UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-80381-CIV-MARRA/JOHNSON JANE DOE NO Pl-3ai-3nt-3i-3ff vs JEFFREY EPSTEIN Defendant SECOND AMENDED COMPLAINT 2652Plaintiff Jane Doe No 223Jane or 223Jane Doe brings this Com)9p1laint against Jef4f4r-1ey Epstein as f4o1llows Parties Jurisdiction and Venue Jane Doe No is a citizen and resident of the Com8m8onwealth of Virginia and is sui juris This Com9p1laint is brought under a fictitious nam9e to protect the identity of the Plaintiff because this Com9p1laint m9akes sensitiv allegations of sexual assault and abuse upon a m8i-2nor Defendant Jeffrey Epstein is a citizen a nd resident of the State of New York This is an action for dam8a-1ges in excess of m8illion This Court has jurisdiction of4 this action a nd set forth herein pursuant to U.S.C a as the m)9atter in controversy i exceeds exclusive of interest and costs and ii is between citizens of different states This Court has venue of this action pursu ant to U.S.C a as a substantial Case Document Entered on FLSD Docket Page of part of the events or om9issions giving rise to the claim9 occurred in this District Factual Allegations At all relevant tim9es Defendant Jeffrey Epstein 223Epstein was an adult m)9ale years old Epstein is a financie and m9oney m9anager with a secret clientele lim9ited exclusively to billionaires He is him8self a m8a-1n of trem8endous wealth power and influence He m8a-1intains his hom9e in New York and also owns residences in New Mexico St Thom9as and Palm9 Beach FL The allegations herein concern Epstein 2s conduct while at his la vish estate in Palm9 Beach Upon inform8ation and belief Epstein has a sexual preference and obsession for underage girls He engaged in a plan and sc hem9e in which he gained access to prim9arily econom9ically disadvantaged m9i-1nor girls in his hom9e sexually assaulted these girls and then gave them8 m8oney In or about Jane Doe then approxim9ately years old fell into Epstein 2s trap and becam9e one of his victim9s Upon inform8ation and belief Jeffrey Epstei carried out his schem9e and assaulted girls in Florida New York and on his private island known as Little St Jam8e-1s in St Thom8as Epstein 2s schem9e involved the use of young girls to recruit underage girls These underage girls were recruited ostensibly to give a wealthy m9an a m9assage for m9onetary his Palm9 Beach m9ansion The girl would be contacted when Epstein was planning to be at his Palm9 Beach residence or soon after he had arrived there Upon inform8ation and belief Epstein generally sought out econom9ically disadvant aged underage girls from9 western Palm9 Beach County who would be enticed by the m8oney bei ng offered generally to per 223m8assage session and who were perceived as less likely to com9p1lain to authorities or have credibility if4 allegations of im9proper conduct were m9ade This was an im9portant elem9ent of Epstein 2s plan Epstein 2s plan and schem9e reflected a pa rticular pattern and m9ethod The underage Case Document Entered on FLSD Docket Page of victim9 would be brought to the kitchen entran ce of Epstein 2s m8a-1nsion where she would be introduced to Sarah Kellen Epstein 2s assistant Ms Kellen would then bring the girl up a flight of stairs to a room9 that contained a m9assage table in addition to other furnishings and a bathroom9 The girl would then find herself al one in the room8 with Epstein who would be wearing only a towel 15He would then rem8ove his towel and lie naked on th m9assage table and direct the girl to rem9ove her clothes Epstein would then perform9 one or m9o1re lewd lascivious and sexual acts including m9asturbation and touching the girl 2s vagina Consistent with the foregoing plan and sc hem8e-1 when Jane Doe was approxim8a-1tely years old she was recruited to give Epstein a m9assage for m9onetary com9p1ensation Jane and another girl were brought to Epstein 2s m9ansion in Pa lm8 Beach to the kitchen5 en tran2ce.2 O4n2ce th2ere,2 they were introduced to Sarah Kellen who led them9 up the f4light of4 stairs to the room9 with the m9assage table Jane and the ot her girl were directed by Epstein to rem9ove their clothes and give him9 a m9assage Jane and the other girl rem9oved th eir clothes except for their panties and bras and com9p1lied with Epstein 2s instructions W10h1ile on the m9assage table Epstein m9asturbated him9self and touched both girls on their vaginas with his hand and with a vibrato After Epstein had com9p1leted the sexual assa ult both girls were then able to get dressed leave the room9 and go back down the stai rs Epstein gave both girls m9oney for this 223m9assage As a result of this encounter with Epst ein Jane experienced confusion sham8e hum9iliation and em9barrassm9ent and has suf4f4ered severe psychological and em9otional injuries COUNT I Sexual Assault and Battery Case Document Entered on FLSD Docket Page of Plaintiff Jane Doe repeats and realleges paragraphs through above Epstein acted with intent to cause an offens ive contact with Jane Doe or a4n5 apprehension of such a contact and Jane Doe was thereby