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Case 9:08-cv-80804-KAM 
Document 1-3 
Entered on FLSD Docket 07/21/2008 
Page 101 of 116 
IN THE CIRCUIT COURT OF THE 
15TH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY 
FLORIDA 
CASE NO: 50 2008 CA 006596 XXXX 
MB AB 
JANE DOE, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, HALEY ROBSON, 
and SARAH KELLEN, 
Defendants. 
AMENDED COMPLAINT 
Plaintiff JANE DOE brings this Complaint against Defendants JEFFREY EPSTEIN, 
HALEY ROBSON, and SARAH KELLEN, and states as follows: 
Parties, Jurisdiction and Venue 
1. Jane Doe is a citizen and resident of the State of Florida. She is a sui juris and over the 
age of 18. 
2. Jane Doe 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. 
3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 
4. Defendant Haley Robson is a citizen and resident of Palm Beach County, Florida. 
5. Defendant Sarah Kellen is a citizen and resident of the State of New York. 
6. This is an action for damages in excess of Fifteen Thousand Dollars ($15,000), exclusive 
of interest and costs. 
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Entered on FLSD Docket 07/21/2008 
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7. 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 
resides in Palm Beach County, Florida. 
Factual Allegations 
8. At all relevant times, Defendant Jeffrey Epstein was an adult male. 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. He maintains his principal home in New York and 
also owns residences in New Mexico, St. Thomas and Palm Beach, Florida. The allegations 
herein concern Epstein's conduct while at his lavish estate in Palm Beach. 
9. Upon information and belief, Epstein has a sexual preference and obsession for minor 
girls. He engaged in a plan, scheme, and/or enterprise in which he gained access to primarily 
economically disadvantaged minor girls in his home, sexually assaulted these girls or coerced or 
attempted to coerce them to engage in prostitution, and then gave them money. In or about 2005, 
Jane Doe, then 14 years old, fell into Epstein's trap and became one of his victims. 
10. Upon information and belief, Jeffrey 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. 
11. An integral player in Epstein's Florida scheme/enterprise was Sarah Kellen, an assistant 
of Epstein's from New York, New York, and Haley Robson, a Palm Beach Community College 
student from Loxahatchee, Florida. They recruited girls ostensibly to give a wealthy man a 
massage for monetary compensation in his Palm Beach mansion. Under Epstein's 
plan/enterprise, Ms. Robson was contacted shortly before or soon after Epstein was at his Palm 
Beach residence. Epstein, Kellen, or someone on their behalf, directed Ms. Robson to bring one 
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Case 9:08-cv-80804-KAM 
Document 1-3 
Entered on FLSD Docket 07/21/2008 
Page 103 of 116 
or more underage girls to the residence. Ms. Robson, upon information and belief, generally 
sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas 
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/enterprise. 
12. Epstein's plan, scheme, and/or enterprise reflected a particular pattern and method. Upon 
arrival at Epstein's mansion, Mr. Robson would introduce each victim 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. Ms. Kellen would then leave the girl alone in this room, 
whereupon Epstein would enter wearing only a towel. He 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. 
13. Consistent with the foregoing plan, scheme, and/or enterprise, Ms. Robson recruited Jane 
Doe to give Epstein a massage for monetary compensation. Ms. Robson brought Jane Doe to 
Epstein's mansion in ?alm Beach. Jane was introduced to Sarah Kellen, who led her up the flight 
of stairs :o the room with the massage table. Ms. Kellen set up the massage table, laid out 
massage oils, told Jane Doe that Epstein would be in shortly, and then left the room. Jane Doe 
was alone in the room when Epstein arrived. Epstein told her to remove her clothes and left the 
303 of 316 
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Case 9:08-cv-80804-KAM 
Document 1-3 
Entered on FLSD Docket 07/21/2008 
Page 104 of 116 
room. When Epstein returned he was wearing only a towel. He removed his towel and laid down 
on his stomach on the massage table. Epstein again told Jane Doe to remove her clothes. In 
shock, fear and trepidation, Jane Doe complied, removing her clothes except for her panties and 
bra. Shortly after starting to rub Epstein's back, Epstein told Jane Doe to sit on his back. Jane 
Doe, out of fear and trepidation, complied. After a period of time Epstein got up from the table 
and went behind the door. 
