alone in the room. Defendant, Jeffrey Epstein, himself would then appear naked or wearing only a towel. He would then demand a massage and during the massage he would attempt, usually successfully, to perform one or more lewd, lascivious, and sexual acts, including, but not limited to, masturbation, touching of the underage minor female's sexual organs, coercing or forcing the underage minor female to perform sex acts with him, using vibrators or sexual toys on the underage minor female, coercing the underage minor female into sexual intercourse with himself or others, and digitally penetrating the underage minor female. He would then give the Plaintiff money for engaging in this sexual activity.
+24. Consistent with Defendants Epstein and foregoing scheme or plan, in or around the summer of 2002, Plaintiff, an economically poor and vulnerable child, was told by another one of Epstein's underage minor sex abuse victims, that she could make \$300 cash by giving an old man a massage on Palm Beach.
+25. Plaintiff's then minor acquaintance (also a sexual abuse victim of Epstein) telephoned Defendant Epstein and scheduled for Plaintiff to go to Defendant Epstein's house to give him a massage. During that call, Defendant Epstein himself got on the phone and spoke with Plaintiff MJ and asked her personally to come to his mansion in Palm Beach.
+26. Plaintiff then took a taxicab to Defendant Epstein's mansion and was greeted by Epstein's top assistant, Defendant
+27. Defendant , in furtherance of the scheme to exploit Plaintiff, escorted Plaintiff upstairs to Defendant Jeffrey Epstein's large bathroom, where Defendant set up the
+massage table and showed Plaintiff different massage lotions to use. Defendant then left Plaintiff alone in the room. Plaintiff was alone in Defendant Epstein's bathroom until Defendant Jeffrey Epstein emerged wearing only a towel.
+28. Defendant Epstein then walked to the massage table that was already open in the room. He lied face down on the table and told Plaintiff to start massaging him, at which time he engaged in a conversation with Plaintiff. During the conversation, Defendant Epstein asked Plaintiff her age and she told him she had recently turned 16.
+29. Consistent with all of Defendant Epstein's known underage minor female victims, Plaintiff had no massage experience whatsoever and she informed him of that, and Defendant Epstein began instructing Plaintiff on how he liked his massage.
+30. After approximately 1\$ minutes, Defendant Epstein turned over onto his back, and he commanded Plaintiff to massage his chest.
+31. Defendant Epstein then suddenly removed his towel and his penis was already erect. He then commanded Plaintiff to remove her shirt and bra and to begin "pinching his nipples" as he began masturbating with his right hand.
+32. As he was masturbating, Defendant Epstein began fondling Plaintiff's breasts.
+33. Defendant Jeffrey Epstein, while masturbating with his right hand, reached out his left hand and grabbed Plaintiff's vagina and butt over her clothes. Plaintiff pushed Defendant's hand away and told him repeatedly not to touch her like that. Epstein was persistent in his attempt to grab Plaintiff's vagina and continued to grab her vagina and butt on multiple occasions after she told him not to.
+34. Defendant Epstein continued to masturbate his exposed penis until he ejaculated in front of the then minor Plaintiff.
+35. Plaintiff was shocked and embarrassed by the events and Defendant Epstein talked to her to persuade her that everything he was doing with he was normal.
+36. Epstein paid Plaintiff \$300 for allowing him to grope her and masturbate in her presence.
+37. Plaintiff returned to Epstein's home on approximately 20 occasions. On each occasion Epstein grabbed Plaintiff's bare breasts, exposed his penis, masturbated and ejaculated in Plaintiff's presence, and paid her \$300 each time.
+38. Defendant Epstein coerced Plaintiff into acts of prostitution, preying on her low economic status and troubled upbringing, complimenting Plaintiff for being "special" to him and having a "very pretty body" and making promises to Plaintiff such as — he told Plaintiff that if she graduated high school, then he would buy her a computer, something that she wanted yet could not afford.
+39. On multiple occasions Defendant Epstein pressured Plaintiff to bring him other underage minor females to abuse; he told Plaintiff that he would pay her \$300 for each girl she brought him, but Plaintiff refused to bring other girls.
+40. Defendant Epstein told Plaintiff that he would pay her more money if she would give him oral sex and that he would pay her \$600 for actual sexual intercourse. Plaintiff refused.
+41. Defendant Epstein personally called Plaintiff at least five times to tell her when she should be at his house to "work" or give him a "massage" (Epstein's criminal enterprise's learned code words for paying minors for Epstein and others to interact with them sexually).
+42. Every other time (approximately 15) Defendant called to inform Plaintiff of the date and time when she needed and was expected to be at Epstein's mansion to "work".
+43. The acts referenced above, committed by Defendant, Jeffrey Epstein, against the then minor Plaintiff were committed in violation of numerous State and Federal criminal statutes
+condemning battery, assault and the exploitation of minor children, contributing to the delinquency of a minor and other crimes, specifically including, but not limited to, those criminal offenses outlined in Chapters 796, 800, and 827 of the Florida Statutes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §796.09, §39.01, §450.151, and §827.04.
+44. The above-described acts took place in Palm Beach County, Florida at the residence of the Defendant, Jeffrey Epstein. My assertions by Defendants, Jeffrey Epstein and that they were unaware of the age of the then minor Plaintiff are belied by their actions and rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual exploitation and abuse of a minor child. The Defendants, Jeffrey Epstein and at all times material to this cause of action, knew and should have known of the Plaintiffs minority as Plaintiff specifically told Epstein her age and Defendant Epstein and criminal organization has a history of seeking out underage minor children to sexually abuse. In fact, one primary goal of the organization is to sexually abuse females who are under the age of IS, and oftentimes Defendant Epstein has turned away females (i.e. refused to engage in sexual acts with them) for being "too old" once she reaches 18 years of age. and he has reprimanded girls for bringing him other girls who are over the age of majority.
+45. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, Defendant Epstein entered pleas of "guilty" to various Florida State crimes related to his exploitation of minors for sex.
+46. As a condition of that plea and in exchange for the Federal Government entering into a Non-Prosecution Agreement with Defendant Epstein, wherein the Federal Government agreed to effectively stay any prosecution of Jeffrey Epstein, and other criminal coconspirators 1 and Leslie Groff, Defendant Epstein agreed to admit that approximately 40 underage minor females, whose names were provided to Defendant Epstein, were his victims. Plaintiff was not included in that list as she moved away from the West Palm Beach area in part to escape from Epstein, and she has lived in fear of Epstein and his organization and has not yet been contacted by law enforcement.
+47. Beginning in or about June 2008 and continuing to the present time, defendant Epstein has been aware he faces significant financial liability for his sexual offenses, both to MJ and to many other similarly-situated girls whom he abused. MJ and these other girls are creditors of Epstein, in that have filed and can file tort actions against him under both Florida and Federal laws. Accordingly, Epstein has conveyed substantial assets and property into the names of other persons and into overseas bank accounts and other financial institutions. These assets and properties could have been attachable and used to pay the debts owed to MJ and to the other girls that Epstein has abused.
+48. As an example of the fraudulent conveyances that Epstein has attempted, in approximately October 2009, Epstein placed his personal 727 aircraft up for sale, with the intent that the proceeds of that sale would be hidden so that MJ and other creditors of Epstein would not be able to secure payment from that substantial asset.
+49. While Epstein is clearly distinct from the criminal enterprise that he oversees that asset, as well as his other airplanes and helicopters and other assets, have been used continuously and repeatedly to further the interest and endeavors of Epstein and his criminal enterprise.
+50. As another example of the fraudulent transfers that Epstein has made, Epstein has titled a F-150 Truck in the name of Larry Visoki (Epstein's personal pilot). Visoski was unaware that the truck was titled in his name when he was questioned under oath in a deposition.
+51. In approximately 2009, Defendant Epstein purchased a \$68,000 Land Rover and registered it in Visoski's name with the intent to hide this asset from MJ and other creditors.
+52. In approximately 2009, Defendant Epstein purchased a Mercedes-Benz 2005 by wiring funds to Visoski and then placing the car in Visoski's name.
+53. In approximately 2009, Defendant Epstein bought a Jaguar X-Type 2005 so that he (Epstein) would have another car around Palm Beach available for his friends to use and then placed the car in Visoski's name.
+54. In approximately September 2009, Visoski attempted to sell a Ferrari owned by Epstein for \$159,000. Epstein intended for the sale to hide the value of this Ferrari and prevent MJ and other creditors from recovering from him.
+55. Epstein is concealing substantial assets through a new corporation, Shmitka Air, Inc., whose representative is Larry Visoski. In September 2010, Epstein attempted to sell a 1999 Bell Helicopter for approximately \$1,900,000. This sale was an attempt to prevent MJ and other creditors from recovering from him.
+56. Epstein is also concealing substantial assets through an entity known at JEGE, Inc. He is currently attempting to sell an aircraft for \$10,000,000 through that entity in an attempt to prevent MJ and other creditors from recovering from him.
+57. Through information and belief, Epstein and/or his criminal enterprise provides the financial support for his various employees, co-conspirators, other criminal enterprise members and associates.
+58. In addition to Epstein's various houses, he owns or controls other condominiums, including approximately 8 to 10 units at 301 East 66 Street, in New York City, where certain of his or his Criminal Enterprise associates live or reside, including Jean Luc Brunel, Nadia
+and at times various underage minor girls are stashed at this location as well.
+59. Defendant Epstein has numerous overseas contacts and accounts and sophistication in international business transactions. He previously served as a trader at Bear Stearns and founded his own financial management firm, J. Epstein and Col. (later called Financial Trust Co.) located on his private island in the U.S. Virgin Islands where, until his recent incarceration, according to him he allegedly managed the assets of billionaire clients.
+60. After extensive investigation into Epstein's employment history, including questioning of Epstein's family, those whom Epstein considers friends and longtime employees of Epstein, the only known client of Epstein was Limited, Inc. Founder Leslie Wexner, although it is believed that even that relationship has been severed. No other legitimate means of income have been reported.
+#### COUNT I
+# 11.'"1 IT' RN' AGAINST DEFENDANT EPSTEIN
+61. Plaintiff M.J. adopts and rcalleges paragraphs I through 60 above.
+62. In the summer of 2002, just after Plaintiff turned 16 years old, Defendant Epstein committed battery against Plaintiff when he intentionally touched intimate areas of her body and person in an offensive manner while she was a minor child.
