This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →
FBI VOL00009
EFTA00234324
100 pages
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Case 9:08-cs-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 61 of 100 STATE COURT PLEADINGS EFTA00234384
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Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 62 of 100 .f3rr ut nen Page. 15151 Date 5129/200812.09:; A IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA JANE DOE, by and through JANE DOE'S MOTHER as parent and natural guardian, • Plaintiffs, V . JEFFREY EPSTEIN, HALEY ROBSON, and SARAH KELLEN, Defendants, 962118 a 0 065 9 6,0000e COMPLAINT ' Plaintiffs, JANE DOE, by and through JANE DOES MOTHER as parent and natural guardian of JANE DOE, bring this Complaint against Defendants JEFFREY EPSTEIN, HALEY ROBSON, and SARAH KELLEN, and state as follows: Parties, Jurisdiction and Vonuc I. Jane Doe is a citizen and resident of the Stale of Florida. She is a minor under the age of I 8 years. 2. Jane Doe'S Mother brings this action as parent and natural guardian of Jane Doe. 3. This Complaint is brought under fictitious names to protect the identity of the Minor Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 4. DefendanfJeffrey Epstein is a citizen and resident of the State of New York. 5. Defendant Haley Robson is a citizen and resident of Palm Beach County, Florida. 6. Defendant Sarah Kellen is a citizen and resident of the Suite of New York. 162 of 316 This fax was received by GFI FAXmaker fax server For more information, visit: http://wmar gfi.com EFTA00234385
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Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 63 of 100 From 11 ,can Page 16/51 Date 5129/2006 12:09: M 7. This is an action for damages in excess of Fifteen Thousand Dollars ($15,000) exclusive of interest and costs 8. 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 9. At all relevant times, Defendant Jeffrey Epstein was an adult male. F;pstein 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. 10. Jpon 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 them to engage in prostitution, and then gave them money. In or about 2005, Jane Doc, then 14 years old, fell into Epstein's trap and became one of his victims. I I. Upon in formmion 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. 12. An integral player in Epstein's Florida scheme was Sarah Kellen, an assistant of Epstein's front 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 befare or soon after Epstein was at his Palm Beach residence Epstein, Kellen or someone on their behalf directed Ms. Robson to bring one or more underage girls to the residence. Page 2 of 9 153 et 315 This fax was received by GFI FAXmakei fax solver. For more information, visit http.//www gip corn EFTA00234386
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Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 64 of 100 From ui wn Page 17/51 Date 5/29/2008 12 09 ", A 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 elementof Epstein's plan/enterprise 13. 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 ton 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. 14. Consistent will the foregoing plan, scheme, and/or enterprise, Ms. Robson recruited Jane Doc to give Epstein a massage for monetary compensation. Ms. Robson brought Jane Doe to Epstein's mansion in Palm Beach. Jane was introduced to Sarah Kellen, who led her up the flight of stairs to the room with the massage table Ms. Kellen set up the message table and laid out message oils and told Jane Doe that Epstein would be in shortly and than left the room. 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 message 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 Page 3 of 9 169 of 316 This fax was reetwed by GFI FAXmaker fax server. For more information, visit http./Mww gfi.com EFTA00234387
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Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket O7/21/2OO8 Page 65 of 100 From u wn Page 18151 Date 5/29/2008 12.09.: vl 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 message table and laid face up on the table. Epstein than told Jane Doe to continue with the message and told her to sit on top of him. Out of fear and trepidation she complied. As Jane Doc rubbed Epstein's chest Epstein began tc use a vibrator on Jane Doe's vagina. Thereafter Epstein began to digitally stimulate and attempt to penetrate Jane's vagina At this same lime Epstein was masturbating. Upon reaching orgasm Epstein Aot lip from the message table and told Jane Doe to write down her name and phone number and than left the room. 15. 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 to him. Ms Robson brought Jane Doe home. 16. As a result of this encounter with Epstein. the I4-year old Jane Doe experienced confusion, shame, humiliation, embarrassment and the assault sent her life into a downward spiral. COUNT I Sexual Assault against Defendant Epstein 17. Plaintiff Jane Doe by and through her Mother, as parent and natural guardian, repeats and realleges paragraphs I through 16 above. :8. Defendant Epstein toniously assaulted Jane Doc sexually in or about 2005. 19. 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. Page 4 of 9 This fax was received by GFI FAXmaker fax server. For more information. visit hap://www. glicorn 1650,316 EFTA00234388
