EFTA00313578

Case 9:08-cv-80069-KAM Document 5 Entered on FLSD Docket 01/29/2008 Page 1 of 3 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-80069 CIV-MARRA/JOHNSON 
JANE DOE NO.1, by and through 
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. 
MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW 
Applicant, JANE DOE'S MOTHER, individually and as parent and natural guardian of 
JANE DOE NO. 1, by and through the undersigned counsel, moves this Court, pursuant to 
Federal Rule of Civil Procedure 24(b), for leave to intervene as a plaintiff in this action in order 
to assert the claims against Defendant JEFFREY EPSTEIN set forth in Applicant's proposed 
complaint (attached hereto as EXHIBIT "A'). In support of this motion, Applicant states that: 
I. Applicant has claims that share common questions of law or fact with the main action. 
2. Applicant's motion to intervene is timely. 
3. The original parties to this action will not be prejudiced by the intervention of Applicant. 
4. Pursuant to Local Rule 7.1.A.3, counsel for Applicant, in a good faith attempt to resolve 
this dispute, made a reasonable effort to confer with all parties who may be affected by 
EFTA00313578

Case 9:08-cv-80069-KAM Document 5 Entered on FLSD Docket 01/29/2008 Page 2 of 3 
her intervention in this action. Counsel for Applicant conferred with Counsel for JANE 
DOE'S FATHER, who do not agree to her intervention in this action. 
MEMORANDUM OF LAW 
Under Federal Rule of Civil Procedure 24(b)(l)(B), "[o]n timely motion, the court may 
permit anyone to intervene who . . . has a claim or defense that shares with the main action a 
common question of law or fact." "Rule 24(b) should be liberally construed. `Basically, anyone 
may be permitted to intervene if his claim and the main action have a common question of law or 
fact,' unless the court in its `sound discretion (determines that) the intervention will unduly delay 
or prejudice the adjudication of the rights of the original parties.'" Moore v. Tangipahoa Parish 
School Bd., 298 F. Supp. 288, 292-93 (D.C. La. 1969) (quoting Allen v. County School Board of 
Prince Edward County, 28 F.R.D. 358, 363 (E.D. Va. 1961)) (citation and footnote omitted). 
Applicant, JANE DOE'S MOTHER, is the parent and natural guardian of JANE DOE 
NO. 1. As demonstrated in the attached proposed complaint, Applicant has claims for the same 
causes of action as JANE DOE'S FATHER. Therefore, her claims share common questions of 
law and fact with the main action. Applicant's motion to intervene is timely because it has been 
filed within days of the filing of the initial complaint in this action. And, because this action has 
just been initiated, permitting Applicant to intervene at this stage will not unduly delay the 
proceedings or prejudice the original parties. 
Page 2 of 3 
EFTA00313579

Case 9:08-cv-80069-KAM Document 5 Entered on FLSD Docket 01/29/2008 Page 3 of 3 
WHEREFORE, Applicant, JANE DOE's MOTHER, respectfully requests the Court 
grant her motion to intervene and accept the attached proposed Intervenor's Complaint as filed. 
Dated: January 29th, 2008 
Respectfully submitted, 
RICCI—LEOPOLD, P.A. 
2925 PGA Blvd., Suite 200 
Palm Beach Gardens,  FL 33410 
Phone' 
Fax: 
By: /s/Theodore J. Leopold, Esq. 
THEODORE J. LEOPOLD 
Florida Bar No. 705608 
I HEREBY CERTIFY that a true and correct copy of the foregoing was filed electronically 
on January 29th , 2008 with the Clerk of the Court through ECF, and that ECF will send an e-notice 
of the electronic filing to the following: Jeffrey M. Herman, 
Mermelstein, 
Stuart S. 
Adam 
D. 
Horowitz, 
/s/Theodore J. Leopold, Esq. 
THEODORE J. LEOPOLD, ESQ. 
Florida Bar No. 705608 
RICO-LEOPOLD, P.A. 
2925 PGA Boulevard, Suite 200 
Palm Beach Gardens FL 33410 
Page 3 of 3 
EFTA00313580

Case 9:08-cv-80069-KAM Document 5-1 Entered on FLSD Docket 01/29/2008 Page 1 of 7 
EXHIBIT A 
EFTA00313581

