UNITED STATES DIST RICT COURT SOUTHERN DI STRICT OF FLOR IDA JANE DOE II CASE NO MARRA/JOH NSON vs JEFFREY EPSTEIN Defendants FIRST AMENDED OMPLAINT Plai ntif JANE DOE II hereby sues JEFFREY EPSTEIN and SARAH KELLEN and states JURISDICTION AND VENUE This is an action for damages in ex cess of ex clusive of interest osts and attorney fees Venue is proper in this Court as all acts occurred in Palm Beach County and all parties reside and/or do business her ein PAR TIES Ms DOE II is a natural pers on residing in Palm Beach ounty Flor ida During the events iving rise to thi claim she was a minor but has now this suit nde a pse udo nym to protect her privacy because the acts alleged occ urred while she was a mi nor Case Document Entered on FLSD Docket Page of Defendant EPSTEIN is a nat ural person who is an a dult and wh resides and/or does business in Palm Beach County Florida and who committed the acts alleged withi the ju risdicti on of Palm Beach County Florida within he boundaries of the nited States Di strict Co urt in and for the South ern District of Florida Defendan KELLEN is a natural person who is an adult believed to resid in the State of New York but who committed some of the acts alleg ed within the jurisdi ction of Palm Beach ounty Flor ida within the boundaries the United States Distric Court in an for the Southern istrict Florida Defendant EPSTE IN is beli eved to now reside in Palm Beach Flori da but claims to be a resident of the Virgi Islands FACTS Defendant EPSTEIN was at all times relevant to this actio a par time resident of Palm Beach County lorida All acts complaine of herein occur red at his es tate residence in the Town of Palm Beac Florida Defendant EPSTEIN has a history of enticing oung women who are minors under years age and sol iciting them to engage in prostitut ion for his ow sexu al gratificati on Defendant EPSTEIN in agreement with tw persons he employed for this urpos HALEY ROB SON and Defendant KELLEN conspired ogether and/or with unnamed others to solicit young omen of the type Defendant EPSTEIN preferred blonde attr acti ve in appearance a nd younger than years of age to prov ide sexual ratification for him by eng aging in acts of prosti tution Defendants EPSTEIN and ELLEN entered i nto a criminal conspiracy to solicit oung women for acts of prostit ution includi ng the Plaint iff Case Document Entered on FLSD Docket Page of From about June unti on or about ebruary Defendants EPSTEIN and KELLEN pers uaded induced or enticed the Pl aintiff to come to Defendant EPSTEIN?s home and provi de Defendant EPSTEIN with massages hich escalated into sexual encounters between Defe ndant EPSTEIN and the Plaintiff designed to fulfill his unnatural sexual des ires for oung women or even younger girls who ere minors These acts included Defendant PSTEIN request that he wante the encounter to be like a porn vi deo De fenda nt EP STEI ould scr ipt lin es fo th Pl aint iff to say i ncluding alling out his na me and eques ting that he perfor a certain sexual ac harder while he ouched the Plaintiff?s agina ith a vibrator or wit his fingers alternately he would masturbate in the presence of the Plaintif after dema nding her to disrobe and walk in fron of him in provo cati ve sexual pos es efendan EPSTEIN wou ld pay the Pl aintiff a fee of on each occasion after he ejaculated while mas turbating i the presence of the Plaintiff Defendant EPSTEIN touched Plaint iff?s ag ina or penetrated Plaintif f?s vagina using his fingers and/or a vibrat or on multiple occasions du ring th time that Plaintiff was a minor causi ng personal injury to her Pursuant to U.S and in viol ation of U.S.C Defendants EPSTEIN and KELLEN knowing ly persua ded induced or ent iced the Pla inti ff to engage in acts of prostit ution when the Pl aintiff was under the age of approximately about the follow ing dates that Plaintiff can document based on payments received and In addition Plaintiff believes that there were as many as to other addition al occasions during this time frame that Defendant EPSTEIN solicited her and procured her to perf orm prostitution service all duri ng the time that she was a minor Case Document Entered on FLSD Docket Page of Defendants manner of persuasion inducement and/or en ticement of the Plai ntif to commit acts of prostitutio was knowing and wilful Defendants in commit ting the abo ve offenses did use a facility or means of interstate foreign commerce to knowingly persuade induce or enti ce Doe II and othe minor females to engage in prostitution and/or a commercial ex act and/or to commit a lewd or lascivious act and/or a sexual battery in violatio of Title Unit ed States Code Se ction The facility or means of interstate and/or foreign commerce includes but is not limited to telephone and cel phone communications between Defendants wherein Defendant EPST EI would olicit the Plai ntif by and throu gh Defendant KELLEN who ould after speaki ng by telephone and cell phone ith Defendant EPSTEIN solicit he Plaintiff by elephone and cell phone COUNT I U.S.C a vs EFENDA NT EPSTEIN Plai ntif brings this claim against Defendant EP STEIN and incorpora tes the allegations set forth in herein Plaintiff seeks dam ages for personal injury in accordance with U.S.C a for each of the acts of pr ostitution set forth above for hich Defendant EPSTEIN solicited the Plaintiff in the amount of for each vio lation totaling be tween and separate occur rences for a tot al range of damag es between million dollars for specified violati ons to mil lion dollar for up to specified and unspecified violations against Defendant EPSTEIN and a reasonable attor ney?s fees and osts as per mitted by the statute WHEREFORE Plaintiff demands judg ment against efenda nt EP STEIN a reasonable attorney fees the costs of this action an any other relief deemed just and proper Case Document Entered on FLSD Docket Page of COUNT II U.S.C a vs EFENDA NT KELLEN Plaintiff bring this clai against Defendant KELLEN and inc orporates the allegations set forth in herein Plaintiff seeks dam ages for personal injury in accordance with U.S.C a for each the acts of prostitution set forth above for which Defendant KELLEN conspired with De fendant EPSTEIN to soli cited the Plaintiff in the amount of for each violati on totaling between and separate occur rences or a total rang of damages between mi llion dollars for specified violati ons to mil lion dollar for up to specified and un specified vio lations against Defendant KEL LEN and a reasonable attorney?s fees and costs as permitted by the statute WHEREFORE Pla inti ff emands judgment ag ainst Defendant KELLEN a reasonable attorney fees the costs of this action an any other relief deemed just and proper A TRIA BY JURY ON A LL ISSUES SO TRIABLE IS HEREBY DEMA NDED Respectfully submitted BY:s Isidro Garcia ISIDRO GARCIA Florida Bar No GARCIA LAW FIRM P.A Datura Str eet Suite West Palm Beach FL Telephone Telecopier e-mail is idrogarc ia bellsouth.net Case Document Entered on FLSD Docket Page of CERTIFICATE OF SERVICE I HEREBY ERTIFY that a true and cor rect copy of the foregoing was furnis hed VIA ECM TRANSMISSION to Robe rt Critto Esq an Michae Pike Es BURMAN CRITTON LUTTIER COLEM AN Counsel for Defendant EPST EIN Dri ve Suite West Palm Beach Florida and to Bru ce Rei nhart Esq BRU CE REI NHAR P.A Counsel for Def endant KELLEN Australian Avenue Suite est Palm Beach Florida this 2nd day of October BY Isidro Garcia ISIDRO GARCIA Case Document Entered on FLSD Docket Page of
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