Court Records
Case 9:08-cv-80380-KAM Document 1 Entered on FLSD Docket 04/14/2008 AMR* of FT D.c. ELECTRONIC
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
April 14, 2008
STEVEN M. LARIMORE
CLERK U.S. 01ST. CT.
S. O. OF FLA. • MIAMI
CASE NO.: 08-CV-80380-Hurley -
JANE DOE NO. 4,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
COMPLAINT
Plaintiff, Jane Doe No. 4 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey
Epstein, as follows:
Parties, Jurisdiction and Venue
1. Jane Doe No. 4 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. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial
part of the events or omissions giving rise to the claim occurred in this District.
HERMAN 6. MERMELSTEIN, P. A. www.hermanlaw.com
loge
- I -
EFTA02740335
Case 9:08-cv-80380-KAM Document 1 Entered on FLSD Docket 04/14/2008 Page 2 of 6
Factual Alleeations
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, 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 2002-2003, Jane Doe, then approximately 15 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. S.
10. 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.
The young girls would be contacted when Epstein was planning to be at his Palm Beach residence or
soon after he had arrived there.._, 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 "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.
HERMAN S. MERMELSTEIN. P. A. www.hermanlaw.com
2015
- 2 -
EFTA02740336
Case 9:08-cv-80380-KAM Document 1 Entered on FLSD Docket 04/14/2008 Page 3 of 6
11. Epstein's plan and scheme reflected a particular pattern and method. The underage
victim would be brought to the kitchen entrance of Epstein's mansion, where she would be
introduced to , Epstein's assistant. 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■ 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, when Jane Doe was approximately 15
years old, she was recruited by to give Epstein a massage for monetary compensation.
Jane was brought to Epstein's mansion in Palm Beach, to the kitchen entrance. 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 remove her clothes and give him a massage.
Jane initially kept her panties and bra on, and complied with Epstein's instructions. Jane was paid by
Epstein for this massage.
13. Jane returned on many occasions to the Palm Beach mansion to provide Epstein with
massages. On those occasions, Epstein engaged in sexual contact and activity with the minor Jane,
which included, among other things, directing Jane to remove all her clothes, masturbating during
the massage, and digitally penetrating Jane's vagina. Jeffrey Epstein often used a vibrator on the
minor Jane during the massage. This sexual abuse continued for approximately three years.
14. As a result of these encounters with Epstein, Jane experienced confusion, shame,
HERMAN & MeRmasTEIN, P. A. www.hermanlaw.com
3015
- 3 -
EFTA02740337
Case 9:08-cv-80380-KAM Document 1 Entered on FLSD Docket 04/14/2008 Page 4 of 6
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. 4 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
HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com
4016
- 4 -
EFTA02740338
Case 9:08-cv-80380-KAM Document 1 Entered on FLSD Docket 04/14/2008 Page 5 of 6
damage to Jane Doe.
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. 4 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: April 55 -112008
HERMAN S. MERMELSTEIN, P. A.
Respectfully submitted,
HERMAN & MERMELSTEIN, P.A.
Attorneys for Plaintiffs
18205 Biscayne Blvd.
Suite 2218
Miami, Florida 33160
Tel: [Phone Redacted]
Fax: 305-93
By:
Jeffrey M. Herman
[Email Redacted]
Florida Bar No. 521647
Stuart S. Mermelstein
[Email Redacted]
Florida Bar No. 947245
Adam D. Horowitz
Florida Bar No. 376980
ahorowitzahermanlaw.com
www.hermanlaw.com
Sole
- 5 -
EFTA02740339
Case 9:08-cv-80380-KAM Docu6:6,1111COkERcScbiEFEtD Docke 04114170nR ParlP (S of
The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing, and serollirtleclayt other papers as rsind law.
except as provided by local rules of court This form, approved by the Judicial Conference of the United States in SeptertigeTf regohe0}orih vseTRIib'C irk of
the Court for the purpose of Initiating the dvil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
1(a) PLAINTIFFS
JANE DOE NO. 4,
(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF
MARION COUNTY
(EXCEPT IN U.S. PLAINTIFF CASES)
DEFENDANTS
JEFFREY EPSTEIN
APR 14 2008
COUNTY OF RESIDENCE OF FRST LIST YORK
(IN U.S. PLAINTIFF .
LAUD.
(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER)
Herman & Mermelsteln, PA, 18205 Biscayne Blvd., Suite 2218, Miami,
FL 33160, ([Phone Redacted]
ATTORNEYS (IF KNOWN)
(d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH
II. BASIS OF JURISDICTION
(PLACE AN X ONE BOX ONLY)
O 1. U.S. Government 0 3 Federal Question
Plaintiff
O 2 U.S. Government
Defendant
III)
(U.S. Government Not a Party)
X 4 Diversity
(indicate CnizensNe of Parties in Kern
cpegov 303 so-hi/a y_ ,),-,bhs
III. CITIZENSHIP OF PRINCIPAL PARTIES
(For Diversity Case Only) PTF
Citizen of This State X 1
Citizen of Another State 0 2
Citizen or Subject of a Foreign Country 0 3 0 3
OEF
0 1
2
PLACE AN X IN ONE BOX FOR PLAINTIFF
AND ONE FOR DEFENDANT PTF DEF
incorporated of Principal Place of 0 4 0 4
Business in This State
Incorporated and Principal Place of 05 05
Business in Another State
Foreign Nation 0 6 0 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.)
