EFTA00222670

Case 9 :08-cv-80119-KAM 
JANE DOE NO. 2, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
Document 1 
Entered on FLSD Docket 02/06/2008 
Pan gtotk 6 
FILED by VT D.C. 
ELECTRONIC 
ebruary 6, 2008 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CLARENCE MADDOX 
CLERK U.S. Cat 
CT. 
S.D. OF HA. • MIAMI 
CASE NO.: 
08-CV-80119-MARRA-JOHNSON 
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 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 $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 
HERMAN 6 MERMELSTEIN. P. A. 
- 1 - 
viww.hermanlavccom 
Toff 
EFTA00222670

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. 
VYWW.hermanlaw.com 
- 2 - 
EFTA00222671

: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 Sarah Kellen, Epstein's assistant, 
who gathered the girl's personal information, including her name and telephone number. Ms. Kellen 
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 Sarah Kellen, 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 & MERMELSTEIN, P. A. 
www.hermanlaw.com 
- 3 - 
EFTA00222672

.: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 
- 4 - 
EFTA00222673

: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. Mcrmelstein 
smermelstein@hermanlaw.com 
Florida Bar No. 947245 
Adam D. Horowitz 
Florida Bar No. 376980 
ahorowitz@hermanlaw.com 
www.hermanlaw.com 
- 5 - 
EFTA00222674

