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This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →

FBI VOL00009

EFTA00234324

100 pages
Pages 61–80 / 100
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Case 9:08-cs-80804-KAM 
Document 1-2 
Entered on FLSD Docket 07/21/2008 
Page 61 of 100 
STATE COURT 
PLEADINGS 
EFTA00234384
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Case 9:08-cv-80804-KAM 
Document 1-2 
Entered on FLSD Docket 07/21/2008 
Page 62 of 100 
.f3rr ut 
nen 
Page. 15151 
Date 5129/200812.09:; 
A 
IN THE CIRCUIT COURT OF THE 
15TH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY 
FLORIDA 
JANE DOE, by and through 
JANE DOE'S MOTHER as parent and natural 
guardian, 
• 
Plaintiffs, 
V . 
JEFFREY EPSTEIN, HALEY ROBSON, 
and SARAH KELLEN, 
Defendants, 
962118 a 0 065 9 6,0000e 
COMPLAINT 
' 
Plaintiffs, JANE DOE, by and through JANE DOES MOTHER as parent and natural 
guardian of JANE DOE, bring this Complaint against Defendants JEFFREY EPSTEIN, HALEY 
ROBSON, and SARAH KELLEN, and state as follows: 
Parties, Jurisdiction and Vonuc 
I. Jane Doe is a citizen and resident of the Stale of Florida. She is a minor under the age of 
I 8 years. 
2. Jane Doe'S Mother brings this action as parent and natural guardian of Jane Doe. 
3. 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 
minor. 
4. DefendanfJeffrey Epstein is a citizen and resident of the State of New York. 
5. Defendant Haley Robson is a citizen and resident of Palm Beach County, Florida. 
6. Defendant Sarah Kellen is a citizen and resident of the Suite of New York. 
162 of 316 
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From 11 
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M 
7. This is an action for damages in excess of Fifteen Thousand Dollars ($15,000) exclusive of 
interest and costs 
8. Venue is proper in this Court under section 47.011, Florida Statutes, because the causes of 
action brought herein accrued in Palm Beach County, Florida and one or more Defendants resides in 
Palm Beach County, Florida. 
Factual Allegations 
9. At all relevant times, Defendant Jeffrey Epstein was an adult male. F;pstein is a financier and 
money manager with a secret clientele limited exclusively to billionaires. He is 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, Florida. The allegations herein concern Epstein's 
conduct while at his lavish estate in Palm Beach. 
10. Jpon information and belief, Epstein has a sexual preference and obsession For minor girls. 
He engaged in a plan, scheme, and/or enterprise in which he gained access to primarily economically 
disadvantaged minor girls in his home, sexually assaulted these girls or coerced them to engage in 
prostitution, and then gave them money. In or about 2005, Jane Doc, then 14 years old, fell into 
Epstein's trap and became one of his victims. 
I I. Upon in formmion and belief, Jeffrey Epstein carried out this scheme/enterprise 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 Sarah Kellen, an assistant of Epstein's 
front New York, New York and Haley Robson, a Palm Beach Community college student from 
Loxahatchee. Florida. They recruited girls ostensibly to give a wealthy man a massage for monetary 
compensation in his Palm Beach mansion. Under Epstein's plan/enterprise. Ms. Robson was 
contacted shortly befare or soon after Epstein was at his Palm Beach residence Epstein, Kellen or 
someone on their behalf directed Ms. Robson to bring one or more underage girls to the residence. 
Page 2 of 9 
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A 
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 elementof Epstein's plan/enterprise 
13. Epstein's plan. scheme, and/or enterprise 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 ton 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, touching the girl's vagina with a vibrator, or digitally penetrating 
the girl's vagina. 
