Court Records
Case 9:08-cv-80994-KAM Document 1 Entered on FLSD Docket 09/11/2008 Page 1 clifvr iKd
•
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
JANE DOE NO. 6,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
CASE NO.:
08-CV-80994-Hurley
/
FILED by VT D.C. ELECTRONIC
SEPT. 10, 2008
STEVEN M. LARIM0RE
CLERK U.S. GIST. CT.
S. 0. OF FLA. • MIAMI
COMPLAINT
Plaintiff, Jane Doe No. 6 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey
Epstein, as follows:
Parties, Jurisdiction and Venue
1. Jane Doe No. 6 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
HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com
I of7
- I -
EFTA02742589
08-CW809944liarierliopinns 1 Entered on FLSD Docket 09/11/2008 Page 2 of 7
jurisdiction pursuant to 28 U.S.C. §1367(a) over all other claims set forth herein which form part of
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 part 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,
approximately 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 2004, Jane Doe, then approximately 13 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. These
underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation
in his Palm Beach mansion. Epstein, upon information and belief, generally sought out economically
disadvantaged underage girls from western Palm Beach County who would be enticed by the money
HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com
2017
- 2 -
EFTA02742590
08-CV40994vflurierlioplassi Entered on FLSD Docket 09/11/2008 Page 3 of 7
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.
12. Epstein's plan and scheme reflected a particular pattern and method. The underage
victim would be brought or directed to Epstein's mansion, where she would be led up a flight of
stairs to a bedroom that contained a massage table in addition to other furnishings. 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.
13. Consistent with the foregoing plan and scheme, when Jane Doe was only 13 years old,
she was recruited by another girl to give Epstein a massage for monetary compensation. Jane was
brought to Epstein's mansion in Palm Beach. Once there, she was led up the flight of stairs to the
room with the massage table. Epstein came into the room and directed Jane to remove her clothes
and give him a massage. As directed by Epstein, Jane stripped to her underwear. Epstein then
sexually assaulted Jane during the massage. hi addition, Epstein masturbated during the massage.
Epstein then paid Jane money.
14. As a result of this encounter with Epstein, Jane experienced confusion, shame,
humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
COUNT I
Sexual Assault and Batten
15. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
16. Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane
Doe, creating a reasonable fear of imminent peril and sexual assault.
HERMAN & MERMELSTEIN. P. A. www.hermanlaw.com
3017
- 3 -
EFTA02742591
.Case 9:08-cv-80994-KAM Document 1 Entered on FLSD Docket 09/11/2008 Page 4 of 7
17. Epstein intentionally inflicted harmful or offensive sexual contact on the person of
Jane Doe.
18. Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts
were intentional, unlawful, offensive and harmful.
19. Epstein's plan and scheme in which he committed such acts upon Jane Doe were done
willfully and maliciously.
20. 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. 6 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 11
Intentional Infliction of Emotional Distress
21. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
22. Epstein's conduct was intentional or reckless.
23. Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds
of decency.
24. Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted
in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health
to be significantly impaired.
25. 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
HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com
- 4 -
EFTA02742592
.Case 9:08-cv-80994-KAM Document 1 Entered on FLSD Docket 09/11/2008 Page 5 of 7
damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing
severe emotional distress to Jane Doe.
26. 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. 6 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 HI
Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. 42422
27. Plaintiff Jane Doe repeats and realleges paragraphs I through 14 above.
28. 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.
29. Epstein's acts and conduct are in violation of 18 U.S.C. §2422.
30. As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal
injury, including mental, psychological and emotional damages.
31. Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a
reasonable attorneys' fee.
WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey
Epstein for all damages available under 18 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.
MERMAN b MERMELSTEIN, P. A. www.hermanlaw.com
- 5 -
EFTA02742593
'Case 9:08-cv-80994-KAM Document 1 Entered on FLSD Docket 09/11/2008 Page 6 of 7
JURY TRIAL DEMAND
Plaintiff demands a jury trial in this action on all claims so triable.
