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Case 9:08-cv-80119-MM 
Document 56 
Entered on FLSD Docket 02/27/2009 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA/IMMI 
JANE DOE NO. 2, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
SECOND AMENDED 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.. 
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 sot 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 
part of the events or omissions giving rise to the claim occurred in this District. 
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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 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 ono 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. (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 
"massage" session - and who were perceived as less likely to complain to authorities or have 
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Case 9:08-cv-80119-KAM 
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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 ton, 
Epstein's assistant, 
who gathered the girl's personal information, including her name and telephone number. Milk 
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 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 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, 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 tall, 
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 exposing his penis. Epstein began to masturbate and he sexually assaulted 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, 
humiliation and embarrassment, and has suffered severe psychological and emotional injuries. 
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COUNT I 
Sexual Assault and Battery 
15. 
Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 
16. 
Epstein acted with intent to cause an offensive contact with Jane Doe, or an imminent 
apprehension of such a contact, and Jane Doe was thereby put in such imminent apprehension. 
17. 
Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane 
Doe, creating a reasonable fear of imminent peril. 
18. 
Epstein intentionally inflicted harmful or offensive contact on the person oflane Doe, 
with the intent to cause such contact or the apprehension that such contact is imminent. 
19. 
Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts 
were intentional, unlawful, offensive and harmful. 
20. 
Epstein's plan and scheme in which he committed such acts upon Jane Doe were 
done willfully and maliciously. 
21. 
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. 4 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 
22. 
Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above. 
23. 
Epstein's conduct was intentional or reckless. 
24. 
Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds 
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of decency. 
25. 
Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted 
in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or 
emotional health to be significantly impaired. 
26. 
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 
damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing 
severe emotional distress to Jane Doe. 
27. 
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 relief as this 
Court deems just and proper. 
COUNT III 
Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. 42422 
28. 
Plaintiff Jane Doe repeats and realleges paragraphs I through 14 above. 
29. 
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. 
30. 
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. 
31. 
As to Plaintiff Jane Doe, Epstein could have been charged with criminal violations of 
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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). 
32. 
Epstein's acts and conduct are in violation of 18 U.S.C. §2422. 
33. 
As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal 
injury, including mental, psychological and emotional damages. 
34. 
Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a 
reasonable attorneys' fee. 
WHEREFORE, Plaintiff Jane Doe No. 2 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. 
JURY TRIAL DEMAND 
Plaintiff demands a jury trial in this action on all claims so triable. 
Dated: February 27, 2008 
Respectfully submitted, 
By: 
s/ Adam D. Horowitz 
No. 947245) 
Adam D. Horowitz L Bar 
980) 
• ST 
& HOROWITZ, P.A. 
Attorneys for Plaintiff 
18205 Biscayne Blvd., Suite 2218 
Miami, Florida 33160 
Tel: 305-931-2200 
Fax: 305-931-0877 
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CERTIFICATE OF SERVICE 
I hereby certify that on February 27, 2009, I electronically filed the foregoing document with 
the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this 
day to all parties on the attached Service List in the manner 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/ Adam D. Horowitz 
. 
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Case 9:08-cv-80119-KAM 
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Entered on FLSD Docket 02/27/2009 
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SERVICE LIST 
DOE vs. JEFFREY EPSTEIN 
CASE NO.: 08-CV-80380-MARRA/. 
United States District Court, Southern District of Florida 
Jack Alan Goldberger, Es . 
D. Critton 
. 
/s/ Adam D. Horowitz 
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