EFTA00222315

Case 9:08-cv-80119-KAM 
Document 1 
Entered on FLSD Docket 02/06/2008 
Pavpitok6 
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: 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
FILED by  VT  D.C. 
ELECTRONIC 
ebruary 6, 2008 
CLARENCE MADDOX 
CLERK U.S. 01ST. CE. 
S.D. OF ILA. • MIAMI 
CASE NO.: 
08-CV-80119-MARRA-JOHNSON 
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 550 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 575,000, 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 
HERMAN 6 MERMELSTEIN. P. A. 
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www.hermanlaw.com 
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EFTA00222315

Case 9:08-cv-80119-KAM 
Document 1 
Entered on FLSD Docket 02/06/2008 
Page 2 of 6 
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 
HERMAN & MERMELSTEIN, P. A. 
www.hermanlaw.com 
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:Case 9:08-cv-80119-KAM 
Document 1 
Entered on FLSD Docket 02/06/2008 
Page 3 of 6 
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 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. 
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 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 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 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. 
HERMAN S. MERMELSTEIN, P. A. 
www.hermanlaw.com 
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Case 9:08-cv-80119-KAM 
Document 1 
Entered on FLSD Docket 02/06/2008 
Page 4 of 6 
14. 
As a result of this encounter with Epstein, Jane experienced confusion, shame, 
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 
HERMAN & MERMELSTEIN, P. A. 
www.hermanlaw.com 
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Case 9:08-cv-80119-KAM 
Document 1 
Entered on FLSD Docket 02/06/2008 
Page 5 of 6 
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 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. 
JURY TRIAL DEMAND 
Plaintiffs demand a jury trial in this action. 
Dated: February C2008 
Respectfully submitted, 
HERMAN & MERMELSTEIN. P. A. 
HERMAN & MERMELSTEIN, P.A. 
Attorneys for Plaintiffs 
18205 Biscayne Blvd. 
Suite 2218 
Miami, Florida 33160 
Tel: 305-931-2200 
Fax: 305-931-
By: 
Jeffrey M. Herman 
jherman@,hermanlaw.com 
Florida Bar No. 521647 
Stuart S. Mermelstein 
smermelstein@hermanlaw.com 
Florida Bar No. 947245 
Adam D. Horowitz 
Florida Bar No. 376980 
ahorowitz@hermanlaw.com 
www.hermanlaw.com 
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Case 9:08-cv-80119-KAM 
Docurc•Nt11:1 CQMFASKEFITSD Docket 02/06/2008 
Page 6 of 6 
The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing, and service of pleading or other papers as required by law, 
except as provided by local rules of court. This Porn, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of 
the Court for the purpose of Initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) 
1(a) PLAINTIFFS 
DEFENDANTS 
JANE DOE NO. 2, 
JEFFREY EPSTEIN 
(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF 
OUT OF STATE 
(EXCEPT IN U.S. PLAINTIFF CASES) 
COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT NEW YORK 
(IN U.S. PLAINTIFF CASES ONLY) 
(c) ATTORNEYS (FIRM NAME. ADDRESS, AND TELEPHONE NUMBER) 
Herman & Mermeistein, PA., 18205 Biscayne Blvd., Sults 2218, Miami, 
FL 33160, (305) 931.2200 
(d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH 
ATTORNEYS (IF KNOWN) 
q !ely V foul-K/9in- ) 0 4-)/71__ 
It. BASIS OF JURISDICTION 
(PLACE AN X ONE BOX ONLY) 
O 1. U.S. Government 
Plaintiff 
O 2 U.S. Government 
Defendant 
III) 
O 3 Federal Question 
(U.S. Government Not a Party) 
X 4 Diversity 
(Indicate Citizenship of Parties In Item 
III. CITV.ENSHIP OF PRINCIPAL PARTIES 
(For Diversity Case Only) 
PTF 
DEF 
Citizen of This Stale 
0 1 O 1 
Citizen of Another State 
X2 x 2 
Citizen or Subject of s Feisty, Country 0 3 03 
PLACE AN X IN ONE BOX FOR PLAINTIFF 
AND ONE FOR DEFENDANT 
PTF 
DEF 
Incorporated of Principal Place of 
O 4 
0 4 
Business in This Stale 
Incorporated and Principal Place of 
O 5 
O 5 
Business in Another State 
Foreign Nation 
O 6 
O 6 
IV. CAUSE OF ACTION 
(CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE. 
DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY.) 
DIVERSITY ACTION UNDER 28 U.S.C. §1332(a) FOR SEXUAL ASSAULT 
IVa. _5_ days estimated (for both aides) to try entire case 
V. NATURE OF SUIT 
(PLACE AN X IN ONE BOX ONLY) 
A CONTRACT 
A TORTS 
B FORFEITURE 
PENALTY 
A BANKRUPTCY 
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VI. ORIGIN 
x 1. Original 
0 2. Removed from 0 3. Remanded from 
0 4. Refilled 
0 6. Multidisbict Litigation 
0 7. 
Appeal to District Judge from 
Proceeding 
State Court 
Appellate Court 
0 5. Transferred from another district 
(Specify) 
Magistrate Judgment 
VII. REQUESTED 
CHECK IF THIS IS A 
O CLASS ACTION 
DEMAND S 
IN COMPLAINT 
K UNDER F.R.C.P. 23 
CI 
Check YE 
complaint: 
JURY DEMAND: 
O NO 
VIII. RELATED 
CASE(S) IF ANY 
(See Instructions): 
(SEE ATTACHED) 
JUDGE 
DOCKET NUMBER 
DATE 
fa . 
I 
UNITED STATES DISTRICT COURT 
S/F 1.2 
REV. 9/94 
SIGNATURE OF ATTORNEY OF RECORD 
' 
.a )
FOR OFFICE USE ONLY: Receipt No. 
 Amount 
Date Paid:  
 Wfp: 
51-1/2-2/5 
EFTA00222320