Dated: September 0( , 2008
Respectfully submitted,
By: Yw
J rcy M. Herman (FL Bar No. 521647)
[Email Redacted]
Stuart S. Merrnelstein (FL Bar No. 947245)
[Email Redacted]
Adam D. Horowitz (FL Bar No. 376980)
ahorowitzahermanlaw.com
HERMAN & MERMELSTEIN, P.A.
Attorneys for Plaintiff
18205 Biscayne Blvd., Suite 2218
Miami, Florida 33160
Tel: [Phone Redacted]
Fax: [Phone Redacted]
HERMAN & MERMELSTEIN. P. A. www.hermanlaw.com
- 6 -
EFTA02742594
08-C \489994-titsrlef -Hopkins-lama COMERISHEETD Docket 09/11/2008 Page 7 of 7
The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing, and service of pleading or other papers as required by law.
except as provided by local rules of court. This form• approved by the Judicial Conference of the United States in September 1974. is required for the use of the Clerk of
the Court for the purpose of initiating the civil docket sheet (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
1(a) PLAINTIFFS
JANE DOE NO. 6,
(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF
PALM BEACH COUNTY
(EXCEPT IN U.S. PLAINTIFF CASES)
DEFENDANTS
JEFFREY EPSTEIN
COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT NEW YORK
(IN U.S. PLAINTIFF CASES ONLY)
(c) ATTORNEYS (FIRM NAME. ADDRESS, AND TELEPHONE NUMBER)
Herman & Mermebteln, PA, 18205 Biscayne Blvd., Suite 2218 Miami,
FL 33160, ([Phone Redacted]
ATTORNEYS (IF KNOWN)
(d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH
11. BASIS OF JURISDICTION
(PLACE AN X ONE BOX ONLY)
O 1. U.S. Goverment X 3 Federal Question
(U.S. Government Not a Party)
0 4. Diversity
(Indicate Citizenship 01 Parties in Item
Plaintiff
O 2. U.S. Government
Defendant
Ill)
evne97V-birki- 4v045 III. CITIZENSHIP OF PRINCIPAL PARTIES
(For Diversity Case Only) PTF DEF
Citizen of This State 01 0
Citizen of Another State 0 2 0 2
Citizen or Sutriect of a Foreign Country U 3 O 3
PLACE AN X IN ONE BOX FOR PLAINTIFF
AND ONE FOR DEFENDANT PTF DEF
Incorporated of Rincipal Place of O 4 0
Business in This State
Incorporated and Prince3al Ptece 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.)
ACTION FOR SEXUAL ASSAULT UNDER 18 U.S.C. $2422 AND STATE LAW
N a. j_ days estimated (for both sides) to try entire case
V. NATURE OF SUIT (PLACE AN X IN ONE BOX ONLY)
A CONTRACT A TORTS B FORFEITURE
PENALTY
A BANKRUPTCY A OTHER STATUS
o !IV..nice
XIS, 1401440514o4 mount*
12 15" .°74(7 01 G." 7.7"" 1Vilrowerl of
J44390044 0 i5 1 Mona Ao
o 112 Res/ el 1300.0•1
SM10.4 Lan CVO
~WO 5
0 163.144wity6404/noweid
of Winos tionolls 8
0 10334:cUbboes Soo
0 Mae Conroe
0 i950m0114Voka LOKI,
PERSONAL INAPT
0 310 Asian 0302 01400014 rIttrwommoricwo
0 315 ADS, .45.4c41.4014y 0 WS prowl IrroorPread Laf
0 320.44siwit Ler a sins owe soma Peens
0 3soreansweeen witav ninemsoustary
0 3401Awar
0 346 Mame Procta USW PERSONAL PROPERTY
0 350 lbw vOcie
0365~ VOW* P,..O L10:041 0370 02047,04
X 140 0804 P00005 401 0 371 MK n WOOS
Oro Cinwheitainst
FKOW413101105
polo 44e0ww
0620 On /KO A 1:4W 0626 On4)7044ad Sawn
erPreCeer 21 USC OM
0 630 Lauce Lass
0 540 II Rit VW,
0 KO MY* Reps
0 CO3 00 *Seri SOR54.04.41
ONO OOP
0 422 Kral 2$ USC ISO
0421 Wo44040 z• use 157
400 Slastarmannintn 410 Ann 430 ens 00134•44o
430 Own.= Raton •
400 alp non
470 R5 awe' Inkrad WO
Conw104540044004
510 SKS Una
WO SocurOW Owywasiii
tett*
Na Cohn., Chahoge
121.11C3410
WI Koweatt AC%
sea aceremt stemma ha
8123 Enocemetal Kollw
A PROPERTY RIGHTS
0610 0540,060 Dal NAGAI
0 840 Traffsvrark
B SOCIAL SECURITY
0 3es Property 06,46.