+63. Defendant Epstein intentionally touched Plaintiff MJ's private areas multiple times against the will of MJ.
+64. Defendant Epstein's tortious commission of battery upon Plaintiff was done willfully.
+65. As a direct and proximate result of the offenses committed by Defendant Epstein against the then minor Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of life, invasion of her privacy and other damages associated with Defendant's manipulation and leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and loss of proper and complete education. These injuries are permanent in nature and Plaintiff MJ will continue to suffer these losses in the future.
+WHEREFORE, Plaintiff MJ demands judgment against Defendant Epstein for compensatory damages, punitive damages and such other relief as this Court deems proper and hereby demands trial by jury on all issues triable as of right by a jury.
+### COUNT II INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS AGAINST DEFENDANT EPSTEIN
+66. The Plaintiff adopts and realleges paragraphs 1 through 60 above.
+67. Defendant Epstein's extreme and outrageous conduct towards the then minor Plaintiff was intentional and reckless.
+68. Defendant Epstein acted with the intent to cause severe emotional distress or with reckless disregard for the high probability of causing severe emotional distress.
+69. As a direct and proximate result of the offenses committed by Defendant Epstein against the then minor Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of life, invasion of her privacy and other damages associated with Defendant's manipulation and leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and
+psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, loss of proper and complete education. These injuries are permanent in nature and Plaintiff MJ will continue to suffer these losses in the future.
+WHEREFORE, Plaintiff M.J. demands judgment against Defendant Epstein for compensatory damages. punitive damages and such other relief as this Court deems proper and hereby demands trial by jury on all issues triable as of right by a jury.
+### COUNT III CONSPIRACY TO COMMIT TORTIOUS ASSAULT OR BATTERY AGAINST DEFENDANT
+70. The Plaintiff adopts and =lieges paragraphs I through 60 above.
+71. Defendant is one of Defendant Epstein's top assistants, as referenced previously in this Complaint. Defendant Epstein, Defendant and others reached an agreement amongst and between them and otherwise conspired for the purpose of allowing Defendant Epstein and others to commit the tortious and illegal acts described above against Plaintiff MJ.
+72. Defendant aided, abetted and assisted Defendant Epstein in his organized scheme and plan to sexually exploit Plaintiff and commit battery against her and/or commit or attempt to commit numerous other crimes against her, including coercing her into prostitution.
+73. Defendant conspired with Defendant Epstein to commit tortious and illegal conduct against Plaintiff, and in furtherance of the conspiracy specifically engaged in overt acts such as contacting Plaintiff MJ on many occasions, scheduling the then minor Plaintiffs appointment for a "massage" knowing that Defendant Epstein was going to commit battery against Plaintiff, attempt sexual battery against Plaintiff, and force her into prostitution and otherwise did everything in her ability to conceal the illegal operation and refuse cooperation with law enforcement.
+74. Additionally, Defendant greeted Plaintiff on the occasions when Plaintiff arrived at Epstein's home and personally lead Plaintiff to Defendant Epstein's bathroom where Epstein appeared for the purposes of committing crimes against Plaintiff.
+75. Defendant Epstein's battery against Plaintiff was facilitated by Defendant and the conspiracy resulted in the various aforementioned crimes being committed against Plaintiff MJ as well as many other underage minor females.
+76. As a direct and proximate result of Defendant, participation in the aforementioned conspiracy, Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of life, invasion of her privacy and other damages associated with Defendant's manipulation and leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, loss of proper and complete education. These injuries are permanent in nature and Plaintiff MJ will continue to suffer these losses in the future.
+WHEREFORE, Plaintiff MJ demands judgment against Defendant for compensatory damages, punitive damages and such other relief as this Court deems proper and hereby demands trial by jury on all issues triable as of right by a jury.
+### COUNTS IV THROUGH XXIII CAUSES OF ACTION AGAINST DEFENDANTS EPSTEIN AND PURSUANT TO 18 USC 42255 IN VIOLATION OF VARIOUS ENUMERATED OFFENSES CONTAINED WITHIN THAT FEDERAL STATUTE
+77. Plaintiff, MJ, adopts and realleges paragraphs I through 60 above.
+78. The allegations contained herein in Counts IV through XXIII are separate and distinct legal remedies.
+79. As a condition of 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, entered into a Non-Prosecution Agreement with the Federal Government; that agreement governed not only Defendant Epstein's conduct but also the conduct of his "co-conspirators" including Defendant as she played an essential and criminal role in the commission of these offenses.
+80. The Plaintiff, MJ, was in fact 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, and against Defendant pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein. and the United States Government.
+81. Specifically, Defendants Epstein and
+(a) knowingly conspired with others known and unknown to use a facility or means of interstate commerce to knowingly persuade, induce, or entice minor females, including Plaintiff MJ, to engage in prostitution, in violation of title 18, United States Code, Section 2422(b).
+(b) knowingly and willfully conspired with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct with minors, including Plaintiff MJ, as defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e);
+(c) used a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females, including Plaintiff MJ, to engage in prostitution; in violation of Title 18, United States Code, Section 2422(b):
+(d) traveled in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(0, with minor females, including Plaintiff MJ; in violation of Title 18, United States Code, Section 2423(b).
+82. As a direct and proximate result of the aforementioned criminal offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of life, invasion of her privacy and other damages associated with Defendant's manipulation and leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and psychological expenses. These injuries arc permanent in nature and Plaintiff MJ will continue to suffer these losses in the future. Plaintiff, M.J., has also incurred attorneys' fees.
+83. With regard to each of the following counts, Plaintiff suffered personal injury, as outlined above from the acts above, as a result of the violations of federal criminal law by Defendant Epstein enumerated in paragraph 33, on approximately 20 occasions, and 's hi le the dates are not all precisely documented or diaried by Plaintiff, Defendants Epstein and committed these crimes and inflicted said injuries on or about the following dates:
+COUNT IV August 2002 COUNT V September 2002 COUNT VI October 2002 COUNT VII November 2002 COUNT VIII December 2002 COUNT IX January 2003
+COUNT X February 2003 COUNT XI March 2003 COUNT XII April 2003 COUNT XIII May 2003 COUNT XIV June 2003 COUNT XV July 2003 COUNT XVI August 2003 COUNT XVII September 2003 COUNT XV III October 2003 COUNT XIX November 2003 COUNT XX December 2003 COUNT XXI January 2004 COUNT XXII February 2004 COUNT XXIII March 2004
+WHEREFORE, with regard to each and every one of these counts, Plaintiff, MJ, demands judgment against Defendant, Jeffrey Epstein, for compensatory damages, loss of income, a loss of the capacity to earn income in the future, 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 XXIV Civil Remedy for Criminal Practices
+84. Plaintiff realleges paragraphs 1 through 60 above and for the purposes of this count incorporates and alleges the RICO Statement that has been filed contemporaneously herewith as Exhibit "A."
+85. The allegations contained herein in Count XXIV are a separate and distinct legal remedy brought pursuant to Florida Statute 772.104(1) and (2).
+86. Defendant, Jeffrey Epstein, was associated with an enterprise, a group of individuals associated in fact although not a legal entity, which was comprised of at least Defendant Jeffrey Epstein, Leslie Groff, Jean Luc Brunel, Ghislaine Maxwell, and (and likely many other yet unknown persons); Defendant Epstein participated in this enterprise, or conspired or endeavored to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4), as further outlined in detail in the RICO statement tiled with this court.
+87. This enterprise was separate and distinct from Epstein himself and had a definite hierarchical structure. Epstein served informally but effectively as the leader, C.E.O, or "boss" of this organization similar to the way an experienced mob boss runs his organized crime family, directing his underlings how to recruit and procure underage girls for his sexual activities and the sexual activities of others, developing the use of slang or code words to be used to discuss the illegal activities of the organization, designing a plan or scheme to gain the cooperation of underage minor females, developing methods and techniques to otherwise avoid detection from law enforcement including making large charitable donations to law enforcement agencies, powerful politicians, businessmen and world leaders, associating with powerful social people and highly influential politicians and attorneys, gathering information to blackmail or extort powerful people, devising a plan to attack the credibility and character of anyone that dare unveil the illegal operations of the enterprise and to take an oath to remain silent and/or lie when confronted by law enforcement about the illegal operations and activities of the criminal organization. Epstein's key "lieutenant" in the local Palm Beach branch of the National
+organization was 1= who served as both his scheduler and a recruiter/procurer of the girls. a lso served as a recruiter and helped Epstein satisfy his criminal sexual desires by, on occasion, directly participating in sexual abuse and prostitution of the minor girls. Epstein also used otherwise-legitimate business activities to help further the purpose of the criminal enterprise. These apparently legitimate activities provided "cover" for Epstein and his associates to commit the crimes. Epstein and his associates maintained the appearance of running an upstanding investment business, as well as other legitimate businesses with connections to modeling agencies and other powerful business and political people, to discourage the minor girls from reporting the abuse to law enforcement. Ghislane Maxwell and Jean Luc Brunel helped to provide "cover" by creating the impression that legitimate modeling opportunities were available for the girls. There are many other known and unknown associates of the criminal organization, that worked throughout the country and possibly internationally, who performed functions to perpetuate the criminal activities of the organization.
+88. Defendant Jeffrey Epstein participated in this enterprise through a pattern of criminal activity in that he engaged in at least two incidents of criminal activity, as defined and required in Florida Statute 772.102 and as described below, that have the same or similar intents, results, accomplices, victims, or methods of commission and are not isolated incidents.
+89. Defendant Jeffrey Epstein engaged in criminal activity by committing, attempting to commit, conspiring to commit or soliciting, coercing or intimidating another person to commit one or more of the following predicate acts as outlined and defined in Florida Statute 772.102:
+- (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 796.03;
+  - (b) Acts of battery in violation of Florida Statutes Chapter 784;
+(c) Forcing, compelling or coercing another to become a prostitute in violation of Florida Statutes Chapter 796.04;
+(d) knowingly recruiting, enticing, harboring, transporting, providing or otherwise obtaining by any means a person, knowing that coercion would be used to cause that person to engage in prostitution in violation of Florida Statutes Chapter 796.045;
+(e) tampering with a witness in violation of Florida Statutes Chapter 914.22;
+(f) altering, destroying, removing, or concealing records or documents or other evidence with the purpose to impair its verity or availability in violation of Florida Statutes Chapter 918.13;
+(g) maintaining a place (or more accurately "places") for the purpose of lewdness or prostitution; offering or securing another for the purpose of prostitution or for some other lewd or indecent act; receiving persons into his Palm Beach mansion for the purpose of prostitution or lewdness; directing, taking or transporting or agreeing to direct take or transport persons to his Palm Beach mansion with knowledge or reasonable belief that the purpose of such directing, taking or transporting was prostitution or lewdness; all in violation of Florida Statutes Chapter 796.07.
+90. The criminal acts of Defendant Epstein occurred repeatedly over a substantial period of time and were not isolated events.
+91. Under Defendant, Jeffrey Epstein's plan, scheme, and enterprise, Defendant, Jeffrey Epstein, paid employees and underlings, including but not limited to MI= to bring him minor girls to his Palm Beach mansion in order for the Defendant to solicit, induce, coerce, entice, compel or force such girls to engage in acts of prostitution and sexual misconduct with
+Defendant Epstein and sometimes and to otherwise commit acts of sexual battery thereon, and further Defendant Epstein worked in concert as part of the enterprise with those who were free to act independently and advance their own interests, including Ghislaine Maxwell and Jean Luc Brunel, to obtain minor girls for sexual purposes.
+92. Plaintiff, MJ, was the victim of Defendant, Jeffrey Epstein's plan, scheme, and enterprise and was so injured by reason of his violations of the provisions of s. 772.104. Plaintiff, MJ, was called on the telephone by Defendant Epstein and other employees of his, including and transported to the Defendant, Jeffrey Epstein's residence, where she was placed in a room along with the Defendant, enticed to commit acts of prostitution, and had acts of sexual battery and sexual exploitation committed against her. Defendant, Jeffrey Epstein, conspired with his assistants and employees in order to accomplish their common motive or intent of seeking out, gaining access to, and exploiting minor children such as the Plaintiff, MJ, in the aforementioned ways, and he further conspired with his employees, assistants and underlings to ensure that the crimes of this criminal enterprise were concealed or undetected by law enforcement. Those who were free to act independently and advance their own interests, including Ghislaine Maxwell and Jean Luc Brunel, also worked with the enterprise to conceal the activities of the enterprise.
+93. After law enforcement began to detect the criminal activities of Defendant Epstein and the other persons involved in the criminal enterprise, the enterprise used resources and information to conceal the illegal activities of the enterprise, threaten the victims of the crimes of the enterprise if they revealed the scope of the enterprise to law enforcement, and concealed or destroyed documents relevant to the prosecution of the various members of the enterprise. The enterprise also made various efforts to discourage the victims from cooperating with law
+enforcement and from filing civil lawsuits to vindicate their rights. Epstein and other members of the enterprise made cash payments and gave gifts to the victims of the enterprise in order to discourage them from reporting crimes to law enforcement and other authorities.
+94. Through information and belief, this criminal enterprise gained valuable consideration from the practice of sex-trafficking underage children and providing underage children to other adults and otherwise derived valuable consideration for running a national and oftentimes international sex-trafficking and underage prostitution ring, typically by coercing and introducing the economically disadvantaged underage minor females into prostitution and sometimes into being underage sex slaves for the enterprise.
+95. The evidence clearly and convincingly establishes that Plaintiff MJ was injured by reason of violations of the provisions of 772.103, and as such is entitled to threefold the actual damages sustained and a minimum of \$200, and reasonable attorney's fees and court costs.
+96. In the alternative, and pursuant to s. 772.104, Plaintiff MJ was injured due to sex trafficking committed in violation of s. 772.103 and is thus entitled to threefold the amount gained from the sex trafficking and to a minimum amount of damages not less than \$200, reasonable attorney's fees and court costs.
+97. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, loss to her property and business opportunities and other losses.
+WHEREFORE, under the provisions of Florida Statutes Chapter 772, Plaintiff, MJ, demands judgment against Defendant. Jeffrey Epstein, for any minimum damages authorized by law, all actual damages sustained (to be trebled as authorized by law), court 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.
+# COUNT XXV
+# Cause of Action Pursuant to Florida Statute 796.09 Against Defendant, Jeffrey Epstein
+98. Plaintiff adopts and reallegcs paragraphs 1 through 60 above.
+99. The allegations contained herein in Count XXV are a separate and distinct legal remedy.
+100. Defendant, Jeffrey Epstein, was a wealthy and powerful man, and Plaintiff was an economically disadvantaged and impressionable minor.
+101. Plaintiff MJ had never engaged in any act of prostitution prior to meeting Epstein or being introduced to any of the members of the criminal enterprise of which Defendant Epstein was an operating member and leader.
+102. Defendant, Jeffrey Epstein, used his vast wealth and power to coerce Plaintiff into prostitution and/or coerced her to remain in prostitution.
+103. Defendant, Jeffrey Epstein, coerced Plaintiff into prostitution in one or more of the following ways:
+- A. Domination of her mind and body through exploitive techniques;
+- B. Inducement;
+- C. Promise of greater financial rewards;
+- D. Exploitation of a condition of developmental disability, cognitive limitation, affective disorder, and/or substance dependency;
+  - E. Exploitation of human needs for food, shelter or affection;
+  - F. Exploitation of underprivileged and vulnerable economic condition or
+- G. Use of a system of recruiting other similarly situated minor girls to further coerce and induce Plaintiff into the lifestyle of prostitution; and
+situation;
+H. Exploitation through demonstration of abundant wealth and power to impress a young and vulnerable then minor Plaintiff and to coerce her into prostitution.
+104. As a direct and proximate result of the offenses committed by Defendant, Jeffrey Epstein, against Plaintiff pursuant to Florida Statutes §796.09, the Plaintiff has in the past suffered, and will in the future suffer, 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 Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff 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 will continue to suffer these losses in the future.
+WHEREFORE, Plaintiff, Jane Doe, demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, punitive damages as specifically allowed by this and other statutes and by law, 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 XXV
+### Cause of Action Pursuant to Florida Statute 726.101 Against Defendant, Jeffrey Epstein
+105. This count alleges an action for redress of fraudulent transfers brought under Florida's Uniform Fraudulent Transfer Act, sections 726.101, et seq., Fla.Stats. ("FUFTA").
+106. Plaintiff adopts and realleges paragraphs I through 60 above.
+107. M.J. is a creditor of defendant Jeffrey Epstein. She has various claims against him for repeated sexual molestation of her when she was a minor, as alleged in the other counts of this complaint.
+108. Given the egregious acts of sexual molestation the defendant perpetrated against her, M.J. has a claim against defendant, once punitive damages are added, is worth in excess of \$50,000,000. Therefore, he is facing judgments in excess of 550,000,000 from her. Epstein is thus a debtor of M.J., as defined in the FUFTA.
+109. Defendant Jeffrey Epstein has numerous overseas contacts and sophistication in international business transactions. He previously served as a trader at Bear Steams and founded his own financial management firm, J. Epstein and Col. (later called Financial Trust Co.) located on his private island in the U.S. Virgin Islands where, until his recent incarceration, he managed the assets of billionaire clients.
+110. Defendant Jeffrey Epstein has transferred, is transferring, and intends to transfer in the near future his assets, to locations overseas and elsewhere and/or to nominee individuals who conceal Epstein's interest in the assets, with the actual intent to hinder, delay and defraud M.J. To prevent M.J. from satisfying any judgment that she might obtain in her pending lawsuit again him, Epstein has moved and intends to move his significant financial assets to locations overseas (i.e., to Israel) or in other unreachable areas and to title his assets (including real property, aircraft, boats, vehicles, and financial instruments) in the names of other persons or entities, even though he maintains (directly or indirectly) control over those assets. These transfers are designed by Epstein to prevent M.J. from being able to collect on any judgment she might obtain against him, including any punitive damages judgment.
+111. In recent lawsuits against him very similar to those filed by M.J., defendant Epstein has refused to answer and taken the Fifth when asked whether he intends to conceal assets from those with claims against him.
+112. In recent lawsuits against him very similar to those filed by M.J., defendant Epstein refused to answer and took the Fifth Amendment when asked whether he intends to remain in the country in the future.
+113. Epstein could currently post a \$15 million bond to satisfy a judgment in this case without financial or other difficulty.
+WHEREFORE plaintiff M.J. demands judgment against defendant Epstein as follows:
+(a) An accounting by defendant Jeffrey Epstein of all of his significant financial assets, whether held in this country or overseas, and all significant transfer of assets in the last three years;
+(b) Avoidance of the fraudulent tiansfers or obligations to the extent necessary to satisfy M.J.'s claims;
+(c) An attachment or other provisional remedy against the asset transferred or other property of the transferee in accordance with applicable law;
+(d) An injunction against defendant Jeffrey Epstein and such transferees as may be appropriate, or both, against further transfers of any assets pending further order of the Court and posting of a bond to protect M.J..;
+(e) Appointment of a receiver to take charge of the assets of defendant Jeffrey Epstein until the Court is satisfied that M.J. interests in having assets available from the defendant to satisfy any judgment are fully protected;
+(f) Posting by defendant Jeffrey Epstein of a \$15,000,000 bond to satisfy any judgment obtained by M.J. in her pending lawsuits; and
+(g) All other relief that the circumstances may require to protect M.J. and her ability to satisfy any judgment she might obtain.
+Plaintiff also demands a jury trial on all issues so triable by jury.
+Dated: Sept. 17, 2010
+Respectfully submitted,
+![]()BY:
+![]()

