EFTA00189979

IN THE CIRCUIT COURT OF THE 
15TH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY 
FLORIDA 
B.B., 
CASE NO: 
Plaintiffs, 
vs. 
JE 
and11101 
Defendants. 
COMPLAINT 
Plaintiff, JANE DOE (B.B.), brings this Complaint against Defendants, JEFFREY 
EPSTEIN an 
and states as follows: 
Parties, Jurisdiction and Venue 
I. 
B.B. brings this Complaint under a fictitious name to protect her identity, because the 
Complaint makes sensitive allegations of sexual assault and abuse that she suffered while a 
minor. 
2. 
B.B. is a citizen and resident of the State of Florida. She is currently over the age of 
18 and otherwise sui furls. 
3. 
Defendant, Jeffrey Epstein, is currently incarcerated in Palm Beach County, is a 
citizen and resident of Palm Beach County, Florida, has full intent to stay in Palm Beach County 
after his incarceration and is otherwise sui furls. 
4. 
Defendant, 
is a citizen and resident of the State of New York and 
otherwise sui furls. 
EFTA00189979

5. 
This is an action for damages in excess of Fifteen Thousand Dollars ($15,000), 
exclusive of interest and costs. 
6. 
Venue is proper in this Court under section 47.011, Florida Statutes, because the 
causes of action brought herein accrued in Palm Beach County, Florida, and one or more 
Defendants reside in Palm Beach County, Florida. 
Factual Allegations 
7. 
At all relevant times, Defendant, Jeffrey Epstein, was an adult male. Mr. Epstein is a 
financier and money manager with a secret clientele limited exclusively to billionaires. He is a 
man of tremendous wealth, power and influence. Before confinement, he maintained homes in 
New York, New Mexico, St. Thomas, U.S. Virgin Islands, and Palm Beach, Florida. The 
allegations herein concern Mr. Epstein's conduct while at his lavish estate in Palm Beach. 
8. 
Upon information and belief, Mr. Epstein has a sexual preference and obsession for 
minor girls. He engaged in a plan, scheme, and/or enterprise wherein he gained access to 
primarily economically disadvantaged minor girls in his Palm Beach home and sexually 
assaulted the girls, or coerced or attempted to coerce the girls to engage in prostitution, and then 
gave them money. 
9. 
In or about 2005, B.B., then 15 years old, fell victim to Mr. Epstein's trap described 
above, at Mr. Epstein's Palm Beach estate. 
10. 
Upon information and belief, Mr. Epstein carried out this scheme/enterprise and 
assaulted girls in Florida, New York and on his private island, known as Little St. James, in St. 
Thomas, U.S. Virgin Islands. 
11. 
Integral conspirators in Mr. Epstein's Florida scheme/enterprise were Defendant; 
an assistant of Mr. Epstein from New York City, New York; an4 
a 
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Palm Beach Community College student from Loxahatchee, Florida; and other Jane Does. Ms. 
Ms...and 
other Jane Does recruited girls ostensibly to give a wealthy man a 
platonic massage for monetary compensation in his Palm Beach mansion. Under Mr. Epstein's 
plan/enterprise, Ms 
was contacted shortly before or soon after Mr. Epstein was at his 
Palm Beach residence. Mr. Epstein, or MM 
or someone on their behalf, directed Ms. 
and others to bring one or more underage girls to Mr. Epstein's residence. Upon 
information and belief, economically-disadvantaged, underage girls from Loxahatchee and 
surrounding areas were specifically targeted because they were easier to entice by the money 
being offered (generally $200 to $300 per "massage" session) and these girls were perceived as 
less likely to complain to authorities or have credibility if allegations of improper conduct were 
made. This was pivitol to Mr. Epstein's plan/enterprise. 
12. 
Mr. Epstein's plan, scheme, and/or enterprise had a particular pattern and method. 
Upon arrival at Mr. Epstein's mansion, the underage girls would be introduced to Ms. 
who in turn gathered the victim's personal information, including her name and telephone 
number. The girls would then be brought up a flight of stairs to a bedroom that contained, 
among other furnishings, a massage table. Photographs of nude women lined the stairway hall 
and bedroom. Ms. 
would then leave the girl alone in this room, whereupon Mr. Epstein 
would enter wearing only a towel. Mr. Epstein would then remove his towel, lay down naked on 
the massage table, and direct the girl to remove her clothes. He then would perform one or more 
lewd, lascivious and sexual acts, including masturbation, touching the girl's vagina with a 
vibrator, or digitally penetrating the girl's vagina, and coerce or attempt to coerce the girl to 
engage in lewd acts and/or prostitution. 