Case 9:08-cv-80119-KAM 
DocuncsiMik- CCNERealt:IFEITSD 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 form, 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 & Mermelstein, PA.,18205 Biscayne Blvd., Suite 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__ 
II. BASIS OF JURISDICTION 
(PLACE AN X ONE BOX ONLY) 
O 1. U.S. Government 
Plaintin 
O 2 U.S. Government 
Defendant 
III) 
O 3 Federal Question 
(U.S. Government Not a Party) 
X 4 Diversity 
(Indicate Citizenship of Parbes in Item 
III. CITTZENSHIP OF PRINCIPAL PARTIES 
(For Diversity Case Only) 
PTF 
DEF 
Citizen of This State 
0 t O 1 
Citizen of Another State 
X2 x 2 
Citizen or Subject of s Foreign 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 sides) to try entire case 
V. NATURE OF SUIT 
(PLACE AN X IN ONE BOX ONLY) 
A CONTRACT 
A TORTS 
B FORFEITURE 
PENALTY 
A BANKRUPTCY 
A OTHER STATUS 
D I 10 Mani 
0 i2,01AWn2 
0 133.06•264 
0 140 4113010016 ireivw.1 
0  15"."1
""""
Wri"
4 VA:waned 0 
Jar. 
o 1511.1,343•0 Ad 
0 IS? Rams, of Defail“ 
511,4301Loans Mc. 
"urn) 6 
o iS3 Rang 01 Oweirroi 
/Vests Seneca 
o 1035bckroblies a 
0 mow Geese 
o 126C0,290 040:420 Latity 
PERSONAL INJURY 
0 310 Milano 
0 3.32 Plan 140,600 1160403102 
0 315 IirgterePadue Umbday 
0306 hnovilmerive0alLibitY 
13 320 Mat LOW & SW*, 
°3m M044101POISOatel 
0 330 7 23.41102272on' Sat 
won proem ustyr 
0 34014.41* 
0343 *ARM Rona USW, 
PERSONAL PROPERTY 
0 =lax 
vet* 
a 3SS ila be WO* Proati Liable/ 0370 Ods / rad 
X 363 ORR 11
/4 010011NRY 
0 371 Toe, measly 0 
0360 Caw Plinewl 
eiricieu ore 
a ass Awry 0,12”032 
Onnoci a 
06i Aran" 
0 623 0•4111003 6 Pic 
a 62$ Om ROSSI Saw* 
Cl Mowry 21 USC 211 
0 630 Inge law 
0 OW RR 1 Truck 
0 ASO Ara Rye 
0 NO 1303.43okal 
Salelluean 
0 NO One 
o 422 *sow a use iss 
0 423 Wintleampl a SC rot.
KO Sou Roacoortwn 
410 AnaNI2 
430 Nam ara Maury 
450 Conant= 
4140,pvtec 6 
420 0424:00101 
470 (LWOW 'Murcia ard 
Camoi Ornalealon 
RIO Sea.. Swot 
•10 S•AttifievConouxlIeW 
A PROPERTY RIGHTS 
0 WO Coonols 
06$ Pw. 
OM Truienri 
Eche., 
1175 Oates 0010.• 
I2USC34I0 
211 R00^121 As 
802 Ewalt 901242812/ I AO 
203 enwoongetal lAseIrs 
RH Erwin mocon" MI 
tOS Fritts ollrfommion AO 
920 APPUI Sr.. Delemnson 
1.1R3441.41Aceen 
ate 
0 260 coniseceein et sue 
901.42 
0 IMO Ors Itiseary Adtee 
••ce6 
Owlantiory NW am mar ie.00M 
lee 0460r6ton 
B SOCIAL SECURITY 
0162 “PA1130td) 
0 862 Mack Lure1923) 
0 663 CINC.01WW WOW 
0 1054 Silo ler An 
o ma as Noma 
AREAL PROPERTY 
A CIVIL RIGHTS 
B PRISONER PETITIONS 
A LABOR 
CI 210 Lard 030OrnnInn 
0 220 rombam 6 
0230 Rem Waal Law. 
0 240 Teas le Lind 
0 245 Ian Piatlat Leta/ 
0 210 Al Onw Ras 1.200/1 
0 441Vo010 
0 442 En62,44401 
0 444w.4,
1,10m1R204:40m4e6skas 
0 444 
0 4400104 OR R43111
0 5101.1710, 10 VasaSerene
Kies 0).TM 
0 530 Gnat' 
0 5351140/. Penny 
0 Lao untrue a one-
0 5930.4 We. 
•A ea 
id Fat 1. rat Strains 
ACI 
0 720 Labor umpires 
Nam% e 
a730 later umwonert 
Rawer° 1 0601.401 
Ad 
0 740 Rafxry LAW nu 
0 703 00•41.10XU130101 
a 791 4,747ne• RN ac 
SIAM ACII a 
A FEDERAL TAX SUITS 
0670 Taw NS Mini • or Oardird) 
a WI 11.9-Thod Poly 26 USC 1600 
I FILED by 
D.C.; 
VI. ORIGIN 
it 1. Original 
0 2. Removed from 0 3. Remanded from 
Proceeding 
State Court 
Appellate Court 
(Specify) 
0 4. Refilled 
0 6. Multidistrict Litigation 
0 7. 
Appeal to District Judge from 
0 5. Transferred from another district 
Magistrate Judgment 
VII. REQUESTED 
IN COMPLAINT 
CHECK IF THIS IS A 
O CLASS ACTION 
DEMAND $ 
o UNDER F.R.C.P. 23 
CI 
Check YE 
complaint: 
JURY DEMAND: 
O NO 
VIII. RELATED 
CASE(S) IF ANY 
(See Instructicos): 
(SEE ATTACHED) 
JUDGE 
DATE pi . 
-1,0 46t 
SIGNATURE OF ATTORNEY OF RECORD 
UNITED STATES DISTRICT COURT 
S/F 1.2 
REV. 9194 
DOCKET NUMBER 
FOR OFFICE USE ONLY: Receipt No. 
 Amount 
Date Paid:  
 Wfp: 
EFTA00222675

Case 9:08-cv-80119-KAM 
Document 12 
Entered on FLSD Docket 06/20/2008 
Page 1 of 6 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA-JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
DEFENDANT'S MOTION FOR STAY 
Defendant Jeffrey Epstein respectfully moves for a mandatory stay of this 
action under Title 18, United States Code, Section 3509(k). As discussed below, 
this action is subject to a mandatory stay based on the existence of two pending 
parallel criminal actions. 
Introduction 
This civil action is a private counterpart to two ongoing criminal actions, one 
in Palm Beach state court, the other in Miami federal court. Both cases purport to 
arise from the same occurrence: the alleged sexual assault of a minor, Jane Doe 
No. 2. A federal statute directly on point provides that when an alleged sexual 
assault involving a child victim results in a "criminal proceeding," a commonly 
EFTA00222676