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marker2/court-redacted-v-epstein-81111/EFTA02821036/EFTA02821036.md ADDED Viewed

	@@ -0,0 +1,87 @@

+At) 440 (Rev. 12/N) Summons in a Colt Act too
+## UNITED STATES DISTRICT COURT
+for the
+Southent District of Florida
+M.J.
+Plaintiff
+V.
+JEFFREY EPSTEIN and
+Defendant
+Civil Action No.
+10-CV-81111-DIMITR0ULEASISN0W
+## SUMMONS IN A CIVIL ACTION
+To: (Defendant name and address) JEFFREY EPSTEIN 9 East 71st Street New York, NY 10021
+A lawsuit has been filed against you.
+Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (02) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney, whose name and address are: J.
+, Jaffe, Weissing, . Fistos & Lehrman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301
+If you fail to respond. judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
+Date: SEPTEMBER 17, 2010
+![](_page_0_Picture_20.jpeg)
+Steven M. Larimore Clerk of Court
+St-1111O\S
+s/Gregory Maestre Deputy Clerk U.S. District Courts AO440 (Rev. 12/09) Summons in a Civil Action
+## UNITED STATES DISTRICT COURT
+for the
+Southern District of Florida
+M.J.
+Plaintiff
+v.
+JEFFREY EPSTEIN and
+Defendant
+To: (Defendant's name and address)
+Civil Action No.
+10-CV-81111-DIMITROULEAS:SNOW
+## SUMMONS IN A CIVIL ACTION
+230 Everglade Avenue. Apt. 102 Palm Beach, FL 33480
+A lawsuit has been filed against you.
+Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: J.
+Jaffe, Weissing, , Fistos & Lehrman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301
+If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
+Date: SEPTEMBER 17, 2010
+![](_page_1_Picture_21.jpeg)
+Steven M. Larimore Clerk of Court
+SUMMONS
+s/Gregory Maestre Deputy Clerk U.S. District Courts

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 10-81111-CIV-DIMITROULEAS
+Plaintiff,
+vs.
+JEFFREY EPSTEIN and
+Defendants.
+## ORDER REOUIRING COUNSEL TO MEET, FILE JOINT SCHEDULING REPORT AND JOINT DISCOVERY REPORT
+THIS ORDER has been entered upon the filing of the Complaint. Plaintiff's counsel is hereby ORDERED to forward to all Defendants, upon receipt of a responsive pleading, a copy of this order.
+It is further ORDERED:
+- I. Pretrial discovery in this case shall be conducted in accord with Federal Rule of Civil Procedure 26 and Southern District of Florida Local Rule 16.1.
+- 2. Within thirty-five (35) calendar days of the filing of the first responsive pleading by the last responding defendant, unless this action is excluded under Rule 26(a)(IXB), the parties shall file a Joint Scheduling Report and Joint Proposed Order pursuant to Local Rule 16.1.B.2.1 In preparing the Joint Scheduling Report and Joint Proposed Order the parties shall adhere to the following deadlines:
+A. The parties must confer within fifteen (15) calendar days after the filing of the
+This time period is inclusive of the additional time provided pursuant to Rule 6(d).
+first responsive pleading by the last responding defendant, to consider the nature and basis of their claims and defenses and the possibilities for a prompt settlement or resolution of the case, to make or arrange for the disclosures required by Rule 26(a)(1), and to develop a proposed discovery plan that indicates the parties' views and proposals concerning the matters listed in Rule 26(f). The parties are jointly responsible for submitting a written report of this conference outlining the proposed discovery plan at the time they file their Joint Scheduling Report and Joint Proposed Order.
+B. Counsel for the parties shall hold a scheduling conference either at the same time as the discovery conference described in Rule 26(f) or within ten (10) calendar days thereafter. See Local Rule 16.1.B.
+C. Within seven (7) calendar days of the scheduling conference, counsel shall file a joint scheduling report pursuant to Local Rule 16.1.B. This report shall indicate the proposed month and year for the trial plus the estimated number of trial days required. Should this be a case in which a class is sought, the report shall include a date by which any motions for class certifications shall be filed.
+D. The Court notes that, pursuant to Local Rule 16.2, parties are required to agree upon a mediator and advise the Clerk's office of their choice within fourteen(14) days of this Court issuing a Scheduling Order.
+3. The parties may submit a single report combining the discovery plan report and the scheduling conference report. However, unilateral submissions are prohibited.
+4. Failure of counsel or unrepresented parties to file a discovery plan report or joint scheduling report may result in dismissal, default, and the imposition of other sanctions including attorney's fees and costs.
+5. If a case is settled, counsel are directed to inform the Court promptly at (954) 769- 5650, and to submit an appropriate stipulation Order for Dismissal, pursuant to Rule 41(a)(1) . Such an Order must be filed within ten (10) calender days of notification of the Court.
+DONE AND SIGNED in at Fort Lauderdale, Broward County, Florida, this 21st day of September, 2010.
+> 6.2 LLIAM P. DIMITR United States District Judge
+Copies furnished to:
+J.

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+AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2)
+Civil Action No.
+PROOF OF SERVICE
+(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (1))
+This summons for (name of individual and title, if any) JEFFREY EPSTEIN
+was received by me on (date) SEPT. 20, 2010
+ I personally served the summons on the individual at (place) \_\_\_\_\_
+on (date) \_\_\_\_\_; or
+ I left the summons at the individual's residence or usual place of abode with (name) MARK
+, a person of suitable age and discretion who resides there,
+on (date) OCT. 8, 2010, and mailed a copy to the individual's last known address; or
+ I served the summons on (name of individual) \_\_\_\_\_, who is
+designated by law to accept service of process on behalf of (name of organization) \_\_\_\_\_
+on (date) \_\_\_\_\_; or
+ I returned the summons unexecuted because \_\_\_\_\_; or
+ Other (specify):
+My fees are \$ \_\_\_\_\_ for travel and \$ \_\_\_\_\_ for services, for a total of \$ 0.00
+I declare under penalty of perjury that this information is true.
+Date: 10-29-10
+*[Handwritten signature]*
+Server's signature
+THOMAS MARSIGLIANO, INVESTIGATOR
+Printed name and title
+RO BOX 1485, PORT WASHINGTON N.Y.
+Server's address 11050
+Additional information regarding attempted service, etc:

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+AO 88A (Rev. (6/09)) Subpoena to Festify at a Deposition in a Civil Action (Page 2)
+Civil Action No. CASE NO.: 9:10-cv-81111
+PROOF OF SERVICE
+(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)
+This subpoena for (name of individual and title, if any) JEFFREY EPSTEIN
+was received by me on (date) SEPT 20, 2010
+ I served the subpoena by delivering a copy to the named individual as follows: ON OCT. 8, 2010
+I DELIVERED A COPY OF THE SUBPOENA TO MARK AT 9 EAST 71ST STREET
+NEW YORK NY. RESIDENCE OF JEFFREY EPSTEIN (date) 10-8-10; or
+ I returned the subpoena unexecuted because:
+Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of \$
+My fees are \$ \_\_\_\_\_ for travel and \$ \_\_\_\_\_ for services, for a total of \$ 0.00
+I declare under penalty of perjury that this information is true.
+Date: OCT. 28, 2010
+![]()Server's signature
+THOMAS MARSIGLIANO, INVESTIGATOR
+Printed name and title
+PO. Box 1485 PORT WASHINGTON NY
+Server's address 11050
+Additional information regarding attempted service, etc:

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+Case No. 9:10-cv-81111-WPD
+M.J.,
+Plaintiff,
+vs.
+JEFFREY EPSTEIN and
+Defendant.
+## AFFIDAVIT OF RICIIARD BARNETT
+1 Richard Barnett, being duly sworn, do depose and state as follows:
+- 1. I am over the age of 18, am otherwise competent to testify and base the following on my personal knowledge.
+- 2. On Wednesday, October 13, 2010, an unmarked and unpostmarlced envelope was discovered in the mailbox at Mr. Espstein's vacation home in New York City at 9 East 71" Street. The envelope contained a Summons and Complaint In the subject action, a Civil Rico Case Statement, a deposition subpoena, notices of video depositions, interrogatories and requests for production.
+  - 3. Service was never delivered to anyone at Mr. Esptein's house.
+![](_page_0_Picture_12.jpeg)
+FURTHER AFFIANT SAYETH NOT.
+![]()RICHARD BARNETT
+Sworn and subscribed before me this 29<sup>th</sup> day of October, 2010 by Richard Barnett who is personally known to me or has produced Drivers Licence as identification.
+![]()NOTARY PUBLIC
+STATE OF NEW YORK
+![](_page_1_Picture_52.jpeg)
+MY COMMISSION EXPIRES: 1/29/11

