Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 1 of 91 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA P| CASE NO.: 08-CV-80811-CIV-MARRA/JJOHNSON Plaintiff(s), vs. JEFFREY EPSTEIN and] Pl Defendant(s). FIRST AMENDED COMPLAINT Parties, Jurisdiction and Venue COMES NOW the Plaintit, and brings this First Amended Complaint against the Defendants, JEFFREY EPSTEIN and SARAH KELLEN, and states as follows: 1. This is an action for damages in excess of $75,000.00, exclusive of interest and costs. 2. This Complaint is brought under a fictitious name in order to protect the identity of the Plaintiff, i. because this Complaint makes allegation of sexual assault and child abuse of a then minor. 3. At all times material to this cause of action, the Plaintist, was a resident of [as 3505-025 Page | of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003349 EFTA00157731

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 2 of 91 Hl. :. Epstein, et al. Case No.; 08-CV-80811-CIV-MARRA/JJOHNSON First Amended Complaint 4, At all times material to this cause of action, the Defendant, JEFFREY EPSTEIN, had a residence located in Palm Beach County, Florida. 5. At all times material to this cause of action, the Defendant, JEFFREY EPSTEIN, was an adult male, born in 1953. 6. This Court has jurisdiction of this action and the claim set forth herein pursuant to 18 U.S.C. §2255. 7. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial part of the events or omissions giving rise to the claim occurred in this district. 8. At all times material, the Defendant, JEFFREY EPSTEIN, owed a duty unto Plaintiff, | to treat her in a non-negligent manner and to not commit intentional or tortious illegal acts against her. Factual Allegations 9. Upon information and belief, the Defendant, JEFFREY EPSTEIN, has demonstrated a sexual preference and obsession for minor girls. He engaged in a plan, scheme, and enterprise in which he gained access to economically disadvantaged minor girls, such as Plaintiff, m7. sexually assaulted these girls, and/or coerced them to engage in prostitution, and in return gave these girls money. 10. The Defendant's plan, scheme and enterprise included an elaborate _ system wherein the then minor Plaintiff and other minor girls were brought to the 3505-025 Page 2 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003350 EFTA00157732

--=PAGE_BREAK=--

| Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 3 of 91 Hs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint Defendant, JEFFREY EPSTEIN’'S, residence by the Defendant's employees and assistants. When the employees and assistants left the then minor Plaintiff and other minor girls alone in a room at the Defendant's mansion, the Defendant, JEFFREY EPSTEIN, himself would appear, remove his clothing, and direct the then minor Plaintiff to remove her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including, but not limited to, masturbation, touching of the then minor Plaintiff's breasts and buttock, and solicitation and enticement of the then minor Plaintiff to engage in sexual acts with another female in JEFFREY EPSTEIN'’S presence, 41. The Plaintiff, was the first brought to the Defendant, JEFFREY EPSTEIN’S, mansion in late May or early June of HEE when she was fifteen-years old and in middle school. 12. The Defendant, JEFFREY EPSTEIN, a wealthy financier with a lavish home, significant wealth, a network of assistants and employees, used his resources and his influence over a vulnerable minor child to engage in a systematic pattern of sexually exploitive behavior. 13. Beginning in approximately late May or early June of || and continuing until approximately August of MM the Defendant coerced and enticed the impressionable, vulnerable, and economically deprived then minor Plaintiff to commit various acts of sexual misconduct. These acts occurred, on average, one to three times per week from late May or early June of I until August of J. At a bare minimum, 3505-025 Page 3 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003351 EFTA00157733

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 4 of 91 vs. Epstein, et al. ase No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint these acts occurred twice a month from June || until August of i. While the precise dates these acts occurred are unknown to Plaintiff, including those weeks in which no acts occurred, these dates are known by Defendant, JEFFREY EPSTEIN, as he is reported to have kept a written log of each and every instance in which he engaged in these illegal acts with the then minor Plaintiff, IEE and others. These acts included, but were not limited to, fondling and inappropriate and illegal sexual touching of the then minor Plaintiff, sexual misconduct and masturbation of the Defendant, JEFFREY EPSTEIN, in the presence of the then minor Plaintiff, soliciting and enticing the then minor Plaintiff to engage in sexual acts with another female in JEFFREY EPSTEIN'S presence, and encouraging the then minor Plaintiff to become involved in prostitution; Defendant, JEFFREY EPSTEIN, committed numerous criminal sexual offenses against the then minor Plaintiff including, but not limited to, sexual battery, solicitation of prostitution, procurement of a minor for the purpose of prostitution, and lewd and lascivious assaults upon the person of the then minor Plaintiff. 14. Defendant, JEFFREY EPSTEIN, used his money, wealth and power to unduly and improperly manipulate and influence the then minor Plaintiff. 15. The acts referenced in paragraphs 9 through 14, committed by Defendant, JEFFREY EPSTEIN, against the then minor Plaintiff, [III were committed in violation of numerous criminal State and Federal statutes condemning the sexual 3505-025 Page 4 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003352 EFTA00157734