Case 9:08-cv-80119-KAM 
Document 12 
Entered on FLSD Docket 06/20/2008 
Page 2 of 6 
derived civil suit "shall be stayed until the end of all phases of the criminal 
action." 18 U.S.C. § 3509(k) (emphasis added).' A stay of this case is required 
until there is no longer a pending criminal action derived from the same underlying 
allegations. See 18 U.S.C. § 3509(k). 
Discussion 
The parallel state criminal action pending in Palm Beach Circuit Court is 
still in the discovery phase. State of Florida v. Jeffi-ey Epstein, Case No. 2006 CF 
09454 AXX (Fifteenth Judicial Circuit, Palm Beach County). Meanwhile, there is 
also a parallel federal criminal grand jury action pending in the Southern District of 
Florida. In re Grand Jury, No. FGJ 07-103(WPB) (S.D. Fla.) Both cases arise 
out of the same occurrence and allege that the minor plaintiff is a victim. 
The language of section 3509(k) of title 18, United States Code, is clear: a 
parallel "civil action shall be stayed until the end of all phases of the criminal 
The full text of the mandatory-stay provision reads: 
If, at any time that a cause of action for recovery of compensation for 
damage or injury to the person of a child exists, a criminal action is 
pending which arises out of the same occurrence and in which the 
child is the victim, the civil action shall be stayed until the end of all 
phases of the criminal action and any mention of the civil action 
during the criminal proceeding is prohibited. As used in this 
subsection, a criminal action is pending until its final adjudication in 
the trial court. 
18 U.S.C. § 3509(k). 
2 
EFTA00222677

Case 9:08-cv-80119-KAM 
Document 12 
Entered on FLSD Docket 06/20/2008 
Page 3 of 6 
action." 18 U.S.C. § 3509(k) (emphasis added). When it comes to statutory 
construction, the mandatory nature of the word "shall" is well-settled. See, e.g., 
Lopez v. Davis, 531 U.S. 230, 241 (2001) (noting Congress' use of a mandatory 
`shall' to impose discretionless obligations") (emphasis added); Lexecon Inc. v. 
Milberg Weiss Bershad Hynes & Lerach, 523 U.S. 26, 35 (1998) (explaining that 
"the mandatory `shall' . . . normally creates an obligation impervious to judicial 
discretion") (emphasis added). Cf. Miller v. French, 530 U.S. 327, 350 (2000) 
("Through the PLRA [Prison Litigation Reform Act], Congress clearly intended to 
make operation of the automatic stay mandatory, precluding courts from 
exercising their equitable powers to enjoin the stay. And we conclude that this 
provision does not violate separation of powers principles.") (emphasis added). 
One district court within the Eleventh Circuit, facing the identical issue with 
a pending state prosecution, recently construed "the plain language of § 3509(k)" 
as "requirfing] a stay in a case . . . where . . . a parallel criminal action [is] 
pending." Doe v. Francis, No. 5:03 CV 260 MCR/WCS, 2005 WL 950623, at *2 
(N.D. Fla. Apr. 20, 2005) (Francis I.1) (emphasis added). Accord Doe v. Francis, 
No. 5:03 CV 260 MCR/WCS, 2005 WL 517847, at *1-2 (N.D. Fla. Feb. 10, 2005) 
(Francis I) (staying federal civil action in favor of "a criminal case currently 
pending in state court in Bay County, Florida, arising from the same facts and 
involving the same parties as the Instant action," noting that "the language of 18 
3 
EFTA00222678

