of April 08-CV-80380-Hurley-Hopkins of Case Document Entered on FLSD Docket Page of Factual Allegations At all relevant times Defendant Jeffrey Epstein Epstein was an adult male years old Epstein is a financier and money manager with a secret clientele limited exclusively to billionaires He is himself a man of tremendous wealth power and influence He maintains his principal home in New York and also owns residences in New Mexico St Thomas and Palm Beach FL The allegations herein concern Epsteins conduct while at his lavish estate in Palm Beach Upon information and belief Epstein has a sexual preference and obsession for underage minor girls He engaged in a plan and scheme in which he gained access to primarily economically disadvantaged minor girls in his home sexually assaulted these girls and then gave them money In or about Jane Doe then approximately years old fell into Epsteins trap and became one of his victims Upon information and belief Jeffrey Epstein carried out his scheme and assaulted girls in Florida New York and on his private island known as Little St James in St Thomas Epsteins scheme involved the use of young girls to recruit underage girls Haley Robson a Palm Beach Community College student from Loxahatchee Florida recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion The young girls would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there Ms Robson upon information and belief generally sought out economically disadvantaged underage girls from western Palm Beach County who would be enticed by the money being offered generally to per massage session and who were perceived as less likely to complain to authorities or have credibility if allegations of improper conduct were made This was an important element of Epsteins plan HERMAN MERMELSTEIN P.A w.hermanlaw.com of Case Document Entered on FLSD Docket Page of Epsteins plan and scheme reflected a particular pattern and method The underage victim would be brought to the kitchen entrance of Epsteins mansion where she would be introduced to Sarah Kellen Epsteins assistant Ms Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings There were photographs of nude women lining the stairway hall and in the bedroom The girl would then find herself alone in the room with Epstein who would be wearing only a towel He would then remove his towel and lie naked on the massage table and direct the girl to remove her clothes Epstein would then perform one or more lewd lascivious and sexual acts including masturbation and touching the girls vagina Consistent with the foregoing plan and scheme when Jane Doe was approximately years old she was recruited by Haley Robson to give Epstein a massage for monetary compensation Jane was brought to Epsteins mansion in Palm Beach to the kitchen entrance Once there Jane was introduced to Sarah Kellen who led her up the flight of stairs to the room with the massage table In this room Jane was directed by Epstein to remove her clothes and give him a massage Jane initially kept her panties and bra on and complied with Epsteins instructions Jane was paid by Epstein for this massage Jane returned on many occasions to the Palm Beach mansion to provide Epstein with massages On those occasions Epstein engaged in sexual contact and activity with the minor Jane which included among other things directing Jane to remove all her clothes masturbating during the massage and digitally penetrating Janes vagina Jeffrey Epstein often used a vibrator on the minor Jane during the massage This sexual abuse continued for approximately three years As a result of these encounters with Epstein Jane experienced confusion shame HERMAN Ct MERMELSTEIN A w.hermanlaw.com of Case Document Entered on FLSD Docket Page of humiliation and embarrassment and has suffered severe psychological and emotional injuries COUNT Sexual Assault Plaintiff Jane Doe repeats and realleges paragraphs through above Epstein tortiously assaulted Jane Doe sexually Epsteins acts were intentional unlawful offensive and harmful Epsteins plan and scheme in which he committed such acts upon Jane Doe were done willfully and maliciously This sexual assault was in violation of Chapter of the Florida Statutes which recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane As a direct and proximate result of Epsteins assault on Jane she has suffered and will continue to suffer severe and permanent traumatic injuries including mental psychological and emotional damages WHEREFORE Plaintiff Jane Doe No demands judgment against Defendant Jeffrey Epstein for compensatory damages punitive damages costs and such other and further relief as this Court deems just and proper COUNT II Intentional Infliction of Emotional Distress Plaintiff Jane Doe repeats and realleges paragraphs through above Epsteins conduct was intentional or reckless Epsteins conduct was outrageous going beyond all bounds of decency Epsteins conduct caused severe emotional distress to Jane Doe Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and HERMAN MERMELSTEIN A w.hermanlaw.com of Case Document Entered on FLSD Docket Page of damage to Jane Doe As a direct and proximate result of Epsteins intentional or reckless conduct Jane Doe has suffered and will continue to suffer severe mental anguish and pain WHEREFORE Plaintiff Jane Doe No demands judgment against Defendant Jeffrey Epstein for compensatory damages costs punitive damages and such other and further relief as this Court deems just and proper JURY TRIAL DEMAND Plaintiffs demand a jury trial in this action Dated April __foaoo8 HERMAN MERMELSTEIN A Respectfully submitted HERMAN MERMELSTEIN P.A Attorneys for Plaintiffs Biscayne Blvd Suite Miami Florida Tel Fax rey Herman jherman hermanlaw.com Florida Bar No Stuart Mermelstein smermelstein hermanlaw.com Florida Bar No Adam Horowitz Florida Bar No ahorowitz hermanlaw.com w.hermanlaw.com of Case Document Entered on FLSD Docket Page of CIVIL COVER
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