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 5 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JJOHNSON First Amended Complaint exploitation of minor children, prostitution, sexual performance by a child, lewd and lascivious assaults, sexual battery, contributing the delinquency of a minor and other crimes, specifically including, but not limited to, those crimes designated in 18 USC §2241, §2242, §2243, §2421, and §2423, criminal offenses outlined in Chapter 800 of the Federal Codes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §39.01; and §827.04, 16. The above-described acts took place in Palm Beach County, Florida, at the residence of the Defendant, JEFFREY EPSTEIN. Any assertions by the Defendant, JEFFREY EPSTEIN, that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual exploitation and abuse of a minor child. The Defendant, JEFFREY EPSTEIN, at all times material to this cause of action, knew and should have known of the Plaintiff, EEE minority. 17. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, the Defendant, JEFFREY EPSTEIN, entered pleas of “guilty” to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purpose of prostitution. 18. As a condition of that plea, and in exchange for the Federal Government not prosecuting the Defendant, JEFFREY EPSTEIN, for numerous federal offenses, Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the 3505-025 Page 5 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003353 EFTA00157735

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 6 of 91 ia vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less”. 19. The Defendant, JEFFREY EPSTEIN, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged in this Complaint, and must effectively admit liability to the Plaintiff, EE COUNT c ion Pursuant to 1 iC §225: 20. The Plaintiff, | | adopts and realleges paragraphs 1 through 19 above. 3505-025 Page 6 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003354 EFTA00157736

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 7 of 91 a... Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 21. In late May or early June of SJ was first introduced to Defendant, JEFFREY EPSTEIN. [MJ was brought to JEFFREY EPSTEIN’S residence by a female friend of hers. MJ sat on the couch while the female friend took off her own clothes, mounted JEFFREY EPSTEIN who was wearing only a towel and lying on a table, and performed a sexual act upon JEFFREY EPSTEIN in the presence of In exchange for her participation as an observer of JEFFREY EPSTEIN'S lewd and lascivious conduct, mz was paid $300 by JEFFREY EPSTEIN. 22. As acondition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in 3505-025 Page 7 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003355 EFTA00157737

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 8 of 91 vs. Epstein, et al. Case No.: 08-CV-8081 1-CIV-MARRA/JOHNSON First Amended Complaint the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 23. The Plaintiff, || was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United i States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 24. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, J. and as such he must effectively admit liability unto the Piaintitt 25. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, i. has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, ME, will in the future suffer additional medical and psychological expenses. The Plaintiff, IE. 3505-025 Page 8 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003356 EFTA00157738

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 9 of 91 HEE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, I, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, IMJ, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT It Cause of Action Pursuant to 18 USC §2255 June Inc it 2 26. The Plaintiff, | | adopts and realleges paragraphs 1 through 19 above. 27. Approximately one week after the first incident, IMME received a telephone call from JEFFREY EPSTEIN requesting that she return to his residence. On this occasion, JEFFREY EPSTEIN directed [J to undress to her brassiere and underwear and to provide him with a massage. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in TR oresence. JEFFREY EPSTEIN paid C.M.A. $300 for this encounter. 3505-025 Page 9 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003357 EFTA00157739

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 10 of 91 vs. Epstein, et al. se No.: 08-CV-8081 1-CIiV-MARRA/JOHNSON First Amended Complaint 28. As acondition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 29. The Plaintiff, || was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 3505-025 Page 10 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003358 EFTA00157740

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 11 of 91 || vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 30. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff MMMM and as such he must effectively admit liability unto the Plaintitt 31. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, | | has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, RE, will in the future suffer additional medical and psychological expenses. The Piaintitt J. 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, EE, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, IJ, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 3505-025 Page 11 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003359 EFTA00157741

--=PAGE_BREAK=--

aH Case 9:08-cv-80811-KAM Document39 — Entered on FLSD Docket 02/09/2009 Page 12 of 91 | | vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT Ill Cause of Action Pursuant to 18 USC §2255 July - Incident 1 32. The Plaintiff, a. adopts and realleges paragraphs 1 through 19 above. 33. In July EE again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed [MJ to undress to her underwear and to provide him with a massage. At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in im presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 34. As acondition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For 12 3505-025 Page 12 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003360 EFTA00157742

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 13 of 91 HEE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 35. The Plaintiff, [III was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 36. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, MM and as such he must effectively admit liability unto the Piaintitt, 37. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, HEE bas in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, 13 3505-025 Page 13 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003361 EFTA00157743

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 14 of 91 vs. Epstein, et al. Case No.: 08-CV-8081 1-CIV-MARRA/JOHNSON First Amended Complaint embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, J. will in the future suffer additional medical and psychological expenses. The Plaintitt, 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, IE will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, JI, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNTIV Cause of Ac! Pursuant to 1 2255 Jul — Incident 2 14 3505-025 Page 14 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003362 EFTA00157744

