EFTA00257462

associated with the treatment of Jane. 
28. 
Jane Doe's Father experienced and will continue to experience great mental anguish, 
pain and suffering from the time that Defendant's tortious conduct occurred. 
WHEREFORE, Plaintiff Jane Doe's Father demands judgment for loss of consortium 
damages, costs and such other and further relief as this Court deems proper. 
JURY TRIAL DEMAND 
Plaintiffs demand a jury trial in this action. 
Dated: January 924, 2008 
Respectfully submitted, 
HERMAN & MERMELSTEIN, P.A. 
Attorneys for Plaintiffs 
18205 Biscayne Blvd. 
Suite 2218 
Miami, Florida 33160 
Tel: 305-931-2200 
Fax: 
- 
- 
By: 
Florida Bar No. 
NIS 
HERMAN & MERMELSTEIN, P. A. 
- 6 - 
www.hermanlaw.com 
EFTA00257482

r. 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 
JANE DOE NO. 2, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
COMPLAINT 
Plaintiff, Jane Doe No. 2 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey 
Epstein, as follows: 
Parties, Jurisdiction and Venue 
1. 
Jane Doe No. 2 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 th is action and the claims set forth herein pursuant to 28 
U.S.C. § I332(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. §139I(a) as a substantial 
HERMAN S. MERMELSTEIN, P. A. 
- I - 
www.hermanlaw.com 
EFTA00257483

0 
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. Thomas 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 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 2004-2005, Jane Doe, then approximately 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. Thomas. 
10. 
Epstein's scheme involved the use of young girls to recruit underage girls. (Upon 
information and belief, the young girl who brought Jane Doe to Epstein was herself a minor victim 
of Epstein, and will therefore not be named in this Complaint). Under Epstein's plan, underage girls 
were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm 
Beach mansion. The recruiter would be contacted when Epstein was planning to be at his Palm 
Beach residence or soon after he had arrived there. Epstein or someone on his behalf would direct 
the recruiter to bring one or more underage girls to the residence. The recruiter, 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 
HERMAN & MERMELSTEIN. P. A. 
- 2 - 
www.hermanlaw.com 
EFTA00257484

"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. 
11. 
Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at 
Epstein's mansion, the underage victim would be introduced to 
, Epstein's assistant, 
who gathered the girl's personal information, including her name and telephone number. IM 
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 hall 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 
12. 
Consistent with the foregoing plan and scheme, Jane Doe was recruited to give 
Epstein a massage for monetary compensation. Jane was brought to Epstein's mansion in Palm 
Beach. Once at the mansion, Jane was introduced to 
who led her up the flight of 
stairs to the room with the massage table. In this room, Epstein told Jane to take off her clothes and 
give him a massage. Jane kept her panties and bra on and complied with Epstein's instructions. 
Epstein wore only a towel around his waste. After a short period of time, Epstein removed the towel 
and rolled over 
Epstein 
Jane. 
13. 
After Epstein had completed the assault, Jane was then able to get dressed, leave the 
room and go back down the stairs. Jane was paid $200 by Epstein. The young girl who recruited 
Jane was paid $100 by Epstein for bringing Jane to him. 
14. 
As a result of this encounter with Epstein, Jane experienced confusion, shame, 
HERMAN & MERMELSTEIN, P. A. 
- 3 - 
www.hermanlaw.com 
EFTA00257485

humiliation and embarrassment, and has suffered severe psychological and emotional injuries. 
COUNT I 
Sexual Assault 
15. 
Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 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. 2 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 
20. 
Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 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 ai MERMELSTEIN, P. A. 
www.hermanlaw.com 
- 4 - 
EFTA00257486

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. 2 demands judgment against Defendant Jeffrey 
Epstein for compensatory damages, costs, punitive damages, and such other and further rel ief as this 
Court deems just and proper. 
JURY TRIAL DEMAND 
Plaintiffs demand a jury trial in this action. 
Dated: February 
2008 
Respectfully submitted, 
HERMAN & MERMELSTEIN, P.A. 
Attorneys for Plaintiffs 
18205 Biscayne Blvd. 
Suite 2218 
Miami, Florida 33160 
Tel: 305-931-2200 
Fax: 305-931-0877 
By: 
HERMAN E. MERMELSTEIN, P. A. 
- 5 - 
www.hermanlaw.com 
EFTA00257487

a. ---- ea.
FILED b$. 
ELOURCAM 
JANE DOE NO. 3, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 
08-CV-80232 
March 5, 2008 
CLERK 0
olsr. cr. 
;..o. or ru. • Wog 
COMPLAINT 
Plaintiff, Jane Doe No.3 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey 
Epstein, as follows: 
Parties, Jurisdiction and Venue 
1. 
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 her 
when she was 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 S75,000, 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 
part of the events or omissions giving rise to the claim occurred in this District. 
HERMAN & MERMELSTEIH, P. A. 
loft 
- 1 - 
vAvw.hermanlaw.com 
EFTA00257488

