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Case 9:09-cv-81092-KAM Document 1-1 Entered on FLSD Docket 07/27/2009 Page 1 of 79

COUNT5 3

Cause of Action Pursuant to 18 U.S.C. § 2255

September 2003 - Incident 1

229. Plaintiff, L.M. adopts and realleges paragraphs 1 through 20 above.

230. On or about September 2003, the exact date being unknown to L.M.,

Defendant, Jeffrey Epstein, committed a federal sexual offense against her, including a

violation of numerous federal criminal statutes condemning the coercion and

enticement of a minor to engage in prostitution or sexual activity, travel with intent to

engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor

children, transport of visual depictions of a minor engaging in sexually explicit conduct,

child exploitation enterprises, and other crimes, specifically including, but not limited to,

those crimes designated in 18 U.S.C. § 2422(b), § 2423(a), § 2423(b), and§ 2423(e).

L.M. is therefore a victim of one or more offenses enumerated in 18 U.S.C. § 2255 and,

as such, asserts a cause of action against the defendant, Jeffrey Epstein, pursuant to

this Section of the United States Code and the agreement between the Defendant,

Jeffrey Epstein, and the United States Government.

231. As a direct and proximate result of the offenses enumerated in Title 18,

United States Code, Section 2255, being committed against her, L.M. has in the past

suffered, and will in the future suffer, physical injury pain and suffering, emotional

distress, psychological trauma, mental anguish, humiliation, embarras

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