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Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009¶
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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA¶
09-80591¶
JANE DOE No. 101,¶
Civil Action No.¶
Plaintiff,¶
vs.¶
CIV-MARRA¶
JEFFREY EPSTEIN,¶
MAGISTRATE JUDGE¶
JOHNSON¶
FILED by AJS¶
INTAKE¶
APR 17 2009¶
Defendant.¶
COMPLAINT AND¶
DEMAND FOR JURY TRIAL¶
STEVEN M. LARIMORE¶
CLERK U.S. DIST. CT.¶
S.D. OF FLA. MIAMI¶
COMPLAINT AND DEMAND FOR JURY TRIAL¶
Plaintiff, Jane Doe No. 101 (“Jane Doe”), brings this Complaint against Defendant, Jeffrey Epstein, and states as follows:¶
PARTIES, JURISDICTION, AND VENUE¶
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At all times material to this cause of action, Plaintiff, Jane Doe, was a resident of Palm Beach County, Florida.
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This Complaint is brought under a fictitious name to protect the identity of Plaintiff, Jane Doe, because this Complaint makes sensitive allegations of sexual assault and abuse of a then minor.
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At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida.
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Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is currently incarcerated in the Palm Beach County Stockade.
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At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953.
Podhurst Orseck, P.A.¶
25 West Flagler Street, Suite 800, Miami, FL 33130, Miarui¶
- Fort Lauderdale
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This Court has jurisdiction of this action and the claims set forth herein pursuant to 18 U.S.C. § 2255.
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This Court has venue of this action pursuant to 28 U.S.C. § 1391(a), as a substantial part of the events giving rise to the claim occurred in this District.
STATEMENT OF FACTS¶
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At all relevant times, Defendant, Jeffrey Epstein, was an adult male, approximately 50 years old. Epstein is known as a billionaire financier and money manager with a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth, power, and influence. He owns a fleet of aircraft that includes a Gulfstream IV, a helicopter, and a Boeing 727. Until his incarceration, he maintained his principal place of residence in the largest home in Manhattan, a 51,000-square-foot eight-story mansion on the Upper East Side. Upon information and belief, he also owns a $6.8 million mansion in Palm Beach, Florida, a $30 million 7,500-acre ranch in New Mexico he named “Zorro,” and a 70-acre private island known as Little St. James in St. Thomas, U.S. Virgin Islands. The allegations herein concern Defendant’s conduct while at his lavish estate in Palm Beach.
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Upon information and belief, Defendant has a sexual preference for underage minor girls. He engaged in a plan, scheme, or enterprise in which he gained access in his home to countless relatively economically disadvantaged minor girls, sexually assaulted or molested these girls, and then gave them money.
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Beginning in or around 2001 through in or around September 2007, Defendant used his resources and his influence over vulnerable minor children to engage in a systematic pattern of sexually exploitative behavior.
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Defendant’s plan and scheme reflected a particular pattern and method. Defendant coerced and enticed impressionable, vulnerable, and relatively economically less
Podhurst Orseck, P.A.¶
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami¶
2¶
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Case 9:09-cv-80591-KAM Document 1 Entered on FLSD Docket 04/20/2009¶
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fortunate minors to participate in various acts of sexual misconduct that he committed upon them. Defendant’s scheme involved the use of underage girls as well as other individuals to recruit other underage girls. Upon information and belief, Defendant or an authorized agent would call and alert Defendant’s assistants shortly before or after he arrived at his Palm Beach residence. His assistants would seek out economically disadvantaged and underage girls from West Palm Beach and surrounding areas who would be enticed by the money being offered—generally $200 to $300 per “massage” session—and who Defendant and/or his assistants perceived as less likely to complain to authorities or have credibility issues if allegations of improper conduct were made. The then minor Plaintiff and other minor girls, some as young as 14 years old, were transported to Defendant’s Palm Beach county mansion by Defendant’s employees, agents, and/or assistants in order to provide Defendant with “massages.”¶
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Defendant would pay the procurer of each girl’s “appointment” approximately $200. Many of the instances of illegal sexual conduct committed by Defendant were perpetrated with the assistance, support, and facilitation of at least three assistants who helped him orchestrate this child exploitation enterprise. These assistants would often arrange times for underage girls to come to Defendant’s residence, transport or cause the transportation of underage girls to Defendant’s residence, escort the underage girls to the massage room where Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the conclusion of each “massage appointment,” and, upon information and belief, take nude photographs and/or videos of the underage girls’ for Defendant without their knowledge.