Case 9:08-cv-80119-KAM 
Document 12 
Entered on FLSD Docket 06/20/2008 
Page 4 of 6 
U.S.C. § 3509(k) is clear that a stay is required in a case such as this where a 
parallel criminal action is pending which arises from the same occurrence 
involving minor victims") (emphasis added). There is no contrary opinion from 
any court. 
In determining that the federal stay provision is mandatory, the Francis II 
court expressed that there was apparently no case law supporting, or even 
"discussing the [avoidance] of a stay [under the command of] § 3509(k)." Francis 
H, 2005 WL 950623, at *2. Deferring to the statute as written, the Francis H court 
rejected the plaintiffs' argument that some of the alleged victims had already 
reached their majority. 
See id. 
The court similarly rejected the plaintiffs' 
argument that it would be in the victims' best interests to avoid a stay so as to 
counteract the victims' "ongoing and increasing mental harm due to the `frustrating 
delay in both the criminal case and [the civil] case.'" Id. The Francis II court, in 
adhering to the plain language of the statute, also adhered to the "well established 
priority of criminal proceedings over civil proceedings." Cf. United States v. 
Hanhardt, 156 F. Supp. 2d 988, 1000 (N.D. I11. 2001) (citing Fed. R. Crim. P. 
50(a)). 
Conclusion 
Because this civil action arises from the same allegations as two pending 
criminal actions, § 3509(k) mandates a stay of this civil action. 
• 
4 
EFTA00222679

Case 9:08-cv-80119-KAM 
Document 12 
Entered on FLSD Docket 06/20/2008 
Page 5 of 6 
WHEREFORE, Defendant Jeffrey Epstein respectfully requests that the 
Court enter a stay under 18 U.S.C. § 3509(k), coextensive with the state and 
federal criminal actions. 
Respectfully submitted, 
ATTERBURY, GOLDBERGER & 
WEISS, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, Florida 33401 
Tel: 561 659 8300 
Fax: 561 835 8691 
By: /s/ Jack A. Goldberger 
Jack A. Goldberger 
Fla. Bar No. 262013 
j goldberger@agwpa.com 
Attorneys for Defendant Jeffiey Epstein 
5 
EFTA00222680

Case 9:08-cv-80119-KAM 
Document 12 
Entered on FLSD Docket 06/20/2008 
Page 6 of 6 
CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7 
Counsel for defendant has conferred in good faith with counsel for the 
plaintiff, who opposes the relief requested in this motion. 
Is/ Jack A. Goldberger 
Jack A. Goldberger 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on June 20, 2008, 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 on counsel of record identified 
below by facsimile and U.S. Mail. 
Jeffrey M. Herman, Esq. 
Stuart S. Mermelstein, Esq. 
Adam D. Horowitz, Esq. 
Herman & Mermelstein, P.A. 
18205 Biscayne Blvd, Suite 2218 
Miami, Florida 33160 
Fax: 305 931 0877 
/s/ Jack A. Goldberger 
Jack A. Goldberger 
6 
EFTA00222681

Case 9:08-cv-80119-KAM 
Document 16 
Entered on FLSD Docket 07/01/2008 
Page 1 of 3 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA-JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
DEFENDANT'S NOTICE CONCERNING MOTION TO STAY IDE 121 
In connection with his motion to stay this action [DE 12], Defendant Jeffrey 
Epstein hereby notifies the Court that the State Court action, State of Florida' 
Jeffrey Epstein, Case No. 2006 CF 09454 AXX (Fifteenth Judicial Circuit, Palm 
Beach County), was resolved on June 30, 2008. See Final Disposition sheets, 
attached hereto as Exhibit A. The federal criminal proceeding, however, remains 
pending. 
Respectfully submitted, 
ATTERBURY, GOLDBERGER & 
WEISS, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, Florida 33401 
Tel: 561 659 8300 
Fax: 561 835 8691 
EFTA00222682

Case 9:08-cv-80119-KAM 
Document 16 
Entered on FLSD Docket 07/01/2008 
Page 2 of 3 
By: /s/ Jack A. Goldberger 
Jack A. Goldberger 
Fla. Bar No. 262013 
jgoldberger@ agwpa.com 
Attorneys for Defendant Jeffrey Epstein 
2 
EFTA00222683

Case 9:08-cv-80119-KAM 
Document 16 
Entered on FLSD Docket 07'01'2008 
Page 3 of 3 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on July 1, 2008, 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 on counsel of record identified 
below by facsimile and U.S. Mail. 
Jeffrey M. Herman, Esq. 
Stuart S. Mermelstein, Esq. 
Adam D. Horowitz, Esq. 
Herman & Mermelstein, P.A. 
18205 Biscayne Blvd, Suite 2218 
Miami, Florida 33160 
Fax: 305 931 0877 
/s/ Jack A. Goldberger 
Jack A. Goldberger 
3 
EFTA00222684

