Case Document Filed Page of Case Document Entered on FLSD Docket Page of Case Document Filed Page of of6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO FILED by VT D.C ElECTRONlC ebruary CLARENCE MADDOX CLERK U.S 01ST CT OF lLA MIAMI JANE DOE NO 08-CV-80119-MARRA-JOHNSON Plaintiff vs JEFFREY EPSTEIN Defendant I COMPLAINT Plaintiff Jane Doe No Jane or Jane Doe brings this Complaint against Jeffrey Epstein as follows Parties Jurisdiction and Venue Jane Doe No is a citizen and resident of the Commonwealth of Virginia and is sui juris This Complaint is brought wider a fictitious name to protect the identity of the 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 of New York This is an action for damages in excess of million This Court has jurisdiction of this action and the claims set forth herein pursuant to U.S.C a as the matter in controversy i exceeds exclusive of interest and costs and ii is between citizens of different states This Court has venue of this action pursuant to U.S.C a as a substantial HERMAN IS MERMELSTEIN A w.hermanlaw.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of I 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 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 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 Epsteins scheme involved the use of young girls to recruit underage girls Upon information and belief the young girl who brought Jane Doe to Epstein was herself a minor victim of Epstein and will therefore not be named in this Complaint Under Epsteins plan underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion The recruiter 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 would direct the recruiter to bring one or more underage girls to the residence The recruiter upon information and belief generally sought out economically disadvantaged underage girls from western Palm Beach HERMAN MERMELSTEIN A w.hermanlaw.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of County 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 Epsteins plan and scheme reflected a particular pattern and method Upon arrival at Epsteins mansion the underage victim would be introduced 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 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 and touching the girls vagina Consistent with the foregoing plan and scheme Jane Doe was recruited to give Epstein a massage for monetary compensation Jane was brought to Epsteins mansion in Palm Beach Once at the mansion Jane was introduced to Sarah Kellen who led her up the flight of stairs to the room with the massage table In this room Epstein told Jane to take off her clothes and give him a massage Jane kept her panties and bra on and complied with Epsteins instructions Epstein wore only a towel around his waste After a short period of time Epstein removed the towel and rolled over exposing his penis Epstein began to masturbate and he sexually assaulted Jane After Epstein had completed the assault Jane was then able to get dressed leave the room and go back down the stairs Jane was paid by Epstein The young girl who recruited Jane was paid by Epstein for bringing Jane to him HERMAN MERMELSTEIN A w.hermanlaw.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of As a result of this encounter with Epstein Jane experienced confusion shame humiliation and embarrassment and has suffered severe psychological and emotional injuries COUNTI Sexual Assault Plaintiff Jane Doe repeats and realleges paragraphs through above Epstein tortiously assaulted Jane Doe sexually 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 This sexual assault was in violation of Chapter of the Florida Statutes which recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane 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 Court 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 was outrageous going beyond all bounds of decency Epsteins conduct caused severe emotional distress to Jane Doe Epstein knew or had HERMAN MERMELSTEIN A w.hermanlaw.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of I reason to know that his intentional and outrageous conduct would cause emotional trauma and damage 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 JURY TRIAL DEMAND Plaintiffs demand a jury trial in this action Dated February HERMAN MERMELSTEIN A Respectfully submitted HERMAN MERMELSTEIN P.A Attorneys for Plaintiffs Biscayne Blvd Suite Miami Florida Tel Jeffrey Herman jherman hermanlaw.com Florida Bar No Stuart Mermelstein smermelstein hermanlaw.com Florida Bar No Adam Horowitz Florida Bar No ahorowitz hermanlaw.com w.hermanlaw.com Case Document Entered on FLSD Docket Page of Case Document Filed Page of CIVIL COVER
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