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Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 66 of 100 From t win Page: 19/51 Date 5/29/2008 12 09 'M 20. As a direct Lnd proximate result of Epstein's assault on Jane Doc, she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. WHEREFORE, Plaintiff Jane Doc, by and through her Mother, as parent and natural guardian, 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 fur punitive damages pursuant to Florida Law. COUNT II Civil Conspiracy against Defendants Epstein, Robson and Kellen 21. Plaintiff Jane Doe by and through her Mother, as parent and natural guardian, repeats and realleges paragraphs I through 16 above. 22. Defendants Epstein, Robson and Kellen conspired to subject Jane Doe to the sexual assault of Defendant Epstein. 23. Each of the Defendants commined an overt act in pursuance of this conspiracy Defendant Ftobscin used false pretenses to lure Jane Doe to the home of Defendant Epstein so that Epstein could sexually assault Jane Doc; 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. 24. 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 Page 5 of 9 166 ot 315 This lax was received by GFI FAXmaker fax server For more information. 'Sit http://www gfi.com EFTA00234389
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Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 67 of 100 From V! AT Page 20/51 Date 5/29/200ti 12 09 A WHEREFORE, Plaintiff Jane Doe, by and through her Mother, as parent and natural guardian, 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 tins Complaint to add it claim for punitive damages pursuant to Florida Law. COUNT HI Intentional infliction of Emotional Distress against Defendant Epstein 25. Plaintiffs Jane Doe by and through her Mother, as parent rind natural guardian, repeat and reallege paragraphs through 16 above 26. Epstein's conduct was intentional or reckless. 27. Epstein's conduct was outrageous, going beyond all bounds of decency. 28. Epstein's conduct caused severe emotional distress not only to lane Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe and her mother. 29. As a direot and proximate result of Epstein's intentional or reckless conduct, Jane Doe will continue to suffer severe mental anguish and pain. WI-IEREFORE, :rine Doe, by and through her Mother, and Jane Doe's Mother, individually, demand 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. ' Page 6 of 9 1670/316 This tax was received by CFI FAXmaker fax server. For more information, visit http.//www gfi corn EFTA00234390
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Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 68 of 100 rorn o, .wn Page 21/51 Date 5/29/2008 12 09. vt COUNT IV Civil Remedy for Violation of Florida Statute Section 772.103 against Defendants Epstein, Robson nod Kellen 30. Plaintiffs Jane Doe by and through her Mother, us parent and natural guardian, repeat and reallege paragraphs I through 16 above. 31. 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). 32. Defendants engaged in this pattern of criminal activity by engaging in of least two of the following incidents of criminal activity with the same or similar intents, results, accomplices, victims, and methods of commission within a S year period: a. Procuring for prostitution, or causing to be prostituted, any person who is under the age of IS 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)(1), or aiding, abetting or participating in such acts in violation of Florida Statute section 796.07(2)(h); e. Knowingly recruiting, enticing, harboring, transporting, providing, or obtaining by' tiny 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 796.04.5; or d. Forcing, compelling, or coercing another to become o prostitute in violation of Florida Statute section 796.04. 33. Under Defendants' plan, scheme and enterprise, Defendant Epstein paid Defendant Robson to repeated y find and bring him underage girls, who were delivered to Epstein by Page 7 of 9 16661316 This tax was received by GFI FAXmaker tax server For more information. visit, hap //v..ww gfi.com EFTA00234391
