EFTA00175901

CM/ECF - Live Pqtabase - flsd 
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U.S. District Court 
Southern District of Florida (West Palm Beach) 
CIVIL DOCKET FOR CASE #: 9:08-cv-80993-DTICH 
Jane Doe No. 71 Epstein 
Assigned to: Judge Daniel T. K. Hurley 
Referred to: Magistrate Judge James M. Hopkins 
Cause: 28:1391 Personal Injury 
Plaintiff 
Jane Doe No. 7 
Date Filed: 09/10/2008 
Jury Demand: Plaintiff 
Nature of Suit: 710 Labor: Fair 
Standards 
Jurisdiction: Federal Question 
represented by Adam D. Horowitz 
Herman & Mermelstein, P.A. 
18205 Biscayne Blvd. 
Suite 2218 
Miami , FL 33160 
305-931-2200 
Fax: 305-931-0877 
Email: [email protected] 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Jeffrey Marc Herman 
Herman & Mermelstein 
18205 Biscayne Boulevard 
Suite 2218 
Miami , FL 33160 
305-931-2200 
Fax: 931-0877 
Email: [email protected] 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Stuart S. Mermelstein 
Herman & Mermelstein 
18205 Biscayne Boulevard 
Suite 2218 
Miami , FL 33160 
305-931-2200 
Fax: 931-0877 
Email: [email protected] 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
JMH 
https://ccf flsd.uscourts.gov/cgi-bin/DktRpt.pl?707770149002069-L_801_0-1 
10/8/2008 
EFTA00175901

CM/ECF - Live nqtabase - flsd 
Page 2 of 2 
Defendant 
Jeffrey Epstein 
represented by Robert Deweese Critton , Jr. 
Burman Critton Luther & Coleman 
515 N Flagler Drive 
Suite 400 
West Palm Beach , FL 33401-2918 
561-842-2820 
Fax: 561-515-3148 
Email: [email protected] 
LEAD ATTORNEY 
ATTORNEY TO BE NOTICED 
Date Filed 
# clear Docket Text 
09/10/2008 
1 r
COMPLAINT against Jeffrey Epstein Filing fee $ 350.00. Receipt#: 
544158, filed by Jane Doe No. 7.(vt) (Entered: 09/10/2008) 
09/10/2008 
F Summons Issued as to Jeffrey Epstein. (vt) (Entered: 09/10/2008) 
09/15/2008 
r 
NOTICE of Attorney Appearance by Robert Deweese Critton, Jr on behalf 
of Jeffrey Epstein (Critton, Robert) (Entered: 09/15/2008) 
10/03/2008 
4 
F 
ACKNOWLEDGMENT OF SERVICE Executed as to 2 Summons 
Issued, 1 Complaint Acknowledgement filed by Jane Doe No. 7. (Herman, 
Jeffrey) (Entered: 10/03/2008) 
10/03/200S 
5 r NOTICE of Striking 4 Acknowledgment of Service filed by Jane Doe No. 
7 by Jane Doe No. 7 (Herman, Jeffrey) (Entered: 10/03/2008) 
10/01'200X 
() 
r 
SUMMONS (Affidavit) Returned Executed by Jane Doe No. 7. Jeffrey 
Epstein served on 9/23/2008, answer due 10/14/2008. (Herman, Jeffrey) 
(Entered: 10/03/2008) 
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https://ccf.flsd.uscourts.gov/cgi-bin/lAtRpt.pl?7077701490020694,_801_0-1 
10/8/2008 
EFTA00175902

Case 9:08-cv-b.....,93-DTKH 
Docui...int 1 
Entered III FLSD Docket 09/ . a/200 FiLmaitoe 11677D.C.
ELECTRONIC 
JANE DOE NO. 7, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
SEPT. 10, 2008 
STEVEN M. LARIMORE 
CLERK U.S. MST. CT. 
5.0. OF FLA. • MIAMI 
CASE NO • 
08-CV-80993-Hurley-Hopkins 
COMPLAINT 
Plaintiff, Jane Doe No. 7 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey 
Epstein, as follows: 
Parties, Jurisdiction and Venue 
1. 
Jane Doe No. 7 is a citizen and resident of the State of Florida, and is sui juris. 
2. 
This Complaint is brought under a fictitious name to protect the identity of the 
Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a 
minor. 
3. 
Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 
4. 
This is an action for damages in excess of $50 million. 
5. 
This Court has jurisdiction of this action and the claims set forth herein pursuant to 28 
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. 
6. 
Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because 
Plaintiff alleges a claim under the laws of the United States. This Court has supplemental 
HERMAN E, MERMELSTEIN, P. A. 
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www.herrnanlaw.com 
tot? 
EFTA00175903