For several minutes Jane Doe heard loud noises and moans and 
believes that Epstein was masturbating. Thereafter Epstein, naked, returned to the massage table 
and laid face up on the table. Epstein than told Jane Doe to continue with the massage and told 
her to sit on top of him. Out of fear and trepidation she complied. As Jane Doe rubbed Epstein's 
chest, Epstein began to use a vibrator on Jane Doe's vagina. Thereafter Epstein began to 
digitally stimulate and attempt to penetrate Jane Doe's vagina. At this same time, Epstein was 
masturbating. Upon reaching orgasm, Epstein got up from the massage table, told Jane Doe to 
write down her name and phone number, and then left the room. 
14. Jane Doe was then able to get dressed, leave the room and go back down the stairs and 
into the kitchen. Epstein, Robson and Kellen were waiting for Jane Doe. Epstein paid Jane Doe 
$300. Ms. Robson was paid $200 by Epstein for bringing Jane Doe to him. Ms. Robson took 
Jane Doe home. 
15. As a result of this encounter with Epstein, the 14-year old Jane Doe experienced 
confusion, shame, humiliation, and embarrassment, and the assault sent her life into a downward 
spiral. 
COUNT I 
Sexual Assault against Defendant Epstein 
16. Plaintiff Jane Doe repeats and realleges paragraphs I through 16 above. 
17. Defendant Epstein tortiously assaulted Jane Doe sexually in or about 2005. 
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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 Doe. 
19. As a direct and proximate result of Epstein's assault on Jane Doe, she has suffered and 
will continue to suffer severe and permanent traumatic injuries, including mental, psychological 
and emotional damages. 
WHEREFORE, Plaintiff Jane Doe 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, Robson and Kellen 
20. Plaintiff Jane Doerepeats and realleges paragraphs I through 16 above. 
21. Defendants Epstein, Robson and Kellen conspired to subject Jane Doe to the sexual 
assault of Defendant Epstein. 
22. Each of the Defendants committed an overt act in pursuance of this conspiracy: 
Defendant Robson used false pretenses to lure Jane Doe to the home of Defendant Epstein so 
that Epstein could sexually assault Jane Doe; Defendant Kellen delivered Jane Doe to Defendant 
Epstein's bedroom so that Epstein could sexually assault Jane Doe; and Defendant Epstein 
actually committed sexual assault against Jane Doe. 
23. As a direct and proximate result of Defendants' civil conspiracy, Jane Doe has suffered 
and will continue to suffer severe and permanent traumatic injuries, including mental, 
psychological and emotional damages. 
WHEREFORE, Plaintiff Jane Doe demands judgment against Defendants Jeffrey Epstein, 
Haley Robson, and Sarah Kellen for compensatory damages, costs, attorney's fees, and such 
Page 5 of 9 
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Case 9:08-cv-80804-KAM 
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Entered on FLSD Docket 07/21/2008 
Page 106 of 116 
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, Robson, and Kellen 
24. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 16 above. 
25. The conduct of Defendants Epstein, Robson, and Kellen in subjecting Jane Doe to the 
sexual assault of Defendant Epstein was intentional or reckless. 
26. The conduct of Defendants Epstein, Robson, and Kellen in subjecting Jane Doe to the 
sexual assault of Defendant Epstein was outrageous, going beyond all bounds of decency. 
27. The conduct of Defendants Epstein, Robson, and Kellen in subjecting Jane Doe to the 
sexual assault of Defendant Epstein caused Jane Doe severe emotional distress. Defendants 
knew or had reason to know that their intentional and outrageous conduct would cause emotional 
trauma and damage to Jane Doe. 
28. As a direct and proximate result of Defendants' intentional or reckless conduct, Jane Doe 
suffered and will continue to suffer severe mental anguish and pain. 
WHEREFORE, Plaintiff Jane Doe demands judgment against Defendants Jeffrey Epstein, 
Haley Robson, and Sarah Kellen 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 IV 
Civil Remedy for Violation of Florida Statute Section 772.103 against 
Defendants Epstein, Robson and Kellen 
29. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 16 above. 
Page 6 of 9 
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30. 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). 
31. 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); 
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. 