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Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 69 of 100 From u ran Page 22151 Date' 5/29/2008 12:09 M 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. 34. PlaintiffJant Doe was the victim of Defendants' plan, scheme and enterprise. Defendant Robson took Jane Doc to Epstein's home under the pretense that Jane Doc would be paid to give Epstein a massage. Defendant Kellett delivered Jane Doe to a room with a message table and told WI 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 o towel. He removed his towel, and laid down on his stomach on the message table. Epstein again told Jane Doc remove her clothes. In shock, fear and trepidation, Jane One complied, removing her clottes except for her panties and bra. Shortly after stoning to rub Epstein's back, Epstein told Jane Doe to sit on his hack. Jane Doe, out of fear and trepidation, complied. After a period of time Epstein got up from the table and went behind the door. Inc several minutes Jane Doc heard loud noises and moans and believes that Epstein was masturbating. Thereafter Epstein, naked, returned to the message table and laid face tip on the table. Epstein than told Jane Doe to continue with the message and told her to sit on top of him. Out of fear and trepidation she complied As Jane 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. Ai tits same time, with his other hand, Epstein was masturbating. Upon reaching orgasm Epstein gm up from the message table and told Jane Doe to write down her name and phone number and :han left the room 35. 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 Doc Page 8 of 9 16901316 This fax was received by GFI FAXmakor fax server For more information, visa hap/Nyww gfi corn EFTA00234392
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Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 70 of 100 From II ,wn Page 23/51 Date 5/29/2008 12 09 : $300. Ms. Robson was paid $200 by Epstein for bringing Jane to him. Ms. Robson brought Jane Doe home. WHEREFORE, Plaintiff Jane Doe, by arid through her Mother, as parent and natural guardian, demands judgment against Defendants Jeffrey Epstein, Haley Robson, and Sarah Kellen for compensatory damages, treble damages under Florida Statute section 772.104, costs arid 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. JURY TRIAL DEMAND Plaintiffs demand a jury trial in this action. Dated: March 6 2008 Respectfully submitted, RICCI—LE 2925 PGA Palm Bea Phone: 56 Fax: 5 Page 9 of 9 LEOPOLD 705608 170 ot 315 This fax was received by GFI FAXmakei fax server. For more information, visit http //www gli.com EFTA00234393
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Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07:21'2008 Page 71 of 100 171 of 316 EFTA00234394
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Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 72 of 100 From awn Page 2451 Date 5/29/2008 1209. [tQl Civil Cover Sheet Form 1.997 Civil Cover Sheet The civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by low. This form is requ:red for the use of the Clerk of the Court for the purpose of reporting judicial workload data pursuant 1C1 Florida Statute 25.075. 50 2008 CA U U 65 9 6 XXXX MB I. CASE STYLE CIRCUIT COURT JANE DOE, by and through JANE DOE'S MOTHER As parent and natural guardian, V. JEFFREY EPSTEIN, HALEY ROBSON end SARAH KELLEN, 2. TYPE' OF CASE: Torts:l Other Civil: Professional Malpractice Products Liability Auto Negligence V Other Negligence -Ir.. C.> 2( Contracts Condominium Real Property/Mortgage Foreclosure Eminent Domain Other 3 IS JURY TRIAL DEMANDED IN COMPLAINT? YES NO FT; 172 of 316 This fax was received by GFI FAXmaker fax server. For more information, visit httpavivw gfi.com EFTA00234395
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Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 73 of 100 From u. iwn Page 25/51 Date 5/29/200812:09:. M DATED THIS day of March, 2008. PICCI-LEOPOLD, P.A 2925 PGA Blvd. Suite 200 Palm Beac Phone: (5 Fax: ( 0 OR!: J POLD 'lorida Bar No. 05 08 173 of 315 This fax was received by GPI FAXmaker fax server. For more information, visit http.//www.gfi.com EFTA00234396
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Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07121'2008 Page 74 of 100 174 o1316 EFTA00234397