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 15 of 91 me: Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 38. The Plaintiff, i. adopts and realleges paragraphs 1 through 19 above. 39. For the second time in July of [IEEE again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed || to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor J At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in [EEE presence. JEFFREY EPSTEIN paid [IJ in excess of $200 for this encounter. 40. Asacondition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in 15 3505-025 Page 15 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003363 EFTA00157745

--=PAGE_BREAK=--

oo Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 16 of 91 Hl .s. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 41. The Plaintift I, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 42. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Piaintit and as such he must effectively admit liability unto the Plaintiff, i. 43. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, a. has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, [I will in the future suffer additional medical and psychological expenses. The Plaintiff, im. 16 3505-025 Page 16 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003364 EFTA00157746

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 17 of 91 Hl vs. Epstein, et al. Case No.; 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, [EEE will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, JM. demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT V Cause of Action P: ant to 18 USC §22: August — Incident 1 44. The Plaintiff, mz. adopts and realleges paragraphs 1 through 19 above. 45. In August of IMM again returned to JEFFREY EPSTEIN’S residence at his request. On this occasion, JEFFREY EPSTEIN directed [III to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, [J the breasts and buttocks of the then minor [I At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in [BEE presence. JEFFREY EPSTEIN paid | in excess of $200 for this encounter. 17 3505-025 Page 17 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003365 EFTA00157747

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 18 of 91 || vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 46. As acondition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense, For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 47. The Plaintitt, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 3505-025 Page 18 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003366 EFTA00157748

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 19 of 91 HEE vs. Epstein, et al. Case No.:; 08-CV-80811-CiV-MARRA/JOHNSON First Amended Complaint 48. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, MM. and as such he must effectively admit liability unto the Plaintitt, 49. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, || has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, HEE, will in the future suffer additional medical and psychological expenses. The Plaintiff ME, 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, i. will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, I. demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 3505-025 Page 19 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003367 EFTA00157749

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 20 of 91 Hl vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT VI ause of in uant to 18 USC §2255 August mi Incident 2 50. The Plaintiff, | | adopts and realleges paragraphs 1 through 19 above. 51. For the second time in August of | again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed | fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor J At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in f | presence. JEFFREY EPSTEIN paid il in excess of $200 for this encounter. 52. As acondition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 20 3505-025 Page 20 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003368 EFTA00157750

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 21 of 91 Gl. :. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 53. The Plaintiff, JI, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 54. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, [IMJ and as such he must effectively admit liability unto the Plaintitt 55. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, ia. has in the past suffered, and will in the future suffer, physical injury, pain and 21 3505-025 Page 21 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003369 EFTA00157751

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 22 of 91 Hl. :. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, a. will in the future suffer additional medical and psychological expenses. The 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, I, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, 4M. demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT Vil Cause of Action Pursuant to 18 USC §2255 September mz- Incident 1 56. The. Plaintiff, i. adopts and realleges paragraphs 1 through 19 above. 22 3505-025 Page 22 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003370 EFTA00157752

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 23 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 57. In September [J again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed [J to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN the breasts and buttocks of the then minor I At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in JIM) presence. JEFFREY EPSTEIN paid || in excess of $200 for this encounter. 58. As acondition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 23 3505-025 Page 23 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003371 EFTA00157753

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 24 of 91 Hs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 59. ‘The Plaintiff, | | was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 60. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, a. and as such he must effectively admit liability unto the Plaintitt, 61. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, HE. has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, IE. will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a 24 3505-025 Page 24 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003372 EFTA00157754

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 25 of 91 H:. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintif, I. will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, i. demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount , provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. vii Cause of Action Pursuant to 18 USC §2255 September —Ine! 2 62. The Plaintiff, i. adopts and realleges paragraphs 1 through 19 above. 63. For the second time in September JN again returned to JEFFREY EPSTEIN’S residence at his request. On this occasion, JEFFREY EPSTEIN directed [I to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondied the breasts and buttocks of the then minor | | At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid [Mj in excess of $200 for this encounter. 25 3505-025 Page 25 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003373 EFTA00157755

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 26 of 91 GEE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 64. As acondition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 65. The Plaintiff, I was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 3505-025 Page 26 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003374 EFTA00157756

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 27 of 91 || vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 66. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, | | and as such he must effectively admit liability unto the Piaintitt 67. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, | | has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, J will in the future suffer additional medical and psychological expenses. The Plaintitt 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, Hi. will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, JI demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 27 3505-025 Page 27 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003375 EFTA00157757

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 28 of 91 Hs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT IX Ca of n Pursuant to 18 USC §2255 October of | — Incident 1 68. The Plaintiff, | adopts and realleges paragraphs 1 through 19 above. 69. In October of P| again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor | At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in [MM presence. JEFFREY EPSTEIN paid || in excess of $200 for this encounter. 70, As acondition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 28 3505-025 Page 28 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003376 EFTA00157758

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 29 of 91 HEB vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 71. The Plaintiff, J was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 72. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, [III and as such he must effectively admit liability unto the Plaintiff, 73. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, HE has in the past suffered, and will in the future suffer, physical injury, pain and 29 3505-025 Page 29 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003377 EFTA00157759

