Case 9:08-cv-80069-KAM Document 1 Entered on FLSD Docket 01/25/2008 Page 1 of 7

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO.:

JANE DOE NO. 1,  by and through
JANE DOE's FATHER as  parent and natural
guardian, and JANE DOE's FATHER, and
JANE DOE's STEPMOTHER, individually,

Plaintiffs,
vs.
JEFFREY EPSTEIN,
Defendant.

08-80069

CIV-MARRA

MAGISTRATE JUDGE
JOHNSON

FILED by: <signature> D.C.
INTAKE
JAN 24 2008
CLARENCE MADDox
CLERK U.S. DIST. CT.
S.D. OF FLA. • FT. LAUD.

COMPLAINT

Plaintiff, Jane Doe No. 1 ("Jane" or "Jane Doe"), by and through Jane Doe's Father asparent and natural guardian, and Jane Doe's Father and Jane Doe's Stepmother, individually, bring this Complaint against Jeffrey Epstein, as follows:

Parties, Jurisdiction and Venue

1. Jane Doe is a citizen and resident of the State of Florida. She is a minor under the age of18 years.

2. Jane Doe's Father brings this action individually and as parent and natural guardian of Jane Doe. Jane Doe's Father is a citizen and resident of the State of Florida.

3. Jane Doe's Stepmother brings this action individually. Jane Doe's Stepmother is a citizen and resident of the State of Florida.

4. This Complaint isbrought under fictitious names to protect the identity of the Minor Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a

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minor.

5. Defendant Jeffrey Epstein is a citizen and resident of the State ofNew York. 6. This is an action for damages in excess of $50 million.

7. This Court has jurisdiction of this action and the claims set forth herein pursuant to28 U.S.C. § 1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs; and (ii) is between citizens of different states.

8. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial part of the events or omissions giving rise to the claim occurred in this District.

Factual Allegations

9. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52 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 Epstein's conduct while at his lavish estate in Palm Beach.

10. 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 2005, Jane Doe, then 14years old, fell into Epstein's trap and became one of his victims.

11. 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.

12. An integral player in Epstein's Florida scheme was Haley Robson, a Palm Beach

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Community College student from Loxahatchee, Florida. She recruited girls ostensibly to give a

wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's plan, Ms. Robson 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 directed Ms. Robson to bring one or more underage girls to the residence. Ms. Robson, upon information and belief, generally sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas who would be enticed by the money being offered - generally $200 to $300 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 Epstein's plan.

13. Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at

Epstein's mansion, Mr. Robson would introduce each victim to Sarah Kellen, Epstein's assistant, who gathered the girl's 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. Ms. Kellen would then leave the girl alone in this room, whereupon Epstein would enter wearing only a towel. He would then remove his towel, lay down naked on the massage table, and direct the girl to remove her clothes. He then would perform one or more lewd, lascivious and sexual acts, including masturbation and touching the girl's vagina with a vibrator.

14. Consistent with the foregoing plan and scheme, Ms. Robson recruited Jane Doe to give Epstein a massage for monetary compensation. Ms. Robson brought Jane to Epstein's mansion in Palm Beach. Jane was introduced to Sarah Kellen, who led her up the flight of stairs to the room with the massage table. She was alone in the room when Epstein arrived wearing only a towel. He

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removed his towel, and laid down naked on the massage table. He demanded that Jane remove her

clothes. In shock, fear and trepidation, Jane complied, removing her clothes except for her underwear. Epstein then sexually assaulted Jane.

15. After Epstein had completed the assault, he left the room. Jane was then able to get

- dressed, leave the room and go back down the stairs. She then met Ms. Robson again who brought Jane home. Jane was paid $300 by Epstein. Ms. Robson was paid $200 by Epstein for bringing Jane to him. to him.

16. As a result of this encounter with Epstein, the 14-year old Jane experienced

- confusion, shame, humiliation, embarrassment and the assault sent her life into a downward spiral.

COUNT I

Sexual Assault

17. PlaintiffJane Doe by and through her Father, as parent and natural guardian, repeats

- and realleges paragraphs 1  through  16  above.

18. Epstein tortiously assaulted Jane Doe sexually in or about 2005.

19. This sexual assault was in violation of Chapter 800 of the Florida Statutes, which

- recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane.

20. As a direct and proximate result of Epstein's 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, by and through her Father, as parent and natural guardian, 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.

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COUNT II

Intentional Infliction of Emotional Distress

21. Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane

- Doe's Father and Jane Doe's Stepmother, individually, repeat and reallege paragraphs 1 through 16 above. above.

