UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CV-80380-MARRA/JOHNSON JANE DOE NO Pl-3ai-3nt-3i-3ff vs JEFFREY EPSTEIN Defendant SECOND AMENDED COMPLAINT 2737Plaintiff Jane Doe No 223Jane or 223Jane Doe brings this Am)9ended Com9p1laint against Jeffrey Epstein as follows Parties Jurisdiction and Venue Jane Doe No is a citizen and resident of the State of Florida 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 Additionally this Court has jurisdicti on pursuant to U.S.C because Plaintiff alleges a claim9 under the laws of th United States This Court has supplem9ental jurisdiction pursuant to U.S.C a over all othe claim5s-4 set f5o2rth herein w4h2ich f5o2rm10 part of5 Case Document Entered on FLSD Docket Page of the sam9e case or controversy Thi-4s-3 Cour-4t-4 ve-3nue-3 of t-4h3is action pursu ant to U.S.C a and as a substantial 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 m9i-1nor girls He engaged in a plan a nd schem9e 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 approxim8a-1tely years old f4ell into E2p1stein 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 Haley Robson a Palm8 Beach Com8m8unity College student from9 Loxahatchee Florida recruited girls gi-4ve-3 ma-3n for-4 mone-5t-6a-5ry com9p1ensation in his Palm9 Beach m9ansion 35The young girls would be contacted when Epstein wa planning to be at his Palm9 Beach residence or soon after he had arrived there Ms Robson upon inform8ation and belief generally sought out e-6c-1onom8ically disadvantaged underage girls from8 we stern Palm8 Beach County who would be enticed by the m8oney being offered generally to per 223m8assage session and who were perceived as less likely to com9p1lain to authoritie or have credibility if4 allegations of4 im9proper Case Document Entered on FLSD Docket Page of 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 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 bedroom9 that contained a m9assage tabl in addition to other furnishings There were photographs of nude wom8e-1n lining the stairway hall and in the bedroom8 The girl would then find herself alone in the room8 with Epstein who would be wearing only a towel He would then rem8ove his towel and lie naked on the m9assage table and di rect the girl to rem9ove her clothes Epstein would then perform9 one or m9o1re lewd lasciv ious and sexual acts including m9asturbation and touching the girl 2s vagina Cons-5i-6s-5t-6e-5nt with the foregoing plan and schem9e when Jane Doe was approxim9ately years old she was recruited by Haley Robson to gi-1ve Epstein a m9a-1ssage for m9onetary com9p1ensation 10Jane was brought to Epstein 2s m9ansion in Palm9 Beach to the kitchen entrance Once there Jane was introduced to Sarah Kellen who led her up the light of4 stairs to the room9 with the m9assage table In this room9 Jane was directed by Epstei to rem9ove her clothes and give him9 a m9assage Jane initially kept her panties and bra on and com9p1lie with Epstein 2s instructions Jane was paid by Epstein for this m8a-1ssage Jane returned on m8a-1ny occasions to the Palm9 B3each m9ansion to provide Epstein w3ith m9assages On those occasions Epstein engaged in sexual contact and activity with the m9i-1nor Jane which included am9ong other things directing Jane to rem9ove all her clothes m9asturbating during the m9assage and digitally penetrating Jane 2s vagina Jeffrey Epstein ofte used a vibrator on the m9i-1nor Jane during the m9assage This sexual abuse continued for approxim9ately three years As a result of these encounters with Epst ein Jane experienced confusion sham8e hum9iliation and em9barrassm9ent and has suf4f4ered severe psychological and em9otional injuries Case Document Entered on FLSD Docket Page of COUNT I Sexual Assault and Battery 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 Florida Statute including subsections and thereof and other Case Document Entered on FLSD Docket Page of 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
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