14. Consistent will the foregoing plan, scheme, and/or enterprise, Ms. Robson recruited Jane 
Doc to give Epstein a massage for monetary compensation. Ms. Robson brought Jane Doe 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 Ms. Kellen set up the message table and laid out message 
oils and told Jane Doe that Epstein would be in shortly and than left the room. Jane Doe was alone in 
the room when Epstein arrived. Epstein told her to remove her clothes and left the room. When 
Epstein returned he was wearing only a towel. He removed his towel, and laid down on his 
stomach on the message table. Epstein again told Jane Doe remove her clothes. In shock, fear 
and trepidation, Jane Doe complied, removing her clothes except for her panties and bra. Shortly 
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vl 
after starting to rub Epstein's back, Epstein told Jane Doe to sit on his back. Jane Doe, out of fear 
and trepidation, complied. After a period of time Epstein got up from the table and went behind 
the door. For several minutes Jane Doe heard loud noises and moans and believes that Epstein 
was masturbating'. Thereafter Epstein, naked, returned to the message table and laid face up on 
the table. Epstein than told Jane Doe to continue with the message and told her to sit on top of 
him. Out of fear and trepidation she complied. As Jane Doc rubbed Epstein's chest Epstein 
began tc use a vibrator on Jane Doe's vagina. Thereafter Epstein began to digitally stimulate and 
attempt to penetrate Jane's vagina At this same lime Epstein was masturbating. Upon reaching 
orgasm Epstein Aot lip from the message table and told Jane Doe to write down her name and 
phone number and than left the room. 
15. Jane Doe was then able to get dressed, leave the room and go back down the stairs and 
into the kitchen. Epstein, Robson and Kellen were waiting for Jane Doe. Epstein paid Jane Doe 
£300. Ms. Robson was paid $200 by Epstein for bringing Jane to him. Ms Robson brought Jane 
Doe home. 
16. As a result of this encounter with Epstein. the I4-year old Jane Doe experienced 
confusion, shame, humiliation, embarrassment and the assault sent her life into a downward 
spiral. 
COUNT I 
Sexual Assault against Defendant Epstein 
17. Plaintiff Jane Doe by and through her Mother, as parent and natural guardian, repeats and 
realleges paragraphs I through 16 above. 
:8. Defendant Epstein toniously assaulted Jane Doc 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 Doe. 
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Date 5/29/2008 12 09 
'M 
20. As a direct Lnd proximate result of Epstein's assault on Jane Doc, she has suffered and 
will continue to suffer severe and permanent traumatic injuries, including mental, psychological 
and emotional damages.
WHEREFORE, Plaintiff Jane Doc, by and through her Mother, as parent and natural 
guardian, demands judgment against Defendant Jeffrey Epstein for compensatory damages, 
costs, attorney's fees, and such other and further relief as this Court deems just and proper. 
Further, Plaintiff reserves the right to amend this Complaint to add a claim fur punitive damages 
pursuant to Florida Law. 
COUNT II 
Civil Conspiracy against Defendants Epstein, Robson and Kellen 
21. Plaintiff Jane Doe by and through her Mother, as parent and natural guardian, repeats and 
realleges paragraphs I through 16 above. 
22. Defendants Epstein, Robson and Kellen conspired to subject Jane Doe to the sexual 
assault of Defendant Epstein. 
23. Each of the Defendants commined an overt act in pursuance of this conspiracy 
Defendant Ftobscin used false pretenses to lure Jane Doe to the home of Defendant Epstein so 
that Epstein could sexually assault Jane Doc; Defendant Kellen delivered Jane Doe to Defendant 
Epstein's bedroom so that Epstein could sexually assault Jane Doe, and Defendant Epstein 
actually committed sexual assault against Jane Doe. 
24. As a direct and proximate result of Defendants' civil conspiracy, Jane Doe has suffered 
and will continue to suffer severe and permanent traumatic injuries, including mental, 
psychological and emotional damages 
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EFTA00234389
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Document 1-2 
Entered on FLSD Docket 07/21/2008 
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From V! 
AT 
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Date 5/29/200ti 12 09 
A 
WHEREFORE, Plaintiff Jane Doe, by and through her Mother, as parent and natural 
guardian, demands judgment against Defendants Jeffrey Epstein, Haley Robson, and Sarah 
Kellen for compensatory damages, costs, attorney's fees, and such other and further relief as this 
Court deems just and proper. Further, Plaintiff reserves the right to amend tins Complaint to add 
it claim for punitive damages pursuant to Florida Law. 
COUNT HI 
Intentional infliction of Emotional Distress against Defendant Epstein 
25. Plaintiffs Jane Doe by and through her Mother, as parent rind natural guardian, repeat and 
reallege paragraphs 
through 16 above 
26. Epstein's conduct was intentional or reckless. 
27. Epstein's conduct was outrageous, going beyond all bounds of decency. 
28. Epstein's conduct caused severe emotional distress not only to lane Doe. Epstein knew 
or had reason to know that his intentional and outrageous conduct would cause emotional trauma 
and damage to Jane Doe and her mother. 
