Doe Jane II v Epstein

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JANE DOE II Plaintiff, ?52:96am vs. EPSTEIN, an" A RAH KELLEN, Defendants. 1 \l 80$ 1ch 0 Til" ?301 COMPLAINT Plaintiff, JANE DOE II, hereby sues JEFFREY EPSTEIN and SARAH KELLEN, and states: JURISDICTION AND VENUE This is an action for damages in excess of $15,000, exclusive of interests and costs. Venue is proper in this Court as all acts occurred in Palm Beach County and all parties reside and/0r do business herein. PARTIES 4. Ms. DOE II is a natural person residing in Palm Beach County, Florida. During the events giving rise to this claim, she was a minor but has now reached majority. 5. Defendant EPSTEIN is a natural person who resides and/or does bu?iness in Palm Beach County, Florida, and who committed the acts alleged within the jurisdiction of Palm Beach County, Florida. Defendant KELLEN is believed to reside in the State of New York, but committed the acts alleged within the jurisdiction of Palm Beach County, Florida. 6. Defendant EPSTEIN is believed to now be incarcerated in the Palm Beach County Jail for crimes committed that are related and/or similar to the claims in this case. 7. Defendant EPSTEIN was, at all times relevant to this action, a part time resident of Palm Beach, Florida. All acts complained of herein occurred at his estate residence in Palm Beach, Florida. 8. Defendant EPSTEIN has a history of enticing young women, under the age of consent, to private sessions that begin with massages and evolve, through his acts of solicitation by use of his lavish wealth, into sexual encounters, wherein Defendant EPSTEIN ful?lls sexual fantasies by using said young women. 9. Defendant EPSTEIN, in agreement with two (2) persons he employed for this purpose, HALEY ROBSON and Defendant KELLEN, conspired with these other two Defendants to solicit young women of the type Defendant EPSTEIN preferred, blonde, attractive in appearance, and younger than the age of legal consent, to provide sexual grati?cation for him. 10. Defendants EPSTEIN and KELLEN entered into a'criminal conspiracy to solicit young women for acts of prostitution, including the Plaintiff. 11. From about June or July, 2008 until February, 2005, Defendants EPSTEIN and KELLEN solicited the Plaintiff to come to Defendant home and provide ?massages? for him. Defendant EPSTEIN corrupted young girls, such as Plaintiff, into engaging in sexual acts to designed to ful?ll his unnatural sexual desires for young women or even younger girls who were under the age of consent. These acts included his requests that he wanted the encounter to be like a ?porn video.? Defendant EPSTEIN would script lines for Plaintiff to say, including calling out his name and requesting that he perform a certain sexual act ?harder,?while he touched the Plaintiffs vagina with a vibrator or with his ?ngers; alternately, he would masturbate in the presence of the Plaintiff after demanding her to disrobe and walk in front of him in provocative sexual poses. - 12. Defendant EPSTEIN touched Plaintiff vagina, or penetrated Plaintiffs vagina, using his ?ngers and/or a vibrator on multiple occasions, during the time that Plaintiff was a minor. COUNT I: SEXUAL BATTERY 13. Plaintiff reasserts and alleges, as if fully set forth in Count I, the allegations of 111] 1-12, ?1_1P_f? l4. Defendant EPSTEIN unlawfully touched the Plaintiff without Plaintiff? consent, and before she reached the age of consent, with the intention of bringing about a harmful and offensive contact. 15. As a direct and proximate result of said unlawful touching, plaintiff suffered physical injuries, severe emotional distress, mental anguish and distress, humiliation and embarrassment and continues to suffer so today. WHEREFORE, Plaintiff respectfully requests that this Court: A. Award Plaintiff compensatory damages for humiliation, loss of reputation, mental anguish and pain and suffering; and B. Award Plaintiff her costs of this action. COUNT II: CIVIL CONSPIRACY 16. Plaintiff reasserts and alleges, as if fully set forth in Count I, the allegations of 1111 1-12, supra. 17. Defendants entered into a criminal conspiracy to solicit young women for the sexual grati?cation of Defendant EPSTEIN, including, but not limited to, soliciting the Plaintiff and others like her for him to exploit and take advantage of their youth, inexperience and ?nancial need. 18. As a direct and proximate result of said unlawful touching, plaintiff suffered physical injuries, severe emotional distress, mental anguish and distress, humiliation and embarrassment and continues to suffer so today. WHEREFORE, Plaintiff reSpectfully requests that this Court: A. Award Plaintiff compensatory damages for humiliation, loss of reputation, mental anguish and pain and suffering; and B. Award Plaintiff her costs of this action. PLAINTIFF DEMANDS A JURY TRIAL ON ALL ISSUES SO TRIABLE. Dated: ?3.100? Respectfully submitted, 1513536 M. Florida Bar No.. 437883 GARCIA, ELKINS BOEHRINGER, PA. 224 Datura St., Ste. 900 West Palm Beach, FL 33401 Telephone: (561)832-8033 Telecopier: (561) 832-7137 E-mail: isidrogarcia@bellsouth.net COUNSEL FOR PLAINTIFF Page: 1 I PALM BEACH CTY CIR CT JISPROD Receipt Nomber: CAMB227404 Date: Cashier: DLAFFERTY Payor: ISIDRO MANUEL GARCIA Addr: 224 DATURA ST #900 THE HARVEY BUILDING WEST PALM BEACH, FL 33401 Violation/Docket Description Amount Case: 2008CA020614 - JANE DOE II JEFFREY EPSTEIN Party: JANE DOE II CAFF 236.00 CAFF 20.00 CHECK RECEIVED GENERAL ACCT -256.00 Total Fees: 256.00 Total Payment: 256.00