08-Ca-80983$„tutter-Hoiak...ts 1 
Entered 
FLSD Docket 09, . a/2008 
Page 2 of 7 
jurisdiction pursuant to 28 U.S.C. §1367(a) over all other claims set forth herein, which form part of 
the same case or controversy. 
7. 
This Court has venue of this action pursuant to 28 U.S.C. §§1391(a) and 1391(b) as a 
substantial part of the events or omissions giving rise to the claim occurred in this District. 
Factual Allegations 
8. 
At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 
approximately 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. 
9. 
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 2004, Jane Doe, then approximately 16 years old, fell into Epstein's trap 
and became one of his victims. 
10. 
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. 
11. 
Epstein's scheme involved the use of young girls to recruit underage girls. Haley 
Robson, a Palm Beach Community College student from Loxahatchee, Florida recruited girls 
ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. 
Ms. Robson, upon information and belief, generally sought out economically disadvantaged 
HERMAN 54 MERMELSTEIN, P. A. 
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wvm.hermanlaw.com 
2 of 
EFTA00175904

0.8-CeVe80993,.,tutterMapik.....isi 
Entered 
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Page 3 of 7 
underage girls from western Palm Beach County 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 
clement of Epstein's plan. 
12. 
Epstein's plan and scheme reflected a particular pattern and method. The underage 
victim would be brought to Epstein's mansion, where she would be introduced to Sarah Kellen, 
Epstein's assistant. 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. The girl would then find herself alone in 
the room with Epstein, who would be wearing only a towel. He woulddirect he rigl to give him a 
massage. Epstein would then perform one or more lewd, lascivious and sexual acts, including 
masturbation and touching the girl's vagina. 
13. 
Consistent with the foregoing plan and scheme, when Jane Doe was 16 years old, she 
was recruited by Haley Robson to give Epstein a massage for monetary compensation. Jane was 
brought to Epstein's mansion in Palm Beach. Once there, Jane was introduced to Sarah Kellen, who 
led her up the flight of stairs to the room with the massage table. In this room, Jane was directed by 
Epstein to give him a massage. During this massage, Epstein sexually assaulted Jane and 
masturbated. Epstein then paid Jane money. 
14. 
Jane returned on many occasions to the Palm Beach mansion to provide Epstein with 
massages for money. On those occasions, Epstein engaged in sexual contact and activity with Jane, 
which included, among other things, Epstein touching Jane's breasts, placing a vibrator on her 
vagina and masturbating himself. This sexual abuse continued over a period of approximately 18-24 
months. 
HERMAN & MERMELSTEIN, P. A. 
- 3 - 
www.hermanlaw.com 
3 WI 
EFTA00175905

Case 9:08-cv-b....93-DTKH 
Docui...;nt 1 
Entered 
FLSD Docket 09i ..)2008 
Page 4 of 7 
15. 
As a result of these encounters with Epstein, Jane experienced confusion, shame, 
humiliation and embarrassment, and has suffered severe psychological and emotional injuries. 
COUNT I 
Sexual Assault and Battery 
16. 
Plaintiff Janc Doe repeats and realleges paragraphs 1 through 15 above. 
17. 
Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane 
Doe, creating a reasonable fear of imminent peril and sexual assault. 
18. 
Epstein intentionally inflicted harmful or offensive sexual contact on the person of 
Jane Doe. 
19. 
Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts 
were intentional, unlawful, offensive and harmful. 
20. 
Epstein's plan and scheme in which he committed such acts upon Jane Doe were done 
willfully and maliciously. 
21. 
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 No. 7 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 
22. 
Plaintiff Jane Doe repeats and realleges paragraphs 1 though 15 above. 
23. 
Epstein's conduct was intentional or reckless. 
HERMAN S. MERMELSTEIN, P. A. 
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EFTA00175906

Case 9:08-cv-b...-93-DTKH 
Doctil ....Int 1 
Entereo 
FLSD Docket 09) 
/2008 
Page 5 of 7 
24. 
Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds 
of decency. 
25. 
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 Doe's mental or emotional health 
to be significantly impaired. 
26. 
Epstein's 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. 
27. 
As a direct and proximate result of Epstein's intentional or reckless conduct, Jane 
Doe, has suffered and will continue to suffer severe mental anguish and pain. 
WHEREFORE, Plaintiff Jane Doe No. 7 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 HI 
Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. *2422 
28. 
Plaintiff Jane Doe repeats and realleges paragraphs 1 through 15 above. 
29. 
Epstein used a facility or means of interstate commerce to knowingly persuade, 
induce or entice Jane Doc, when she was under the age of 18 years, to engage in prostitution or 
sexual activity for which any person can be charged with a criminal offense. 
30. 
Epstein's acts and conduct are in violation of 18 U.S.C. §2422. 
31. 
As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal 
injury, including mental, psychological and emotional damages. 
HERMAN & MERMELSTEIN, P. A. 
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www.hermanlaw.com 
EFTA00175907