32. Under Defendants' plan, scheme and enterprise, Defendant Epstein paid Defendant 
Robson to repeatedly find and bring him underage girls, who were delivered to Epstein by 
Defendants Robson and Kellen, in order for Epstein to solicit, induce, coerce, entice, compel or 
force such girls to engage in acts of prostitution and/or lewdness. 
33. Plaintiff Jane Doe was the victim of Defendants' plan, scheme and enterprise. Defendant 
Robson took Jane Doe to Epstein's home under the pretense that Jane Doe would be paid to give 
307 a1316 
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Case 9:08-cv-80804-KAM 
Document 1-3 
Entered on FLSD Docket 07/21/2008 
Page 108 of 116 
Epstein a massage. Defendant Kellen delivered Jane Doe to a room with a massage table and 
told her that Epstein would be in shortly. Jane Doe was alone in the room when Epstein arrived. 
Epstein told her to remove her clothes and left the room. When Epstein returned he was wearing 
only a towel. He removed his towel and laid down on his stomach on the massage table. Epstein 
again told Jane Doe remove her clothes. In shock, fear and trepidation, Jane Doe complied, 
removing her clothes except for her panties and bra. Shortly after starting to rub Epstein's back, 
Epstein told Jane Doe to sit on his back. Jane Doe, out of fear and trepidation, complied. After a 
period of time Epstein got up from the table and went behind the door. For several minutes Jane 
Doe heard loud noises and moans and believes that Epstein was masturbating. Thereafter, 
Epstein, naked, returned to the massage table and laid face up on the table. Epstein then told 
Jane Doe to continue with the massage and told her to sit on top of him. Out of fear and 
trepidation, she complied. As Jane Doe rubbed Epstein's chest, Epstein began to use a vibrator 
on Jane Doe's vagina. Thereafter, Epstein began to digitally stimulate and attempt to penetrate 
Jane Doe's vagina. At this same time, with his other hand, Epstein was masturbating. Upon 
reaching orgasm, Epstein got up from the massage table, told Jane Doe to write down her name 
and phone number, and then left the room. 
34. Jane Doe was then able to get dressed, leave the room and go back down the stairs and 
into the kitchen where Epstein, Robson and Kellen were waiting for her. Epstein paid Jane Doe 
$300. Ms. Robson was paid $200 by Epstein for bringing Jane Doe to him. Ms. Robson took 
Jane Doe home. 
WHEREFORE, Plaintiff Jane Doe demands judgment against Defendants Jeffrey Epstein, 
Haley Robson, and Sarah Kellen for compensatory damages, treble damages under Florida 
Statute section 772.1C4, costs and attorney's fees under Florida Statute section 772.104, and such 
30a a1316 
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Case 9:08-cv-80804-KAM 
Document 1-3 
Entered on FLS D Docket 07/21/2008 
Page 109 of 116 
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. 
JURY TRIAL DEMAND 
Plaintiff derr ands a jury trial in this action. 
Dated: Jufe2 (2008 
Respectfully submitted, 
RICCI—LEOPOLD, P.A. 
2925 PGA Blvd., Suite 200 
Palm Beac 
ardens, 
33410 
Phone: 56 
4-65 
Fax: 
56 
By: 
RE J. LEOPOLD 
Florida Bar No.: 705608 
SPENCER T. KUVIN 
Florida Bar No.: 089737 
Page 9 of 9 
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Entered on FLSD Docket 07/21/2008 
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EFTA00234217

Case 9:08-cv-80804-KAM FroGoeument 1P3ge lEaterebterr/RLSO DtOtItety07/21/2008 
Page 111 of 116 
IN THE COURT OF THE FIFTEENTH 
JUDICIAL CIRCUIT, IN AND FOR PALM 
BEACH COUNTY, FLORIDA 
JANE DOE, by and through 
JANE DOE'S MOTHER as 
natural guardian 
Plaintiffs, 
v. 
parent and CASE NO. 502008CA006596XXXXMB AB 
JEFFREY EPSTEIN, HALEY ROBSON. 
and SARAH KELLEN, 
Defendants, 
NOTICE OF CANCELLATION OF HEARING 
TO: 
SPENCER T. KUVIN, ESO., Ricci-Leopold. P.A., 2925 PGA Blvd., Suite 200, Palm 
Beach Gardens, FL 33410. JACK A. GOLDBERGER, ESO., Atterbury Goldberger & 
Weiss. P.A., One Clearlake Centre, Suite 1400, 250 Australian Avenue South, West 
Palm Beach, FL 33401 DOUGLAS M. McINTOSH, ESO. and JASON A. McGRATH, 
ESQ., McIntosh, Sawran, Peltz & Cartaya, P.A., Centurion Tower, 1601 Forum Place. 
