Court Records
ar 4 tr.* I
Case 9:08-cv-80381-KAM Document 1 Entered on FLSD Docket 04/15/2008 irteuebli of FT D.c. ELECTRONIC
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
April 14, 2008
STEVEN M. LARIMORE
CLERK U.S. DIST. CT.
S. 0. OF FLA. • MIAMI
CASE NO.: 08-CV-80381-Marra-
JANE DOE NO. 5,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
COMPLAINT
Plaintiff, Jane Doe No. 5 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey
Epstein, as follows:
Parties, Jurisdiction and Venue
1. Jane Doe No. 5 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. §1391(a) as a substantial
HERMAN & MERMELSTEIN. P. A. www.hermanlaw.com
1.05
- 1 -
EFTA02741488
Case 9:08-cv-80381-KAM Document 1 Entered on FLSD Docket 04/15/2008 Page 2 of 6
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. 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 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 15-16 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.
10. Epstein's scheme involved the use of young girls to recruit underage girls. These
underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation
in his Palm Beach mansion. The 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, Epstein
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 & MERMELSTEIN, P. A. ww.v.hermanlaw.com
2016
- 2 -
EFTA02741489
Case 9:08-cv-80381-KAM Document 1 Entered on FLSD Docket 04/15/2008 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 room that contained a massage table in addition to other furnishings, and a bathroom.
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
15-16 years old, she was recruited to give Epstein a massage for monetary compensation. Jane and
another girl were brought to Epstein's mansion in Palm Beach, to the kitchen entrance. Once there,
they were introduced to who led them up the flight of stairs to the room with the
massage table. Jane and the other girl were directed by Epstein to remove their clothes and give him
a massage. Jane and the other girl removed their clothes except for their panties and bras, and
complied with Epstein's instructions. While on the massage table, Epstein masturbated himself
and touched both girls on their vaginas with his hand and with a vibrator.
13. After Epstein had completed the sexual assault, both girls were then able to get
dressed, leave the room and go back down the stairs. Epstein gave both girls money for this
"massage."
14. As a result of this encounter with Epstein, Jane experienced confusion, shame,
humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com
3016
- 3 -
EFTA02741490
Case 9:08-cv-80381-KAM Document 1 Entered on FLSD Docket 04/15/2008 Page 4 of 6
COUNT I
Sexual Assault
15. Plaintiff Jane Doe repeats and realleges paragraphs I through 13 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. 5 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 H
Intentional Infliction of Emotional Distress
20. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 13 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 5. MERMELSTEIN, P. A. www.hermanlaw.com
4016
- 4 -
EFTA02741491
• Case 9:08-cv-80381-KAM Document 1 Entered on FLSD Docket 04/15/2008 Page 5 of 6
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. 5 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 ILI , 2008.
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 7
By:
effrey M. Herman
iherman hermanlaw.com
Florida Bar No. 521647
Stuart S. Mermelstein
smermelsteinhermanlaw.com
Florida Bar No. 947245
Adam D. Horowitz
Florida Bar No. 376980
ahorowitzQhermanlaw.com
www.hermanlaw.com
Sole
- 5 -
EFTA02741492
Case 9:08-cv-80381-KAM DocueMl1L1CAki4€McSNEI$-SD Docket 04/15/2008
The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing, and service
except as provided by local niles of court. This form, approved by the Judicial Conference of the United Slates in Septe
the Court for the purpose of initiating the civil docket sheet (SEE INSTRUCTIONS ON THE REVERSE OF THE FOR .)
Page 6 of 6
uired for the use of t9.
w,
0
1(a) PLAINTIFFS
JANE DOE NO. 5,
(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF
COMMONWEALTH OF VIRGINIA
(EXCEPT IN U.S. PLAINTIFF CASES)
DEFENDANTS
JEFFREY EPSTEIN APR 1 4 Y008
COUNTY OF RESIDENCE OF FIRS LISTED CalfratapittlisairdiefORK
(IN U.S. PLAI IFF CASUERVIST.S. DIST. CT. S.D. OF RA. FT. 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
Plaintiff
O 2 U.S. Government
Defendant
III)
0 3. Federal Oueseon
(U.S. Government Not a Party)
X 4. Diversity
(Indicate Olizenshp of Parties In Item
peg ev tern laton_Ls)thnlyt, III. CITIZENSHIP OF PRINCIPAL PARTIES
PLACE AN X IN ONE BOX FOR PLAINTIFF
(For Diversity Case Only) AND ONE FOR DEFENDANT PTF DEF
PTF DEF Incorporated of Principal Place of LI 4 ❑ 4
titian of This Stale X 1 0 1
Business in This State
Citizen of Another State 0 2 x 2
Citizen or Subject of a Foreign Country 0 3 0 3
Incorporated and Principal Place of 0 5 0 5
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. §1332(a) FOR SEXUAL ASSAULT
IVa. 5 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
0 n0492•93.
