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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 
JANE DOE NO. 1, by and through 
08 
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. 
80Q69 
CIV-MARRA 
WaLSTRATE 111116B 
IONNSON 
FILED by 
INTAKE 
JAN 24 2008 
SSC.LEM0RIC
CIIr
a:•14DIR
ASDT.721b. 
COMPLAINT 
Plaintiff, Jane Doe No. 1 ("Jane" or "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, 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 of 18 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 is brought 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 of New 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 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. 
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 14 years 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 -a
 Palm Beach 
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Community College student from 
She recruited girls ostensibly to give a 
wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's 
plat 
vould 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 directedMI 
to bring 
one or more underage girls to the residence 
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, would 
introduce each victim tB=Epstein's 
assistant, 
who gathered the girl's personal information, including her name and telephone number. 
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 
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 
14. 
Consistent with the foregoing plan and scheme 
recruited Jane Doe to 
give Epstein a massage for monetary compensation. 
nought Jane to Epstein's mansion 
in Palm Beach. Jane was introduced tc
vlio 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 mel=Mgain 
who brought 
Jane home. Jane was paid $300 by Epstein. 
'as paid $200 by Epstein for bringing Jane 
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. 
Plaintiff Jane 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. 
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 to know 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. 
Plaintiff Jane 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 of comfort, 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 of consortium 
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 924, 2008 
Respectfully submitted, 
HERMAN & MERMELSTEIN, P.A. 
Attorneys for Plaintiffs 
iami, rton 
Tel: 305-931-2200 
Fax: 305-931-0877 
By: 
Stuart S. Mermelstein 
Adam D. Horowitz 
HERMAN & MERMELSTEIN, P. A. 
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