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Facts Specific to B.B. 
13. 
Consistent with the foregoing plan, scheme, and/or enterprise, B.B., then 15 years of 
age, was recruited to give Mr. Epstein a massage for monetary compensation. B.B. was brought 
by taxi with another girl 15 years of age to Mr. Epstein's mansion in Palm Beach. B.B. and the 
other girl were brought into the kitchen of the home and led up the flight of stairs to a large 
bathroom containing a massage table. Upon arriving in the bathroom, a young woman, on 
information and belief, Ms. 
xited a sauna wearing only a towel, placed a tube of lotion 
on the counter and stated, "I guess you will need this more than I will." 
14. 
Several minutes later, Mr. Epstein came into the bathroom and shut the door behind 
him, told both girls to remove their clothes and undressed himself. Mr. Epstein then placed a 
small washcloth over his genitals and asked both girls to rub lotion on his naked body. At some 
point Mr. Epstein told the other 15 year old girl to leave the room, leaving B.B. alone with Mr. 
Epstein. Mr. Epstein then began to masturbate while B.B. was massaging him. 
15. 
At this point, Mr. Epstein specifically asked B.B. her age, to which B.B. honestly 
advised she was 15 years old. 
16. 
Mr. Epstein took his free hand and began to touch B.B. between her legs and in her 
genitals while simultaneously masturbating himself. B.B. told Mr. Epstein to stop, but he 
continued to rub B.B. between her legs in her genital area. Mr. Epstein then ejactulated and told 
B.B. she could get dressed. 
17. 
B.B. was then allowed to get dressed, leave the room and go back down the stairs and 
into the kitchen. Mr. Epstein gave the other 15 year old girl money and told B.B. that this girl 
"had her money" and then left. B.B. was given $200 by the other 15 year old girl. 
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18. 
As a result of this encounter with Mr. Epstein, the 15 year old B.B. experienced 
confusion, shame, humiliation and embarrassment, and the assault sent her life into a downward 
spiral. 
COUNT I 
Sexual Assault and Battery against Defendant Epstein 
19. 
Plaintiff B.B. repeats and realleges paragraphs 1 through 18 above. 
20. 
This is a count for sexual assault and battery against Defendant, Mr. Epstein. 
21. 
Mr. Epstein tortiously and sexually assaulted B.B. 
22. 
Mr. Epstein's actions amounted to an unapproved and intentional touching. 
23. 
Mr. Epstein's sexual assault violated Chapter 800 of the Florida Statutes, which 
defines Mr. Epstein's lewd and lascivious acts upon B.B, as a crime. 
24. 
As a direct and proximate result of Mr. Epstein's assault on B.B., she has suffered and 
will continue to suffer severe and permanent traumatic injuries, including mental, psychological 
and emotional damages. 
WHEREFORE, Plaintiff, B.B., demands judgment against Defendant, Jeffrey Epstein, for 
compensatory damages, costs, attorney's fees, and such other and further relief as this Court 
deems just and proper. Further, Plaintiff reserves the right to amend this Complaint to add a 
claim for punitive damages pursuant to Florida Law. 
COUNT II 
Civil Conspiracy against Defendants Epstein an= 
25. 
Plaintiff B.B. repeats and reallege paragraphs 1 through 18 above. 
26. 
This is a count for civil conspiracy against the Defendants, Mr. Epstein and Ms. 
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27. 
Defendant, Mr. Epstein and Ms. 
conspired to subject B.B. to the sexual 
assault and battery by Defendant, Mr.Epstein. 
28. 
Each Defendant committed an overt act in furtherance of the conspiracy: Defendant 
assisted Epstein so that he could sexually assault B.B.; and, Defendant Epstein actually 
committed sexual assault and battery against B.B. 
29. 
As a direct and proximate result of Defendants' civil conspiracy, B.B. has suffered 
and will continue to suffer severe and permanent traumatic injuries, including mental, 
psychological and emotional damages. 
WHEREFORE, Plaintiff B.B. demands judgment against Defendants, Jeffrey Epstein and 
for compensatory damages, costs, attorney's fees, and such other and further relief 
as this Court deems just and proper. Further, Plaintiff reserves the right to amend this Complaint 
to add a claim for punitive damages pursuant to Florida Law. 
COUNT III 
Intentional Infliction of Emotional Distress against 
Defendants Epstein and 
30. 
Plaintiff B.B. repeats and realleges paragraphs 1 through 18 above. 
31. 
This is a count for intentional infliction of emotional distress against Defendants, Mr. 