22. Epstein's conduct was intentional or reckless.

23. Epstein's conduct was outrageous, going beyond all bounds of decency.

24. Epstein's conduct caused severe emotional distress not only to Jane Doe, but also to

- her parents, Jane Doe's Father and Jane Doe's Stepmother. Epstein knew or had reason toknow that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe's parents.

25. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane

- Doe, Jane Does' Father and Jane Doe's Stepmother have suffered and will continue to suffer severe mental anguish and pain.

WHEREFORE, Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane Doe's Father and Jane Doe's Stepmother demand 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 III

Loss of Parental Consortium

26. PlaintiffJane Doe's Father repeats and realleges paragraphs 1 through 16 above.

27. Epstein's tortious conduct is the direct and proximate cause of damages to Jane Doe's

- Father, consisting of parental loss ofcomfort, companionship and society and healthcare costs

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associated with the treatment of Jane.

28. Jane Doe's Father experienced and will continue to experience great mental anguish, pain and suffering from the time that Defendant's tortious conduct occurred.

WHEREFORE, Plaintiff Jane Doe's Father demands judgment for loss ofconsortium

damages, costs and such other and further relief as this Court deems proper.

JURY TRIAL DEMAND

Plaintiffs demand a jury trial in this action.

Dated: January 24, 2008

Respectfully submitted,
HERMAN & MERTELSTEIN, P.A.
Attorneys for Plaintiffs
18205 Biscayne Blvd.
Suite 2218
Miami, Florida 33160
Tel: 305-931-2200
Fax: 305-931-0877
By: <signature>
Jeffrey M. Herman
jherman@hermanlaw.com
Florida Bar No. 521647
Stuart S. Mermelstein
smermelstein@hermanlaw.com
Florida Bar No. 947245
Adam D. Horowitz
Florida Bar No. 376980
ahorowitz@hermanlaw.com

HERMAN & MERMELSTEIN, P. A.

www.hermanlaw.com

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Case 9:08-cv-80069-KAM DocumeIVIL COVER SHEED Docket 01/25/2008 Page 7 of 7

The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing, and service of pleading or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of the Court for the purpose ofinitiating the ci·Jil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)

I(a) PLAINTIFFS
JANE DOE, by and through
JANE DOE's FATHER as parent and natural
guardian, and JANE DOE's FATHER, and
JANE DOE's STEPMOTHER, individually,

(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF
PALM BEACH COUNTY
(EXCEPT IN U.S. PLAINTIFF CASES)

(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER)
Herman & Mermelstein, P.A., 18205 Biscayne Blvd., Suite 2218, Miami,
FL 33160, (305) 931-2200

(d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH

DEFENDANTS
JEFFREY EPSTEIN

COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT NEW YORK
(IN U.S. PLAINTIFF CASES ONLY): 08-80069

ATTORNEYS (IF KNOWN): CIV-MARRA <signature>

CIVIL ACTION NO.: 9:08CV80069-KAMJohnson

II. BASIS OF JURISDICTION
(PLEASE AN X ONE BOX ONLY)
[ ] 1. U.S. Government
X 3. Federal Question
Plaintiff
(U.S. Government Not a Party)
[ ] 2. U.S. Government
[ ] 4. Diversity
Defendant
(Indicate Citizenship of Parties in Item III)

III. CITIZENSHIP OF PRINCIPAL PARTIES
(For Diversity Case Only)
PLACE AN X IN ONE BOX FOR PLAINTIFF AND ONE FOR DEFENDANT
PTF DEF
Citizen of This State
x 1
[ ] 1
Business in This State
Citizen of Another State
[ ] 2
x 2
Incorporated and Principal Place of
Citizen or Subject of a Foreign Country
[ ] 3
[ ] 3
Business in Another State
Foreign Nation
[ ] 4
[ ] 4
[ ] 5
[ ] 5
[ ] 6
[ ] 6

IV. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE.
DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY.)
DIVERSITY ACTION UNDER 28 U.S.C. §1332(a) FOR SEXUAL ASSAULT

IVa._L days estimated (for both sides) to try entire case

V. NATURE OF SUIT (PLACE AN X IN ONE BOX ONLY)

A CONTRACT:
[ ] 110 Insurance
[ ] 120 Marine
[ ] 130 Miller Act
[ ] 140 Negotiable Instrument
[ ] 150 Recovery of Overpayment & Enforcement of Judgment
[ ] 151 Medicare Act
[ ] 152 Recovery of Defaulted Student Loans (Excl. Veterans') B
[ ] 153 Recovery of Overpayment of Veteran's Benefits B
[ ] 160 Stockholder's Suits
[ ] 190 Other Contract
[ ] 195 Contract Product Liability