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 30 of 91 HEB vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, [N. will in the future suffer additional medical and psychological expenses. The Plaintiff, I, 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 Plaintit, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, [II demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT X Cause of Action Pursuant to 18 USC §2255 tober — Incident 2 30 3505-025 Page 30 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003378 EFTA00157760

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 31 of 91 HEE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 74. The Plaintiff, MJ, adopts and realleges paragraphs 1 through 19 above. 75. For the second time in October fr again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 76. As acondition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in 31 3505-025 Page 31 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003379 EFTA00157761

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 32 of 91 | Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 77. The Plaintiff, | | was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 78. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, NMI. and as such he must effectively admit liability unto the Plaintiff, 79. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, | | has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff EE will in the future suffer additional medical and psychological expenses. The Plaintiff, | 32 3505-025 Page 32 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003380 EFTA00157762

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 33 of 91 iz vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, a. will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, JJ. demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XI Cai Pursuant to 18 USC §2255 November — Incident 1 80. The Plaintiff adopts and realleges paragraphs 1 through 19 above. 81. In November] again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed[to fully | undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then mince At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in | ey JEFFREY EPSTEIN paid || in excess of $200 for this encounter. 33 3505-025 Page 33 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003381 EFTA00157763

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 34 of 91 mz vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 82. As acondition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 83. The Plaintiff, | a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 34 3505-025 Page 34 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003382 EFTA00157764

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 35 of 91 HEE vs. Epstein, et al. Case No.: 08-CV-8081 1-CIV-MARRA/JOHNSON First Amended Complaint 84. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, IMJ, and as such he must effectively admit liability unto the Plaintitt, 85. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, HE has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, a. will in the future suffer additional medical and psychological expenses. The Piaintitt, 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, [IIE will continue to suffer these losses in the future. WHEREFORE, the Piaintit, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further ae 3505-025 Page 35 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003383 EFTA00157765

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 36 of 91 || vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT Xii Cause of Action Pursuant to 18 USC §2255 November of — Incident 2 86. The Plaintiff, || adopts and realleges paragraphs 1 through 19 above. 87. For the second time in November EE acain returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed | fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in | | presence. JEFFREY EPSTEIN paid J in excess of $200 for this encounter. 88. Asa condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the. Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 36 3505-025 Page 36 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003384 EFTA00157766

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 37 of 91 HEE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 89. The Plaintiff, i. was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 90. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, JINN} and as such he must effectively admit liability unto the Plaintirt 91. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, i has in the past suffered, and will in the future suffer, physical injury, pain and 37 Page 37 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003385 EFTA00157767

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 38 of 91 HB vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, EM. wil in the future suffer additional medical and psychological expenses. The Plaintiff, i. 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, the Plaintiff, a. demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. Ht n P. 18 USC §2255 o! |— Incident 1 92. The Plaintiff, || adopts and realleges paragraphs 1 through 19 above. 38 3505-025 Page 38 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003386 EFTA00157768

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 39 of 91 HBBME vs. Epstein, et al. Case No.: 08-CV-8081 1-ClV-MARRA/JOHNSON First Amended Complaint 93. In December EN again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor || At the conclusion of the massage, JEFFREY EPSTEIN masturbated himsetf. in EM presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 94. As acondition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the. intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 39 3505-025 Page 39 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003387 EFTA00157769

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 40 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 95. The Plaintiff, (Ij. was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code-and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 96. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, i. and as such he must effectively admit liability unto the Piaintitt, 97. Asa direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, 7 has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, a. will in the future suffer additional medical and psychological expenses. The Plaintiff, I. has suffered a loss of income, a loss of the capacity to earn income in the future, and a 3505-025 Page 40 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003388 EFTA00157770

--=PAGE_BREAK=--

oo Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 41 of 91 Hs. Epstein, et al. Case No.; 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, {. witt continue to suffer these losses in the future. WHEREFORE, the Plaintiff, I, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XIV Cause of Action Pursuant to 18 USC §2255 cel Incident 98. The Plaintit, adopts and realleges paragraphs 1 through 19 above. 99. For the second time in December NY again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed [EI to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor im At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in JM presence. JEFFREY EPSTEIN paid [Min excess of $200 for this encounter. 41 3505-025 Page 41 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003389 EFTA00157771

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 42 of 91 HEB vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 100. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 101. The Plaintitt, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 42 3505-025 Page 42 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003390 EFTA00157772

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 43 of 91 || vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 102. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, i. and as such he must effectively admit liability unto the Plaintiff, || 103. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, || has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Piaintitt, SI wil in the future suffer additional medical and psychological expenses. The 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, the Plaintiff, II, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 43 3505-025 Page 43 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003391 EFTA00157773

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 44 of 91 ls. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XV Cause of Action Pursuant to 18 USC §225: January of —In nt 1 104. The Plaintiff, i. adopts and realleges paragraphs 1 through 19 above. 105. In January MY again retumed to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed [EE to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor i | At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself yi presence. JEFFREY EPSTEIN paid | | in excess of $200 for this encounter. 106. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Govemment not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 44 3505-025 Page 44 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003392 EFTA00157774