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+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+Case No. 9:10-cv-81111-WPD
+M.J.,
+Plaintiff,
+vs.
+JEFFREY EPSTEIN and
+Defendant.
+# MOTION OF DEFENDANT JEFFREY ESPTEIN TO QUASH SERVICE OF PROCESS AND SUPPORTING MEMORANDUM OF LAW
+Defendant Jeffrey Epstein, by and through undersigned counsel, respectfully moves pursuant to Fed. R. Civ. P. 12(b)(5) to quash service of process, and without waiving any available jurisdictional defenses and without making a general appearance, states as follows:
+# SUMMARY OF ARGUMENT
+Plaintiff, M.J., attempted to effect service on Mr. Epstein by leaving a copy of the Summons and Complaint in an unmarked, unaddressed and unpostmarked envelope in a mailbox at Mr. Epstein's vacation house at 9 East 71" Street, New York, New York, at an unknown time between October 8, 2010 and October 13, 2010. Such "service" does not comply with the requirements for service of process under New York, Florida or federal law. The attempt at service of process was ineffective. Service of process should be quashed.
+# BACKGROUND
+- 1. The Complaint in this action was filed, and a summons was issued as to Jeffrey
+Case No. 9:10-cv-81111-WPD
+Epstein, on September 17, 2010.
+2. On Wednesday, October 13, 2010, an unmarked, unaddressed and unpostmarked envelope was discovered in the mailbox at Mr. Epstcin's vacation home at 9 East 7P1 Street, New York, New York. The envelope contained a Summons and Complaint in the subject action, a Civil Rico Case Statement, a deposition subpoena, notices of video depositions, interrogatories and requests for production. (Ex. A, Aff. Richard Barnett).
+3. Service was never delivered to anyone at Mr. Epstein's vacation home in New York. (Id.).
+4. On or about October 13, 2010, Plaintiff's counsel, Brad M, Esq. upon leaving a hearing in Bankruptcy Court before the Honorable Raymond Ray, advised Knight, Esq., that Plaintiff M.I. had service on Mr. Epstein at his building in New York. That prompted undersigned counsel's firm to review the court file in the instant case, which indicated that there was no return of service in the court file. As of today, there is a document which purports to be a return of service.
+#### ARGUMENT
+### NO SERVICE UNDER FLORIDA, NEW YORK OR FEDERAL LAW
+In this action, three methods of service of process are authorized by the Federal Rules of Civil Procedure. First, service can be effected pursuant to the procedures "in the state where the district court is located" — i.e. Florida. See Fed. R. Civ. P. 4(e)(1). Second, service can be effected in accordance with the procedures "in the state . . . where service is made" — i.e. New York. Id. Finally, service can be effected pursuant to federal procedures by delivering a copy of the summons and
+Case No. 9:10-cv-81111-WPD
+complaint to the individual personally, leaving a copy of same at the individual's dwelling "with someone of suitable age and discretion who resides there" or delivering a copy to an agent authorized to accept service of process. See Fed. R. Civ. P. 4(e)(1). Service was not effected pursuant to any of these three methods of service available to Plaintiff.
+No Service Under Florida Law. Under § 48.031(1Xa), Ha. Stat., service "is made by delivering a copy of it to the person to be served with a copy of the complaint, petition, or other initial pleading or paper or by leaving the copies at his or her usual place of abode with any person residing therein who is 15 years of age or older and informing the person of their contents. . . ." Leaving an unmarked envelope with a summon and complaint in a mailbox at a vacation residence does not comply with § 48.031(1)(a), Fla. Stat.
+No Service Under New York Law. Under New York law, personal service may be made inter alio on an individual by delivering the summons and complaint to the defendant or "to a person of suitable age and discretion at the actual place of business, dwelling place or usual abode of the [defendant)," and by mailing the summons and complaint to the person to be served at his last known address by first class mail. N.Y.C.P.L.R. §308(2). (McKinney 2008). Proof of such service must be "filed with the clerk of the court designated in the summons within twenty days of either such delivery or mailing, whichever is effected later." IS Neither of these procedures was followed in the instant case. Merely leaving an unmarked envelope with a summons and complaint in a mailbox does not comply with New York law on service of process.
+No Service under Federal Law. Under Fed. R. Civ. P. 4(e)(2), service is effected by delivering a copy of the summons and complaint to the defendant personally; by leaving a copy of
+Case No. 9:10-cv-81111-WPD
+same at the "individual's dwelling or usual place of abode with someone of suitable age and discretion who resides there; or by delivering a copy of same "to an agent authorized by appointment or by law to receive service of process." There is no question that service was not effected pursuant to any of foregoing provisions of federal law.
+Accordingly, service of process must be quashed because it was completely ineffective under Florida, New York and federal law.
+WHEREFORE, Defendant Jeffrey Epstein respectfully requests that service of process be quashed.
+Respectfully submitted,
+E. Knight
+Fla. Bar No. 607363
+Lilly Ann
+Fla. Bar No. 195677
+Helaine S. Goodner
+Fla. Bar No. 462111
+BURNETT P.A.
+Espirito Santo Plaza, 14i° Floor
+1395 Brickell Avenue
+Miami, Florida 33131-3302
+Telephone: (305) 789-9200
+Facsimile: (305) 789-9201
+Counsel for Defendant Jeffrey Epstein
+#### CERTIFICATE OF SERVICE
+I hereby certify that on October 29, 2010, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing.
+> s/Lill Ann Lilly Ann
+### SERVICE LIST
+M.J• v. Epstein
+United States District Court, Southern District of Florida
+J. brad@ athto'u. ice.co , Jaffe, Weissing, Fistos & Lehrman, PL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone: (954) 524-2820 Facsimile: (954) 524-2822 Attorneys for Plaintiff M.J. Served via CM/ECF

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+Case No. 9:10-cv-81111-WPD
+M.J.,
+Plaintiff,
+vs.
+JEFFREY EPSTEIN and
+Defendant.
+## NOTICE OF APPEARANCE
+PLEASE TAKE NOTICE that Helaine S. Goodner of the law firm of Burnett, P.A. hereby gives notice of appearance as attorney to be noticed for Defendant JEFFREY ESPTEIN in the above-styled cause. All parties are requested to forward copies of all pleadings, notices, electronic notices, papers and correspondence to undersigned counsel.
+Case No. 9:10-cv-81111-WPD
+Respectfully submitted,
+lain Goodner
+E. Knight
+Fla. Bar No. 607363
+Helaine S. Goodner
+Fla. Bar No. 462111
+Lilly Ann
+Fla. Bar No. 195677
+M ISIJRNEIT P.A.
+Espirito Santo Plaza, 14th Floor
+1395 Brickell Avenue
+Miami, Florida 33131-3302
+Telephone: (305) 789-9200
+Facsimile: (305) 789-9201
+Counsel for Defendant Jeffrey Epstein
+## CERTIFICATE OF SERVICE
+I hereby certify that on November 1, 2010, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified on the attached Service List in the manner specificd, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing.
+s/Helaine S. Goodner
+Helaine S. Goodner
+Fla. Bar No. 462111
+Case No. 9:10-ev-81111-WPD
+## SERVICE LIST
+M.J. v. Epstein
+Case No. 9:10-cv-8111I-WPD
+United States District Court, Southern District of Florida
+J. brad athtojustice.com
+Jaffe, Weissing,
+Fistos & Lehrman, PL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone: (954) 524-2820 Facsimile: (954) 524-2822 Attorneys for Plaintiff M.J. Served via CM/ECF

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 9:10-cv-81111
+M.J.,
+Plaintiff,
+vs.
+JEFFREY EPSTEIN and
+Defendants.
+/
+## PLAINTIFF, Mrs, NOTICE OF STRIKING CERTIFICATE OF SERVICE (DES) AND CERTIFICATE OF SERVICEIDIa
+Plaintiff, MJ, by and through her undersigned counsel and pursuant to The Clerk Notice to Filer entered November 1, 2010, hereby strikes CERTIFICATE OF SERVICE by MJ Proof of Service Summons on Defendant, Epstein (DE 5), and CERTIFICATE OF SERVICE by MJ Proof of Service of Subpoena to Testify at a Deposition to Defendant, Epstein (DE 6), due to incorrect filing.
+DATED: November 2. 2010
+Respectfully Submitted,
+JAFFE, WEISSING, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com
+## CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on November 2, 2010 I electronically filed the foregoing document with the Clerk of the Court using CMIECF. I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CMIECF or in some other authorized manner for those parties who are not authorized to receive electronically filed Notices of Electronic Filing.
+J.
+## SERVICE LIST
+M.J. v. Jeffrey Epstein United States District Court, Southern District of Florida
+Lill Ann E. Kni ht
+Helaine S. Goodner
+BURNETT PA Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, FL 33131-3302
+Counsel for Defendant. Jeffrey Epstein

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+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 9:10-cv-81111
+M.J.,
+Plaintiff,
+vs.
+JEFFREY EPSTEIN and
+Defendants.
+## PLAINTIFF, MJ's, SUMMONS (AFFIDAVIT) RETURNED EXECUTED PROOF OF SERVICE SUMMONS ON DEFENDANT, EPSTEIN
+Plaintiff, MJ, by and through her undersigned counsel and pursuant to The Clerk Notice to Filer entered November 1, 2010, hereby file executed, PROOF OF SERVICE SUMMONS ON DEFENDANT EPSTEIN.
+DATED: November 2. 2010
+Respectfully Submitted,
+JAFFE, WEISSING, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: bnd@pathtojustice.com
+#### CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on November 2, 2010 I electronically filed the foregoing document with the Clerk of the Court using CMIECF. I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CMIECF or in some other authorized manner for those parties who arc not authorized to receive electronically filed Notices of Electronic Filing.
+"WIWI. 3.
+# SERVICE LIST
+M.J. v. Jeffrey Epstein United States District Court, Southern District of Florida
+Lill Ann E. Kni ht
+Helaine S. Goodner
+BURNETT PA Espirito Santo Plaza, 14i° Floor 1395 Brickell Avenue Miami, FL 33131-3302
+Counsel for Defendant. Jeffrey Epstein
+Civil Action No.
+PROOF OF SERVICE
+(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (1))
+This summons for (name of individual and title, if any) JEFFREY EPSTEIN
+was received by me on (date) SEPT. 20, 2010
+ I personally served the summons on the individual at (place) \_\_\_\_\_
+on (date) \_\_\_\_\_; or
+ I left the summons at the individual's residence or usual place of abode with (name) MARK
+, a person of suitable age and discretion who resides there,
+on (date) OCT. 8, 2010, and mailed a copy to the individual's last known address; or
+ I served the summons on (name of individual) \_\_\_\_\_, who is
+designated by law to accept service of process on behalf of (name of organization) \_\_\_\_\_
+on (date) \_\_\_\_\_; or
+ I returned the summons unexecuted because \_\_\_\_\_; or
+ Other (specify):
+My fees are \$ \_\_\_\_\_ for travel and \$ \_\_\_\_\_ for services, for a total of \$ 0.00
+I declare under penalty of perjury that this information is true.
+Date: 10-29-10
+*[Handwritten signature]*
+Server's signature
+THOMAS MARSIGLIANO, INVESTIGATOR
+Printed name and title
+RO BOX 1485, PORT WASHINGTON N.Y.
+Server's address 11050
+Additional information regarding attempted service, etc:

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+**UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA**
+Case No. 9:10-cv-81111-WPD
+M.J.,
+Plaintiff,
+vs.
+JEFFREY EPSTEIN and
+[REDACTED],
+Defendant.
+\_\_\_\_\_/
+**AFFIDAVIT OF RICHARD BARNETT**
+I, Richard Barnett, being duly sworn, do depose and state as follows:
+1. 1. I am over the age of 18, am otherwise competent to testify and base the following on my personal knowledge.
+2. 2. I was on the premises of 9 East 71<sup>st</sup> Street, New York, New York, the entire day of October 8, 2010.
+3. 3. On October 8, 2010, no individual by the name of "Mark" worked, resided or was present on the premises of 9 East 71<sup>st</sup> Street, New York, New York.
+4. 4. On October 8, 2010, no individual by the name of "Mark" received a subpoena at 9 East 71<sup>st</sup> Street, New York, New York.
+FURTHER AFFIANT SAYETH NOT.
+![]()RICHARD BARNETT
+![](_page_0_Picture_106.jpeg)
+NOTARY PUBLIC STATE OF NEW YORK
+Sworn and subscribed before me this '2- day of It-AVert'ev- , 2010 by Richard Barnett who is personally known to me or has produced as identification.
+HARRY I. BELLER Notary Public. State of New York No. 018E4853924 Oualified in Rockland County 111 Commission Expires Feb. 17. 20.L.7
+MY COMMISSION EXPIRES:

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+Case No. 9:10-cv-81111-WPD
+M.J.,
+Plaintiff,
+vs.
+JEFFREY EPSTEIN and
+Defendant.
+## NOTICE OF FILING SUPPLEMENTAL AFFIDAVIT
+Defendant Jeffrey Epstein, hereby files the Supplemental Affidavit of Richard Barnett (Exhibit A) in support of its Motion of Defendant Jeffrey Esptein to Quash Service of Process and Supporting Memorandum of Law (D.E. 7).
+Respectfully submitted,
+s/Lilly Ann
+E. Knight
+Fla. Bar No. 607363
+Lilly Ann
+Ha. Bar No. 19 77
+Helaine S. Goodner
+Fla. Bar No. 462111
+BURNETT P.A.
+Espirito Sar•fiaza, 14i6 Floor
+1395 Brickell Avenue
+Miami, Florida 33131-3302
+Telephone: (305) 789-9200
+Facsimile: (305) 789-9201
+Counsel for Defendant Jeffrey Epstein
+Case No. 9:10-cv-81111-WPD
+## CERTIFICATE OF SERVICE
+I hereby certify that on November 3, 2010, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing.
+> s/Lill Lill Ann
+## SERVICE LIST
+M.J. v. Epstein
+United States District Court, Southern District of Florida
+J. S athtojusuce.cona Jaffe, Weissing, Fistos & Lehrman, PL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone: (954) 524-2820 Facsimile: (954) 524-2822 Attorneys for Plaintiff M.J. Served via CM/ECF

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 10-81111-CIV-DIMITROULEAS
+M.J..
+Plaintiff,
+vs.
+JEFFREY EPSTEIN and
+Defendants.
+## ORDER DENYING MOTION WITHOUT PREJUDICE
+THIS CAUSE is before the Court upon the Motion of Defendant Jeffrey Epstein to Quash Service of Process and Supporting Memorandum of Law [DE-7], filed herein on October 29, 2010. The Court has carefully considered the Motion and is otherwise fully advised in the premises.
+Accordingly, it is ORDERED AND ADJUDGED that the Motion of Defendant Jeffrey Epstein to Quash Service of Process and Supporting Memorandum of Law [DE-7] is hereby DENIED WITHOUT PREJUDICE to file a motion that complies with the requirements of S.D. Fla. L.R. 7.I.A.3., which requires the moving party to certify that he has conferred, or describes a reasonable effort to confer, with the parties affected in a good faith effort to resolve the dispute.
+DONE AND ORDERED in 8th day of November, 2010. at Fort Lauderdale, Broward County, Florida this
+Copies furnished to: Counsel of Record
+United States District Judge

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+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+Case No. 9:10-cv-81111-WPD
+M.J.,
+Plaintiff,
+vs.
+JEFFREY EPSTEIN and
+Defendant.
+# RENEWED MOTION OF DEFENDANT JEFFREY EPSTEIN TO QUASH SERVICE OF PROCESS AND SUPPORTING MEMORANDUM OF LAW
+Defendant Jeffrey Epstein, by and through undersigned counsel, respectfully moves pursuant to Fed. R. Civ. P. 12(6)(5) to quash service of process, and without waiving any available jurisdictional defenses and without making a general appearance, states as follows.
+# SUMMARY OF ARGUMENT
+Plaintiff, M.J., attempted to effect service on Mr. Epstein by leaving a copy of the Summons and Complaint in an unmarked, unaddressed and unpostmarked envelope in a mailbox at Mr. Epsteins' vacation house at 9 East 71" Street, New York, New York, at an unknown time between October 8, 2010 and October 13, 2010, and by purportedly leaving a summons with "Mark" at Mr. Epstein's alleged "residence or usual place of abode." Such purported "service" does not comply with the requirements of service of process under New York, Florida or federal law. The attempt at service of process was ineffective. Service of process should be quashed.
+#### BACKGROUND
+I. The Complaint in this action was filed, and a summons was issued as to Jeffrey Epstein, on September 17, 2010.
+2. The Proof of Service filed by Plaintiff (D.E. 11 at 3) recites that the process server left the summons at Mr. Epstein's
+> residence or usual place of abode with Mark, a person of suitable age and discretion who resides there, on Oct. 8, 2010, and mailed a copy to the individual's last known address ....
+The foregoing proof of service was originally filed on October 29, 2010. (D.E. 5). It was subsequently stricken (D.E. 10), and then refiled on November 2, 2010 (D.E. 11).
+3. On Wednesday, October 13, 2010, an unmarked, unaddressed and unpommarked envelope was discovered in the mailbox at Mr. Epstein's vacation home at 9 East 71" Street, New York, New York. The envelope contained a Summons and Complaint in the subject action, a Civil Rico Case Statement, a deposition subpoena, notices of video depositions, interrogatories and requests for production. (Affidavit of Richard Barnett, D.E. 7-1; Exhibit "A" to D.E. 7).
+4. According to the Affidavit of Richard Barnett, who was at the premises the entire day of October 8, 2010, no individual by the name of "Mark" worked, resided or was present on the premises of 9 East 71" Street, New York, New York. (Supplemental Affidavit of Richard Barnett, D.E. 12-1; Exhibit "A" to D.E. 12).
+Case No. 9:10-cv-81111-WPD
+#### ARGUMENT
+## NO SERVICE WAS MADE ON MR. EPSTEIN
+In this action three methods of service of process arc authorized by the Federal Rules of Civil Procedure. First, service can be effected pursuant to the procedures "in the state where the district court is located" - i.e. Florida. See Fed. R. Civ. P. 4(e)(1). Second, service can be effected in accordance with the procedures "in the state ... where service is made" - i.e. New York. Id. Finally, service can be effected pursuant to federal procedures by delivering a copy of the summons and complaint to the individual personally, leaving a copy of same at the individual's dwelling "with someone of suitable age and discretion who resides there" or delivering a copy to an agent authorized to accept service of process. See Fed. R. Civ. P. 4(e)(1). Service was not effected pursuant to any of the foregoing methods of service.
+No Service Under Florida Law. Under § 48.031(1)(a), Fla. Stat., service "is made by delivering a copy of it to the person to be served with a copy of the complaint, petition, or other initial pleading or paper or by leaving the copies at his or her usual place of abode with any person residing therein who is 15 years of age or older and informing the person of their contents ...." Plaintiff did not comply with § 48.031(1)(a), Fla. Stat. First, leaving an unmarked envelope with a summon and complaint in a mailbox at a vacation residence does not comply with § 48.031(I)(a), Fla. Stat. Second, although the process server recited that he left the summons with "Mark," there was no "Mark" on the premises on October 8, let alone a "Mark" who resided at 9 East 71' Street. (See Ex. B). Finally, the proof of service does not state that "Mark" was informed of the contents of the complaint, as required by § 48.031(1Xa), Fla. Stat.
+Case No. 9:10-cv-8I 1 1 1 -WPD
+No Service Under New York Law. Under New York law, personal service may be made by delivering the summons and complaint to the defendant or "to a person of suitable age and discretion at the actual place of business, dwelling place or usual abode of the [defendant]," and by mailing the summons and complaint to the person to be served at his last known address. N.Y.C.P.L.R. § 308(2). (McKinney 2008). In addition, proof of such service must be "filed with the clerk of the court designated in the summons within twenty days of either such delivery or mailing, whichever is effected later." Id. The foregoing requirements were not satisfied in the instant case. First, merely leaving an unmarked envelope with a summons and complaint in a mailbox does not constitute "mailing" under New York law. Second, there was no substitute service because there was no "Mark" on the premisses on October 8, 2010. (See Ex. B). Third, in violation of New York law, proof of service was not filed with the Clerk of the United States District Court for the Southern District of Florida within twenty (20) days of purported service. See C.P.L.R. § 308(2). Although the summons was purportedly delivered on October 8, 2010, it was not filed in the district court until October 29, 2010 -- after the 20-day period expired. Finally, C.P.L.R. 308(2) requires that the proof of service state the "date, time and place of service ...." The Affidavit filed by Plaintiff does not state the time or place of service, as required by C.P.L.R. § 308(2).
+Failure to comply strictly with the requirements of C.P.L.R. 308(2) requires dismissal. See, e.g., Fova, Inc. v. Latino Films, Inc., 2010 N.Y. Misc. LEXIS 4069, at \*7 (Sup. Ct. N.Y. County Aug. 11, 2010) (affidavit of service which failed to state address that the summons was mailed to was a jurisdictional defect requiring dismissal); Stanley Agency v. Behind the Bench, 2009 N.Y. Misc. LEXIS 833, at \*21 (Sup. Ct. Kings County April 13, 2009) (same).
+Case No. 9: I 0-cv-811 I I -WPD
+No Service Under Federal Law. Under Fed. R. Civ. P. 4(e)(2), service is effected by delivering a copy of the summons and complaint to the defendant personally, by leaving a copy of same at the "individual's dwelling or usual place of abode with someone of suitable age and discretion who resides there; or by delivering a copy of same "to an agent authorized by appointment or by law to receive service of process." Service was not effected pursuant to any of foregoing provisions of federal law.
+Accordingly, service of process must be quashed because it was invalid under Florida, New York and federal law.
+Certificate of Good Faith Conference Pursuant to S.D. Fla. L.R. 7.1. I hereby certify that counsel for the movant has conferred with all parties or non-parties who may be affected by the relief sought in this motion in a good faith effort to resolve the issues but has been unable to do so.
+WHEREFORE, Defendant Jeffrey Epstein respectfully requests that service of process be quashed.
+Case No. 9:10-cv-81111-WPD
+Respectfully submitted,
+E. Kni ht
+E. Knight
+Fla. Bar No. 607363
+Helaine S. Goodner
+Fla. Bar No. 462111
+Lilly Ann
+Fla. Bar No. 195677
+L. Ackerman
+Fla. Bar No. 235954
+BURNETT P.A.
+Espirito Santo Plaza, 14th Floor
+1395 Brickell Avenue
+Miami, Florida 33131-3302
+Telephone: (305) 789-9200
+Facsimile: (305) 789-9201
+Counsel for Defendant Jeffrey Epstein
+# CERTIFICATE OF SERVICE
+I hereby certify that on November 10, 2010, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing.
+Si E. Knight
+. Knight
+Fla. Bar No. 607363
+Case No. 9:10-cv-81111-WPD
+## SERVICE LIST
+M.J. v. Epstein
+Case No. 9:10-cv-81111-WPD
+United States District Court, Southern District of Florida
+J. brad a athto'ustice.com
+, Jaffe, Weissing,
+Fistos & Lehrman, PL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone: (954) 524-2820 Facsimile: (954) 524-2822 Attorneys for Plaintiff M.J. Served via CM/ECF

