Court Records
Case 9:09-cv-80802-KAM Document 24 Entered on FLSD Docket 12/14/2009 Page 1 of 8
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 09-CV-80802-MARRA/JOHNSON
JANE DOE NO. 8,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
AMENDED COMPLAINT
Plaintiff, Jane Doe No. 8 ("Jane" or "Jane Doe"), files and serves this Amended Complaint
against Jeffrey Epstein, as follows:
Parties, Jurisdiction and Venue
I. Jane Doe No. 8 ("Jane Doe") 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, and
presently serving a prison sentence in Palm Beach County, Florida for, inter alia solicitation of
prostitution and solicitation of minors to engage in prostitution..
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;
- I -
EFTA02743419
Case 9:09-cv-80802-KAM Document 24 Entered on FLSD Docket 12/14/2009 Page 2 of 8
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
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 Allocations
8. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male in his
early 50's. 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 2001, Jane Doe, then approximately 16 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.
II. 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
- 2 -
EFTA02743420
Case 9:09-cv-80802-KAM Document 24 Entered on FLSD Docket 12/14/2009 Page 3 of 8
in his Palm Beach mansion. Epstein, upon information and belief, generally sought out economically
disadvantaged underage girls from 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.
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 room 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.
13. Consistent with the foregoing plan and scheme, Jane Doe was recruited by another
girl, who told her that she could make some money, but did not tell her what was involved. At all
relevant times, the girl who recruited Jane Doe was acting on behalf of and as agent for Epstein.
Jane was contacted by this girl by telephone. Jane was then picked up and 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.
Jane was frightened and felt trapped. As directed by Epstein, Jane removed her clothes. Epstein
then during the massage touched Jane on her breasts and vagina, and he grabbed her hand and placed
it on his penis. Epstein masturbated himself during the massage. Epstein then left money for Jane.
14. As a result of this encounter with Epstein, Jane experienced confusion, shame,
humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
- 3 -
EFTA02743421
Case 9:09-cv-80802-KAM Document 24 Entered on FLSD Docket 12/14/2009 Page 4 of 8
COUNT I
Sexual Assault and Battery
15. Plaintiff Jane Doe repeats and realleges paragraphs I 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.
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 and loss of enjoyment of life.
WHEREFORE, Plaintiff Jane Doe No. 8 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
21. Plaintiff Jane Doe repeats and realleges paragraphs I 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.
-4-
EFTA02743422
Case 9:09-cv-80802-KAM Document 24 Entered on FLSD Docket 12/14/2009 Page 5 of 8
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
mason 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.
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, psychological and emotional
injuries and los of enjoyment of life. .
WHEREFORE, Plaintiff Jane Doe No. 8 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 U.S.C. §2.422
27. Plaintiff Jane Doe repeats and rcalleges 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. On June 30, 2008, Epstein entered a plea of guilty to violations of Florida §§ 796.07
and 796.03, in the 15th Judicial Circuit in and for Palm Beach County (Case nos. 2008-cf-
009381AXXXMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and
scheme as alleged herein.
- 5 -
EFTA02743423
Case 9:09-cv-80802-KAM Document 24 Entered on FLSD Docket 12/14/2009 Page 6 of 8
30. As to Plaintiff Jane Doe, Epstein could have been charged with criminal violations of
Florida Statute §796.07(2) (including subsections (c), (d), (e), (f), (g), and (h) thereof), and other
criminal offenses including violations of Florida Statutes §§798.02 and 800.04 (including
subsections (5), (6) and (7) thereof).
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
psychological and physical injuries.
33. Although Epstein's acts of inducement and enticement to sexual activity occurred in
or about 2001, when Jane Doe was minor, she was not immediately aware of her injuries.
Specifically, she did not become aware that she had suffered psychological and emotional effects
from the acts and conduct of Epstein until no earlier than calendar year 2008.
34. Jane Doe did not (and due to various coping mechanisms, was unable to) make a
causal connection between her injuries and the sexual acts and other misconduct of Epstein until
2008. Jane Doe did not know, and could not reasonably have been expected to know, that she had
been injured and that Epstein had caused her injuries until calendar year 2008.
35. Plaintiff retained Mermelstein & Horowitz, P.A. (f/k/a Herman & Mermelstein, P.A.),
as her attorneys in this matter and agreed to pay them a reasonable attorneys' fee.
WHEREFORE, Plaintiff Jane Doe No. 8 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.
-6-
EFTA02743424
Case 9:09-cv-80802-KAM Document 24 Entered on FLSD Docket 12/14/2009 Page 7 of 8
JURY TRIAL DEMAND
Plaintiff demands a jury trial in this action on all claims so triable.
Dated: December 14, 2009
Respectfully submitted.
By: /s/ Stuart S. Mermelstein
Stuart S. Mermelstein (FL Bar No. 947245)
[Email Redacted]
Adam D. Horowitz (FL Bar No. 376980)
[Email Redacted]
MERMELSTEIN & HOROWITZ, P.A.
Attorneys for Plaintiff
18205 Biscayne Blvd., Suite 2218
Miami, Florida 33160
Tel: [Phone Redacted]
Fax: [Phone Redacted]
CERTIFICATE OF SERVICE
I hereby certify that on December 14, 2009, I electronically fi led thefcregoi ng document with
the Clerk of the Court using CM/ECF. I al so certify that thef °regal ng document is bei ng served this
day to a I parties on the attached Service List in the mariner 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/ Stuart S. Mermelstein
- 7 -
EFTA02743425
Case 9:09-cv-80802-KAM Document 24 Entered on FLSD Docket 12/14/2009 Page 8 of 8
SERVICE LIST
DOE vs JEFFREY EPSTEIN
CASE NO.: 09-CV-80802-MARRA
United States District Court, Southern District of Florida
Jack Alan Goldberger. Esq.
[Email Redacted]
Robert D. Critton, Esq.
[Email Redacted]
/s/ Stuart S. Mermelstein
- 8 -
EFTA02743426