PERSONAL INJURY:
[ ] 310 Airplane
[ ] 315 Airplane Product Liability
[ ] 320 Assault, Libel & Slender
[ ] 330 Federal Employers' Liability
[ ] 340 Marine
[ ] 345 Marine Product Liability
[ ] 350 Motor Vehicle
[ ] 355 Motor Vehicle Product Liability
[x] 360 Other Personal Injury
[ ] 362 Personal Injury-Med Malpractice
[ ] 365 Personal Injury-Product Liability
[ ] 368 Asbestos Personnel Injury Product Liability
PERSONAL PROPERTY:
[ ] 370 Other Fraud
[ ] 371 Truth in Lending B
[ ] 380 Other Personal Property Damage
[ ] 385 Property Damage Product Liability

B FORFEITURE PENALTY:
[ ] 610 Agriculture
[ ] 620 Other Food & Drug
[ ] 625 Drug Related Seizure of Property 21 USC 881
[ ] 630 Liquor Laws
[ ] 640 R.R. & Truck
[ ] 650 Airline Regs
[ ] 660 Occupational Safety/Health
[ ] 690 Other

A BANKRUPTCY:
[ ] 422 Appeal 28 USC 158
[ ] 423 Withdrawal 28 USC 157

A OTHER STATUS:
[ ] 400 Status Reappointment
[ ] 410 Antitrust
[ ] 430 Banks and Banking
[ ] 450 Commerce/ICC Rates/etc. B
[ ] 460 Deportation
[ ] 470 Raketeer Influenced and Corrupt Organizations
[ ] 810 Selective Service
[ ] 850 Securities/ Commodities/ Exchange
[ ] 875 Customer Challenge 12 USC 3410
[ ] 891 Agricultural Acts
[ ] 892 Economic Stabilization Act
[ ] 893 Environmental Matters
[ ] 894 Energy Allocation Act
[ ] 895 Freedom of Information Act
[ ] 900 Appeal of Fee Determination Under Equal Access to Justice
[ ] 950 Constitutionality of State Statutes
[ ] 890 Other Statutory Actions* * A or B

A REAL PROPERTY:
[ ] 210 Land Condemnation
[ ] 220 Foreclosure B
[ ] 230 Rent Lease & Ejectionment
[ ] 240 Torts to Land
[ ] 245 Tort Product Liability
[ ] 290 All Other Real Property

A CIVIL RIGHTS:
[ ] 441 Voting
[ ] 442 Employment
[ ] 443 Housing/Accommodations
[x] 444 Welfare
[x] 445 Other Civil Rights

B PRISONER PETITIONS:
[ ] 510 Motions to Vacate Sentence Habeas Corpus
[ ] 530 General*
[ ] 535 Death Penalty
[ ] 540 Mandamus & Other*
[ ] 550 Civil Rights *A or B

A LABOR:
X 710 Fair Labor Standards Act
[ ] 720 Labor Management Relations B
[ ] 730 Labor Management Reporting & Disclosure Act
[ ] 740 Railway Labor Act
[ ] 790 Other Labor Litigation
[ ] 791 Employee Ret. Inc. Security Act B

A FEDERAL TAX SUITS:
[ ] 870 Taxes (U.S. Plaintiff or Defendant)
[ ] 871 IRS-Third Party 26 USC 7609

FILED by K D.C.

VI. ORIGIN:
[x] 1. Original
[ ] 2. Removed from
[ ] 3. Remanded from
[ ] 4. Refilled
[ ] 6. Multidistrict Litigation Appeal to District Judge from
[ ] 7.
[ ] 5. Transferred from another district Magistrate Judgment

INTAKE:
JAN 24 2008
CLARENCE MADDOX CLERK U.S. DIST. CT. S.D. OF FLA , BAY P T LAWDY
VII. REQUESTED IN COMPLAINT:
CHECK IF THIS IS A
[ ] UNDER F.R.C.P. 23
[ ] CLASS ACTION
DEMAND $ <empty>
Check YES only if demanded in LAWDY complaint:
JURY DEMAND:
[ ] NO

VIII. RELATED CASE(S) IF ANY (See Instructions): (SEE ATTACHED)
JUDGE: <empty> DOCKET NUMBER: <empty>

DATE: 1/24/08 SIGNATURE OF ATTORNEY OF RECORD: <signature>

UNITED STATES DISTRICT COURT S/F 1-2 REV. 9/94 FOR OFFICE USE ONLY:
Receipt No.: <empty> Amount: 350.00
Date Paid: 3/21/07 M/ifp: <empty>
court-records/Doe v. Epstein, No. 908-cv-80069 (S.D. Fla. 2008)/001.pdf
{"year":"2008","court":"S.D. Fla","people":["jeffrey epstein","haley robson","sarah kellen","jeffrey m. herman","stuart s. mermelstein","adam d. horowitz","clarence maddox"]}