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+## AFFIDAVIT OF JAMES
+- 1. I am an attorney in good standing with the Florida Bar and admitted to practice in the Southern District of Florida.
+- 2. The law firm of Jaffe Weissing Fistos and Lehrman, of which I am apartner, filed a recent lawsuit on September 17, 2010 against Jeffrey Epstein, case number 10- 81111, in federal Court in the Southern District of Florida.
+- 3. Defendant Epstein is aregistered sex offender as a result of his pleading guilty to felonies related to his illegal sexual conduct with minor children.
+- 4. Through discovery in other cases, I learned that Ghislaine Maxwell and Jean Luc Brunel were close friends and business associates of Mr. Epstein who had important and relevant information concerning Mr. Epstein.
+- 5. Both Ms. Maxwell and Mr. Brunel avoided having their depositions taken by relaying false information that they were out of the country with no intentions of returning.
+- 6. Ms. Maxwell relayed through counsel that, just before her scheduled deposition, her mother became deathly ill, and Ms. Maxwell was therefore going to be with her mother outside the United States with no intention of returning.
+- 7. She was photographed a month later in the United States attending Chelsea Clinton's wedding and that photograph was captured in US Weekly magazine.
+- 8. According to widely circulated press reports, including a 60 minutes documentary and Ian Halperin's book "Bad and Beautiful: Inside the Dazzling and Deadly World of Supermodels", Mr. Brunel has been known as adrug abuser that has molested children through his modeling agencies.
+- 9. Mr. Brunel frequently stayed at Epstein's house as a house guest and also has reported his primary address at an apartment building in New York at 301 East 66th Street, an apartment that is believed to be owned by Mr. Epstein.
+- 10. Mr. Brunel visited Mr. Epstein approximately 67 times while Mr. Epstein was in jail serving his jail sentence for his sexual crimes in Palm Beach County.
+- 11. Mr. Brunel was set for deposition and avoided his deposition by providing information through his counsel that he was out of the country with no intention of ever returning to the United States.
+- 12. When Mr. Brunel relayed the information that he was out of the country with no plans to return, he was actually staying with Mr. Epstein at Mr. Epstein's according to Mr. Epstein's probation logs.
+- 13. During discovery it was nearly impossible to take the deposition of someone that could provide relevant information against Mr. Epstein that was not represented by an attorney being paid by Mr. Epstein.
+- 14. It was learned that in addition to paying for his own counsel, Mr. Epstein also paid for counsel for the following other material witnesses: (Epstein's executive assistant and procurer of girls for him to abuse), Larry Visoski (Epstein's personal pilot), Dave Rogers (Epstein's personal pilot), Larry (Epstein's personal pilot), (Epstein's housekeeper), (Epstein's live-in sex slave), Ghislaine Maxwell (manager of Epstein's affairs and businesses) , Mark Epstein (Epstein's brother), and Janusz Banasiak (Epstein's house manager).
+1. 15. In this case of MJ v. Jeffrey Epstein, case 10-81111, I contacted Mr. Epstein's counsel, Mr. Knight to request that he accept service for his client and he declined.
+2. 16. My law firm was then forced to retain the services of ██████████ Marsigliano, a private investigator in New York, to serve Mr. Epstein.
+3. 17. My law firm has been forced to spend more than \$1,400.00, on the service of process in this case to date.
+4. 18. In a previous civil case against Jeffrey Epstein that I litigated on behalf of my client, Jane Doe, case number 08-80893, Mr. Epstein invoked his 5<sup>th</sup> amendment right against self-incrimination on nearly all discovery requests as well as all relevant questions posed to him and his co-conspirators in deposition.
+5. 19. One piece of "evidence" that Mr. Epstein was ordered to produce included correspondence between him and his lawyers and the United States government.
+6. 20. Mr. Epstein alleged to have produced all correspondence from the U.S. government to him or his attorneys but did not produce that correspondence from him or his attorneys to the government.
+7. 21. I recently learned that there exists additional correspondence between Mr. Epstein or his attorneys and the United States government that was not produced for some unknown reason.
+8. 22. Specifically, I learned that there exists correspondence between Epstein attorney Lilly Ann ██████████ and former United States prosecutor Matthew Menchel as well as between Epstein attorney Ken Starr and various government attorneys and/or supervisors.
+I declare under penalty of perjury that the foregoing is true and correct.
+FURTHER AFFIANT SAYETH NAUGHT.
+Dated this 11<sup>th</sup> day of November, 2010.
+![]()The foregoing instrument was acknowledged before me this 11th day of November, 2010 by BRAD ██████████, who is personally known to me.
+![]()Print Name: \_\_\_\_\_
+My Commission Expires:
+![](_page_1_Picture_396.jpeg)

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+## UNITED STATES DISTRICT COURT
+## SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 9:10-CV-81111-WPD
+IN RE PLAINTIFF MJ
+## AFFIDAVIT OFD MARSIGLIANO
+1. Your Affiant is aformer New York City Police Detective and acurrent private investigator licensed by the State of New Yo11242nduct investigatio rve process, <sup>I</sup>have been retained by the law firm of Jaffe Weissing Fistos and Lehrman to serve a summons, complaint, subpoena for deposition, interrogatories, request for production on Jeffrey Epstein. The case is MJ v. Jeffrey Epstein, No. 10-81111, and is currently pending in the U.S. District Court for the Southern District of Florida.
+2. On Se tember 20, 2010 I received apackage from the law firm of I.! . Jaffe Weissing Fistos and Lehrman which contained the summons, complaint, subpoena for deposition, interrogatories, request for production on MJ v. Jeffrey Epstein. <sup>I</sup> was advised by Michael Fisten, a Florida Licensed Private Investigator who is working for the law firm of la Jaffe Weissing MIS Fistos and Lehrman that the summons should be served at Epstein's New York residence located at 9 East 71 Street, New York City, New York.
+3. I had learned from Investigator Fisten that Epstein's New York residence has been featured in Magazines and News Papers as aresidence that once belonged to Epstein's long time associate Leslie Wexner and now belongs to Jeffrey Epstein. Investigator Fisten also related to me that while Epstein was on probation in 2010, Epstein listed his residence in New York as 9 East 71 Street on official probation travel documents and that an asset investigation revealed that Epstein was the owner of the residence.
+4. On Tuesday the 21' Day of September 2010 your Affiant conducted surveillance at the Epstein residence. Activity was observed in and out of the residence which would indicate that persons(s) were residing within. At one point Federal Agents from the Department of State secured the Epstein residence and closed the street where the residence was located. The State Department Agents were providing security for aforeign dignitary that was visiting the Epstein residence.
+5. On Friday the 8th day of October 2010, your Affiant knocked on the residential front door of the Epstein residence located at 9 East 71 Street, New York, New York. <sup>A</sup> male who identified himself as "Marc" answered the front door. Your Afliant advised "Mark" that I was a New York Private Investigator and that I had court papers to serve on Jeffrey Epstein for a lawsuit in Florida. Mark advised that Mr. Epstein was not at home at the time. Mark agreed to accept service for Mr. Epstein. I left the summons, complaint, subpoena for deposition, interrogatories, request for production with "Mark" who reentered the residence carrying the package in his hands.
+6. Based on my interaction with "Mark" and my observations, it was obvious that "Mark" was familiar with Jeffrey Epstein, had authority to answer the door of Mr. Epstein's home and accept service for Mr. Epstein.
+7. Mark agreed to give the papers to Mr. Epstein or Epstein's lawyers before accepting the documents and returning back inside the home.
+8. Your affianiared the proper return of service documents and forwarded them to Attorney to file in Florida.
+<sup>I</sup>declare under penalty of perjury that the foregoing is true and correct.
+FURTHER AFFIANT SAYETH NAUGHT.
+Dated this dcday of November, 2010.
+omas M ano, Private Investigator
+The foregoing instrument was acknowledged before me this ,..5"Lh day of November, 2010 by Marsigliano, who is personally known to me. ntooi!i4.0~ ALLSIssigat
+My Commission Expires:
+## NOTARY PUBLIC
+Print Names
+worn OESSNER stare at Now York No. SO404970982 OuoRiled In laNnou\_C <sup>f</sup>Commission Expires nw=14

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+**IMPORTANT MESSAGE**
+FOR Jeffrey
+DATE 4/1/05 TIME 8:08 A.M.
+P.M.
+M Jean-Luc
+OF \_\_\_\_\_
+PHONE/
+MOBILE 646 286 7000
+| TELEPHONED         | <u>8</u> | PLEASE CALL       |  |
+|--------------------|----------|-------------------|--|
+| CAME TO SEE YOU    |          | WILL CALL AGAIN   |  |
+| WANTS TO SEE YOU   |          | RUSH              |  |
+| RETURNED YOUR CALL |          | SPECIAL ATTENTION |  |
+MESSAGE He has a teacher
+for you to teach you
+how to speak Russian.
+Shez is 2x8 years old
+not blande Lessons are
+free and you can
+have for today if you
+call
+SIGNED \_\_\_\_\_
+1184