Case 9:08-cv-80119-KAM 
Document 16-2 
Entered on FLSD Docket 07:01:2008 
Page 1 of 4 
EXHIBIT A 
EFTA00222685

Case 9:08-cv-80119-KAM 
Document 16-2 
Entered on FLSD Docket 07/01/2008 
Page 2 of 4 
: 
tiP 
• ' 
CASE PIO 
±-122OO.1.:IFO-51/4
541sXXX 
CF 
V. 
JEFFREY E. EPSTEIN 
Z41 
'FP 
^i ria4 
Y 
tr..mr.y..PRzia"rtnivz•zrt 
: . • 
. 
7 
'Crt. Rep. lun,L__ 
Date : • -17 vcri 
J 
„Asir 
)----=-- 
• 
/ PD e--P:9fot Pres, 
De ft--Pres 
of Pres.- W /- /O  
S 
Before the Court for. 
C 
r 
O Granted O Denied O With /Without Prejudiced ^-O Withdrawn O Court Reserves Ruling O Written Order to Follow 
O 
Warrant O ordered O Recalled O Bort 
Cl See Belbw DAlso Covers . 04 Cond 
O Bond Forf 
OOR: Distil / Revoked /Reinstated 
O Bond Fat Vacated O Previous Bond Reinstated, if B 
an 
/Reuniter 
O$GR:Disch/Revoked/Reinsmted 
• 
- 
- 
O State failed to file charges 0 -Released OR /8:O1L 
O Deft 
Indigent 
O PD Appt 
O Erg only . PD Pres 
• O- Court Appts
_ 
Evaluation for: O Drug Farm 
O DOC Non-Secure Bed by •
• 
• 
O Pre-Plea . O PSI ordered by/within 
' 
.days 
O wfinput from DU / Staffing 
O Referred to: FIT / SAAP / PADD 
O Case p cod on theabsentee docket 
DEFT ENTERED A LEA OF: O NOT GUILTY 
GUILTY O NO CONTEST O BEST INTEREST O TO THE COURT 
Als,Charged-Cts 
MA.' 
er Cts 
Lesser Charge ' 
40' Sw & lest 
dv of Rts 
Waived PSI 
Lesser Cts 
Lesser Charge 
17ADJ GUILTY as Charged as to Cu____,21264 
Lesstr Cts 
O FOUND GUILTY as Charged as to Cts 
Lesser Cts 
. 
O ADJ WftiELD as to Cts 
O SENT W/BELD as to Cts 
O FOUND AND ADJUDICATED DELINQUENT as to Cts 
' ODisoOolenofollowflikd 
O FOUND & AD: NOT GUILTY as to Cts 
O Dismiss 
O Nolte Prase Cts 
. 
Prob / Comm Control: O Revoked 
O Reinsta 
O Modified 
O Stip/Found: (violent) Habitual Off. 775.084 
a 
o 
SENTENCE: 
PBCJisilP/15 
Cis: 
O Term. Successfully / Unsuccessfully - 
- 
. • . 
e-- - 
• 
exual Predator 
O Stip/Found:. P.R.R. 
/ 
e 
Os. 
PBC2- 
Cts• 
/ DOC. 
- Os.
for 
 
/ 
. 
. 
Deft Remanded 
:meretirlf 
O Deft to remain on same rel. status pending sent. 
•
St
W/Credit 
an / Consec / Co-'h in w/cases / 
: 
• 
O Execution of Sentence Stayed 
O Sentence Suspended 
O Time 
O Youthful Off O Habitual Off- O Min/ Maud- 
served as ki Cts • 
as to Cts 
O ABOVE SENTENCE1O BE FOLLOWED By: O Probation O Drag/Sex OffProb O Comm. Control' .O I . O E - See Pg. 2 
O DRIVERS LICENSE TO BE SUSPENDED / REVOKED FOR 
YEARS AS'A RESULT OF THIS PLEA. 
,
B
 
