EFTA Document EFTA01308056

Palm [teacher Jeffrey Epstein faces new lawsuit alleging sexual battery PalmBeachDaily119 rp • site win) I', 'at'. 1007 Cent ie I LIM ".^ . 2" " " * Weennwn wimp l Nnwa I 90CE Ty I ~Way Ana I FASWOM. OWTUAKIL5 I Owen I artalvtra I maim shOTS a.:141,11). Featured Vehicles Owns no t • ett homes six t Tel • yaps, Palm Beacher Jeffrey Epstein faces new lawsuit alleging sexual battery f,LfR own rif Sunday. 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CopmgM 2007 Palm Beech Daly News All nth, ~Heed The Palm l4 .eh D.xy NWYd“ Privacy Paris I Alxvnnu% VIC I Wale le U5 COK lutp://www.palmbeachdailynews.cominewskontentinews/webBrief Epstein07 I I .html li2008 SDNY_GM_00328628 EFTA 00201380 EFTA01308056 - Not an Official Document Report Selection Criteria Case ID: Docket Start Date: Docket Ending Date: Case Description Case ID: Case Caption: Division: Filing Date: Court: Location: Jury: Type: Status: 502008CA020614XXXXMB 502008CA020614XXXXMB JANE DOE II V JEFFREY EPSTEIN AF - LEWIS Thursday , July 10th. 2008 CA - CIRCUIT CIVIL MB - MAIN BRANCH Y-Jury OC - OTHER CIRCUIT PE - PENDING Related Cases No related cases were found. Case Event Schedule No case events were found. Case Parties Page I of 3 2 1 ATTORNEY 0437883 GARCIA , ESQ, Aliases: I ISIDRO MANUEL DEFENDANT DEFENDANT @1430497 EPSTEIN, JEFFREY none Aliases: none none http://courtcon.co.palm-beach.fl.us/pls/jiwpick_public_my_doet.cp_dktrpt_docket_report?... 7/I I/2008 SDNY_GM_0032862.9 EFTA_00201381 EFTA01308057 - Not an Official Document Page 2 of 3 5 JUDGE AF LEWIS, JUDGE Aliases: none DIANA Dkcket Entries Docket Number Docket Type Book and Page No. j Attached To: 00000 - ADDITIONAL COMMENTS Filing Date: 10-JUL-2008 Filing Party: Disposition Amount: Docket Text: OWES $65.00 800FF - GAFF Filing Date: 10-JUL-2008 Filing Party: JANE DOE II, Disposition Amount: IIHHHIVH:11»:: :inou:H PE - PENDING Filing Date: 10-JUL-2008 Filing Party: Disposition Amount: Docket Text: none. RCPT - RECEIPT FOR PAYMENT [Filing Date: 10-JUL-2008 Filing Party: JANE DOE II, Amount: (Docket Docket Text: A Payment of -$256.00 was made on receipt CAMB227404. L1 CMP - COMPLAINT Filing Date: 10-JUL-2008 Filing Party: JANE DOE II, Disposition Amount: Docket Text: none. 2 CCS - CIVIL COVER SHEET http//councon.co.palm-bcachil.us/p1s/jiwp/ck_public_qry_doctcp_dktrpt_docketreport?... 7/11/2008 SDNY_GM_00328630 EFTA 00201382 EFTA01308058 - Not an Official Document Filing Date: Filing Party: Disposition Amount: Docket Text: none 3 SMIS - SUMMONS ISSUED Filing Date: 10-JUL-2008 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text ISM-08-119679 4 SMIS - SUMMONS ISSUED Filing Date: 10-JUL-2008 Filing Party: Disposition Amount: Docket Text: RCPT - RECEIPT FOR PAYMENT Filing Date: 11-JUL-2008 Filing Party: JANE DOE II. Disposition Amount Docket Text: A Payment of -$65.00 was made on receipt CAMB227523. 110-JUL-2008 NE DOE II, Page 3 of 3 http://courtcon.co.palin-beach.fLus/pls/jiwp/ck_public_qry_doct.cp_dkirpt_docket_report?... 7/11/2008 SONYGM_00328631 EF1'A_0020B83 EFTA01308059 Header - blue MESIISINISMINEM EXECUTIVE Off ICES 101 North flat Ave VWst Palm Peach Fl 33401 (561I 3554906 Page 1 of 1 hlip://courtcon.co.palm-beach.fl.us/p1s/jiwp/ckpublic_qry_main.cp_headceititle_phrasc=... 7/11/2008 SONY_GM_00328632 EFTA_00201384 EFTA01308060 Page I of I ► Search Nome ► New Search ► ROCCO Selection ► toesDe? clinten 0 Related i- eses ► Event Schorkile ► Cese Parties ► DOCliel Nile: MCorp, 1956 Minted Compiner Sysn-nn bc. ACS and ho ACS frogo are icorsleied Ingenterts CounComeo in Varernert WPCS ina mown oat% sixiets aro is sttiect to a conitkat a9leent The 1,mM:wed pose 051.011. MC. teprodulgal. diStatUitil. dVay. Or tiViostile el the ,nasal a me rionnabon catanof wet s pectiblat All (.013 rescrred User AccepoiAorees II) Ur✓Lnrr inii lot onaii ute http://courtcon.co.palm-beachAus/pls/jiwp/cic_public_qry_doacp_dktrpt_toc?backto=P... 7/1 1, 2008 SONY_GM_00328633 EF1'A_00201385 EFTA01308061 • •••••et UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: JANE DOE NO. 1, by and through JANE DOE's FATHER as parent and natural guardian, and JANE DOE's FATHER, and JANE DOE's STEPMOTHER, individually, Plaintiffs, vs. JEFFREY EPSTEIN, Defendant. OS-8 0 69 CIV-MARRA MAWSTRAIE JOHNSON FILED by INTAKE JAN 2 4 2%8 CIARTACE Winnow 5.8.1v€ COMPLAINT Plaintiff, Jane Doe No. I ("Jane" or "Jane Doe"), by and through Jane Doe's Father as parent and natural guardian, and Jane Doe's Father and Jane Doe's Stepmother, individually, bring this Complaint against Jeffrey Epstein, as follows: Parties, Jurisdiction and Venue I. Jane Doe is a citizen and resident of the State of Florida. Shc is a minor under the age of 18 years. 