Case Document Entered on FLSD Docket Page of EXHIBIT A Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO CIV-MARRA/JOHNSON JANE DOE NO.1 by and through JANE DOEs FATHER as parent and natural guardian and JANE DOEs FATHER and JANE DOEs STEPMOTHER individually Plaintiffs JANE DOES MOTHER individually and as parent and natural guardian of JANE DOE NO Intervenor-Plaintiff vs JEFFREY EPSTEIN Defendant I INTERVENORS COMPLAINT Intervenor-Plaintiff JANE DOEs MOTHER individually and as parent and natural guardian of JANE DOE NO by and through the undersigned counsel brings this Complaint against Defendant JEFFREY EPSTEIN and as grounds states as follows Parties Jurisdiction and Venue Jane Doe No is a citizen and resident of the State of Florida She is a minor under the age of years Jane Does Mother brings this action individually and as parent and natural guardian of Jane Doe No Jane Does Mother is a citizen and resident of the State of Georgia Case Document Entered on FLSD Docket Page of This Complaint is brought under fictitious names to protect the identity of the Minor Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a minor Defendant Jeffrey Epstein is a citizen and resident of the State ofNew York This is an action for damages in excess of Fifty Million Dollars 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 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 An integral player in Epsteins Florida scheme was Haley Robson a Palm Beach Community College student from Loxahatchee Florida She recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion Under Epsteins plan Ms Robson would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there Epstein or someone on his behalf directed Ms Page of Case Document Entered on FLSD Docket Page of Robson to bring one or more underage girls to the residence Ms Robson upon information and belief generally sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas 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 I Epsteins plan and scheme reflected a particular pattern and method Upon arrival at Epsteins mansion Mr Robson would introduce each victim to Sarah Kellen Epsteins assistant who gathered the girls personal information including her name and telephone number 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 Ms Kellen would then leave the girl alone in this room whereupon Epstein would enter wearing only a towel He would then remove his towel lay down naked on the massage table and direct the girl to remove her clothes He then would perform one or more lewd lascivious and sexual acts including masturbation and touching the girls vagina with a vibrator Consistent with the foregoing plan and scheme Ms Robson recruited Jane Doe to give Epstein a massage for monetary compensation Ms Robson brought Jane to Epsteins mansion in Palm Beach Jane was introduced to Sarah Kellen who led her up the flight of stairs to the room with the massage table She was alone in the room when Epstein arrived wearing only a towel He removed his towel and laid down naked on the massage table He demanded that Jane remove her clothes In shock fear and trepidation Jane complied removing her clothes except for her underwear Epstein then sexually assaulted Jane Page of Case Document Entered on FLSD Docket Page of After Epstein had completed the assault he left the room Jane was then able to get dressed leave the room and go back down the stairs She then met Ms Robson again who brought Jane home Jane was paid by Epstein Ms Robson was paid by Epstein for bringing Jane to him As a result of this encounter with Epstein the 14-year old Jane experienced confusion shame humiliation embarrassment and the assault sent her life into a downward spiral COUNTI Intentional Infliction of Emotional Distress Intervenor-Plaintiff JANE DOEs MOTHER 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 not only to Jane Doe but also to her parents including Jane Does Mother Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Does parents As a direct and proximate result of Epsteins intentional or reckless conduct Jane Does Mother has suffered and will continue to suffer severe mental anguish and pain WHEREFORE Intervenor-Plaintiff Jane Does Mother 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 Page of Case Document Entered on FLSD Docket Page of COUNT II Loss of Parental Consortium Plaintiff Jane Does Mother repeats and realleges paragraphs through above Epsteins tortious conduct is the direct and proximate cause of damages to Jane Does Mother consisting of parental loss of comfort companionship and society and healthcare costs associated with the treatment of Jane Jane Does Mother experienced and will continue to experience great mental anguish pain and suffering from the time that Defendants tortious conduct occurred WHEREFORE Plaintiff Jane Does Mother demands judgment for loss of consortium damages costs and such other and further relief as this Court deems proper JURY TRIAL DEMAND Intervenor-Plaintiff demands a jury trial in this action Dated January __ I HEREBY CERTIFY that a true and Respectfully submitted RICCI LEOPOLD P.A PGABI Palm Beach Intervenors Complaint was filed electronically on with the Clerk of the Court through ECF and that ECF will send an e-notice of the electronic filing to the following Jeffrey Page of Case Document Entered on FLSD Docket Page of Herman jherman hermanlaw.com Stuart Mermelstein smermelstein hermanlaw.com Adam Horowitz ahorowitz hennanlaw.com RIC Palm Page of
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