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Case 9:08-cv-80804-KAM Document Eresse0acpapoc,,;(et 07/21/2008 Page 75 of 100 From u, wn IN THE CIRCUIT COURT OF THE • ISTII JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO: 50 2998 CA 006596 XXXX MB AB JANE DOE, by and through JANE DOE'S MOTHER, as parent and natural guardian, Plaintiff, VS. JEFFREY EPSTEIN, HALEY ROBSON and SARAH KELLEN, Defendants. SUMMONS PERSONAL SERVICE ON A NATURAL PERSON •1.O DEFENDANT; JEFFREY EPSTEIN 457 Madison Avenue 4th Floor New York, New York IMPORTANT • . • •••••-•.' A lawsuit has been filed against you. You have 20 calendar clays after this summons is served on you to file n written response to the attached complaint/petition with the Clerk of this Court. A phone call %ill not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the Court to hear your side of the case. If you dc not file yotr response on time, you may lose the case, and your wages, money, and properly may thereafter be taken without further warning from the Court. There are other legal requirements. You may want to cull an attorney right away. If you do not know an attorney, you muy call an attorney referral service or a legal aid office (listed in the phone book). If you choose to file a written response yourself, at the same time you file your written response to the Court you must also mail or take a copy of your written response to the "Plaintiff/ Plaintiffs Attorney" named below. 17501716 This fax was received by GPI FAXmakei fax server. For more information, visit. http:JW/ww.gli corn EFTA00234398
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Case 9:08-cv-80804-KAM Document 1-2 Erii9re9Thglgipocicet 07/21/2008 Page 76 of 100 from w wn Page 27/51 a e "In accordance with the Americans with Disabilities Act, persons in need of a special accommodation to participate in this proceeding shall, within a reasonable time prior to any proceeding, contact the Administrative Office of the Court, 205 North Dixie Highway, Room 5 2500, West Palm Bench, FL 33401, telephone (561)355.2431, 1-800-955-R771 (IDD), or 1-800- 955-8770(V), via Florida Relay Service". THEODORE J. LEOPOLD, ESQUIRE RICO-LEOPOLD, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410 (561) 684-6500 THE STATE OF FLORIDA TO EACH SHERIFF OF THE STATE! You arc commanded yt serve is Sum ons and a copy of the complaint/petition in this lawsuit on the above named defendant(s). DATED ON I MPORTANT By: Deputy Clerk SANDRA CU CIRCUIT COURT Usied ha side demanded° legalmente. Tiene 20 Dias, contados a pair del recibo du este notification, pan' contester la demanda adjunta, pr escrito, y presentarla ante esie tribunal. Una Ilamada telefonica no lo protegera. Si usted desea que el tribunal considere su defense, debt presentar su respuesui por escrito, incluyendo el numbero del caso y los nombres de las panes interesadas. Si usted no contesta la demanda a tiempo, pudiese perder cl ens° y podria ser despojado de sus ingresos y propiedades, o privado de sus derechos, sin previo oviso del u•ibunal. Existen otros requisitos legates. Si to desea, puede usted consulter a un abused° inmediatamente. Si DO conoce a un abogado, pucdc Ilamar a uno de las oficinas de asistencin legal que apace= en la gull telefonica. Page 2 of 3 175 of 315 This tax was received by GFI FAXmaket fax serve( For more information, visit http.//www gli corn EFTA00234399
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Case 9:08-ov-80804-KA/
From.
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Page 77 of 100
Si ,desen responder a la demand!' por su cutout, al mismo ticmpo en que presents su
respuesta ante el tribunal, debera usted envier por correo o entregar una copia dc su respuesta a la
persona denominada airejo tomo "Plaintiff/Plaintiffs Attorney" (Demandants o Abogado del
Demandanie).
"De acuerdo con el Acto b Decreto de los Americansos con Impedimentos,
Inhabilitados, personas en necesidad del servicio special pare participar en estc procedimiento
deberfui, dentio dc un 'lemon razonable, antes de cualquier procedinnento, ponerse en comacto con
Is officina Administratativa du la Cone, 205 North Dixie Highway, oficina 5.2500, West Palm
Beach, FL 33401, Téléfrino (561) 355-2431, 1.800-955-8771 (TOD) 4 1-800-955-8770 (V), Via
Flonda Relay Service".
IMPORTANT
Des noursuites judiciures ona ets entreprises contre vous.
Vous eve?, 20 jotes
consecutifs o partir de la date de ('assignation de cane citation pour deposer tine reponse sents a In
plaint< citioinie eupres de ce tribunal. Un simple coup de telephone est insuflisunt pour vous
protegcr. Vous ems oblige de deposer votre reponse ecrite, avec mention du numero de dossier ci-
dessus et du nom 'des panics nominees ici, si vous souhaitcz clue le tribunal entendc votis cause. Si
vous ne dcposez pas votre reponse ecrite Bans Ic rclai requis, vous risquez de perdre la cause ainsi
que volts salaire, votre argent, et vos biens peuvent etre saisis par In suite, sans aucun preavis
ulicricur du tribunal. II y a d'autres obligations juridiques et vous pouvez requerir les services
immediats d'un avoc.at. Si vous ne connaissez pas d'avocat, vous pourriez telephoner a un service de
reference d'avocats ou a on bureau d'assistance juridique (figurant a I'annuaire de telephones).
Si vous choisissez de deposer vous-mane tine reponse ecrite, it vous faudru
cgalement, en meme temps clue cette fonnalite, faire parvenir ou expedier one copio de votre
reponse ecrite au "Plainciff/Plainti ffs Attorney" (Plaignant ou a son avocet) nonune ci-dessous.