2. Jane Doe's Father brings this action individually and as parent and natural guardian of Jane Doe. Jane Doe's Father is a citizen and resident of the State of Florida. 3. Jane Doe's Stepmother brings this action individually. Jane Doe's Stepmother is a citizen and resident of the State of Florida. 4. 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 HERMAN & MERMELSTEIN, P. A. www.herman law torn SDNY_GM_00328634 EFTA_00201386 EFTA01308062 f minor. 5. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 6. This is an action for damages in excess of $50 million. 7. 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. 8. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial part of the events or omissions giving rise to the claim occurred in this District. Factual Aliceations 9. 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. 10. 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 2005, Jane Doe, then 14 years old, fell into Epstein's trap and became one of his victims. 11. Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted girls in Florida, New Yak and on his private island, known as Little St. James, in St. Thomas. 12. An integral player in Epstein's Florida scheme was IMM, a Palm Beach HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com SDNY_GM_00328635 EFTA_00201387 EFTA01308063 She recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's plan, w ould 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 directed to bring one or more underage girls to the residence. upon information and belief, generally sought out economically disadvantaged underage girls fromIMMand surrounding areas who would be enticed by the money being offered - generally 5200 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. 13. Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at Epstein's mansion, EMMinould introduce each victim ton.. 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. -mould 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 and touching the girl's vagina with a vibrator. 14. Consistent with the foregoing plan and scheme, recruited Jane Doe to give Epstein a massage for monetary compensation. brought Jane to Epstein's mansion in Palm Beach. Jane was introduced to who led her up the flight of stairs to the room with the massage table. She was alone in the room when Epstein arrived wearing only a towel. He HERMAN & MERMELSTEIN. P. A. mwe.hermanlaw.com SDNY_GM_00328636 EFTA 00201388 EFTA01308064 removed his towel, and laid down naked on the massage table. He demanded that Jane remove her clothes. In shock, fear and trepidation, Jane complied, removing her clothes except for her underwear. Epstein then sexually assaulted Jane. 15. After Epstein had completed the assault, he left the room. Jane was then able to get dressed, leave the room and go back down the stairs. She then me' again who brought Jane home. Jane was paid $300 by Epstein...Was paid $200 by Epstein for bringing Janc to him. 16. As a result of this encounter with Epstein, the 14-year old Jane experienced confusion, shame, humiliation, embarrassment and the assault sent her life into a downward spiral. COUNT I Sexual Assault 17. Plaintiff Jane Doc by and through her Father, as parent and natural guardian, repeats and rcalleges paragraphs I through 16 above. 18. Epstein tortiously assaulted Jane Doe 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. 20. As a direct and proximate result of Epstein's assault on Jane, shc has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. WHEREFORE, PlaintiffJane Doe, by and through her Father, as parent and natural guardian, 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. HERMAN & MERMELSTEIN. P. A. wkwi.nermanlaw.com SDNY_GM_00328637 EFTA 00201389 EFTA01308065 COUNT II Intentional Infliction of Emotional Distress 21. Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane Doe's Father and Jane Doe's Stepmother, individually, repeat and rcallege paragraphs 1 through 16 above. 22. Epstein's conduct was intentional or reckless. 23. Epstcin's conduct was outrageous, going beyond all bounds of decency. 