 Set /Remains Set / Reset
• 
 
Div • 
Rm— at 
AM/PM 
Div 
Rm 
 at 
AM/PM 
Set / Remains Set / Reset  
•
O Deft sign  
O Def Co 
O Prob °Jail ODD O GAL 
Notified by mail by: 
O County Courthouse 
205 N. Dixie, West Palm Beach 
O ASA 
O Courtroom, Criminal Justice Bldg. 
38844 State Road 80, Belle Glade 
O Bondsman 
 on 
/ 
O Courtroom,- Criminal Justice Complex 
3228 Gun Club Rd., West Palm Beach 
IF VON ARE A PERSON VAIN A OISAESUre WHO WEDS MY ACCOVIIKOCS NORDIN TO PARDMIME II TES PECCEEDEC1 YOU AfE 941111114 AT NO CUSP TO YOU.10 THE PROVISION OF 
• 
CERTAIN AS9STAhrE Kass CONTACT Lww JAFFE. ADA COORDIVEDE IN TIC ACEANSMATHE awe CHIT COM PAW BEACH MOEN ECWRFICEISM 205 N EWE I'MT, RE SSA 
WEST PALM MACK FL MEN: TUB:HONE (561)6%.4150, WWI a ME NNE ONS Of YOUR Rear OF THE NONCE. IF YOU AM HEARING OR VOCE IMPAIRED, CALL 14304554Th. 
— , 
Form 6)1 EDP Ray 11/06 
EFTA00222686

Case 9:08-cv-80119-KAM 
Document 1 6- 2 
Entered on FLSD Docket 07/01/2008 
Page 3 of 4 
Case No.:  
20080=ND093Si= 
W 
 ST of FL vs.  
JEFFREY'EPSEBIN 
charges.  PROCURE PERSON lla 
MB GE' 18 FOR PAGSTI5lll-liCN 
(eater FROM 2006CF009454=kr 
Assad/ - 
 
Bond# 
Date 
in 
n 
• 
• 
- 
/udge 
 
. 
-• 
- 
. Crt. Rep. / 
• .11 )11017/4'..)
ASA 
.4/./.47 
DC 
r- 
 , 
• 
- 
• 
Int 
_ . 
4/..../j.::..n/tf 
.-Tet--Pres-/,Oot Pres. 
W i/W/O pa. OS. 
.1,: tin 
• 
Esq CP137-
res / Not Pros. 
_....• 
. . 
-Beftliellti Court for: 9.4 A05 
f 
I 
O Granted 0 Denied .. 0 With / Without Prejudice 0 Withdravin 
0 COurt Reserves Ruling a Written Order to Follow 
O Warrant 
0 Ordered 
0 Recalled 
0 Bond Set at S 
. Ince Below 
0
 
Also Covers 0 Sp Cond 
0. Bond Pod 
0 OR: Disch / Revoked / Reinstated 
0 Bond] Disch /Revoked •cISOR: Discb / Revoked /Reinstated 
Cl Bond Foil Vacated 
Cl Previous Bond Reinstated, if Bondsman agrees . Cl State failed to file charges - 0 Released O.R. / S.O.R. . 
0 Deft 
Indigent o pp Sppt 
CI firg only 
PD Pres 
a Court ApPts 
_ 
. 
Evaluation for: 0 Drug PAIR 0 DOC Non-Secure Bed by 
• 
0 Pre-Plea 0 PSI ordered by/within 
• 
days. 
0 vainput. from DJJ /Staffing 
0 Referred to: PTI / SAAP / PADD 0 Case pla 
on the absentee docket . 
• 
' 
DEFT ENTERED A PLEA O12: 't3 NOT GUILTY. 
GUILTY ONO CONTEST Cl BEST INTEREST 0 TO THE COURT 
•• I i loc. 
At 
Charged-Cts 
.< 
Lesser Cts 
• 
-Lesser Charge 
.
t
 i
q sw & Thu 
Adv of Rts of gaived PSI ' 
Lesser Cts 
• 
teiserCharge • 
ADS GUILTY as Charged as to Cts 
el •1••?A• y 
Lesser CG 
• • • • 
0 FOUND GUILTY as Charged as to as 
.. 
Lesser Cts• •• 
CP ADJ• W/HELD as to Cts 
0 -SENTW/1-= astoCts ' 
CI FOUND AND ADJUDICATED DELINQUENT as to Cts• 
• 
' • • 
• 
0 Dispo Order to follow / Piled 
0 POUND & ADI NOT GUILTY as to Cts 
0 DisMies : 0 NolleProsseCts 
Prob / Comm Control: 
0 Revoked .0 Reinstated 
0 Modified. 0 Term. Successfully / Unsuccessfully . • 
0 Deft. to pay fine or complete 
hrs. Community Service or Serve 
days PBCJ. 
0 Stip/Found: (violent)'liabitugl Off. 775.084 . 
Stip/Founds:SeZeal .Offensle?/ Sexual Predator 
0 Stip/Found: P.R.R. 
SENTENCE: 
PBC31-441.71`) 
PRO- 
 