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+#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
+JANE DOE, CASE NO. 08-CV-80893-CIV-MARRA/
+Plaintiff,
+Vs.
+JEFFREY EPSTEIN, et al.
+Defendant.
+Related Cases:
+08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
+### PLAINTIFF JANE DOE'S MOTION FOR AN ORDER TO SHOW CAUSE AND FOR AN ORDER TO COMPEL AND INCORPORATED MEMORANDUM OF LAW
+Plaintiff, Jane Doe, respectfully files this motion for entry of an order directed to Jean Luc Brunel and his counsel ordering them to show cause why they should not be held in contempt, for sanctions, and for an order compelling Jean Luc Brunel to appear for a deposition within 20 days. After plaintiff Jane Doe served Brunel with a subpoena for a deposition in this case, his attorney, on his behalf, represented that Brunel would appear for a deposition if Jane Doe would postpone the scheduled deposition date. As an accommodation to him, Jane Doe did postpone the scheduled deposition date, but then Brunel has not appeared as agreed for a deposition. After much communication in an attempt to coordinate Brunel's deposition, Brunel's counsel represented that Brunel was outside of the country, and thus unavailable, when in fact he was inside the country
+and easily available for a deposition. Because of these false representations, this Court should direct Brunel and his counsel to show cause why they should not be held in contempt. This Court should also compel Brunel to appear for the deposition that was previously scheduled and that he has avoided only through these false representations. Finally, the Court should sanction the appropriate person(s) for causing the undersigned to spend unnecessary time filing this motion.
+# BACKGROUND
+Jane Doe personally served Jean Luc Brunel in New York City to appear for deposition in this case. The subpoena indicated a deposition date of September 22, 2009 at 10:00 A.M. in New York City, New York. Brunel is an important witness in this case, as he is a good friend of Epstein's and has information regarding Epstein's pattern and practice of obtaining young girls for sexual purposes, relevant issues not yet admitted by Defendant Epstein.
+Shortly after Brunel was served, counsel for Jane Doe was contacted by Tama Beth Kudman, Esq., a licensed attorney in Florida. Kudman stated that she represented Brunel with regard to the subpoena and that she would produce Brunel for deposition in West Palm Beach if Jane Doe would agree not to go forward with the deposition date in New York. Counsel for Jane Doe honored that request, and with Kudman jointly arranged a deposition date for Brunel in West Palm Beach for October.
+Shortly before his deposition was to take place, Ms. Kudman contacted counsel for Jane Doe to move that deposition date because of a personal conflict. Once again, counsel for Jane Doe agreed. After several conversations regarding the deposition of
+Brunel, Kudman asked that counsel for Jane Doe set Brunel for deposition in January of 2010, as that was a time when she could assure his availability.
+In January, counsel for Jane Doe again contacted Ms. Kudman to arrange a mutually convenient deposition time. Ms. Kudman stated that Brunel would be in Florida the first week of February and she would work to coordinate his deposition for that time.
+The undersigned's office contacted Ms. Kudman's office on several occasions in January to coordinate a February deposition date of Brunel. On January 29, 2010, Ms. Kudman returned the call and left a voicemail apologizing for not returning the call sooner and indicating that she had only been waiting to hear from Mr. Brunel as to his availability, and she invited the undersigned to contact her the following week to set it up. On February 5, 2010, counsel for Jane Doe contacted Ms. Kudman to coordinate Brunel's deposition. During that telephone conversation, Ms. Kudman represented that her client, Mr. Brunel, had previously left the country to go to his home country of France before the New Year. Ms. Kudman further represented that while she believed he was going to return, it turned out that he had no plans to return. Ms. Kudman also stated that if Brunel was in the country, she would make good on her representation that she would produce him. However, she had just spoken to him via a telephone call from him in France. Brunel told Kudman that he was staying there indefinitely with no plans to return. In subsequent telephone conversations, Ms. Kudman continued to represent that Mr. Brunel had been out of the country since sometime prior to the New Year and was not planning to return.
+Counsel for Jane Doe responded that this representation seemed quite strange, since Brunel has a significant business in the United States. Kudman replied that it was simply too expensive for him to return and that because of the expense he had no intentions of returning. Counsel for Jane Doe then pointed out that when Brunel was served, Kudman had promised he would be produced for deposition. Kudman replied that because he is in France with no plans to return there was simply nothing she could do. Kudman further advised counsel for Jane Doe that if he wanted to take Brunel's deposition in France, then it would be necessary to obtain a Letters Rogatory and go through the Consulate. After these procedures, Kudman then indicated it would be necessary to take a trip to France for his deposition. Counsel for Jane Doe indicated that he might be willing to go through that process, but that he would like for Kudman to tell him if Brunel happened to return to the United States. Kudman promised that she would.
+Remarkably, after all of these representations had been made by Kudman, it turns out that Brunel was actually in the United States during the time when Jane Doe was trying to take his depositon. In fact, on February 16, 2010, counsel for Jane Doe took the deposition of Jeffrey Epstein's house manager, Janusz Banaziak. Mr. Banaziak was asked if he knew Mr. Brunel. In summary, he responded that he knew him as Mr. Epstein's friend. He elaborated that Mr. Brunel had stayed with Epstein at Epstein's Palm Beach home on at least two occasions in 2010. The first 2010 visit was in January, when Mr. Brunel stayed for approximately 3 days. Then Mr. Brunel stayed at Mr. Epstein's home from approximately February 1091 or 11'" through February le,
+2010. It was known by Epstein that Brunel was coming to stay at the house in February 2010, as he was picked up at the airport and driven to Epstein's home by Epstein's bodyguard, Igor Zinoview, and after his stay with Epstein, Brunel was driven from Epstein's house to the airport by . See deposition of Janusz Banaziak at page 154-161 and 168-16 attached hereto as Exhibit "A."
+## MEMORANDUM OF LAW
+As is readily apparent from the foregoing facts, Ms. Kudman has either made false representations about Mr. Brunet's whereabouts or Mr. Brunel has made false representations about his whereabouts that she passed on. In either case, they should be required to show cause why her and/or she should not be held in contempt of court for making false representations. See, e.g., Acton v. Target Corp., 2009 WL 5214419 at \*5 (W.D. Wash. 2009) (entering order to show cause why counsel should not be held in contempt for making false representations). In particular, Mr. Brunel and Ms. Kudman should explain how it came to pass that Mr. Brunel was in Florida at the very time that Jane Doe was attempting to take his deposition while Ms. Kudman was confidently reporting that he was unavailable in France. Given the known facts, Ms. Kudman was either an unwitting messenger who passed along false representations delivered to her by her client Mr. Brunel, or she was a knowing participant in Brunel and/or Epstein's attempt to obstruct discovery; either way a show cause order should be entered and the appropriate person(s) sanctioned and held in contempt.
+Mr. Brunel and Ms. Kudman should also be required to provide a full explanation of who precisely is paying the attorney fees for Ms. Kudman's services. Most, if not all,
+of the witnesses that have been deposed in this and related cases against Epstein have appeared with counsel retained and paid for by Defendant Jeffrey Epstein. In this instance, we know that Mr. Epstein was together with his house guest, Mr. Brunel, at a time when Brunel's counsel was representing that Brunel was out of the country and could thus not attend a deposition. Mr. Epstein also knew at that time that the undersigned had been trying to coordinate Brunel's deposition for months. Therefore, there is no doubt that Mr. Epstein was assisting Mr. Brunel and/or Ms. Kudman in obstructing discovery. At the very least, Mr. Epstein was an accomplice, but was he the person paying the attorney to make false representations and tamper with important witnesses? While Mr. Epstein may be able to invoke his 5th amendment rights on such questions, Mr. Brunel and Ms. Kudman do not have that luxury, and at this point they should be required to provide these answers.
+Again, as the facts make clear, Ms. Kudman has not delivered on promises made (as an officer of the court) to counsel for Jane Doe, and Mr. Brunel has not appeared for a deposition. As such, Jane Doe moves this Court to enter an order directing Mr. Brunel to promptly appear for a deposition in West Palm Beach within 14 days. He was properly served with a subpoena by Jane Doe, and only through deceitful maneuvers he has been able to avoid his deposition. This Court should not permit subpoenas to be avoided in this fashion.
+WHEREFORE, Jane Doe respectfully requests the Court to direct Mr. Brunel and Ms. Kudman to show cause why they should not be held in contempt for making false representations in an effort to avoid a deposition. If the Court finds that they are in
+contempt, the Court should also impose appropriate sanctions, including attorney's fees for Jane Doe in connection with filing this motion. The Court should also compel Mr. Brunel to appear for a deposition within 14 days of the Court's order and grant any additional relief the Court deems just and proper.
+# PRE-FILING CONFERENCE
+Counsel for Jane Doe has attempted to confer with Ms. Kudman about this motion, but she declined to make Brunel available for deposition, and in fact has again stated as recently as March 5, 2010 that Brunel has been out of the country since prior to the New Year with no plans to return.
+DATED: March 10, 2010
+Respectfully Submitted,
+AFFE, WEISSING, , FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com
+and
+Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu
+### CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on March 10, 2010, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically filed Notices of Electronic Filing.
+> s/ J.
+### SERVICE LIST
+Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq. Jaoldberaer@aawoa.com
+Robert D. Critton, Esq. rcritton@bciclaw.com
+Isidro Manual isidrogarcia@bellsouth.net
+Jack jph@searcylaw.com •
+Katherine Warthen Ezell KEzell@podhurst.com
+Michael James Pike MPike@bciclaw.com
+Paul G. Cassell cassellp@law.utah.edu
+Richard Horace Willits lawyerswillits@aol.com
+Robert C. Josefsberg
+CASE NO: 08-CV-80119-MARRA/[REDACTED]
+[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com)
+Adam D. Horowitz
+[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com)
+Stuart S. Mermelstein
+[ssm@sexabuseattorney.com](mailto:ssm@sexabuseattorney.com)

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