Suite 1110, West Palm Beach, FL 33401. GUY LEWIS, ESQ. and MICHAEL R. TEIN, 
ESO.. Lewis & Tein, PL, 3059 Grand Avenue, Coconut Grove, FL 33133; BRUCE E. 
REINHART, ESQ„ Bruce E. Reinhart, P.A., 250 Australian Avenue South, Suite 1400. 
West Palm Beach, FL 33401 
YOU ARE HEREBY NOTIFIED that the hearing scheduled on July 7, 2008 at 
8:45 a.m. on Defendant Epstein's Motion for a Two-Week Enlargement of Time to 
Respond to the Complaint is hereby CANCELLED. 
I HEREBY CERTIFY that a good faith effort has been made to resolve the issues 
herein, or same shall be made prior to the hearing. 
I HEREBY CERTIFY that a true copy of the foregoing has been furnished by 
facsimile and U.S. Mall to the above addressees, this 
3rd 
day of. 
July .  2008. 
BURMAN, CRITTON, LUTTIER 
& COLEMAN, LLP 
515 N. Flagler Drive, Suite 400 
West Palm Beach, FL 
01 
(561) 842-2820 
By: 
Robert 0. ritton, Jr. 
Florida 
r #224162 
Michael J. Pike 
Florida Bar #617296 
This fax was received by GFI FAXmaker fax server For more information, visit http://www.gfi.com 
311 a1316 
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Document 1-3 
Entered on FLSD Docket 07/21/2008 
Page 112 of 116 
312 of 316 
EFTA00234219

Case 9:08-cv-80804-KAM 
Document 1-3 
Entered on FLSD Docket 07/21/2008 
Page16-11Ar 116 
IN THE CIRCUIT COURT OF THE 
15TH JUDICIAL CIRCUIT IN AND 
FOR PALM BEACH COUNTY 
FLORIDA 
JANE DOE, by and through JANE DOE'S 
CASE NO: 50 2008 CA 006596 XXXX 
MOTHER, as parent and natural guardian, 
MB AB 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, HALEY ROBSON and 
SARAH ICELLEN, 
Ilefendants. 
AGREED ORDER ON DEFENDANT SARAH KELLEN'S MOTION TO QUASH 
SERVICE OFP ROCESS AND SET ASIDE CLERK'S DEFAULT 
THIS CAUSE having come before the Court on Defendant Sarah Kellen's Motion to 
Quash Service of Process and Set Aside Clerk's Default, and the Court having been advised in 
the premises, it is hereby 
ORDERED AND ADJUDGED that: 
1. 
Defendant Sarah Kellen's Motion to Quash Service of Process is hereby 
GRANTED, an Alias summons shall be issued, and Plaintiff shall have 120 days to serve Sarah 
Kellen. 
2. 
The Clerk shall set aside the Default entered against Sarah Kellen. 
DONE AND ORDERED at Palm Beach County, Florida, this  
 day of 
 
 2038. 
