Victim Civil (S.D. Fla.) — 09-cv-80656

Case 09-cv-80656 was filed in the U.S. District Court for the Southern District of Florida on May 1, 2009 by a plaintiff proceeding pseudonymously as 'Jane Doe No. 102' against Jeffrey Epstein. The Complaint and Demand for Jury Trial (D.E. 1, EFTA00210921) was signed by Robert C. Josefsberg and Katherine W. Ezell of Podhurst Orseck, P.A. (Miami) and originally captioned to Judge Kenneth L. Ryskamp and Magistrate Judge Ann E. Vitunac, but the file-stamp shows the case was promptly reassigned into the Marra/Johnson pair that managed the rest of the Florida Doe cluster (subsequent docket entries carry the 9:09-cv-80656-KAM caption — see EFTA02738807, EFTA02738878, EFTA02738979).

The substantive claims were brought under the federal child-victims civil-remedy statute, 18 U.S.C. § 2255. The Complaint alleged that Epstein, between roughly 1998 and September 2007, used his wealth and influence over vulnerable minor girls to engage in a 'systematic pattern of sexually exploitative behavior' at his Palm Beach, Manhattan, New Mexico ('Zorro Ranch'), U.S. Virgin Islands (Little St. James), London, and Paris residences, and described Epstein as 'a billionaire financier' with 'a fleet of aircraft' (EFTA00210921). The pleading mirrors the form complaints filed by Podhurst Orseck and co-counsel in the other 2008–2009 Florida Doe suits.

By May 2009, 09-cv-80656 was administered alongside 08-cv-80119 (Jane Doe No. 2 v. Epstein, the lead case), 08-cv-80232, 08-cv-80380, 08-cv-80381, 08-cv-80811 (C.M.A.), 08-cv-80893 (Jane Doe), 08-cv-80993, 08-cv-80994, 09-cv-80469 (Doe II), 09-cv-80591 (Jane Doe No. 101), 09-cv-80802, and 09-cv-81092. Filings in 09-cv-80656 routinely carry consolidated multi-case captions enumerating these dockets (EFTA02738807, EFTA02738878, EFTA02739051, EFTA02746050, EFTA02750494). The sample corroborates that the cluster moved together on contested issues including Epstein's motion to stay civil discovery on Non-Prosecution-Agreement / parallel-criminal-proceedings grounds — to which the United States itself responded that no stay was 'necessary' or 'contemplated by the Non-Prosecution Agreement' (EFTA00222798).

Procedurally, on July 2, 2009 Judge Marra granted Epstein's unopposed motion for an extension of time to serve a responsive pleading to Doe 102's Complaint, ordering him to do so on or before August 20, 2009 (D.E. 36-1, EFTA02738979). Briefing on substantive motions continued into the fall, including a November 16, 2009 reply (D.E. 57, EFTA02739101) on Epstein's emergency motion for preservation of evidence directed at Rothstein Rosenfeldt Adler, P.A. (the Scott Rothstein firm that represented L.M. against Epstein in a parallel state-court action and was, by November 2009, in court-supervised wind-down following Rothstein's Ponzi-scheme arrest). The corpus sample's latest 09-cv-80656-captioned filings are dated late 2009. The corpus does not contain a settlement agreement, a stipulation of dismissal, or a final judgment for 09-cv-80656; public records and downstream litigation indicate the matter, like the rest of the Florida Doe cluster, was resolved through confidential settlement.

The DOJ corpus contains 304 EFTA-stamped pages and 104 emails linked to 09-cv-80656. The high-confidence sample is dominated by court filings, with a small number of related downstream case documents. The earliest native 09-cv-80656 filing in the sample is the Complaint itself (D.E. 1, EFTA00210921), which lays out the § 2255 jurisdictional theory and the factual narrative shared across the Doe cluster. The sample then captures the case's procedural arc through 2009: Plaintiff's notice (D.E. 11, May 14, 2009, EFTA02738807) and a 17-page filing entered May 29, 2009 (D.E. 22, EFTA02738878) — the same date Epstein filed motions to dismiss in the parallel 09-cv-80591 action; Judge Marra's July 2, 2009 order extending Epstein's responsive pleading deadline to August 20, 2009 (D.E. 36-1, EFTA02738979); a July 29, 2009 multi-case filing (D.E. 44, EFTA02739051); and Epstein's November 16, 2009 reply concerning preservation of evidence held by the Rothstein Rosenfeldt Adler firm in connection with Jane Doe v. Epstein, 08-cv-80893 (D.E. 57, EFTA02739101).

A significant portion of the high-confidence sample is composed of cross-captioned filings from the lead 08-cv-80119 docket and its sister cases that name 09-cv-80656 on the caption page — for example, the United States' response on Epstein's motion to stay civil proceedings (EFTA00222798), Plaintiffs' May 22, 2009 Podhurst Orseck filing (EFTA00722801, D.E. 113 in 08-cv-80119), the August 7, 2009 cross-Doe response on C.M.A.'s § 2255 statutory-damages notice (D.E. 256, EFTA02746050), and a series of dispositive- and discovery-motion captions enumerating the entire Doe cluster (EFTA00599359, EFTA00728870, EFTA01098622, EFTA02744380, EFTA02744585, EFTA02744925, EFTA02745124, EFTA02745437, EFTA02750494). These caption pages are the principal mechanism by which 09-cv-80656 appears throughout the production: the litigation was administered jointly enough that almost every contested motion in the lead case is, formally, also a filing in 09-cv-80656.

The corpus also contains a 2010-vintage state-court appendix (Epstein v. Rothstein, Palm Beach Cir. No. 50-2009-CA-040800, EFTA02761329) cataloguing federal Doe-case filings as exhibits, and a 2016 declaration in Giuffre v. Maxwell, S.D.N.Y. 15-cv-7433 (EFTA02798063), that attaches the Doe 102 Complaint as Exhibit R — confirming the 09-cv-80656 Complaint was later re-deployed as evidence in downstream civil litigation. Two other documents help frame the case but are not 09-cv-80656 filings per se: Jane Doe 1 and Jane Doe 2's 2016 consolidated motion for partial summary judgment in the CVRA action 08-cv-80736 (EFTA00184224) and a 2021 Maxwell criminal-case reply memorandum (DOJ-OGR-00004228) appear in the sample by virtue of cross-references and shared evidentiary record. The corpus sample does not include a settlement agreement, a final order of dismissal, the original PACER docket sheet, or any deposition transcripts taken in 09-cv-80656.