Dataset: 9 · Pages: 19 · Words: 6,697
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 1 of 19
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
JANE DOE No. 101,
09-80591
Civil Action No.
Plaintiff,
PILED by en DC
VS.
CIV-MARRP INTAKE
MAGISTRATE JUDGE APR 1 7 2009
JEFFREY EPSTEIN, JOHNSON STEVEN M LARIMORE
CLERK U.S DIST. CT.
S.0 OF FLA. MIAMI
COMPLAINT AND
Defendant. DEMAND FOR JURY TRIAL
COMPLAINT AND DEMAND FOR JURY TRIAL
Plaintiff, Jane Doe No. 101 ("Jane Doe"), brings this Complaint against Defendant,
Jeffrey Epstein, and states as follows:
PARTIES. JURISDICTION, AND VENUE
1. At all times material to this cause of action, Plaintiff, Jane Doe, was a resident of
Palm Beach County, Florida.
2. This Complaint is brought under a fictitious name to protect the identity of
Plaintiff, Jane Doe, because this Complaint makes sensitive allegations of sexual assault and
abuse of a then minor.
3. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a
residence located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida.
4. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is
currently incarcerated in the Palm Beach County Stockade.
5. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an
adult male born in 1953.
Podluust Orseck, P.A.
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort Lauderdale 954.46.3.4346 www.podhunttorn
EFTA00212996
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 2 of 19
6. This Court has jurisdiction of this action and the claims set forth herein pursuant
to 18 U.S.C. § 2255.
7. This Court has venue of this action pursuant to 28 U.S.C. § 1391(a), as a
substantial part of the events giving rise to the claim occurred in this District.
STATEMENT OF FACTS
8. At all relevant times, Defendant, Jeffrey Epstein, was an adult male,
approximately 50 years old. Epstein is known as a billionaire financier and money manager with
a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth, power,
and influence. He owns a fleet of aircraft that includes a Gulfstream IV, a helicopter, and a
Boeing 727. Until his incarceration, he maintained his principal place of residence in the largest
home in Manhattan. a 51,000-square-foot eight-story mansion on the Upper East Side. Upon
information and belief, he also owns a $6.8 million mansion in Palm Beach, Florida, a $30
million 7,500-acre ranch in New Mexico he named "Zorro," and a 70-acre private island known
as Little St. James in St. Thomas, U.S. Virgin Islands. The allegations herein concern
Defendant's conduct while at his lavish estate in Palm Beach.
9. Upon information and belief, Defendant has a sexual preference for underage
minor girls. He engaged in a plan, scheme, or enterprise in which he gained access in his home
to countless relatively economically disadvantaged minor girls, sexually assaulted or molested
these girls, and then gave them money.
10. Beginning in or around 2001 through in or around September 2007, Defendant
used his resources and his influence over vulnerable minor children to engage in a systematic
pattern of sexually exploitative behavior.
11. Defendant's plan and scheme reflected a particular pattern and method.
Defendant coerced and enticed impressionable, vulnerable, and relatively economically less
Podhurst Orseck, P.A. 2
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami [Phone Redacted] Fax [Phone Redacted] • Fort lauderdak [Phone Redacted] www.podhonst.com
EFTA00212997
Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009 Page 3 of 19
fortunate minors to participate in various acts of sexual misconduct that he committed upon
them. Defendant's scheme involved the use of underage girls as well as other individuals to
recruit other underage girls. Upon information and belief, Defendant or an authorized agent
would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach
residence. His assistants would seek out economically disadvantaged and underage girls from
West Palm Beach and surrounding areas who would be enticed by the money being offered—
generally $200 to $300 per "massage" session—and who Defendant and/or his assistants
perceived as less likely to complain to authorities or have credibility issues if allegations of
improper conduct were made. The then minor Plaintiff
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