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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 
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"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 toa 
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, 
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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. 
Asa 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. 
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Y.. net • 1/4. gkar 
24. 
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. 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 
smermelstein®hermanlaw.com 
Florida Bar No. 947245 
Adam D. Horowitz 
Florida Bar No. 376980 
ahorowitz 
ennanlaw.com 
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