29. As a direot and proximate result of Epstein's intentional or reckless conduct, Jane Doe 
will continue to suffer severe mental anguish and pain. 
WI-IEREFORE, :rine Doe, by and through her Mother, and Jane Doe's Mother, individually, 
demand judgment against Defendant Jeffrey Epstein for compensatory damages, costs, attorney's 
fees, and such other and further relief as this Court deems just and proper. Further, Plaintiff 
reserves the right to amend this Complaint to add a claim for punitive damages pursuant to 
Florida Law. 
' 
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Date 5/29/2008 12 09. 
vt 
COUNT IV 
Civil Remedy for Violation of Florida Statute Section 772.103 against 
Defendants Epstein, Robson nod Kellen 
30. Plaintiffs Jane Doe by and through her Mother, us parent and natural guardian, repeat and 
reallege paragraphs I through 16 above. 
31. Defendants participated in an enterprise, or conspired or endeavored to so participate, 
through a pattern of criminal activity in violation of Florida Statute section 772.103(3)-(4). 
32. Defendants engaged in this pattern of criminal activity by engaging in of least two of the 
following incidents of criminal activity with the same or similar intents, results, accomplices, 
victims, and methods of commission within a S year period: 
a. Procuring for prostitution, or causing to be prostituted, any person who is under 
the age of IS years in violation of Florida Statute section 796.03; 
b. Soliciting, inducing, enticing, or procuring another to commit prostitution, 
lewdness, or assignation in violation of Florida Statute section 796.07(2)(1), or 
aiding, abetting or participating in such acts in violation of Florida Statute section 
796.07(2)(h); 
e. Knowingly recruiting, enticing, harboring, transporting, providing, or obtaining 
by' tiny means a person, knowing that force, fraud, or coercion will be used to 
cause that person to engage in prostitution in violation of Florida Statute section 
796.04.5; or 
d. Forcing, compelling, or coercing another to become o prostitute in violation of 
Florida Statute section 796.04. 
33. Under Defendants' plan, scheme and enterprise, Defendant Epstein paid Defendant 
Robson to repeated y find and bring him underage girls, who were delivered to Epstein by 
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Case 9:08-cv-80804-KAM 
Document 1-2 
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From u 
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Date' 5/29/2008 12:09 
M 
Defendants Robson and Kellen, in order for Epstein to solicit, induce, coerce, entice, compel or 
force such girls to engage in acts of prostitution and/or lewdness. 
34. PlaintiffJant Doe was the victim of Defendants' plan, scheme and enterprise. Defendant 
Robson took Jane Doc to Epstein's home under the pretense that Jane Doc would be paid to give 
Epstein a massage. Defendant Kellett delivered Jane Doe to a room with a message table and 
told WI Epstein would be in shortly. Jane Doe was alone in the room when Epstein arrived. 
Epstein told her to remove her clothes and left the room. When Epstein returned he was wearing 
only o towel. He removed his towel, and laid down on his stomach on the message table. Epstein 
again told Jane Doc remove her clothes. In shock, fear and trepidation, Jane One complied, 
removing her clottes except for her panties and bra. Shortly after stoning to rub Epstein's back, 
Epstein told Jane Doe to sit on his hack. Jane Doe, out of fear and trepidation, complied. After a 
period of time Epstein got up from the table and went behind the door. Inc several minutes Jane 
Doc heard loud noises and moans and believes that Epstein was masturbating. Thereafter 
Epstein, naked, returned to the message table and laid face tip on the table. Epstein than told 
Jane Doe to continue with the message and told her to sit on top of him. Out of fear and 
trepidation she complied As Jane rubbed Epstein's chest Epstein began to use a vibrator on Jane 
Doe's vagina. Thereafter Epstein began to digitally stimulate and attempt to penetrate Jane 
Doe's vagina. Ai tits same time, with his other hand, Epstein was masturbating. Upon reaching 
orgasm Epstein gm up from the message table and told Jane Doe to write down her name and 
phone number and :han left the room 
35. Jane Doe was then able to get dressed, leave the room and go back down the stairs and 
into the kitchen. Epstein, Robson and Kellen were waiting for Jane Doe. Epstein paid Jane Doc 
Page 8 of 9 
16901316 
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EFTA00234392
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Date 5/29/2008 12 09 : 
$300. Ms. Robson was paid $200 by Epstein for bringing Jane to him. Ms. Robson brought Jane 
Doe home. 
