EFTA00221172

Case 9:08-cv-80993-KAM 
Document 1 
Entered on FLSD Docket 09/10/200 FiLmine 1 [1177  D.C. 
ELECTRONIC 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 
JANE DOE NO. 7, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
SEPT. 10, 2008 
STEVEN M. LARIMORE 
CLERK U.S. GIST. CT. 
S.D. OF FLA. • MIAMI 
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 & MERMELSTEIN, P. A. 
www.hermanlaw.com 
1417 
- 1 - 
EFTA00221172

08-eMe813993eNuttey-Hoekins 
Entered on FLSD Docket 09/10/2008 
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 pan 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. 
, 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. 
upon information and belief, generally sought out economically disadvantaged 
HERMAN S MERMELSTEIN, P. A. 
www.herrnanlaw.com 
2 Ott 
- 2 - 
EFTA00221173

08-CALe80993341tittey-Hopkins 
Entered on FLSD Docket 09/10/2008 
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 i f allegations of improper conduct were made. This was an important 
element 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 
Epstein's assistant. 
ould 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 
to give Epstein a massage for monetary compensation. Jane was 
brought to Epstein's mansion in Palm Beach. Once there, Jane was introduced to 
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. 
www.hemianlaw.com 
3 of 7 
- 3 - 
EFTA00221174

Case 9:08-cv-80993-KAM 
Document 1 
Entered on FLSD Docket 09/10/2008 
Page 4 of 7 
IS. 
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 Batten 
16. 
Plaintiff Jane Doe repeats and rcalleges 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 H 
Intentional Infliction of Emotional Distress 
22. 
Plaintiff Jane Doe repeats and realleges paragraphs 1 through 15 above. 
23. 
Epstein's conduct was intentional or reckless. 
HERMAN & MERMELSTEIN. P. A. 
www.hermanlaw.com 
- 4 - 
EFTA00221175

Case 9:08-cv-80993-KAM 
Document 1 
Entered on FLSD Docket 09/10/2008 
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 III 
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 Doe, 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. 
www.hermanlaw.com 
- 5 - 
EFTA00221176

Case 9:08-cv-80993-KAM 
Document 1 
Entered on FLSD Docket 09/10/2008 
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 10, 2008 
Respectfully su 
By. 
Jeffrey M. Herman (FL Bar No. 521647) 
jhermanahermanlaw.com 
Stuart S. Mermelstein (FL Bar No. 947245) 
[email protected] 
Adam D. Horowitz (FL Bar No. 376980) 
[email protected] 
HERMAN & MERMELSTEIN, P.A. 
Attorneys for Plaintff 
18205 Biscayne Blvd., Suite 2218 
Miami, Florida 33160 
Tel: 305-931-2200 
Fax: 305-931-0877 
HERMAN S. MERMELSTEIN, P. A. 
www.hermanlaw.com 
- 6 - 
EFTA00221177

