Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of 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 c!ientele 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 infonnation 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 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 Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of 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 As a result of this encounter with Epstein Jane experienced confusion shame humiliation and embarrassment and has suffered severe psychological and emotional injuries Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of COUNT Sexual Assault and Battery Plaintiff Jane Doe repeats and realleges paragraphs through above Epstein acted with intent to cause an offensive contact with Jane Doe or an imminent apprehension of such a contact and Jane Doe was thereby put in such imminent apprehension Epstein made an intentional unlawful offer of offensive sexual contact toward Jane Doe creating a reasonable fear of imminent peril Epstein intentionally inflicted harmful or offensive contact on the person of Jane Doe with the intent to cause such contact or the apprehension that such contact is imminent 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 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 with a minor was extreme and outrageous going beyond all bounds Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of of decency Epstein committed willful acts ofchild sexual abuse on Jane Doe These acts resulted in mental or sexual injury to Jane Doe 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 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 COUNT I Coercion and Enticement to Sexual Activity in Violation of U.S.C Plaintiff Jane Doe repeats and realleges paragraphs 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 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 Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page 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 of18 U.S.C Plaintiff has suffered personal injury including mental psychological and emotional damages 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 Adam Horowitz Stuart Mermelstein FL Bar No ssm sexabuseattomey.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 CASE NO 08-CV-80380-MARRA/JOHNSON United States District Court Southern District of Florida Jack Alan Goldberger Esq jgoldherger agwpa.com Robert Critton Esq rcritton bclclaw.com Isl Adam Horowitz
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