SIGNED AND DATED 
JUL 0 9 2008 
HONOR
P IATGFRBER 
cc: 
Spencer T. Kuv:n, Esq., RICCI-LEOPOLD, P.A., 2925 
ou evard,`Sult 
00, Palm Beach 
Gardens, FL 33410 
313 o1316 
inli-fer 
Th q 
ffier9V7 
fOr 
EFTA00234220

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Document 1-3 
Entered on FLSD Docket 07/21/2008 
Page 114 of 116 
Bruce E. Reinhart, Esq., Bruce E. Reinhart, P.A., 250 Australian Avenue South, Suite 1400, 
West Palm Beach, FL 33401 
Douglas M. McIntosh, Esq., Jason A. McGrath, Esq., McIntosh, Sawran, Peltz & Cartaya, 
P.A., Centurion Tower, Suite 1110, 1601 Forum Place, West Palm Beach, FL 33401 
Robert Crittor, Esq., Burman, Critton, Luther & Coleman, LLP, 515 N. Flagler Drive, S.uite 
400, West Palm Beach, FL 33401 
Michael R. Tein, Esq., 3059 Grand Avenue, Suite 340, Coconut Grove, FL 33133 
Page 2 of 2 
314 al 316 
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Document 1-3 
Entered on FLSD Docket 07121;2008 
Page 115 of 116 
ATTACHMENT 
DEFENDANTS' ATTORNEYS 
Defendant Jeffrey Epstein 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, Florida 33401 
Burman, Critton, Luttier & Coleman, LLP 
515 N. Flagler Drive, Suite 400 
West Palm Beach, Florida 33401 
Lewis Tein, P.L. 
3509 Grand Avenue, Suite 340 
Coconut Grove, Florida 33133 
Defendant Haley Robson 
McIntosh, Sawran, Peltz & Cartaya, P.A. 
Centurion Tower 
1601 Forum Place, Suite 1110 
West Palm Beach, Florida 33401 
Defendant Sarah Kellen 
Bruce Reinhart, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, Florida 33401 
915 col 316 
EFTA00234222

°8- N§C4gg
ittgAN
A OSAIN§P
N Entered on FLSD Docket 07/21/2008 
• 
• IT 44 (Rev 300) 
CIVIL COVER SHEET 
lklig16.4(I 
_ D.C. 
The JS 44 civil t o et sheet and the informationcontained herein neidia replace nor supplement the filing andserviceofpleadings or other papers as required 
b) local rules of Court Thu form, approved by the Judicial Cooferenceof the United Slates in September 1974. is required for the use of the Clerk of Coun 
the civil docket Shed 
(SEE INSTRUCTIONS ON nit REVERSE OE THE FORM.) 
NOTICE: Attorneys MUST Indicate MI Ee-flled Cases B 
I. (a) PLAINTIFFS 
DEFENDANTS 
DOE, JANE a/k.a DOE, JANE NO. I 
(lb) County of Residence of First Listed Plaintiff UNKNOWN
(EXCEPT IN U $ PLAINTIFF CASES) 
(C) MIMICS .11 Own Heim. Adam. eisd Telephone Neat° 
R1CCI-LEOPOLD, P.A. 
2925 PGA BLVD., SUITE 200 
PALM BEACH GARDENS, FL 33410 
C 
July 18, 2008 
STEVEN M. LARIMORE 
CLERK U.S. 01ST. CT. 
S.D. Of FLA. • MIAMI 
EPSTEIN, JEFFREY; ROBSON, HALEY; KELLEN, SARAH 
County of Residence of Fine Listed Defendant 
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O 3 Re.med. 
O 
4 Reinstated or 
O 
5 another 
auks 
O 6 Multidistrict 
Proceeding 
State Coon 
(see VI below) 
Reopened 
(sPaifY) 
Litigation 
Appeal to Monet 
O , 
lodge from 
' 
Mapstrate 
Judgment 
VI. RELATED/RE-FILED 
CASE(S). 
IS.. ilrIniC1800. 
it<001.001) 
Re-filed Case n YES or NO 
JUDGE 
b) Related Casts OYES ONO 08-80069, 08-80119, 
08-80232, 
C8.80380, 
DOCKET NUMBER 
08-80381 
Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not alts Jurisdictions' statutes unless 
diversity): 
VII. CAUSE OF ACTION REMOVAL FROM STATE COURT 
LENGTH OF TRIAL via 
days ali ted (kw both sides to try entire case) 
VIII. REQUESTED IN 
O CHECK IF THIS IS ACI 
Acn 
COMPLAINT: 
UNDER F.R.C.P. 23 
DEMANDS 
CHECK YES only if demanded in complaint: 
JURY DEMAND: 
Yes fl No 
ABOVE INFORMATION IS TRUE & CORRECT TO 
s 
THE BEST OF MY KNOWLEDGE 
sl 
WYO. RECORD 
DATE 
R 
I 4
1
vol rot
 VNLY 
AMOUN 
RECEIPT 7ca 
IFP 
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