WHEREFORE, Plaintiff Jane Doe, by arid through her Mother, as parent and natural 
guardian, demands judgment against Defendants Jeffrey Epstein, Haley Robson, and Sarah 
Kellen for compensatory damages, treble damages under Florida Statute section 772.104, costs 
arid attorney's fees under Florida Statute section 772.104, and such other and further relief as this 
Court deems just 'and proper. Further, Plaintiff reserves the right to amend this Complaint to add 
a claim for punitive damages pursuant to Florida Law. 
JURY TRIAL DEMAND 
Plaintiffs demand a jury trial in this action. 
Dated: March  6  2008 
Respectfully submitted, 
RICCI—LE 
2925 PGA 
Palm Bea 
Phone: 56 
Fax: 
5 
Page 9 of 9 
LEOPOLD 
705608 
170 ot 315 
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EFTA00234393
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EFTA00234394
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From 
awn 
Page 2451 
Date 5/29/2008 1209. 
[tQl 
Civil Cover Sheet 
Form 1.997 Civil Cover Sheet 
The civil cover sheet and the information contained herein neither replace nor supplement 
the filing and service of pleadings or other papers as required by low. This form is 
requ:red for the use of the Clerk of the Court for the purpose of reporting judicial 
workload data pursuant 1C1 Florida Statute 25.075. 
50 2008 CA U U 65 9 6 XXXX MB 
I. 
CASE STYLE 
CIRCUIT COURT 
JANE DOE, by and through JANE DOE'S MOTHER 
As parent and natural guardian, 
V. 
JEFFREY EPSTEIN, HALEY ROBSON end 
SARAH KELLEN, 
2. 
TYPE' OF CASE: 
Torts:l
Other Civil: 
Professional Malpractice 
Products Liability 
Auto Negligence 
V Other Negligence 
-Ir.. 
C.> 
2( 
Contracts 
Condominium 
Real Property/Mortgage Foreclosure 
Eminent Domain 
Other 
3 
IS JURY TRIAL DEMANDED IN COMPLAINT? 
YES 
NO 
FT; 
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EFTA00234395
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Date 5/29/200812:09:. 
M 
DATED THIS 
day of March, 2008. 
PICCI-LEOPOLD, P.A 
2925 PGA Blvd. 
Suite 200 
Palm Beac 
Phone: (5 
Fax: 
( 
0 
OR!: J 
POLD 
'lorida Bar No. 05 08 
173 of 315 
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EFTA00234396
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From u, 
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IN THE CIRCUIT COURT OF THE • 
ISTII JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY 
FLORIDA 
CASE NO: 50 2998 CA 006596 XXXX 
MB AB 
JANE DOE, by and through JANE DOE'S 
MOTHER, as parent and natural guardian, 
Plaintiff, 
VS. 
JEFFREY EPSTEIN, HALEY ROBSON and 
SARAH KELLEN, 
Defendants. 
SUMMONS 
PERSONAL SERVICE ON A NATURAL PERSON 
•1.O DEFENDANT; 
JEFFREY EPSTEIN 
457 Madison Avenue 
4th Floor 
New York, New York 
IMPORTANT 
• 
. • 
•••••-•.' 
A lawsuit has been filed against you. You have 20 calendar clays after this summons is 
served on you to file n written response to the attached complaint/petition with the Clerk of this 
Court. A phone call %ill not protect you. Your written response, including the case number given 
above and the names of the parties, must be filed if you want the Court to hear your side of the case. 
If you dc not file yotr response on time, you may lose the case, and your wages, money, and 
properly may thereafter be taken without further warning from the Court. There are other legal 
requirements. You may want to cull an attorney right away. If you do not know an attorney, you 
muy call an attorney referral service or a legal aid office (listed in the phone book). 
If you choose to file a written response yourself, at the same time you file your written 
response to the Court you must also mail or take a copy of your written response to the "Plaintiff/ 
Plaintiffs Attorney" named below. 