En accordance avec la Loi des "Americans With Disabilities". Les personnes en
besoin crone accommodation speciale pour paniciper a ces procedures dowerit, dens tin temps
raisonable, avant à'enrreprendre &Kura :Wire démarche, contacter l'office administrative tic la Court
Otte su 5.2500, 205 North Dixie Highway, West Palm Beach, FL 33401 le telephone (561)355-
2431 ou I -800-955-877 I (Tco) ou 1-800-955-8770 (V) Via Florida Relay Service.
IMPORTANT
D4pré aka ki let avek Americans With Disabilities Act, tout moan ki ginyin you
bézwen éspésiyal pou akomodasiyon pou yo patisipé nan pwogram sera dwt, nan ylin rézonab avan
ninpot aranjman kapab fet, yo dwe kontakte Administrative Office of the Court, Id nan niméro 205
Nonh Dixie Highway, Chain niméro 5.2500 West Palm Beach, Florida 33401 telefon nan se
(561)355-2431 oubyen 1.800-955-8771 (T.D.D. oubycn 1-800-955-8770 (V) an pasan pa Florida
Relay Service.
Page 3 of 3
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Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 78 of 100 178 of 316 EFTA00234401
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Case 9:08-cv-80804-Kttlm ,DozymecItag1e-3,/.51 Ergreekeffj4aDooket 07/21/2008 Page 79 of 100 IN TFIE 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, by and through JANE DOE'S MOTHER, as parent and natural guardian, Plaintiff, vs. JEFFREY EPSTEIN, HALEY ROBSON and SARAH KELLEN, Defendants. SUMMON; PERSONAL SERVICE ON A NATURAL PERSON TO DEFENDANT: HALEY ROBSON 12247 72N0 COURT NORTH ROYAL PALM BEACH, FL IMPORTANT A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the Clerk of this Court, A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the Court to hear your side of the case. II you do not file your response on time, you may lose the ease, and your wages, money, and property may thereafter be taken without further warning from the Cowl. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an anompy referral service or a legal aid office (listed in the phone book). If you choose to file a written response yourself, at the same time you file your written response to the Chun you must also mail or take a copy of your wrinen response to the "Plaintiff/ Plaintiffs Attorney" named below. 170 of 316 This fax was received by GFI FAXmaker fax server For more information, visit he') &Amy gli.corn EFTA00234402
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Case 9:08-cv-80804-KM1r, ,D096Ifneritaii2soist EntOigkilltaai2D0CITtet 07/21/2008 Page 80 100 "In accordance with the Americans with Disabilities Act, persons in need of a special accommodation to participate in this proceeding shall, within a reasonable time prior to any proceeding, contact the Administrative Office of the Court, 205 North Dixie Highway, Room 5.2500, West PAM Bach, FL 33401, telephone (561)355.2431, 1-800.9554771 (TDD), or 1-800- 955-8770 (V), via Florida Relay Service". THEODORE J. LEOPOLD, ESQUIRE RJCCI-LEOPOLD, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410 (561)684-6500 THE STATE OF FLORIDA TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons and a copy of the complaint/petition in this lawsuit onik above named defendant(s). MR 1 8 au DATED ON , 2008. ° is I M PORTANTE LIg.led ha sido demandado legalmente. Tiene 20 Dias, contados a pertir del recibo de esta notificacion, ,pam contester le demanda adjunta, por escrito, y presentarla ante este tribunal. Una Hamada telefonica no lo protegera. Si usted desea que el tribunal considere su defense, debe presenter su respuesm par escrito, incluyendo et numbero del caso y los nombres de las panes interesadas. Si usted no contesta la demanda a tiempo, pudiese perder el caso y podria set clespojado de sus ingresos y propiedades, o privado de sus derechos, sin previo aviso del tribunal. Existen cams requisitos legates. Si lo desea, puede usted consultor a un abogado inmediatarnente. Si no conoce a un abogado, puede 'lamer a uno de las oficinas de asistencia legal que aparecen en la pia telefonica Si desea responder a la demanda por su cuenta, al mismo tiempo en que presenta su respuesta ante el tribunal, debera usted envier por correo o entregar uno copia de su respuesta a la Page 2 or 3 -his tax was received by GP FAXmalter fax server. For more information, visit httpitwww.gfi corn 18601316 EFTA00234403