 
/ DOC: 
 Cts-
jC
1 
W/Credit for 
• • 
• 
Days / e_
..., crel 
It/ oeftto temain on sarpe reL•status pending sent. 
nc 
onset Co-Term w/cases 
. fiet_,/. .."' .x! :, ..' el' 
.1 
• 
' f 
• • 
• 
. 
• • 
0 Execution of Sentence Stayed 
0 Sentence Suspended 
0 Time served as to CIS  
ie.
Youthful Off 
C
l
 
Habitual Off 
0 Min /Mend-  
 as to $ 
ABOVE SENTENCE TO BE FOLLOWED By: 0 Probation. 0 Drug Off Prob  
Comm. Control t/ I 0 
- S
ICePage 
. - 
  Set / Remains Set / Reset 
• Div" 
Rm — 
at 
AM/PM 
 
 Set / Remains Set /Reset 
•  Div 
 Rm 
 ..ar_ 
AM/PM 
• 
0 Deft sign  
• 0 Def Co  
0 ASA 
' 
. 
O Prob 
0 Jail 
0 DJJ. 0 GAL 
Notified by mail by: 
Cl County Courthouse 
• . 0 Courtroom, Criminal Justice Bldg. • 
• 
• 205 N. Dixie, West Palm Beach. 
• 
38844 State Road 80, Belle Glade• 
on 
O Bondsman • 
1 
./ 
O Courtroom, entitle:II lustice Complex 
' 3228 Gun Club Rd., West Palm Beach 
IF YOU ARE AMMONyin A COSANUTY WHO NEEDOANY A000111100A1RIN IN ORDER TO PARMCIFATE IN THIS PROCIIMM YOU All 8111121), AT NO COSTIO YOU, TO THE FROMM OF 
cemssrssysruce num career sow uessrtADACOORCINKIte DINE ACUMSTMONE Off= OF TOO O0Un PALM BEACH COMFY COW MIME, 201a WOE KOK FOI 
WESIFF/118EACK FL 33601: TELEPHONE (561) 3364163. VIMIN 2 WOR1ONO DAYS OF YOUR RECI3PT OF MS Pancarybu ARE MONO OR VOICE IMPAIRED. CALL 14034654M. 
Form 611 soap rev 3/02 
EFTA00222687