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 45 of 91 | | vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 107. The Plaintiff, QE was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 108. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, [IIB and as such he must effectively admit liability unto the Plaintitt, 109. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, HE, has in the past suffered, and will in the future suffer, physical injury, pain and 45 3505-025 Page 45 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003393 EFTA00157775

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 46 of 91 Hl. Epstein, et al. Case No.: 08-CV-8081 1-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, | | will in the future suffer additional medical and psychological expenses. The Plaintiff, a. has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, | will continue to suffer these losses in the future. WHEREFORE, the Plaintif, IIE. demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further telief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XVI Cau tion P. 18 USC §22! nui — Incident 2 110. The Plaintiff, | | adopts and realleges paragraphs 1 through 19 above. 3505-025 Page 46 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003394 EFTA00157776

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 47 of 91 HEB vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 111. For the second time in January EJ again returned to JEFFREY EPSTEIN’S residence at his request. On this occasion, JEFFREY EPSTEIN directed || to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor a At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid || in excess of $200 for this encounter. 112. As acondition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No More; no less.” 47 3505-025 Page 47 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003395 EFTA00157777

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 48 of 91 Hs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 113. The Plaintiff, | | was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 114. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, || and as such he must effectively admit liability unto the Plaintitt, 115. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, HEEB hes in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, i. will in the future suffer additional medical and psychological expenses. The Plaintiff, | | has suffered a loss of income, a loss of the capacity to earn income in the future, and a 3505-025 Page 48 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003396 EFTA00157778

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 49 of 91 Hs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff BE. will continue to suffer these losses in the future. WHEREFORE, the Plaintitt demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XVII Cause of Action Pursuant to 18 USC §2255 Februa - it 1 116. The Plaintiff, a. adopts and realleges paragraphs 1 through 19 above. 117. In February MY again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed] to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid | | in excess of $200 for this encounter. 49 3505-025 Page 49 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003397 EFTA00157779

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 50 of 91 Hs. Epstein, et al. Case No.; 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 118. As a condition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 119. The Plaintiff, | | was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 3505-025 Page 50 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003398 EFTA00157780

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 51 of 91 || vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 120. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, a. and as such he must effectively admit liability unto the Piaintitt, 121. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, HEB. has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, J. will in the future suffer additional medical and psychological expenses. The Plaintiff, ID 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, J, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, a. demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 51 3505-025 Page 51 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003399 EFTA00157781

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 52 of 91 | vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/ JOHNSON First Amended Complaint . relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. co Lil] Cause rsuant 2255 Februa’ — Incident 2 122. The Plaintiff, | | adopts and realleges paragraphs 1 through 19 above. 123. For the second time in February MY again retumed to JEFFREY EPSTEIN'’S residence at his request. On this occasion, JEFFREY EPSTEIN directed {Jj to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor || At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in JD presence. JEFFREY EPSTEIN paid {J in excess of $200 for this encounter. 124. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, $2 3505-025 Page 52 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003400 EFTA00157782

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 53 of 91 HE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 125. The Plaintiff, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 126. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintif, HBB. ang as such he must effectively admit liability unto the Plaintit, 127. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, mz. has in the past suffered, and will in the future suffer, physical injury, pain and 53 3505-025 Page 53 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003401 EFTA00157783

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 54 of 91 HEE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff EEE will in the future suffer additional medical and psychological expenses. The Plaintiff, i. 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, IIE, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, HNL demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XIX Cause of Action Pursuant to 18 USC §2255 March — Incident 1 128. The Plaintif, [MMMM adopts and realleges paragraphs 1 through 19 above. 54 3505-025 Page 54 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003402 EFTA00157784

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 55 of 91 HE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/ JOHNSON First Amended Complaint 129. in March [BBM again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed [I to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor | | At the conclusion of the massage, JEFFREY EPSTEIN masturbated himsetf in [MIM presence. JEFFREY EPSTEIN paid || in excess of $200 for this encounter. 130. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 3505-025 Page 55 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003403 EFTA00157785

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 56 of 91 Hl: Epstein, et al. Case No.: 08-CV-8081 1-CIV-MARRA/JOHNSON First Amended Complaint 131. The Plaintiff, | | was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 132. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, IM. and as such he must effectively admit liability unto the Plainttt, 133. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, | | has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, JI. will in the future suffer additional medical and psychological expenses. The Plaintiff, IEE, has suffered a loss of income, a loss of the capacity to earn income in the future, and a 56 3505-025 Page 56 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003404 EFTA00157786

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 57 of 91 HEE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, IEEE. will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, I, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XX Cause of Action Pursuant to 18 USC §2255 March — Incident 2 134. The Plaintiff, a. adopts and realleges paragraphs 1 through 19 above. 135. For the second time in March of [EE again returned to JEFFREY EPSTEIN’S residence at his request. On this occasion, JEFFREY EPSTEIN directed | fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondied the breasts and buttocks of the then minor {Ml At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in | presence. JEFFREY EPSTEIN paid il in excess of $200 for this encounter. $7 3505-025 Page 57 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003405 EFTA00157787

