Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of jurisdiction pursuant to U.S.C a over all other claims set forth herein which form part of the same case or controversy This Court has venue of this action pursuant to U.S.C a and as a substantial part of the events or omissions giving rise to the claim occurred in this District Factual Allegations At all relevant times Defendant Jeffrey Epstein Epstein was an adult male approximately 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 infom1ation 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 These underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion Epstein 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 Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of 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 Epsteins plan and scheme reflected a particular pattern and method The underage victim would be brought or directed to Epsteins mansion where she would be led up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings 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 Consistent with the foregoing plan and scheme when Jane Doe was only years old she was recruited by another girl to give Epstein a massage for monetary compensation Jane was brought to Epsteins mansion in Palm Beach Once there she was led up the flight of stairs to the room with the massage table Epstein came into the room and directed Jane to remove her clothes and give him a massage As directed by Epstein Jane stripped to her underwear Epstein then sexually assaulted Jane during the massage In addition Epstein masturbated during the massage Epstein then paid Jane money As a result of this encounter with Epstein Jane experienced confusion shame humiliation and embarrassment and has suffered severe psychological and emotional injuries COUNTI Sexnal Assault and Battery Plaintiff Jane Doe repeats and realleges paragraphs through above Epstein made an intentional unlawful offer of offensive sexual contact toward Jane Doe creating a reasonable fear of imminent peril and sexual assault Epstein intentionally inflicted harmful or offensive sexual contact on the person of Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Jane Doe Epstein tortiously committed a sexual assault and battery on Jane Doe 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 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 Comi 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 with a minor was extreme and outrageous going beyond all bounds of decency Epstein committed willful acts of child sexual abuse on Jane Doe These acts resulted in mental or sexual injury that caused or were likely to cause Jane Does mental or emotional health to be significantly impaired 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 distress and damage to Jane Doe or Epstein acted with reckless disregard of the high probability of causing Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of severe emotional distress 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 COUNTI Coercion and Enticement to Sexual Activity in Violation of U.S.C Plaintiff Jane Doe repeats and realleges paragraphs I through above Epstein used a facility or means of interstate commerce 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 criminal offense On June Epstein entered a plea of guilty to violations of Florida and in the 15th Judicial Circuit in and for Palm Beach County Case nos IAXMB and for conduct involving the same plan and scheme as alleged herein As to Plaintiff Jane Doe Epstein could have been charged with criminal violations of Florida Statute including subsections and thereof and other criminal offenses including violations of Florida Statutes and including subsections and thereof Epsteins acts and conduct are in violation of U.S.C As a result of Epsteins violation of U.S Plaintiff has suffered personal injury including mental psychological and emotional damages Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Plaintiff hired Herman Mermelstein P.A in this matter and agreed to pay them a reasonable attorneys fee WHEREFORE Plaintiff Jane Doe No demands judgment against Defendant Jeffrey Epstein for all damages available under U.S.C a including without limitation actual and compensatory damages costs of suit and attorneys fees and such other and further relief as this Court deems just and proper JURY TRIAL DEMAND Plaintiff demands a jury trial in this action on all claims so triable Dated February Respectfully submitted By sf Adam Horowitz Stuart Mermelstein FL Bar No ssm sexabuseattorney.com Adam Horowitz FL Bar No ahorowitz sexabuseattorney.com MERMELSTEIN HOROWITZ P.A Attorneys for Plaintiff Biscayne Blvd Suite Miami Florida Tel Fax Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of CERTIFICATE OF SERVICE I hereby certify that on February I electronically filed the foregoing document with the Clerk of the Court using CM/ECF I also certify that the foregoing document is being served this day to all parties on the attached Service List in the manner specified either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing Adam Horowitz Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of SERVICE LIST DOE vs JEFFREY EPSTEIN United States District Court Southern District of Florida Jack Alan Goldberger Esq jgoldberger agwpa.com Robert Critton Esq rcritton a bclclaw.com Isl Adam Horowitz
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