EFTA00175264

Case 9:09-cv-80469-KAM Document 1 Entered on FLSD Docket 03/25/2009



FILIPAGE 1P05 D.
ELECTRONIC


UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Mar. 24, 2009



STEVEN M. LARIMORE
CLERK U.S. DIST. CT.
S.D. OF FLA. - MIAMI


# 09-80469-Civ-RYSKAMP/VITUNAC



## COMPLAINT

1. Plaintiff, JANE DOE II, hereby sues JEFFREY EPSTEIN and , and states:

## JURISDICTION AND VENUE

2. This is an action for damages in excess of $75,000, exclusive of interests, costs and attorney's fees.

3. Venue is proper in this Court as all acts occurred in Palm Beach County and all parties reside and/or 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. She files this suit under a pseudonym to protect her privacy because the acts alleged occurred while she was a minor.

1 of 5

EFTA00175265

09-80469 Civ RYSKAMP/VITUNAC

Entered on FLSD Docket 03/25/2009

Page 3 of 5

11. From about June, 2003 until on or about February, 2005, Defendants EPSTEIN and persuaded, induced, or enticed the Plaintiff to come to Defendant EPSTEIN's home and provide Defendant EPSTEIN with "massages" which escalated into sexual encounters between Defendant EPSTEIN and the Plaintiff designed to fulfill his unnatural sexual desires for young women or even younger girls who were minors. These acts included Defendant EPSTEIN's request that he wanted the encounter to be like a "porn video." Defendant EPSTEIN would script lines for the Plaintiff to say, including calling out his name and requesting that he perform a certain sexual act "harder," while he touched the Plaintiff's or with alternately, he would in the presence of the Plaintiff after demanding her to disrobe and walk in front of him in provocative sexual poses. Defendant EPSTEIN would pay the Plaintiff a fee of $200 on each occasion after he while in the presence of the Plaintiff.

12. Defendant EPSTEIN touched Plaintiff's , or Plaintiff's on multiple occasions, during the time that Plaintiff was a minor, causing personal injury to her.

13. In violation of 18 U.S.C. §2422(b), Defendants EPSTEIN and knowingly persuaded, induced, or enticed the Plaintiff to engage in acts of prostitution, when the Plaintiff was under the age of 18, approximately on or about the following dates that Plaintiff can document based on payments received: 6/16/03, 7/2/03, 4/9/04, 6/7/04, 7/30/04, 8/30/04, 10/9/04, 10/12/04, 10/30/04 and 11/9/04. In addition, Plaintiff believes that there were as many as 10 to 20 other occasions during this time frame that Defendant EPSTEIN solicited her and procured her to perform prostitution services, all during the time that she was a minor.

3

3 of 5