° 8-qY;§(aHMAgYA4°PilfringritVilL CgAigificIWKID Docket 09/10/2008 
Page 7 
ocfDi
t ye µA 
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 of initiating the civil docket sheet (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) 
1(a) PLAINTIFFS 
DEFENDANTS 
JANE DOE NO. 7, 
JEFFREY EPSTEIN 
(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF 
ORANGE COUNTY 
(EXCEPT IN U.S. PLAINTIFF CASES) 
COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT NEW YORK 
(IN U.S. PLAINTIFF CASES ONLY) 
(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER) 
Herman & Mermelstein, PA, 18205 Biscayne Blvd., Suite 2218, Miami, 
FL 33180, (305) 931.2200 
ATTORNEYS (IF KNOWN) 
(d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH 
II. BASIS OF JURISDICTION 
(PLACE AN X ONE BOX ONLY) 
a 1. U.S. Government 
X 3 Federal Question 
Plaintiff 
(U.S Government Not a Party) 
O 2 U S. Government 
O 4. Diversity 
Defendant 
(Indicate Citizenship of Parries in Item 
111) 
f'6V Re970-ei-74y-M,A4.5
III. CITIZENSHIP OF PRINCIPAL PARTIES 
(For Diversity Case Only) 
PTF 
DEF 
Citizen of This State 
O 1 O 1 
Citizen of Another State 
CI 2 
O 2 
Citizen or Subject of a Foreign Country O 3 O 3 
PLACE AN X IN ONE BOX FOR PLAINTIFF 
AND ONE FOR DEFENDANT 
PTF 
DEF 
Incorporated of Principal Place of 
O 4 
O 4 
Business in This State 
incorporated and Principal Piece of 
O 5 
O 5 
Business in Another State 
Foreign Nation 
O 6 
O 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.) 
ACTION FOR SEXUAL ASSAULT UNDER 18 U.S.C. 52422 AND STATE LAW 
Na. j
 days estimated (for both sides) to try entire case 
V. NATURE OF SUIT 
(PLACE AN X IN ONE BOX ONLY) 
A CONTRACT 
A TORTS 
B FORFEITURE 
PENALTY 
A BANKRUPTCY 
A OTHER STATUS 
o 1101ratirce 
0 1204.104. 
0 type. Ac 
0  110400441atis risintrel 
CI 151"4".." 4°Nal)ar al
A Eitrowenof 
.10514w1 
0 151144400440 Act 
0 152 Rseg 000000 
Sasein Nee Nal 
~Ina 
a  asu man., awn
. 
44VolwaYs110WO 0 
o 1003,0100440 a Sub 
0 Maw Cava 
o 1950,1002 Padua 1000y 
PERSONAL INJURY 
030 0.414100 
0 362 Pw1010 1110,4400 Wm.= 
03,5 &fling Avoca Lay 
0336 Prime 1140.0100.0 144044y 
0120 AualtLIMI s suno« 
02nd masa emotes 
0 3131404401t4r07.01 La, 
tn." •00140 1.00440 
0 34411Arkw 
0 345 Name Pc04c4 ant 
PERSONAL PROPERTY 
0 350 SAN WAN 
0 355 Na. 
Whom Polua La 
0370 Ors RAO 
/4 51001. Perna00•01 
0 171 Tn. 0101000 I 
afro 0104 Periorml 
Progeny Damage 
a345 Room 0440400
Ont0.014.044 
00+0 442404•44, 
0 COO 071044.3410n4 
a We Dow nested Sieve 
 of 110:0041/211190 411 
0010 Lbw Lan 
0 &ORR& TruOt 
0 NO AS* Reis 
0 002 Ocomplans 
SAMA4• 04P 
0 NO CO. 
0 422 40000 2$ USG 04 
0423 Watirsni MSC ist 
400 As Roaccoraw4 
410 Aroma. 
430 0.414 a* Ban140 
440 Cown00140X R1041.4c B 
400 Owyesion 
ne rudeue sermon 
ConwsOrganaft. 
110 Sawa Spa 
eS0 SloseWtoenneami 
A PROPERTY RIGHTS 
040 C00412/14 
040 Past 
0040 Tracleauei 
Lida/0 
0/5 Cvasyrst Ca* 
1311303410 
MI Aptcatia Ada 
RO Ecoveic Statesfito ea 
1133 tomonnoval Wan 
404 (tow Aloa000M2 
405 1000550101,400mbwiA0 
op 00p•44 01n 0410000.0et 
Untle4040.400040401 
am 
0 050 Coullulion0004 Sus 
SWAM 
0 KO OM! ROAM Mids.
• A one 
Darts' rants' IWO Wm Omit 
100464004on 
B SOCIAL SECURITY 
0101 MIA11316M 
0002 Dag lam (OM 
0163 D(V/CONAV(41:60)) 
OW 550 TY XV1 
CMS 413, 1•05001 
A REAL PROPERTY 
A CIVIL RIGHTS 
B PRISONER PETITIONS 
A LABOR 
0 PO Ista0700., 040,
Cs 220 Fon004.04 0 
0 270 Pun Lean & Fagan 
0 20 Tale IAN 
a 2403 Tad R1 
1000y 
0 ND 00044 RAN AVON 
0 441 VOWS 
0 442 ton0Pone• 
0 443 OtionpaaornerCdator• 
0 444 WWI* 
0 44001w C0410;011 
0 510.1040e4 ID Waite Steens 
Hata Caps 
0 Lx. Garr 
0 5350041,Pet, 
0 440 Manatamus 10•44' 
0 5.50004 R9t
vat 
1010 Fat lax SlanlaRIS 
40 
0 720 Lao, 444040.0.444 
Itslain I 
0 730 140a 1.1040~4 
A FEDERAL TAX SUITS 
114.140 4 00:0444, 
Aa 
0 740 !Won Lator la 
0 no owe War LII0a4on 
0 791 &WO.' Ra tic 
tarn Acta 
0 CO 700411/S Mann ce C•040 0 10 
0 571 RSTiwo Petry 26 USG )019 
VL ORIGIN 
x 1. Original 
O 2. Removed from O 3. Remanded from 
Proceeding 
State Cowl 
Appellate Court 
(Specify) 
O 4. Refilled 
O 6. Multidistrict Litigation 
O 7. 
Appeal to District Judge from 
O 5. Transferred from another district 
Magistrate Judgment 
VII. REQUESTED 
IN COMPLAINT 
a UNDER F.R.C.P. 23 
CHECK IF THIS IS A 
O CLASS ACTION 
DEMAND $ 
O 
Check YES only if demanded in 
X YES 
complaint: 
JURY DEMAND: 
O NO 
VIII. RELATED 
(See Instructions): 
CASE(S) IF ANY 
Jane Doe 2 v. Jeffrey Epstein 
Jane Doe 3 v. Jeffrey Epstein 
Jane Doe 4 v. Jeffrey Epstein 
Jane Doe 5 v. Jeffrey Epstein 
(SEE ATTACHED) 
JUDGE KENNETH k MARRA 
JUDGE KENNETH A. MARRA 
JUDGE KENNETH A MARRA 
JUDGE KENNETH A MARRA 
DOCKET NUMBER 08-CV-80119-MARRA-JOHNSON 
DOCKET NUMBER 08-CV-80232-MARRA-JOHNSON 
DOCKET NUMBER 08-CV-80380-MARRA/JOHNSON 
DOCKET NUMBER 08-80 
1-CIV- 
RNJOHNSON 
DATE 
O-eF' 
, 
2-OO 
UNITED STATES DISTRICT COURT 
S/F 1-2 
REV. 9/94 
SIGNATURE OF ATTORNEY OF RECORD 
tity 
FOR OFFICE USE ONLY: Receipt No. 
 Amount i?
Ali
Date Paid: 
Wfp: 
5-47/aS 
EFTA00221178