IN•54,41.411‘ty WI 504.010400070" 496 75.4433.61 blamwon Ad
KO two. ca r« Ogoonnown
UnSw WO Acton
Mao.
0 060 CavaJonalty 44 Sale
SOAK
0 SW 08w SeakAoy•Kons' • Ace 13
Dalaratyy role ard WOOS' Wes
ix Swam
0 VI ML411336/71 MU Kin Low (023) 0 SO OMOOMW(40680)
0 054 SSC Too *I
0606 14.51(405801 A REAL. PROPERTY A ChM RIGHTS 8 PRISONER PETITIONS A LABOR
210 WO Orawycno,
220 Fouts.. a
230 Rao law 165575,nent
240 faro Lard
246 Ton 0043•2 Leith
AO An Ore Rey Awn
0 441 Wog
0 44204045)4'w1
0 443 ANNOY ACCOTTOOSIDAI
0 444 O Wire
044001w CM Rate
C 510Woons 45 vial* Senn
1448401C4fpo
0 $313 Grow 0 WOK. May
0 540 Woods II COW
0 MOON KKK
'Aer13
5 710 FoP Lab°, Sandal.
AO
0 720 Labc41825.10stneel
Relapse
0 730 UO0. 4645141•••re Wimp 1 01400on AO
0 740 As0rey Lace AR
0100 Caw 1.01s LOOMO,
0 101 favotwell, 10t Want An 18
A FEDERAL TAX SUITS
06th USW S Plac4104004401.43
0 571 a &NW 4140y 26 IJEC 7000
VI. ORIGIN
x 1. Original O 2. Removed from
Proceeding State Court
O 3. Remanded from
Appellate Court
(Specify)
O 4. Refilled O 6. Multidisbict Litigation
O 7. Appeal to Diable* Judge from
O 5. Transferred from another district
Magistrate Judgment
VII. REQUESTED
IN COMPLAINT
CHECK IF THIS IS A D CLASS ACTION
O UNDER F.R.C.P. 23
DEMAND $ O Check YES only if demanded in X YES
compleint
JURY DEMAND: D NO
VIII. RELATED
CASE(S) IF ANY
Jane Doe 2 v. Jeffrey Epstein
Jane Doe 3 v. Jeffrey Epstein
Jane Doe 4 v. Jeffrey Epstein
Jane Doe 5 v. Jeffrey Epstein
(See Instructions): (SEE ATTACHED)
JUDGE KENNETH A. MARRA
JUDGE KENNETH A. MARRA
JUDGE KENNETH A MARRA
JUDGE KENNETH A MARRA
DOCKET NUMBER 08-CV-80119-MARRA-
DOCKET NUMBER 08-CV-80232-MARRA
DOCKET NUMBER 08-CV-80380-MARRA
DOCKET NUMBER 08:80381 --MARRA
DATE Sep~ (o IA E
UNITED STATES DISTRICT COURT
S/F 1-2
REV. 954
SIGNATURE OF ATTORNEY OF RECORD /
Receipt No. Amount
Date Paid: ^ M.410:
FOR OFFICE USE ONLY:
EFTA02742595