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 58 of 91 HEB vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 136. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 137. The Plaintiff, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 58 3505-025 Page 58 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003406 EFTA00157788

--=PAGE_BREAK=--

oH Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 59 of 91 i vs. Epstein, et al. Case No.: 08-CV-8081 1-CIV-MARRA/JOHNSON First Amended Complaint 138. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, MIME, and as such he must effectively admit liability unto the Plaintiff 139. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, ma. has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, EEE, will in the future suffer additional medical and psychological expenses. The Plaintiff, IE. has suffered a loss of income, a loss of the capacity to eam income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff IEEE, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, JM. demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 59 3505-025 Page 59 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003407 EFTA00157789

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 60 of 91 HEB vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT Xx! use of n P to 18 USC §225! April o' — Incident 1 140. The Plaintiff, || adopts and realleges paragraphs 1 through 19 above. 141. In April PY again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed ia. fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor || At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself na presence. JEFFREY EPSTEIN paid mi. excess of $200 for this encounter. 142. As a condition of the Defendant, JEFFREY EPSTEIN'’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 60 3505-025 Page 60 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003408 EFTA00157790

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 61 of 91 Es. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 143. The Plaintiff, | | was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 144. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, MJ, and as such he must effectively admit liability unto the Plaintiff, 145. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, ia. has in the past suffered, and will in the future suffer, physical injury, pain and 61 3505-025 Page 61 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003409 EFTA00157791

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 62 of 91 vs. Epstein, et al. Case No.: 08-CV-8081 1-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, || will in the future suffer additional medical and psychological expenses. The Plaintitt, ID 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, the Plaintiff, I] demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XXil Cause of Ac Pursuant to 18 USC 5 April J 146. The Plaintiff). adopts and realleges paragraphs 1 through 19 above. 62 3505-025 Page 62 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003410 EFTA00157792

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 63 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 147. For the second time in April [EEE again returned to JEFFREY EPSTEIN'’S residence at his request. On this occasion, JEFFREY EPSTEIN directed HM to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor fd At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in i. presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 148. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 63 3505-025 Page 63 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003411 EFTA00157793

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 64 of 91 Hs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint ~ 149. The Plaintitt, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 150. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, a. and as such he must effectively admit liability unto the Plaintirt, 151. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, ; | has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, a. will in the future suffer additional medical and psychological expenses. The Plaintiff, | | has suffered a loss of income, a loss of the capacity to earn income in the future, and a 3505-025 Page 64 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003412 EFTA00157794

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 65 of 91 ia vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, || will continue to suffer these losses in the future. WHEREFORE, the Piaintirt A. demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XXII Cause of Action Pursuant to 18 USC §2255 May o' — Incident 1 152. The Plaintiff, ma. adopts and realleges paragraphs 1 through 19 above. 153. In May iz again returned to JEFFREY EPSTEIN’S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in i presence. JEFFREY EPSTEIN paid | | in excess of $200 for this encounter. 65 3505-025 Page 65 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003413 EFTA00157795

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 66 of 91 || vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 154. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 155. The Plaintiff, || was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 3505-025 Page 66 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003414 EFTA00157796

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 67 of 91 Ea vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JJOHNSON First Amended Complaint 156. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, ia. and as such he must effectively admit liability unto the Plaintirt, 157. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, HE, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor, The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, JJ, will in the future suffer additional medical and psychological expenses. The Plaintiff, JE 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, MEE, witt continue to suffer these losses in the future. WHEREFORE, the Plaintiff, [II. demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 67 3505-025 Page 67 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003415 EFTA00157797

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 68 of 91 HE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XXIV Cause of Action Pursuant to 18 USC §2255 May Incident 2 158. The Plaintiff, JNM. adopts and realleges paragraphs 1 through 19 above. 159. For the second time in May (EEE again returned to JEFFREY EPSTEIN’'S residence at his request. On this occasion, JEFFREY EPSTEIN directed || to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in {EEE presence. JEFFREY EPSTEIN paid I in excess of $200 for this encounter. 160. As a condition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: "Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 68 3505-025 Page 68 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003416 EFTA00157798

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 69 of 91 HEE vs. Epstein, et al. Case No.: 08-CV-8081 1-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 161. The Plaintiff, J. was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 162. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and ondeted of the sexual offenses committed against the Plaintiff, i. and as such he must effectively admit liability unto the Plaintitt, 163. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, i. has in the past suffered, and will in the future suffer, physical injury, pain and 69 3505-025 Page 69 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003417 EFTA00157799

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 70 of 91 HE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, ia. will in the future suffer additional medical and psychological expenses. The Plaintiff, i. 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, [EEE, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, JI. demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XXV Cause ion Pursuant to 18 USC §2255 June — Incident 164. The Plaintir, adopts and realleges paragraphs 1 through 19 above. 70 3505-025 Page 70 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003418 EFTA00157800

