Civil complaint against Jeffrey Epstein over Palm Beach assault, 2008

EXHIBIT 18¶

ELECTRONIC FILED by VT D.C. ebruary 6, 2008 CLARENCE MADDOX CLERK U.S. DIET. CT. 5.0. OP /LA. • MIAMI¶

JANE DOE NO. 2,¶

Plaintiff,¶

vs.¶

JEFFREY EPSTEIN,¶

Defendant.¶

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA¶

CASE NO.:¶

08-CV-80119-MARRA¶

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 $50 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

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. 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 Doc, 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.

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 hersel f 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 “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 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 s 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. 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.

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

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 5, 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:¶

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.)¶

| (a) PLAINTIFFS JANE DOE NO. 2,¶

| DEFENDANTS 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, P.A., 18205 Biscayne Blvd., Suite 2218, Miami, FL 33160, (305) 931-2200¶

| ATTORNEYS (IF KNOWN)¶

(d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH 9:08CV 8019-KAM-Johnson¶

II. BASIS OF JURISDICTION III. CITCZENSHIP OF PRINCIPAL PARTIES	PLACE AN X IN ONE BOX FOR PLAINTIFF
O 1. U.S. Government
PTF DEF
Citizen of This State O 1 O I
Citizen of Another Slate X2 x 2
Citizen or Subject Of a FOONSai Country 03 O 3
AND ONE FOR DEFENDANT (PLACE AN X ONE BOX ONLY) (For Diversity Case Only)	PTF	DEF
Incorporated of Principal Place of O 3 Federal Question Business in This Stale Plaintiff (U.S. Government Not a Party)	O 4	0 4
Incorporated and Principal Place of O 2 U.S. Government X 4. Diver,” Defendant (Indicate Citizenship or Parties In Item	O 5 Business in Another State	O 5
Foreign Nation III)	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. _6_ days estimated (for both aides) 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
110 Insurance 120 Marine 130 Act 140 Negotiable Instrument 150 Recovery of Overpayment & Enforcement of Judgment 151 Medicare Act 152 Recovery of Defaulted Student Loans (Excl. Veterans) B 153 Recovery of Overpayment of Veteran’s Benefits B 160 Stockholder’s Suits 170 Other Contract 185 Contract Product Liability	PERSONAL INJURY 310 Airplane 315 Airplane Product Liability 320 Assault, Libel & Stander 330 Federal Employers’ Liability 340 Marine 345 Marine Product Liability 350 Motor Vehicle 355 Motor Vehicle Product Liability 360 Other Personal Injury	610 Agriculture 620 Other Food & Drug 625 Drug Related Seizure of Property 21 USC 881 630 Liquor Laws 640 R.R. & Truck 650 Airline Regs 660 Occupational Safety/Health 660 Other	422 Appeal 28 USC 158 423 Withdrawal 28 USC 157 A PROPERTY RIGHTS 820 Copyrights 830 Patent 840 Trademark B SOCIAL SECURITY 861 HIA (1305ff) 862 Black Lung (823) 863 DWC:D/WW (405(g)) 864 SSID Title XVI 865 RSI (405(g))	400 Status Reporting 410 Artistst 430 Banks and Banking 450 Commerce/CC Rates/etc. B 480 Deportation 470 Racketeer Influenced and Comput Organizations 810 Selective Service 850 Securities/Commodities/Exchange 875 Customer Challenge 12USC3410 891 Agricultural Acts 892 Economic Stabilization Act 893 Environmental Matters 894 Energy Allocation Act 895 Freedom of Information Act 900 Appeal of Free Determination Under Equal Access to Justice 960 Constitutionality of State Statutes 890 Other Statutory Actions” ” A or B
A REAL PROPERTY	A CIVIL RIGHTS	B PRISONER PETITIONS	A LABOR
210 Land Condensation 220 Foreclosure B 230 Rent Lease & Ejectment 240 Torts to Land 245 Tort Product Liability 290 All Other Real Property	441 Voting 442 Employment 443 Housing/Accommodations 444 Welfare 440 Other Civil Rights	510 Motions to Vacate Serrence Hubeas Corpus 530 General” 535 Death Penalty 540 Mandamus & Other” 550 Civil Rights ” A or B	710 Fair Labor Standards Act 720

VI. ORIGIN
x 1. Original	2. Removed from	3. Remanded from	4. Refilled	6. Multidistrict Litigation	7. Appeal to District Judgment	8. Magistrate Judgment	9. S.D.	10. CLERK - U.S. DIST. CIT.	11. S.D.	12. CLERK - MADDOX	13. S.D.	14. S.D.	15. S.D.	16. S.D.	17. S.D.	18. S.D.	19. S.D.	20. S.D.	21. S.D.
Proceeding	State Court	Appellate Court	2. Removed from	4. Refilled	6. Multidistrict Litigation	7. Appeal to District Judgment	8. Magistrate Judgment	9. S.D.	10. CLERK - MADDOX	11. S.D.	12. CLERK - U.S. DIST. CIT.	13. S.D.	14. S.D.	15. S.D.	16. S.D.	17. S.D.	18. S.D.	19. S.D.	20. S.D.

VII. REQUESTED	CHECK IF THIS IS A	O CLASS ACTION	DEMAND S
IN COMPLAINT	O UNDER F.R.C.P. 23
				O	Check YE
					JURY DEMAND:	O NO

VIII. RELATED CASE(S) IF ANY (See Instructions): (SEE ATTACHED) JUDGE _____ DOCKET NUMBER _____¶

DATE Feb. 5, 2016 SIGNATURE OF ATTORNEY OF RECORD [Signature]¶

UNITED STATES DISTRICT COURT S/F 1-2 REV. 9/94¶

FOR OFFICE USE ONLY: Receipt No.                      Amount: Date Paid:                      M/ifp:¶