o 1201Any
0 *Mee 444
0 1404/400sto rammed
CI 1513°.""ini°.".....nI 46:4404.1 01
NIOnt4
01st Maas Pa
o1621444.6.4 Or 069•4410
Mai Leans (EN
Non* 6
01O IA Reacaly 0.erpir~
td Vanes Dora I
a 14105466tatits Sue
O 1930•6903nno
0 IDSGonna Mahe lat4tr
PERSONAL INJURY
0 310 Arpin 0362 Perwail rparyakid Mattatia
0 315 Aniline Proaa LNSy 0666 Remora' 6644.01.641ta Lately 0 330 MARA WM 454~ 0 XS As0•046 Pommel
0 330 i • t 1a I• DISOrs . WS , irva Product LiabIty
NO 0 Moro0 War*ProSilUaNly PERSONAL PROPERTY
vamp
0355 'tea Padua Labley 0 370 Mx Fr
x510 Pomona rest 0 371 TNIII roaregol I
0 360 Ore Potemer
Pre01.1 On* .
°' Acose/Or629•
Prow toga
0 613 440,0Are
0 60 CA* Fa. • 010
0625 One Raakc154inte
of PARRA, V 1.4C 64I
La 0 630 Loaf n
0 640 RA a True
0650 Mine ARA
0 see ooxixicoix salovil6NP
°600 Olrer
0422 A00.41 TS USC 151
0423 wilarawl 26 USC 1S7
4/0 Sias 646xCearan
410 MAW430 list sr) ISOM
460 CoassromAX Rasa 9
440 0.63.91136
00 asamorteuerced and
Gavot. 0.644
SIC Solna WC*
ISO Sea.144,/ Corna00644,
FastrO4
VS Carle CNAree
A PROPERTY RIGHTS
Dam Colylea
0 630 Pawn
ONO Trader%
121JSC4410
4411 Nintalut Acia
ma Eterarit Siablaabn Fa
NO alNaha
664 4aIRRA444a0nAci NS FANNIN as NflabnAo
900 wow of Fa DoyemANon
Woe WS Acana 16
Pleo1
0 COO OveNcoNsv nolo
Sugar
0 NO Ono NANO ACIOne
'sae
DoNcoory MO ard Ow op.cin
kw ornomaloi
B SOCIAL SECURITY
0 *I NA 113091
0 662 Mock Lur9 0231
GM ONCOMW1606011
0 664 SSA Tot )0a
O MS 952 i4056101
A REAL PROPERTY A CIVIL RIGHTS B PRISONER PETITIONS A LABOR
210 We Grelownalca
220 Fracbes• 6
AO Rol low a Crecna
240 UP lo W.
245 Psi Pecdual UNIty
263 MC.st 464.0 6406401
044I004
0 4420 ntiornent
0 443 maioni*: 4061^0 3440.60 444 Miran
0 44006.06 ;63146
0 510.63tors to %Poole &News
146)4010:44•41
0 [Phone Redacted]*
0 S360041.Ptati
0 NO Mandows ION ,
0 55006 WO
'A ce 6
x 710 ris LAM, 59006404
AO
0 720 Las 14146406,04, 4
R Shire e
0 730 Lae LlifuNnom
Kamm a Ostiosa
Aci
0 740 Rainy tar Aa
0 793 Ors Labor LbIalca
0 201 Groom RS 171c Seam Ads
A FEDERAL TAX SUITS
O470 Taos CU or 'Wolof Dthinlinu
057' 'SuedPato 26 USC 1000
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
0 7. Appeal to District Judge from
0 5. Transferred from another district
Magistrate Judgment
VII. REQUESTED
IN COMPLAINT
CHECK IF THIS IS A o CLASS ACTION
0 UNDER F.R.C.P. 23
DEMAND $ CI Check YES only If demanded in X YES
complaint
JURY DEMAND: 0 NO
VIII. RELATED (See Instructions):
CASE(S) IF ANY
Jane Doe 2 v. Jeffrey Epstein
Jane Doe 3 v Jeffrey Epstein
1408DATE
UNITED STATES DISTRICT COURT
S/F 1.2
REV. 9/94
(SEE ATTACHED)
JUDGE KENNETH A. MARRA
JUDGE KENNETH A. MARRA
DOCKET NUMBE CV- FLA
DOCK -80232-MARRA=
SIGNATURE OF ATTORNEY OF RECORD
FOR OFFICE USE ONLY: Receipt No
r51 O11
Arnount
Date Pa MAfp:
Sole
5 2/2771)
EFTA02741493