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 71 of 91 vs. Epstein, et al. ase No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 165. In June MD again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed [to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor a At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself Zz presence, JEFFREY EPSTEIN paid in excess of $200 for this encounter. 166. As acondition of the Defendant, JEFFREY EPSTEIN'’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 71 3505-025 Page 71 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003419 EFTA00157801

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 72 of 91 i vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 167. The Plaintiff, IJ was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 168. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, Is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, J) and as such he must effectively admit liability unto the Piaintit, 169. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, | | has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintift, JEM, will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a 72 3505-025 Page 72 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003420 EFTA00157802

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 73 of 91 | vs. Epstein, et al. Case No.; 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Piaintift, BIBI, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, IIE demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XXVI Cause of Action Pursuant to 18 USC §2255 june — Incident 2 170. The Plaintiff, Jj. adopts and realleges paragraphs 1 through 19 above. 171. For the second time in June {EEE again retuned to JEFFREY EPSTEIN'’S residence at his request. On this occasion, JEFFREY EPSTEIN directed | | to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor || At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in MINS presence. JEFFREY EPSTEIN paid IEE in excess of $200 for this encounter. 73 3505-025 Page 73 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003421 EFTA00157803

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 74 of 91 GB vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 172. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 173. The Plaintiff, HE, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the oo 3505-025 Page 74 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 United States Government. EFTA_00003422 EFTA00157804

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 75 of 91 iz vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 174. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, MMI. and as such he must effectively admit liability unto the Plaintiff, 175. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, | has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, J. will in the future suffer additional medical and psychological expenses. The Piaintirt, 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 EEE will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, [II. demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 75 3505-025 Page 75 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003423 EFTA00157805

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 76 of 91 HE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XXVil Cause of Action Pursuant to 18 USC §2255 J pf — Incident 1 176. The Plaintiff, || adopts and realleges paragraphs 1 through 19 above. 177. In July FI again returned to JEFFREY EPSTEIN’S residence at his request. On this occasion, JEFFREY EPSTEIN directed [Ij to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the. then minor ll At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in PE vresence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 178. As acondition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 76 3505-025 Page 76 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003424 EFTA00157806

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 77 of 91 GEE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 179. The Plaintiff, J was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 180. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintit, and as such he must effectively admit liability unto the Plaintiff, 181. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, mz has in the past suffered, and will in the future suffer, physical injury, pain and 77 3505-025 Page 77 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003425 EFTA00157807

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 78 of 91 HM vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, mz will in the future suffer additional medical and psychological expenses. The Piaintift a. has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, i. will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, I. demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT iT} Cause of Action Pursuant to 18 USC §2255 July of — Incident 182. The Plaintiff, MMMM, adopts and realleges paragraphs 1 through 19 above. 78 3505-025 Page 78 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003426 EFTA00157808

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 79 of 91 vs. Epstein, et al. ase No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 183. For the second time in July KEE again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed HEHE to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor [EN At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in [J presence. JEFFREY EPSTEIN paid [I in excess of $200 for this encounter. 184. Asa condition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 79 3505-025 Page 79 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003427 EFTA00157809

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 80 of 91 EEE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 185. The Plaintiff, HE, was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 186. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, | | and as such he must effectively admit liability unto the Plaintiff, 187. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, i. has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, EE. will in the future suffer additional medical and psychological expenses. The Plaintiff, has suffered a loss of income, a loss of the capacity to earn income in the future, and a 80 3505-025 Page 80 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003428 EFTA00157810

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 81 of 91 EEE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, HE, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff EE, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XXIX Cause of Action Pursuant to 18 USC §2255 Augus: — Incident 1 188. The Plaintiff, MMMM, adopts and realleges paragraphs 1 through 19 above. 189. In August of 2003, again returned to JEFFREY EPSTEIN’S residence at his request. On this occasion, JEFFREY EPSTEIN directed to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondied the breasts and buttocks of the then minor | | At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in presence. JEFFREY EPSTEIN paid (MJ in excess of $200 for this encounter. 3505-025 Page 81 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003429 EFTA00157811

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 82 of 91 HEB vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 190. As a condition of the Defendant, JEFFREY EPSTEIN’s criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less.” 191. The Plaintiff, || was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 82 3505-025 Page 82 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003430 EFTA00157812

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 83 of 91 HE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 192. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, WM and as such he must effectively admit liability unto the Plaintitt 193. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, || has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, ME, will in the future suffer additional medical and psychological expenses. The Plaintiff, 7. 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, [I will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, IJ demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further 83 3505-025 Page 83 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003431 EFTA00157813

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 84 of 91 {EE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Compiaint 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 XXX Cause of Action Pursuant to 18 USC §2255 August — Incident 2 194. The Plaintiff, mz adopts and realleges paragraphs 1 through 19 above. 195. For the second time in August FY again returned to JEFFREY EPSTEIN’S residence at his request. On this occasion, JEFFREY EPSTEIN directed JJ to fully undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondied the breasts and buttocks of the then minor [I At the conclusion of the massage, JEFFREY EPSTEIN masturbated himself in . | presence. JEFFREY EPSTEIN paid in excess of $200 for this encounter. 196. Asa condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, 84 3505-025 Page 84 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003432 EFTA00157814