Case 9:08-cv-80069-KAM Document 5-1 Entered on FLSD Docket 01/29/2008 Page 2 of 7 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-80069 CIV-MARRA/JOHNSON 
JANE DOE NO.1, by and through 
JANE DOE's FATHER as parent and natural 
guardian, and JANE DOE's FATHER, and 
JANE DOE's STEPMOTHER, individually, 
Plaintiffs, 
JANE DOE'S MOTHER, individually and as parent 
and natural guardian of JANE DOE NO. 1, 
Intervenor-Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
INTERVENOR'S COMPLAINT 
Intervenor-Plaintiff, JANE DOE's MOTHER, individually and as parent and natural 
guardian of JANE DOE NO. 1, by and through the undersigned counsel, brings this Complaint 
against Defendant JEFFREY EPSTEIN, and as grounds states as follows: 
Parties, Jurisdiction and Venue 
I. Jane Doe No. 1 is a citizen and resident of the State of Florida. She is a minor under the 
age of 18 years. 
2. Jane Doe's Mother brings this action individually and as parent and natural guardian of 
Jane Doe No. 1. Jane Doe's Mother is a citizen and resident of the State of Georgia. 
EFTA00313582

Case 9:08-cv-80069-KAM Document 5-1 Entered on FLSD Docket 01/29/2008 Page 3 of 7 
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. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 
5. This is an action for damages in excess of Fifty Million ($50,000,000.00) Dollars. 
Factual Allegations 
6. 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. 
7. 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. 
8. 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. 
9. An integral player in Epstein's Florida scheme was Haley Robson, a Palm Beach Community 
College student from Loxahatchee, Florida. She recruited girls ostensibly to give a wealthy 
man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's plan, 
Ms. Robson 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 directed Ms. 
Page 2 of 6 
EFTA00313583

Case 9:08-cv-80069-KAM Document 5-1 Entered on FLSD Docket 01/29/2008 Page 4 of 7 
Robson to bring one or more underage girls to the residence. 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 element of Epstein's plan. 
10. Epstein's plan and scheme 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 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. 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 and touching 
the girl's vagina with a vibrator. 
11. Consistent with the foregoing plan and scheme, Ms. Robson recruited Jane Doe to give 
Epstein a massage for monetary compensation. Ms. Robson brought Jane 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. She was alone in the room when Epstein arrived 
wearing only a towel. He 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. 
Page 3 of 6 
EFTA00313584

Case 9:08-cv-80069-KAM Document 5-1 Entered on FLSD Docket 01/29/2008 Page 5 of 7 
12. 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. 
13. 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 
Intentional Infliction of Emotional Distress 
14. Intervenor-Plaintiff JANE DOE's MOTHER repeats and realleges paragraphs 1 through 
13 above. 
15. Epstein's conduct was intentional or reckless. 
16. Epstein's conduct was outrageous, going beyond all bounds of decency. 
17. Epstein's conduct caused severe emotional distress not only to Jane Doe, but also to her 
parents, including Jane Doe's Mother. Epstein knew or had reason to know that his 
intentional and outrageous conduct would cause emotional trauma and damage to Jane 
Doe's parents. 
18. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe's 
Mother has suffered and will continue to suffer severe mental anguish and pain. 
WHEREFORE, Intervenor-Plaintiff Jane Doe's Mother 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. 
Page 4 of 6 
EFTA00313585

Case 9:08-cv-80069-KAM Document 5-1 Entered on FLSD Docket 01/29/2008 Page 6 of 7 
COUNT II 
Loss of Parental Consortium 
19. Plaintiff Jane Doe's Mother repeats and realleges paragraphs 1 through 13 above. 
20. Epstein's tortious conduct is the direct and proximate cause of damages to Jane Doe's 
Mother, consisting of parental loss of comfort, companionship and society and healthcare 
costs associated with the treatment of Jane. 
21. Jane Doe's Mother 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 Mother demands judgment for loss of consortium, 
damages, costs and such other and further relief as this Court deems proper. 
JURY TRIAL DEMAND 
Intervenor-Plaintiff demands a jury trial in this action. 
Dated: January 
, 2008 
Respectfully submitted, 
RICCI—LEOPOLD, P.A. 
2925 PGA Blvd. : ''te 200 
Palm Beach G 
FL 
B 
Fl 
POLD, Esq. 
608 
I HEREBY CERTIFY that a true and correct copy of the oregoing Intervenor's 
Complaint was filed electronically on  
2008 with the Clerk of the Court 
through ECF, and that ECF will send an e-notice of the electronic filing to the following: Jeffrey M. 
Page 5 of 6 
EFTA00313586

Case 9:08-cv-80069-KAM Document 5-1 Entered on FLSD Docket 01/29/2008 Page 7 of 7 
Herman 
Adam D. Horowitz, 
Stuart S. Mermelstein, 
RICCI-
2925 P 
Palm B 
By: 
33410 
POLD, Esq. 
lorida Bar No 
5608 
Page 6 of 6 
EFTA00313587