Case 6:08-cv-6,..,n-DTKH 
Docut.idnt 1 
Entered 
i FLED Docket 09, u/2008 
Page 6 of 7 
32. 
Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a 
reasonable attorneys' fee. 
WHEREFORE, Plaintiff Jane Doe No. 7 demands judgment against Defendant Jeffrey 
Epstein for all damages available under 18 U.S.C. §2255(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: September i V , 2008 
Respectfully su 
By: 
Jeffrey M. Herman (FL Bar No. 521647) 
ihermanftermanlaw.com 
Stuart S. Mermelstein (FL Bar No. 947245) 
[email protected] 
Adam D. Horowitz (FL Bar No. 376980) 
ahorowitzahermanlaw.com 
HERMAN & MERMELSTEIN, P.A. 
Attorneys for Plaintiff 
18205 Biscayne Blvd., Suite 2218 
Miami, Florida 33160 
Tel: 305-931-2200 
Fax: 305-931-0877 
HERMAN & MERMELSTEIN, P. A. 
- 6 - 
www.hermanlaw.com 
EFTA00175908

08 
• 
-511439. 
,AgYnkl
-PPISOtihieW l-  CQWgf&ck.rgraD Docket 04/ 012008 
Page 7 of 7 
The JS -44 owl 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 Stales in September 1974, Is required for the use of the Clerk of 
the Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) 
1(a) PLAINTIFFS 
JANE DOE NO. 7, 
(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF 
ORANGE COUNTY 
(EXCEPT IN U.S. PLAINTIFF CASES) 
DEFENDANTS 
JEFFREY EPSTEIN 
COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT NEW YORK 
(IN U.S. PLAINTIFF CASES ONLY) 
(c) ATTORNEYS (FIRM NAME. ADDRESS, AND TELEPHONE NUMBER) 
Herman 8 Mermelsteln, PA., 18205 Biscayne Blvd., Suite 2218, Miami, 
FL 33160, (305) 931.2200 
(d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH 
H. BASIS OF JURISDICTION 
(PLACE AN X ONE BOX ONLY) 
O 1. U.S. Govenvnenl 
Plaintiff 
O 2. US. Government 
Defendanl 
X 3 Fedora! Coeslion 
(U.S Coyerranenl Not a Party) 
0 4. Olversity 
(Instate Citizenship of Ponies in fern 
ATTORNEYS (IF KNOWN) 
gyi(t/i/ gen earn- grn4-5
III. CITIZENSHIP OF PRINCIPAL PARTIES 
PLACE AN X IN ONE BOX FOR PLAINTIFF 
(For Diversity Case Only) 
AND ONE FOR DEFENDANT 
PIE 
DEF 
PTF 
DEE Incorporaled of Principal Place of 
0 4 
0 4 
Citizen of This Slate 
0 I 0 1 
Citizen of Another Stale 
0 2 0 2 
Citizen or SAW of a Foreign Country 0 3 0 3 
Business In This State 
Incorporated and Principal Piece of 
Business in Another State 
Foreign Nation 
O 5 
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O a 
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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.) 
ACTION FOR SEXUAL ASSAULT UNDER 18 U.S.C. $2422 AND STATE LAW 
IVs. I_ days estimated (for both sides) to try entire case 
F. NATURE OF SUIT 
(PLACE AN X IN ONE BOX ONLY) 
A CONTRACT 
A TORTS 
B FORFEITURE 
PENALTY 
A BANKRUPTCY 
A OTHER STATUS 
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VI. ORIGIN 
x 1. Original 
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K 3. Remanded from 
0 4. Refilled 
0 6. Multicilstict Ligation 
0 7. 
Appeal to District Judge from 
Appellate Court 
0 5. Transferred from another district 
(Specify) 
Magistrate Judgment 
VII. REQUESTED 
IN COMPLAINT 
O UNDER F R.C.P. 23 
CHECK IF THIS IS A 
0 CLASS ACTION 
DEMAND S 
o 
Check YES only If demanded in 
X YES 
mnplaInt: 
JURY DEMAND: 
0 NO 
VIII. RELATED 
CASE(S) IF ANY 
i l
Jane Doe 2 . Jeffrey Epstein 
Jane Doe 3 . Jeffrey Epstein 
Jane Doe 4 . Jeffrey Epstein 
Jane Doe 5 . Jeffrey Epstein 
(See Instructions): 
(SEE ATTACHED) 
JUDGE KENNETH A. MARRA 
JUDGE KENNETH A. MARRA 
JUDGE KENNETH A MARRA 
JUDGE KENNETH A MARRA 
DOCKET NUMBER 08-CV-80119-MARRA.JOHNSON 
DOCKET NUMBER 08-CV-S0232-MARRA-JOHNSON 
DOCKET NUMBER 08-CV-80380-MARRA/JOHNSON 
DOCKET NUMBER 08-80381-CIV-MARRNJOHNSON 
DATE 
Cerf— (C)1 
2,4O 
UNITED STATES DISTRICT COURT 
S/F 1.2 
REV. 0/94 
SIGNATURE OF ATTORNEY OF RECORD 
FOR OFFICE USE ONLY: Receipt No. 
Date Paid: 
54#3 
Ma 
EFTA00175909