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 85 of 91 HE vs. Epstein, et al. Case No,; 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." 197. The Plaintiff, i. was a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the United States Government. 198. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, MJ. and as such he must effectively admit liability unto the Plaintitt, 199. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, a. has in the past suffered, and will in the future suffer, physical injury, pain and 85 3505-025 Page 85 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003433 EFTA00157815

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 86 of 91 HEE vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, Invasion of her privacy and other damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, i. will in the future suffer additional medical and psychological expenses. The Plaintiff, a. has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, || will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, i. demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XXX! Sexual Battery 200. The Plaintiff, MM adopts and realleges paragraphs 1 through 199 above. 3505-025 Page 86 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003434 EFTA00157816

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 87 of 91 GE vs. Epstein, et ai. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 201. Between late May or early June of and August of a. Defendant, JEFFERY EPSTEIN, engaged in dozens of illegal and depraved sexual acts against Plaintiff, 202. As described more fully in the above paragraphs, Defendant, JEFFERY EPSTEIN, intentionally inflicted harmful and/or offensive sexual contact on the person of || 203. Defendant, JEFFREY EPSTEIN’S, tortuous commission of sexual battery upon were done willfully and maliciously. 204. As a direct and proximate result of JEFFREY EPSTEIN'S battery on i. she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. WHEREFORE, the Plaintiff, JI}, demands judgment against the Defendant, JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. COUNT XXXII to it Tortio ult Against Defendan RAH KELLEN 205. Plaintiff incorporates into this count the allegations of paragraphs 1 through 19, 87 3505-025 Page 87 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003435 EFTA00157817

--=PAGE_BREAK=--

i Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 88 of 91 || vs. Epstein, et al. Case No.; 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 206. Defendant, SARAH KELLEN, is one of Defendant, JEFFREY EPSTEIN’S, employees/assistants referenced in paragraph 12 above. Defendant, JEFFREY EPSTEIN, Defendant, SARAH KELLEN, and others reached an agreement between themselves for the purpose of allowing Defendant, JEFFREY EPSTEIN, to commit the illegal acts described above upon Plaintiff 207. Many of the instances of illegal sexual conduct committed by Defendant, JEFFREY EPSTEIN, described above were perpetrated with the assistance, support, and facilitation by Defendant, SARAH KELLAN. In fact, Defendant, SARAH KELLEN, aided, assisted, and/or abetted Defendant, JEFFREY EPSTEIN, in his organized scheme and plan to sexually assault, and/or coerce Plaintiff, i. to engage in prostitution. 208. Defendant, SARAH KELLEN, would often arrange times for [I to come to Defendant, JEFFREY EPSTEIN’, residence, would escort [I to the room where Defendant, JEFFREY EPSTEIN, was waiting, would deliver cash from Defendant, JEFFREY EPSTEIN, at the conclusion of a session, and took nude photographs of Plaintiffs, IIE for Defendant, JEFFREY EPSTEIN. 209. As a direct and proximate result of Defendant, SARAH KELLEN's, participation in the skensanlonl conspiracy, Plaintiff, a. has suffered and will continue to suffer damages, including, but not limited to, pain, suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of 88 3505-025 Page 88 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003436 EFTA00157818

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 89 of 91 ME vs. Epstein, et al. Case No.; 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint self-esteem, loss of dignity, invasion of personal privacy and other damages associated with JEFFREY EPSTEIN'S controlling , manipulating, and coercing MEM. into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, a. will in the future suffer additional medical and psychological expenses. The Plaintiff, i. 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 Piaincit, i. will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, III, demands judgment against the Defendant, SARAH KELLEN, for compensatory damages of at least the minimum amount provided by law, punitive damages, attorney's fees, costs, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. CERTIFICATE OF SERVICE | HEREBY CERTIFY that on the 9th day of February, 2009, | electronically filed the foregoing with the Clerk of the Court by using CM/ECF system, which will send a notice of electronic filing to all counsel of record on the attached service list. 89 3505-025 Page 89 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003437 EFTA00157819

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 90 of 91 |] vs. Epstein, et al Case No,: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Compiaint Page 90 of 91 Attomeys for Plaintiff(s) 3505-025 Page 90 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003438 EFTA00157820

--=PAGE_BREAK=--

Case 9:08-cv-80811-KAM Document39 Entered on FLSD Docket 02/09/2009 Page 91 of 91 HE vs. Epstein, et a! Case No.: 08-CV-8081 1-CIV-MARRA/ JOHNSON First Amended Complaint Page 91 of 91 COUNSEL LIST Robert Critton, Esquire Burman Critton Luttier & Coleman LLP Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. Bruce E. Reinhart, Esquire Bruce E. Reinhart, P.A. 91 3505-025 Page 91 of 91 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00003439 EFTA00157821