Court Records
Case 9:08-cv-80380-KAM Document 49 Entered on FLSD Docket 09/22/2008 Page 1 of 8
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80380-MARRA
JANE DOE NO. 4,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
AMENDED COMPLAINT
Plaintiff, Jane Doe No. 4 ("Jane" or "Jane Doe"), brings this Amended 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. Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because
Plaintiff alleges a claim under the laws of the United States. This Court has supplemental
jurisdiction pursuant to 28 U.S.C. §1367(a) over all other claims set forth herein, which form part of
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the same case or controversy.
7. This Court has venue of this action pursuant to 28 U.S.C. §§1391(a) and 1391(b) as a
substantial pan of the events or omissions giving rise to the claim occurred in this District.
Factual Allegations
8. 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. and Palm Beach,
FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach.
9. 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.
10. 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.
11. 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
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conduct were made. This was an important element of Epstein's plan.
12. 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 perfonn one or more lewd, lascivious and sexual acts, including masturbation and
touching the girl's vagina.
13. 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.
14. 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.
15. As a result of these encounters with Epstein, Jane experienced confusion, shame,
humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
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COUNT I
Sexual Assault and Battery
16. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 15 above.
17. Epstein acted with intent to cause an offensive contact with Jane Doe, or an imminent
apprehension of such a contact, and Jane Doe was thereby put in such imminent apprehension.
18. Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane
Doe, creating a reasonable fear of imminent peril.
19. Epstein intentionally inflicted harmful or offensive contact on the person of Jane Doe,
with the intent to cause such contact or the apprehension that such contact is imminent.
20. Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts
were intentional, unlawful, offensive and harmful.
21. Epstein's plan and scheme in which he committed such acts upon Jane Doe were
done willfully and maliciously.
22. 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
23. Plaintiff Jane Doe repeats and realleges paragraphs I through IS above.
24. Epstein's conduct was intentional or reckless.
25. Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds
of decency.
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26. Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted
in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or
emotional health to be significantly impaired.
27. 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 distress and
damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing
severe emotional distress to Jane Doe.
28. 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.
COUNT III
Coercion and Enticement to Sexual Activity in Violation of 18 US.C. §2422
29. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 15 above.
30. Epstein used a facility or means of interstate commerce to knowingly persuade,
induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or
sexual activity for which any person can be charged with a criminal offense.
31. Epstein's acts and conduct are in violation of 18 U.S.C. §2422.
32. As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal
injury, including mental, psychological and emotional damages.
33. Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a
reasonable attorneys' fee.
WHEREFORE, Plaintiff Jane Doe No. 4 demands judgment against Defendant Jeffrey
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Epstein for all damages available under 28 U.S.C. §2255(a), including without limitation, actual
and compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as
this Court deems just and proper.
JURY TRIAL DEMAND
Plaintiff demands a jury trial in this action on all claims so triable.
Dated: September 22, 2008
Respectfully submitted,
By: s/ Jeffrey M. Herman
Jeffrey M. Herman (FL Bar No. 521647)
[Email Redacted]
Stuart S. Mermelstein (FL Bar No. 947245)
[Email Redacted]
Adam D. Horowitz (FL Bar No. 376980)
[Email Redacted]
HERMAN & MERMELSTEIN, P.A.
Attorneys for Plaintff
18205 Biscayne Blvd., Suite 2218
Miami, Florida 33160
Tel: [Phone Redacted]
Fax: [Phone Redacted]
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CERTIFICATE OF SERVICE
I hereby certify that on September 22, 2008,1 electronically filed the foregoing document
with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
served this day to all parties on the attached Service List in the manner specified, either via
transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized
manner for those parties who are not authorized to receive electronically Notices of Electronic
Filing.
/s/ Jeffrey M. Herman .
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SERVICE LIST
DOE vs. JEFFREY EPSTEIN
CASE NO.: 08-CV-80380-MARRAI
United States District Court, Southern District of Florida
Jack Alan Goldberger, Esq.
[Email Redacted]
Michael R. Tein, Esq.
[Email Redacted]
Robert D. Critton, Esq.
[Email Redacted]
Michael Pike, Esq.
[Email Redacted]
Is/ Jeffrey M. Herman
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