24. Epstein's conduct caused severe emotional distress not only to Jane Doc, but also to her parents, Jane Doe's Father and Jane Doe's Stepmother. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe's parents. 25. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe, Jane Does' Father and Jane Doe's Stepmother have suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane Doe's Father and Jane Doe's Stepmother demand judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this Court deems just and proper. COUNT III Loss of Parental Consortium 26. Plaintiff Jane Doe's Father repeats and realleges paragraphs I through 16 above. 27. Epstein's tortious conduct is the direct and proximate cause of damages to Jane Doe's Father, consisting of parental loss of comfort, companionship and society and healthcare costs MERMAN & MERMELSTEIN. P. A. vmfuthermanlaw tom SDNY_GM_00328638 EFTA 00201390 EFTA01308066 associated with the treatment of Jane. 28. Jane Doe's Father experienced and will continue to experience great mental anguish, pain and suffering from the time that Defendant's tortious conduct occurred. WHEREFORE, Plaintiff Jane Doe's Father demands judgment for loss of consortium damages, costs and such other and further relief as this Court deems proper. JURY TRIAL DEMAND Plaintiffs demand a jury trial in this action. Datcd: January 2008 Respectfully submitted, HERMAN & MERMELSTEIN, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 By: HERMAN & MERMELSTEIN, P. A. Jeff M. Herman ermana.hermkuilaw.com Florida Bar No. 521647 Stuart S. Mennelstein smermelstein®hetmanlaw,com Florida Bar No. 947245 Adam D. Horowitz Florida Bar No. 376980 phorowitztabennantaw.corn www.hermanlaw.com SDNY_GM00328639 EFTA_00201391 EFTA01308067 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: JANE DOE NO. 2, vs. JEFFREY EPSTEIN, Defendant. COMPLAINT Plaintiff, Jane Doe No. 2 (- Jane" or "Jane Doe"). brings this Complaint against Jeffrey Epstein, as follows: Parlies..lurisdiction and Venue I. Jane Doe No. 2 is a citizen and resident of the Commonwealth of Virginia. and is sui juris. 2. This Complaint is brought undcr 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 $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuant to 28 U.S.C. § I332(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. §139I(a) as a substantial HERMAN & MERMELSTEIN. P. A. moo hermanlaw corn SDNY_GM_00328640 EFTA_00201392 EFTA01308068 • part of the events or omissions giving rise to the claim occurred in this District. Factual A Ikea tions 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. lie 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 County who would be enticed by the money being offered - generally $200 to $300 per HERMAN b, MERMELSTEIN, P. A. vAwthennanlawoom SONY_GM_00328641 EFTA_0020 1393 EFTA01308069 "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 Epstcin's plan. I I. 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. A Iter a short period °Dime. 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. 14. As a result of this encounter with Epstein, Jane experienced confusion, shame. HERMAN & MERMELSTEIN. P. A. VAAwhermantaw.com SONY_GM_00328642 EFTA_00201394 EFTA01308070 humiliation and embarrassment, and has suffered severe psychological and emotional injuries. COUNT I Sexual Assault 15. PlaintifTJanc Doe repeats and real leges paragraphs I 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 permammt 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. PlaintiffJane Doe repeats and realleges paragraphs I 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 reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe. HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com SDNY_GM_00328643 EFTA_00201395 EFTA01308071 24. As a direct and proximate result of Epstein's intentional or reckless conduct. Jane Doc, 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 reliefas this Court deems just and proper. JURY TRIAL DEMAND Plaintiffs demand a jury trial in this action. Dated: February . 2008 Respectfully submitted. HERMAN & MERMELSEEIN, P,A. Attorneys for Plainiek 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 By: Jeffrey M. Herman flu:mania herntanlau Loin Florida Bar No. 521647 Stuart S. Mermelstein sincnneliacinia hermanlan .CO111 Florida Bar No. 947245 Adam D. Horowitz Florida Bar No. 376980 altorowitzialacnnanlaw coin HERMAN & MERMELSTEIN. P. A. YAW! hermanlaw corn SONY_GM_00328644 EFTA_00201396 EFTA01308072 e) Aa.e•eirlj FILED by VT D.C. ELIWIRCNC March 5, 2008 loll JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA STIVUT M. altiNent CLOUT 04. 