17501716 
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a e 
"In accordance with the Americans with Disabilities Act, persons in need of a special 
accommodation to participate in this proceeding shall, within a reasonable time prior to any 
proceeding, contact the Administrative Office of the Court, 205 North Dixie Highway, Room 
5 2500, West Palm Bench, FL 33401, telephone (561)355.2431, 1-800-955-R771 (IDD), or 1-800-
955-8770(V), via Florida Relay Service". 
THEODORE J. LEOPOLD, ESQUIRE 
RICO-LEOPOLD, P.A. 
2925 PGA Boulevard 
Suite 200 
Palm Beach Gardens, FL 33410 
(561) 684-6500 
THE STATE OF FLORIDA 
TO EACH SHERIFF OF THE STATE! You arc commanded yt  serve 
is Sum ons and a copy of 
the complaint/petition in this lawsuit on the above named defendant(s). 
DATED ON 
I MPORTANT 
By: 
Deputy Clerk 
SANDRA CU 
CIRCUIT COURT 
Usied ha side demanded° legalmente. Tiene 20 Dias, contados a pair del recibo du 
este notification, pan' contester la demanda adjunta, pr escrito, y presentarla ante esie tribunal. 
Una Ilamada telefonica no lo protegera. Si usted desea que el tribunal considere su defense, debt 
presentar su respuesui por escrito, incluyendo el numbero del caso y los nombres de las panes 
interesadas. Si usted no contesta la demanda a tiempo, pudiese perder cl ens° y podria ser 
despojado de sus ingresos y propiedades, o privado de sus derechos, sin previo oviso del u•ibunal. 
Existen otros requisitos legates. Si to desea, puede usted consulter a un abused° inmediatamente. 
Si DO conoce a un abogado, pucdc Ilamar a uno de las oficinas de asistencin legal que apace= en la 
gull telefonica. 
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Si ,desen responder a la demand!' por su cutout, al mismo ticmpo en que presents su 
respuesta ante el tribunal, debera usted envier por correo o entregar una copia dc su respuesta a la 
persona denominada airejo tomo "Plaintiff/Plaintiffs Attorney" (Demandants o Abogado del 
Demandanie). 
"De acuerdo con el Acto b Decreto de los Americansos con Impedimentos, 
Inhabilitados, personas en necesidad del servicio special pare participar en estc procedimiento 
deberfui, dentio dc un 'lemon razonable, antes de cualquier procedinnento, ponerse en comacto con 
Is officina Administratativa du la Cone, 205 North Dixie Highway, oficina 5.2500, West Palm 
Beach, FL 33401, Téléfrino (561) 355-2431, 1.800-955-8771 (TOD) 4 1-800-955-8770 (V), Via 
Flonda Relay Service". 
IMPORTANT 
Des noursuites judiciures ona ets entreprises contre vous. 
Vous eve?, 20 jotes 
consecutifs o partir de la date de ('assignation de cane citation pour deposer tine reponse sents a In 
plaint< citioinie eupres de ce tribunal. Un simple coup de telephone est insuflisunt pour vous 
protegcr. Vous ems oblige de deposer votre reponse ecrite, avec mention du numero de dossier ci-
dessus et du nom 'des panics nominees ici, si vous souhaitcz clue le tribunal entendc votis cause. Si 
vous ne dcposez pas votre reponse ecrite Bans Ic rclai requis, vous risquez de perdre la cause ainsi 
que volts salaire, votre argent, et vos biens peuvent etre saisis par In suite, sans aucun preavis 
ulicricur du tribunal. II y a d'autres obligations juridiques et vous pouvez requerir les services 
immediats d'un avoc.at. Si vous ne connaissez pas d'avocat, vous pourriez telephoner a un service de 
reference d'avocats ou a on bureau d'assistance juridique (figurant a I'annuaire de telephones). 
Si vous choisissez de deposer vous-mane tine reponse ecrite, it vous faudru 
cgalement, en meme temps clue cette fonnalite, faire parvenir ou expedier one copio de votre 
reponse ecrite au "Plainciff/Plainti ffs Attorney" (Plaignant ou a son avocet) nonune ci-dessous. 
En accordance avec la Loi des "Americans With Disabilities". Les personnes en 
besoin crone accommodation speciale pour paniciper a ces procedures dowerit, dens tin temps 
raisonable, avant à'enrreprendre &Kura :Wire démarche, contacter l'office administrative tic la Court 
Otte su 5.2500, 205 North Dixie Highway, West Palm Beach, FL 33401 le telephone (561)355-
2431 ou I -800-955-877 I (Tco) ou 1-800-955-8770 (V) Via Florida Relay Service. 