DIVERSITY ACTION UNDER 28 U.S.C. S1332(a) FOR SEXUAL ASSAULT
IVa. 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 Mawr° O 00 Ono 0 I3OLYWM
0 NO Snot% hammer*
0 150Rianey of 04.46.494
3 Enlortemen ol
Si
0 MIAS** Ad
0 132Rostory of Waned
Sulet tam cE03
wen) a
0 IS3RaconflolOorpreNn
of ~ail BANN B
O [Phone Redacted].'s 5,As
o 190Coa Canna
0 196081fra, P,8301 any
PERSONAL INJURY
0310 M
430
ans 0362 p.naa Naiad ANWIC1414
0 315 AISW Axacitay 0306 Nan 80.414800.4 Welty
0 320 Assail. Ltd I SINS 0 366 Mann Poneroal
0 330 Folmar EftWopen 348044 vaaPpand U.0
ow Ian
Mow Pew LAWN PERSONAL PROPERTY 0 350 Watio
0356 Was Ncan Lets, cr St 0 On, 74403
x300• KNOW Irlonf 0 371 TM a lio0n2 El
0 380 Ohm Prawn%
Pnwsay 0480P
0 306 Pecosny Conan
0,00.4A tab*
;$
18
flu
I
0 422 Appel NUSC Ill
0 423 Verna MAC ¶57
Sins RoNporriarn 403
410 Marta
Ding on Nrona
CO CONansICC ileac (4
On OOK•Labri
470 Radar vanrced vd
0flor0gonalen4
ON 5092.4 Sone
MO SecnoniOna
fanallo
873 Oaten Canenn
I2US0410
le *Want
a
KO Ettwoot Sitanlon oa Emeornown Maws
A PROPERTY RIGHTS
0 830 0:010 80
0830 Paint
ONO Tranvia%
B SOCIAL SECURITY Its
N4 &cm Allocaton Ad
le F 'Woo. Mal Masan MI
OM AC044101 No Oanworni
DKr tan Aeons 0
Mao
0960 Ccooluicially of NS 510444
CI KO Oner $74440n Acme
' A te 8
Codaniory We ard NM IN Oro
t, Ninon
0 NI MA (1306$)
AREAL PROPERTY A CIVIL RIGHTS B PRISONER PETITIONS A LABOR
ONO INO Lang (0231
0 803 018400A5W(405(0)
0 864 No la XVI
0066 89(4064111
o 210 LAN Catomralo,
0 no FORS*" a
O 230 Red Web £ 1440,484
0 240 Tani Iola
o 246 Ton Padua LOIS
0 260 MOPe , as NW's ,
0 441Vmag
0 642 emplamot
0 40140S gaoterneOlatant
o 44.worn 0 4400er Cos Rom
0 SIO Woes *vas SONcte
maga Corps
0 $30C4841018
0 536080 , Peaty
0 540 Onana a COW
0 NOW Naas
'Ana
X J10 Fat Labot Swa%
so
0 720 Ltd AINNOrtsrt
Restos a
0730 Lapp inanagenoni
Ronne & °Noon
b
0 740 RYAN Labor MI
0 KO Ote Laby Lana&
0 791 6000,04 Rio IOC
lowly Ada
A FEDERAL TAX SUITS
0870 Tans NS OWN or 0048dar0
0 671 IRSMN Pity 2411-GC 7K•
VI. ORIGIN
x 1. Original 0 2. Removed from 0 3. Remanded from
Proceeding State Court Appellate Court
(Specify)
0 4. Refilled 0 6. Multidistrict Litigation
❑ 7. Appeal to District Judge from
0 5. Transferred from another district
Magistrate Judgment
VII. REQUESTED
IN COMPLAINT 0 UNDER F.R.C.P. 23
CHECK IF THIS IS A 0 CLASS ACTION DEMAND S 0 Check YES only if demanded in X YES
complaint:
JURY DEMAND: 0 NO
VIII. RELATED (See Instruc5ons):
CASE(S) IF ANY
Jane Doe 2 v. Jeffrey Epstein
Jane Doe 3 v. Jeffrey €pstein
DATE
UNITED STATES DISTRICT COURT
S/F 1-2
REV. 9/94
(SEE ATTACHED)
)
DOCKET NU 08-CV 2-MARRA
SIGNATURE OF ATTORNEY OF RECORD
INII_ JUDGE KENNETH A. MARRA DOCKET NUMBER 08-CV-80119-MARRA
JUDGE KENNETH A. MARRA
FOR OFFICE USE ONLY: Receipt No. Amount: al? W
I
Date Paid: MAfp:
_57/P -71 f 60f6
EFTA02740340