Epstein and Ms. I-
32. 
The conduct of Defendants Mr. Epstein and Main 
subjecting B.B. to Mr. 
Epstein's sexual assault and battery, was intentional or reckless. 
33. 
The conduct of Defendants, Mr. Epstein and Ms 
in subjecting B.B. to Mr. 
Epstein's sexual assault and battery was outrageous, going beyond all bounds of decency. 
34. 
The conduct of Defendants Mr. Epstein and Ms 
in subjecting B.B. to Mr. 
Epstein's sexual assault and battery, caused B.B. severe emotional distress. Defendants knew or 
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EFTA00189984

had reason to know that their intentional and outrageous conduct would cause emotional trauma 
and damage to B.B. 
35. 
As a direct and proximate result of Defendants' intentional or reckless conduct, B.B. 
suffered and will continue to suffer severe mental anguish and pain. 
WHEREFORE, Plaintiff B.B. demands judgment against Defendants, Jeffrey Epstein and 
or compensatory damages, costs, attorney's fees, and such other and further relief 
as this Court deems just and proper. Further, Plaintiff reserves the right to amend this Complaint 
to add a claim for punitive damages pursuant to Florida Law. 
COUNT IV 
Civil Remedy for Violation of Florida Statute 11.2.103 
against 
Defendants Epstein!and 
36. 
Plaintiffs, S.G. and B.B., repeat and reallege paragraphs 1 through 18 above. 
37. 
This is a count for Defendants' violation of Florida Statute § 772.103. 
38. 
Defendants participated in an enterprise, or conspired or endeavored to so participate, 
through a pattern of criminal activity, in violation of Florida Statute section 772.103(3)-(4). 
39. 
Defendants engaged in this pattern of criminal activity by engaging in at least two of 
the following incidents of criminal activity with the same or similar intents, results, accomplices, 
victims, and methods of commission within a 5 year period: 
a. Procuring for prostitution, or causing to be prostituted, any person who is 
under the age of 18 years in violation of Florida Statute section 796.03; 
b. Soliciting, inducing, enticing, or procuring another to commit prostitution, 
lewdness, or assignation in violation of Florida Statute section 796.07(2)(f), or 
aiding, abetting or participating in such acts in violation of Florida Statute 
section 796.07(2)(h); 
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c. Knowingly recruiting, enticing, harboring, transporting, providing, or 
obtaining by any means a person, knowing that force, fraud, or coercion will 
be used to cause that person to engage in prostitution in violation of Florida 
Statute section 796.045; or, 
d. Forcing, compelling, or coercing another to become a prostitute in violation of 
Florida Statute section 796.04. 
40. 
Under Defendants' plan, scheme and enterprise, Mr. Epstein paid Ms 
and 
others to repeatedly find and bring him underage girls, who were delivered to Mr. Epstein by 
Defendant Ms. 
Ms. nd 
other Jane Does, in order for Mr. Epstein to solicit, 
induce, coerce, entice, compel or force such girls to engage in acts of prostitution and/or 
lewdness. 
41. 
Plaintiff B.B., was the victim of Defendants' plan, scheme and enterprise. Ms. 
assisted Mr. Epstein in obtaining these underage girls. B.B. was left alone in the room with Mr. 
Epstein. Mr. Epstein told B.B. to remove her clothes. Mr. Epstein wore a towel in front of B.B., 
and removed the towel to masturbate in front of B.B.. In shock, fear and trepidation, B.B. 
complied with Mr. Epstein's requests. 
42. 
Mr. Epstein paid B.B. $200. Mr. Epstein paid various Jane Does, including Ms. 
:5200 for bringing girls, including but not limited to B.B., to him. 
WHEREFORE, Plaintiff B.B., demands judgment against Defendants, Jeffrey Epstein and 
for compensatory damages, treble damages under Florida Statute section 772.104, 
costs and attorney's fees under Florida Statute section 772.104, and such other and further relief 
as this Court deems just and proper. Further, Plaintiff reserves the right to amend this Complaint 
to add a claim for punitive damages pursuant to Florida Law. 
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EFTA00189986

JURY TRIAL DEMAND 
Plaintiff demands a jury trial in this action. 
Dated: November 
2008 
Respectfully submitted, 
LEOPOLD-KUVIN, P.A. 
2925 PGA Blvd., Suite 200 
Palm Beach Gardens, FL 33410 
Phone: 561-515-1400 
Fax: 
561-515-1401 
By: 
THEODORE J. LEOPOLD 
Florida Bar No.: 705608 
SPENCER T. KUVIN 
Florida Bar No.: 089737 
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