Case 9:08-cv-80119-KAM 
Document.16-2 
Entered on FLSD Docket 07/01/2008 
P ge 4 of 4 
0 
• 
Th
." 
0 
DATE: 6 3 OS-.
7age 2 
• 
• 
r , 
I
CL/ 
TERM OF Prob / Sex Off / Drug Off 
C.C.9 C.C. II: 
AZ. 
— (mos yh-as tiers ___L
_ 
O conc w/ O bonsec. w/ 
O Probation transferred to: 
SPECIAL CONDITIONS: 
- 
O Complete Originally Ordered Conditions 
. 
 ' 
" 
. 
O Curfew: 
p m with the following exception. 
• • 
• 
, 
O Deft. to report to Prob.. Dept. immediately upon release 
, • 
• 
O Deft. not Jo have in care, custody; or control any.unlawful &illegal material, subst, device, or object. 
O Deft. to Immediately notify Prob. Officer if place of residence or job changes. 
• 
O Restitution CRO filed .. 
. 
. 
. . 
O Subject to all ordinary and special odnditions of Probation •' • 
• 
_..... 
. 
O Substance Abuse Eval. / PeycholdgiCal Eval: / Psychosexual Eval. within / by' 
a
and deft. to successfullycomplete' recommended treatment " •' : •- 
•
• 
• • • •' . 
CI Random DrUg/Alcohol Testing .. • 
O At Deit's Expense • ." CI Costs Waived 
0 No Consumption/Possession of Alcohol or. Drugs or intoxicants without a Piescription. 
• 
O Attend 
.AA and/or NA Meetings per. Week: 
- 
,
O Deft. not to frequent any place of business whose primary purpose is the sale of alcohol. ' . 
O Complete 
Community Senlice to be done at the rate of • 
Hrs..per Wk /Mo.(Min.).
_ -___Hreof 
O License Revoked / Suspended for 
• 
. 
mos /
 • 
. 
Q Attend and successfully complete DUI' chool and 1 session of Victim impact Panel
O No Contact / No Violent Contact / No Direct or: Indirect contact w/yictim(s) or others listed: .• •
, 
. 
• 
. 
cl Nd Contact w/Minor Children w/o Adult'Supervision aware 0 thii case and the disposition: 
. 
O Cost of Bdpervision: $ 
. 
‘: 
per month 
O Waived by Court. 
O Enter and Successfully Complete DOC Non-Becure.Bed Program and Any Recommended Aftercare. 
O Hold in Custody, release only to DOC Non-Secure Bed•Prograni Officer. 
O Enter and Successfully Complete PBSCILong / Short Track Drug Farm and-Any Roc: Aftercare. • . - 
O Forfeit Weapon / Money seized at the time of arrest to: 
O Enter and Complete: . O Anger Management Program 
" O Batterers Intervention Program . . 
0 Theft Abatement Program: 
• 
O Other. 
CI Defendant may apply for Early Termination after 
., provided all conds. are satisfied. 
O Serve 
• . 
.. 
days / months in P$C4,wittr credit for . 
days / months. 
j • 
/ 
• 
A 
- 
// • Il . 'kill pa -_lioritnifrrot* 
. 
•
. 
.: . 
c -, 
• 
fe . .
. 
. 
— 
. 
--wiz-. ; -71?-4 ,,R.,, r 1/4-)V
rdr.1 
'1. -11- O"."7"er 
, 
. 
. , 
1 1 e.:7 . : 
%,,s 
i ,.. 
• 
. 
• 
• 
a 
• • 
• 
. 
o 
. 
. • 
. 
. 
. 
a • 
. 
. 
. . 
. 
- 
• 
' 0 
 
O 
FORM 979 ter 3/02 
EFTA00222688

Case 9:08-cv-80119-KAM 
Document 21 
Entered on FLSD Docket 07:1672008 
Page 1 of 3 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
NO. 08-80119-CIV-MARRA/JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
1. 
JEFFREY EPSTEIN, 
Defendant. 
ORDER DENYING MOTION TO SEAL 
THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to File Ex 
Pane and Under Seal, filed July 10, 2008. Defendant seeks to file a Notice of Continued 
Pendency of Federal Criminal Action under seal.' The Court has carefully considered the motion 
and the record and is otherwise fully advised in the premises. 
As stated in the Local Rules for the Southern District of Florida, "proceedings in 
the United States District Court are public and Court filings are matters of public record." S.D. 
Fla. L.R. 5.4(A). It is well settled that the media and the public in general possess a common-law 
right to inspect and copy judicial records. See Nixon I Warner Communications, Inc., 435 U.S. 
589, 597 (1978). "The right to inspect and copy records is not absolute, however. As with other 
forms of access, it may interfere with the administration of justice and hence may have to be 
curtailed." 
Graddick, 696 F.2d 796, 803 (11th Cir.1983). This right of access creates 
'All documents filed conventionally shall henceforth be filed directly with the Office of 
the Clerk in West Palm Beach, Florida. The parties shall not file documents conventionally in 
any other division of the Southern District of Florida. 
1 
EFTA00222689