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Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 7 of 14
and other powerful individuals and that would likely have been prevented it from being
concluded in the secretive manner in which it was.
Jane Doe #4's Circumstances
if permitted to join this action, Jane Doe #4 would allege, and could prove at trial, that
she has CVRA claims similar to those advanced by Jane Doe #1 and Jane Doe #2, based on the
following:
As with the other Jane Does, Jane Doe #4 was repeatedly sexually abused by Epstein. In
or around the summer of 2002, Jane Doe #4, an economically poor and vulnerable sixteen-year-
old child, was told by another one of Epstein's underage minor sex abuse victims, that she could
make $300 cash by giving an old man a massage on Palm Beach. An acquaintance of Jane Doe
#4 (also a minor sexual abuse victim of Epstein) telephoned Epstein and scheduled Jane Doc #4
to go to Epstein's house to give him a massage. During that call, Epstein himself got on the
phone (a means of interstate communication) with Jane Doe #4, asking her personally to come to
his mansion in Palm Beach.
Jane Doc #4 then went to Epstein's mansion and was escorted upstairs to Epstcin's large
bathroom by one of Epstein's assistants. Shortly thereafter Jeffrey Epstein emerged and lay face
down on the table and told Jane Doc #4 to start massaging him. Epstein asked Jane Doc #3 her
age and she told him she had recently turned sixteen. Epstein subsequently committed illegal
sexual acts against Jane Doc #4 on many occasions.
Epstein used a means of interstate communication (i.e., a cell phone) to arrange for these
sexual encounters. Epstein also frequently travelled in interstate commerce (i.e., on his personal
jet) for purposes of illegally sexually abusing Jane Doc #4.
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