Amended complaint by an anonymous accuser against Jeffrey Epstein, Feb. 2009

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UNITED STATES DISTRICT COURT¶

SOUTHERN DISTRICT OF FLORIDA¶

CASE NO.: 08-80993-CIV-MARRA/JOHNSON¶

JANE DOE NO. 7,¶

Plaintiff,¶

vs.¶

JEFFREY EPSTEIN,¶

Defendant.¶

AMENDED COMPLAINT¶

Plaintiff, Jane Doe No. 7 (“Jane” or “Jane Doe”), brings this Complaint against Jeffrey Epstein, as follows:¶

Parties, Jurisdiction and Venue¶

1. Jane Doe No. 7 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 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. Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because Plaintiff alleges a claim under the laws of the United States. This Court has supplemental

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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.¶

12. Epstein’s plan and scheme reflected a particular pattern and method. The underage victim would be brought to Epstein’s mansion, where she would be introduced to Epstein’s assistant. Ms would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. The girl would then find herself alone in the room with Epstein, who would be wearing only a towel. He would direct he rigl to give him a massage. Epstein would then perform one or more lewd, lascivious and sexual acts, including

13. Consistent with the foregoing plan and scheme, when Jane Doe was 16 years old, she was recruited by to give Epstein a massage for monetary compensation. Jane was brought to Epstein’s mansion in Palm Beach. Once there, Jane was introduced to who led her up the flight of stairs to the room with the massage table. In this room, Jane was directed by Epstein to give him a massage. During this massage, Epstein sexually assaulted Jane and Epstein then paid Jane money.

14. Jane returned on many occasions to the Palm Beach mansion to provide Epstein with massages for money. On those occasions, Epstein engaged in sexual contact and activity with Jane, which included, among other things, Epstein touching Jane’s placing on her This sexual abuse continued over a period of approximately 18-24 months.

15. As a result of these encounters with Epstein, Jane experienced confusion, shame, humiliation and embarrassment, and has suffered severe psychological and emotional injuries.

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in mental or sexual injury that caused or were likely to cause Jane Doe’s mental or emotional health to be significantly impaired.¶

26. 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 distress and damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing severe emotional distress to Jane Doe.

27. 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. 7 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.¶

COUNT III¶

Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422¶

28. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 15 above.

29. Epstein used a facility or means of interstate commerce to knowingly persuade, induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or sexual activity for which any person can be charged with a criminal offense.

30. On June 30, 2008, Epstein entered a plea of guilty to violations of Florida §§ 796.07 and 796.03, in the 15th Judicial Circuit in and for Palm Beach County (Case nos. 2008-cf-009381AXXXMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and scheme as alleged herein.

31. As to Plaintiff Jane Doe, Epstein could have been charged with criminal violations of Florida Statute §796.07(2) (including subsections (c), (d), (e), (f), (g), and (h) thereof), and other

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Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing.¶

/s/ Adam D. Horowitz ___ .¶

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