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Case 9:10-cv-81111-WPD Document 1-1 Entered on FLSD Docket 09/17/2010 Page 1 of 10
CIVIL RICO CASE STATEMENT
PURSUANT TO LOCAL RULE 12.1
1. Plaintiff M.J. alleges a violation of Florida Statutes §§ 772.103(3) (participation in an
enterprise through a criminal activity) and 772.103(4) (conspiracy to do so). The following
information describes both the § 772. 103(3) claim and the § 772.103( 4) conspiracy claim,
with the additional note that the conspiracy was between defendant Jeffrey Epstein, Sarah
Kellen, Nadia Marcinkova, Ghislaine Maxwell, Jean Luc Brunel and other persons whose
identity is, at this time, unknown to M.J.. Epstein, Kellen, Marcinkova and others all
conspired together to violate the provisions of § 772 .103(3 ), doing so willfully and with full
knowledge of the criminal activities that were planned as part of the criminal enterprise. For
convenience in this statement, Florida Statutes§§ 772.103(3) and (4) will be referred to as
the "Florida Civil RICO provisions."
2. Epstein served as the leader, boss, and "C.E.O." of the criminal enterprise. He also
criminally sexually abused and prostituted M.J. and other minor girls who were victims of
the criminal enterprise. He also paid for Kellen and Marcinkova and numerous other
associates to be a part of the enterprise and conspired with them to commit criminal acts of
sexual abuse and prostitution of minors. The basis for Epstein's liability is also described in
M.J. 's complaint.
3. The other wrongdoers and criminal participants included Nadia Marcinkova, Ghislaine
Maxwell, and Jean Luc Brunel. (M.J. is uncertain as to the precise spelling of their names
and their full legal names.) They assisted defendant Jeffrey Epstein in recruiting and
procuring minor girls to satisfy Epstein's crimina
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