013T. CT. Y.O. Of ILA. • ITIAMI CASE NO.: 08-CV-80232-Marra-Johnson COMPLAINT Plaintiff, Jane Doe No.3 ("Jane" or "Jane Doc"), brings this Complaint against Jeffrey Epstein, as follows: Parties, Jurisdiction and Venue I. Jane Doc is a citizen and resident of the State of Florida, 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 her when she was a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of Ncw 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 past of the events or omissions giving rise to the claim occurred in this District. HERMAN & MERMELSTEIN. P. A. wvAv.hermanlawcom SDNY_GM_00328645 EFTA 00201397 EFTA01308073 Factual Attentions 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. lie 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 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. An integral player in Epstein's Florida scheme was a Palm Beach . Shc recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's plan, 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 directed o bring one or more underage girls to the residence, upon information and belief, generally sought out economically disadvantaged underage girls from_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 HERMAN & MERMELSTEIN, P. A. wmv.hermaniaw.corn SDNY_GM_00328646 EFTA_00201398 EFTA01308074 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 victim would be brought to the kitchen. Shc would then be led up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. Once the girl was alone in this room, Epstein would enter wearing only a towel to cover his private area. He then would lay down on the massage table and perform one or more lewd, lascivious and sexual acts, including masturbation and touching the girl sexually. 12. Consistent with the foregoing plan and scheme, recruited Jane Doe to give Epstein a massage for monetary compensation. brought Jane to Epstein's mansion in Palm Beach. Jane was led up the flight of stairs to the room with the massage table. She was alone in the morn when Epstein arrived wearing a towel to cover his private parts. He laid down on the massage table, and sexually assaulted Jane Doe during the massage. In addition, Jeffrey Epstein masturbated during the massage. 13. After Epstein had completed the assault, he left the room. Jane was then able to leave the room and go back down the stairs. She then met again who brought Jane home. Jane was paid $200 by Epstein. was also paid by Epstein for bringing Jane to him. 14. Ma result of this encounter with Epstein, the 16-year old Jane experienced trauma, shock, confusion, shame, humiliation and embarrassment. COUNT I Sexual Assault 15. Plaintiff Jane Doe repeats and rcalleges paragraphs 1 through 14 above. 16. Epstein tortiously assaulted Jane Doe sexually in or about 2004-2005. Epstein's acts were intentional, unlawful, offensive and harmful. HERMAN & MERMELSTEIN. P. A. www.hermanlaw.com SDNY_GM_00328647 EFTA 00201399 EFTA01308075 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, shc has suffand and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. WHEREFORE, Plaintiff Jane Doc, 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. Plaintiffs 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 Doc. Epstein knew or had 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 Ectstein's intentional or reckless conduct, Jane Doe has suffered and will continue to suffer severe mental anguish and pain. WHEREFORE, Plaint' ffJane Doe demands judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this Court HERMAN a MERMELSTEIN. P. A. www.hermanlaw.com SDNY_GM_00328648 EFTA_00201400 EFTA01308076 deems just and proper. JURY TRIAL DEMAND Plaintiffs demand a jury trial in this action. Dated: March I, 2008 Respectfully submitted, HERMAN & MBRMBLSTEIN, P.A. Attorneys for Plainiffs 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0 Jeffrey M. Herman bertanlaw.com Florida Bar No. 521647 Stuart S. Mcnnelstein smemtelsteinehennanlaw,com Florida Bar No. 947245 Adam D. Horowitz Florida Bar No. 376980 ahorowitzabcrmanlaw.com HERMAN & MERMELSTEIN. P A www.hermanlaaw.com SDNY_GM_00328649 EFTA_00201401 EFTA01308077