EFTA00257027

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. 
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, 
deniands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive damages, 
costs, and such other and further relief as this Court deems just and proper. 
HERMAN & MERMELSTEIN, P. A. 
- 4 - 
vtnivw.hermanlaw.com 
EFTA00257047

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 
Do; 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 HI 
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 
HERMAN & MERMEI-STEIN, P. A. 
- 5 - 
whrw.hermanlaw.com 
EFTA00257048

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 ‘211, 2008 
Respectfully submitted, 
HERMAN & MERMELSTEIN, P.A. 
Attorneys for Plaintiffs 
18205 Biscayne Blvd. 
Suite 2218 
Miami, Florida 33160 
Tel: 305-931-2200 
Fax: 305-931-0877 
By: 
Je 
M. Herman 
[email protected] 
Florida Bar No. 521647 
Stuart S. Mermelstein 
[email protected] 
Florida Bar No. 947245 
Adam D. Horowitz 
Florida Bar No. 376980 
ahorowitz@hennaniawsom
HERMAN & MERMELSTEIN, P. A. 
- 6 - 
www.hermanlaw.com 
EFTA00257049

Billionaire investor sued for alleged sexual assault of teen 
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Billionaire investor sued for alleged sexual 
assault of teen 
THE ASSOCIATED PRESS 
WEST PALM BEACH, Fla. -- Mother woman is suing a New York 
billionaire, claiming he sexually assaulted her when she was underage. 
The unidentified woman says she was 16 when she was brought to 
Jeffrey Epstein's Palm Beach mansion and paid $200 to give the 
money manager a massage. Instead, she claims he abused her. 
The suit filed Wednesday in federal court is seeking more than $50 
million in damages from Epstein. 
Another teenage girl made similar claims against Epstein in a lawsuit 
filed last month. 
Epstein also faces a felony charge of solicitation of prostitution. A 
conviction could send him to prison for five years. 
Epstein's attorney has denied the allegations, but did not return phone 
messages Wednesday. 
Last modified: February 06. 2008 12:01PM 
SI 
Adver 
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http://www.heraldtribune.com/article/20080206/APN/802060750 
2/6/2008 
EFTA00257050

Billion4ire investor sued for alleged sexual assault of teen 
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Billionaire investor sued for alleged sexual assault of teen 
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EFTA00257052

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 
JANE DOE NO. 2, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
COMPLAINT 
Plaintiff, Jane Doe No. 2 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey 
Epstein, as follows: 
Parties, Jurisdiction and Venue 
1. 
Jane Doe No. 2 is a citizen and resident of the Commonwealth of Virginia, 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. 
This Court has venue of this action pursuant to 28 U.S.C. §139I(a) as a substantial 
HERMAN 5. MERMELSTEIN, P. A. 
- I - 
www.hermanlaw.com 
EFTA00257053

part of the events or omissions giving rise to the claim occurred in this District. 
Factual Allegations 
7. 
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. 
8. 
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 2004-2005, Jane Doe, then approximately 16 years old, fell into Epstein's 
trap and became one of his victims. 
9. 
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. 
10. 
Epstein's scheme involved the use of young girls to recruit underage girls. (Upon 
information and belief, the young girl who brought Jane Doe to Epstein was herself a minor victim 
of Epstein, and will therefore not be named in this Complaint). Under Epstein's plan, underage girls 
were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm 
Beach mansion. The recruiter 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 would direct 
the recruiter to bring one or more underage girls to the residence. The recruiter, upon information 
and belief, generally sought out economically disadvantaged underage girls from western Palm 
Beach County who would be enticed by the money being offered - generally $200 to $300 per 
HERMAN & MERMELSTEIN, P. A. 
- 2 - 
www.hermanlaw.com 
EFTA00257054

"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. 
11. 
Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at 
Epstein's mansion, the underage victim would be introduced to 
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. The girl would then find herself alone in the room with Epstein, who would be wearing 
only a towel. He would then remove his towel and lie naked on the massage table, and direct the girl 
to remove her clothes. Epstein would then perform one or more lewd, lascivious and sexual acts, 
including masturbation and touching the girl's vagina. 
12. 
Consistent with the foregoing plan and scheme, Jane Doe was recruited to give 
Epstein a massage for monetary compensation. Jane was brought to Epstein's mansion in Palm 
Beach. Once at the mansion, Jane was introduced to 
who led her up the flight of 
stairs to the room with the massage table. In this room, Epstein told Jane to take off her clothes and 
give him a massage. Jane kept her panties and bra on and complied with Epstein's instructions. 
Epstein wore only a towel around his waste. After a short period of time, Epstein removed the towel 
and rolled over exposing his penis. Epstein began to masturbate and he sexually assaulted Jane. 
13. 
After Epstein had completed the assault, Jane was then able to get dressed, leave the 
room and go back down the stairs. Jane was paid $200 by Epstein. The young girl who recruited 
Jane was paid $100 by Epstein for bringing Jane to him. 
14. 
As a result of this encounter with Epstein, Jane experienced confusion, shame, 
HERMAN & MERMELSTEIN, P. A. 
- 3 - 
www.hermanlaw.com 
EFTA00257055

humiliation and embarrassment, and has suffered severe psychological and emotional injuries. 
COUNT I 
Sexual Assault 
15. 
Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 
16. 
Epstein tortiously assaulted Jane Doe sexually. Epstein's acts were intentional, 
unlawful, offensive and harmful. 
17. 
Epstein's plan and scheme in which he committed such acts upon Jane Doe were 
done willfully and maliciously. 
18. 
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. 
19. 
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. 2 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 
20. 
Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 
21. 
Epstein's conduct was intentional or reckless. 
22. 
Epstein's conduct was outrageous, going beyond all bounds of decency. 
23. 
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 trauma and 
damage to Jane Doe. 
HERMAN & MERMELSTEIN, P. A. 
www.hermanlaw.com 
- 4 - 
EFTA00257056

t
24. 
As a direct and proximate result of Epstein's intentional or reckless con ct, Jane 
Doe, has suffered and will continue to suffer severe mental anguish and pain. 
WHEREFORE, Plaintiff Jane Doe No. 2 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. 
JURY TRIAL DEMAND 
Plaintiffs demand a jury trial in this action. 
Dated: February 
2008 
Respectfully submitted, 
HERMAN & MERMELSTEIN, P.A. 
Attorneys for Plaintiffs 
18205 Biscayne Blvd. 
Suite 2218 
Miami, Florida 33160 
Tel: 305-931-2200 
Fax: 305-931-0877 
By: 
Jeffrey M. Herman 
[email protected] 
Florida Bar No. 521647 
Stuart S. Mermelstein 
[email protected] 
Florida Bar No. 947245 
Adam D. Horowitz 
Florida Bar No. 376980 
ahorowitz@hennan law.com 
HERMAN & MERMELSTEIN, P. A. 
- 5 - 
www.hermanlaw.com 
EFTA00257057

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