put in such im8m8i-2nent apprehension Epstein m8a-1de an intentional unlawful offe of offensive sexual contact toward Jane Doe creating a reasonable fear of im9m9i-1nent peril Epstein intentionally inf4licte5d6 h6a5r4m14f9u6l o6r4 ffensive contact on the person of Jane Doe with the intent to cause such contact or the apprehension that such cont act is im9m9i-1nent Epstein tortiously com9m9itted a sexual assault and battery on Jane4 E6p5s5t3e4i3n5 a4c4ts5 were intentional unlawful offensive and harm8ful Epstein 2s plan and schem8e-1 in which he com9m9itted such acts upon Jane Doe were done willfully and m8a-1liciously As a direct and proxim9ate result of Epst ein 2s assault on Jane she has suffered and will continue to4 s3u4f7f7e3r2 s3e3v4e3r2e3 a3n4d4 p4e3r2m12a3n4e3n4t tr2a3u4m12a3tic3 in4ju4r2i2e3s3,4 in4c3l2u4d4i2n4g4 p4s3y4c3h4o4l2o4g4i2c3a3l a3n4d4 em9otional dam9ages 2613W9H2EREFORE Plaintiff Jane Doe No de m8a-1nds judgm8ent against Defendant Jeffrey Epstein for compensatory dam12a3ges punitive dam9ages costs and such other and f4u1rther relief4 as this Court deem9s just and proper COUNT II Intentional Infliction of Emotional Distress Plaintiff Jane Doe repeats and realleges paragraphs through above Epstein 2s conduct was intentional or reckless Epsteins conduct with a m8i-2nor was ex trem4e and outrageous going beyond all bounds of decency Case Document Entered on FLSD Docket Page of Epstein com9m9itted willf4ul acts of4 child s5e5x6u6a5l a1b2u2s1e1 o2n2 J1a1n2e1 T3h2e1s1e1 a1c1ts1 re1s1u2lte1d2 in m9ental or sexual injury to Jane Doe that cau sed or were likely to cause Jane Doe 2s m9ental or em9otional health to be significantly im9paired Epstein 2s conduct caused severe em9otional dist ress to Jane D4o2e E3p2stein knew4 or had reason to know that his intentional and outrage ous conduct would cause em9otional distress and dam9age to Jane Doe or Epstein acted with eckless disregard of4 the high probability of4 causing severe em9otional distress to Jane Doe As a direct and proxim9ate result of Epstei 2s intentional or reckless conduct Jane Doe has suffered and will continue to suffer severe m8e-1ntal anguish and pain 2613W9H2EREFORE Plaintiff Jane Doe No de m8a-1nds judgm8ent against Defendant Jeffrey Epstein for compensatory dam12a3ges costs punitive dam9ages and such other and f4u1rther relief4 as this Court deem9s just and proper COUNT I Coercion and Enticement to Sexual Acti vity in Violation of U.S.C Plaintiff Jane Doe repeats and realleges paragraphs through above Epstein used a facility or m9eans of in terstate com9m9erce to knowingly persuade induce or entice Jane Doe when she was under the age of years to engage in prostitution or sexual activity for which any person can be charged with a crim9inal offense On June Epstein entered a plea of guilty to violations of Florida and in the 15th Judicial Circuit in a nd for Palm8 Beach County Case nos and for conduc involving the sam9e plan and schem9e as alleged herein As-5 to Plaintiff Jane Doe Epstein could have been charged with crim9inal violations of Case Document Entered on FLSD Docket Page of Florida Statute including subsections and thereof and other crim9inal offenses including violations of Florida Statutes and including subsections and thereof Epstein 2s acts and conduct are in violation of U.S.C As a result of Epstein 2s violation of U.S.C Plaintiff has suffered personal injury including m9ental psychological and em9otional dam9ages Plaintiff hired Herm8an Merm8elstein P.A in this m9atter and agreed to pay them9 a reasonable attorneys fee 2238W9H2EREFORE Plaintiff Jane Doe No de m8a-1nds judgm8ent against Defendant Jeffrey Epstein for all dam9ages available under U.S a including without lim)9itation actual and com9p1ensatory dam9ages costs of suit and atto rneys fees and such other and further relief as this Court deem9s just and proper JURY TRIAL DEMAND Plaintif4f4 dem9ands a jury trial in this action on all claim9s so triable Dated February Respectf4u1lly 2750subm9itted By Adam8 Horowitz_ Stuart Merm8elstein FL Bar No ssm9 sexabuseattorney.com Adam8 Horowitz FL Bar No ahorowitz sexabuseattorney.com MERMELSTEIN HOROW8ITZ P.A Attorneys for Plaintiff Biscayne Blvd Suite Miam9i Florida Tel Fax Case Document Entered on FLSD Docket Page of CERTIFICATE OF SERVICE he-5r-6e-5by c-5ertify that on February I elect ronically filed the foregoing docum9ent with the Clerk of the Court using CM/ECF I also certify foregoing docum9ent is being served this day to all parties on the attached Service List in the m9anner specified either via transm9ission of Notices of Electronic Filing generated by CM/ECF or in som9e other authorized m9anner for those parties who are not authorized to receive electronically Notices of Elec tronic Filing Adam8 Horowitz Case Document Entered on FLSD Docket Page of SERVICE LIST DOE vs JEFFREY EPSTEIN United States District Court 2Southern District of Florida Jack Alan Goldberger Esq jgoldberger agwpa.com Robert Critton Esq rcritton bclclaw.com Adam8 Horowitz Case Document Entered on FLSD Docket Page of