IMPORTANT 
D4pré aka ki let avek Americans With Disabilities Act, tout moan ki ginyin you 
bézwen éspésiyal pou akomodasiyon pou yo patisipé nan pwogram sera dwt, nan ylin rézonab avan 
ninpot aranjman kapab fet, yo dwe kontakte Administrative Office of the Court, Id nan niméro 205 
Nonh Dixie Highway, Chain niméro 5.2500 West Palm Beach, Florida 33401 telefon nan se 
(561)355-2431 oubyen 1.800-955-8771 (T.D.D. oubycn 1-800-955-8770 (V) an pasan pa Florida 
Relay Service. 
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Case 9:08-cv-80804-Kttlm ,DozymecItag1e-3,/.51 Ergreekeffj4aDooket 07/21/2008 
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IN TFIE CIRCUIT COURT OF THE 
15TH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY 
FLORIDA 
CASE NO: 50 2008 CA 006596 XXXX 
MB AB 
JANE DOE, by and through JANE DOE'S 
MOTHER, as parent and natural guardian, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, HALEY ROBSON and 
SARAH KELLEN, 
Defendants. 
SUMMON; 
PERSONAL SERVICE ON A NATURAL PERSON 
TO DEFENDANT: 
HALEY ROBSON 
12247 72N0 COURT NORTH 
ROYAL PALM BEACH, FL 
IMPORTANT 
A lawsuit has been filed against you. You have 20 calendar days after this summons is 
served on you to file a written response to the attached complaint/petition with the Clerk of this 
Court, A phone call will not protect you. Your written response, including the case number given 
above and the names of the parties, must be filed if you want the Court to hear your side of the case. 
II you do not file your response on time, you may lose the ease, and your wages, money, and 
property may thereafter be taken without further warning from the Cowl. There are other legal 
requirements. You may want to call an attorney right away. If you do not know an attorney, you 
may call an anompy referral service or a legal aid office (listed in the phone book). 
If you choose to file a written response yourself, at the same time you file your written 
response to the Chun you must also mail or take a copy of your wrinen response to the "Plaintiff/ 
Plaintiffs Attorney" named below. 
170 of 316 
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Case 9:08-cv-80804-KM1r, ,D096Ifneritaii2soist EntOigkilltaai2D0CITtet 07/21/2008 
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"In accordance with the Americans with Disabilities Act, persons in need of a special 
accommodation to participate in this proceeding shall, within a reasonable time prior to any 
proceeding, contact the Administrative Office of the Court, 205 North Dixie Highway, Room 
5.2500, West PAM Bach, FL 33401, telephone (561)355.2431, 1-800.9554771 (TDD), or 1-800-
955-8770 (V), via Florida Relay Service". 
THEODORE J. LEOPOLD, ESQUIRE 
RJCCI-LEOPOLD, P.A. 
2925 PGA Boulevard 
Suite 200 
Palm Beach Gardens, FL 33410 
(561)684-6500 
THE STATE OF FLORIDA 
TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons and a copy of 
the complaint/petition in this lawsuit onik above named defendant(s). 
MR 1 8 au 
DATED ON 
, 2008. 
° 
is 
I M PORTANTE 
LIg.led ha sido demandado legalmente. Tiene 20 Dias, contados a pertir del recibo de 
esta notificacion, ,pam contester le demanda adjunta, por escrito, y presentarla ante este tribunal. 
Una Hamada telefonica no lo protegera. Si usted desea que el tribunal considere su defense, debe 
presenter su respuesm par escrito, incluyendo et numbero del caso y los nombres de las panes 
interesadas. Si usted no contesta la demanda a tiempo, pudiese perder el caso y podria set 
clespojado de sus ingresos y propiedades, o privado de sus derechos, sin previo aviso del tribunal. 
Existen cams requisitos legates. Si lo desea, puede usted consultor a un abogado inmediatarnente. 
Si no conoce a un abogado, puede 'lamer a uno de las oficinas de asistencia legal que aparecen en la 
pia telefonica 
Si desea responder a la demanda por su cuenta, al mismo tiempo en que presenta su 
respuesta ante el tribunal, debera usted envier por correo o entregar uno copia de su respuesta a la 
Page 2 or 3 
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18601316 
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