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. Thomas 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 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 2004-2005, Jane Doe, then 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. Thomas. 
10. 
An integral player in Epstein's Florida scheme was 
, a Palm Beach 
Community College student from Loxahatchee, Florida. She recruited girls ostensibly to give a 
wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's 
plan, 
would be contacted when Epstein was planning to be at his Palm Beach residence 
or soon after he had arrived there. Epstein or someone on his behalf directed 
to bring 
one or more underage girls to the residence. 
upon information and belief, generally 
sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas 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 
HERMAN & MERMELSTEIN, P. A. 
- 2 - 
www.hermanlaw.com 
EFTA00257489

improper conduct were made. This was an important element of Epstein's plan. 
11. 
Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at 
Epstein's mansion, the victim would be brought to the kitchen. She would then be led up a flight of 
stairs to a bedroom that contained a massage table in addition to other furnishings. Once the girl was 
alone in this room, Epstein would enter wearing only a towel to cover his private area. He then 
would lay down on the massage table and 
12. 
Consistent with the foregoing plan and scheme, 
recruited Jane Doe to 
give Epstein a massage for monetary compensation. 
brought Jane to Epstein's mansion 
in Palm Beach. Jane was led up the flight of stairs to the room with the massage table. She was 
alone in the room when Epstein arrived wearing a towel to cover his private parts. He laid down on 
the massage table, aniz
. In addition, Jeffrey Epstein 
during the massage. 
13. 
After Epstein had completed the assault, he left the room. Jane was then able to leave 
the room and go back down the stairs. She then met 
again who brought Jane home. 
Jane was paid $200 by Epstein. 
was also paid by Epstein for bringing Jane to him. 
14. 
As a result of this encounter with Epstein, the 16-year old Jane experienced trauma, 
shock, confusion, shame, humiliation and embarrassment. 
COUNTI 
Sexual Assault 
15. 
PlaintiffJane Doe repeats and realleges paragraphs 1 through 14 above. 
16. 
Epstein tortiously assaulted Jane Doe sexually in or about 2004-2005. Epstein's acts 
were intentional, unlawful, offensive and harmful. 
HERMAN & MERMELSTEIN, P. A. 
- 3 - 
www.herrnanlaw.com 
EFTA00257490

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, 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 
20. 
Plaintiffs Jane Doe repeats and realleges paragraphs 1 through 14 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. 
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 demands judgment against Defendant Jeffrey Epstein for 
compensatory damages, costs, punitive damages, and such other and further relief as this Court 
HERMAN F. MERMELSTEIN, P. A. 
- 4 - 
www.hermanlaw.com 
EFTA00257491

deems just and proper. 
JURY TRIAL DEMAND 
Plaintiffs demand a jury trial in this action. 
Dated: March  I , 2008 
HERMAN & MERMELSTEIN, P. A. 
- 5 - 
Respectfully submitted, 
HERMAN & MERMELSTEIN, P.A. 
Attorneys for Plaintiffs 
18205 Biscayne Blvd. 
Suite 2218 
Miami, Florida 33160 
Tel: 305-931-2200 
Fax: 
By: 
vAvw.hermaniaw.com 
EFTA00257492

v/I. 
1네그놔4』J 
身勿弓 
匹(Ic 心甘 
3 
7杆-C 
叫，
旭ci 
4 JEt' 秘E川 白瓠口It 
(-T105多 
5
.
 
ic r7 
1 
(G나t』
占니 
a
-
 
] 
＼뇨 ＼忙 C1 
7g 
K
>
 
\n-0 
= 
／刀 
'
1
兀
（ 
크戶孑r 
LGHm, 
A 
1勺 
Vt " 
7d刃／ (r 甲乙 
, ,i_ 
(9놔凡a 
V勺2. 
V
/
\ 
=1口내 
'I 弓; 
2而多／ I (, yes口 
[(, 놔e (}1: 
口 나00(d 
It . 
(7 놔（2d 
V/ 4 1' ! . 
夕毋5／근eoG IL, 
／恥 \ 
\9 ,VLd 
f 
EFTA00257493