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Epstein designed the scheme to secure a private place in Defendant’s mansion where only persons employed and invited by Epstein would be present, so as to reduce the chance of detection of Defendant’s sexual abuse and prostitution as well as to make it more
Podhurst Orseck, P.A.¶
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami¶
3¶
- Fort Lauderdale
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difficult for the minor girls to flee the premises and/or to credibly report his actions to law enforcement or other authorities. The girls were usually transported by his employees, agents, and/or assistants or by a taxicab paid for by Defendant in order to make it difficult for the girls to flee his mansion.¶
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Upon arrival at Defendant’s mansion, each underage victim would generally be introduced to one of Defendant’s assistants, who would gather the girl’s personal contact information. The minor girl would then be led up a flight of stairs to a room that contained a massage table and a large shower. The staircase leading to the room was plastered with nude photographs of young girls, including some photographs depicting two or more young girls engaged in lewd acts. Upon information and belief, Defendant, Jeffrey Epstein, had such photographs in each of his four homes and on his computer.
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At times, if it was the girl’s first “massage” appointment, another female would be in the room to “lead the way” until Defendant would have her leave. Generally, Defendant would start his massage wearing only a small towel, which eventually would be removed. Defendant would direct the girl to massage him, giving her specific instructions as to where and how he wanted to be touched, and then direct her to remove her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including masturbation, fondling the minor’s breasts and/or sexual organs, touching the with a and/or
performing¶
and/or coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution. The exact degree of molestation and frequency with which the sexual crimes took place varied and is not yet completely known; however, at least when Defendant was in Palm Beach, Florida, such acts occurred usually on a daily basis and, in most instances, several times a day.¶
Podhurst Orseck, P.A.¶
4¶
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami¶
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As previously stated in paragraph 14, Defendant displayed nude photographs of underage girls throughout his homes in New York, Palm Beach, New Mexico, and the U.S. Virgin Islands. Upon information and belief, some of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant’s home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate commerce.
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Consistent with the foregoing plan and scheme, Defendant used his money, wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff. Plaintiff, Jane Doe, was recruited by one of Defendant’s agents to give Defendant a massage for compensation. Plaintiff was apprehensive, but needed the money and finally agreed to go. Plaintiff was first brought to Defendant’s mansion in or about the spring of 2003, when she was merely 17 years old and in high school. Epstein’s procurer drove her to Jeffrey Epstein’s mansion. Plaintiff was led up a flight of stairs by a blonde woman to a spa room with a shower and a massage table, where she was left alone. A woman with dark hair, an accent, and naked from the waist up entered and tried to coax Plaintiff to remove her shirt, but Plaintiff refused. After the woman showed Plaintiff how to use the lotions that were there, the woman left. Defendant walked in wearing only a small towel. He lay down on the massage table still wearing the small towel, and Plaintiff began to massage his shoulders and neck. Nervously, she asked him what he did for a living. Defendant responded that he was a scientist. Defendant asked Plaintiff what year she would graduate high school, to which Plaintiff honestly replied that she would graduate in 2004. Plaintiff massaged Defendant’s lower back and calves. Defendant
Podhurst Orseck, P.A.¶
5¶
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami¶
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Document 1 Entered on FLSD Docket 04/20/2009¶
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told her to remove his towel. Defendant told her that he had just worked out and wanted his buttocks massaged. Although disgusted, she was afraid to refuse and did it. At some point, Defendant ordered Plaintiff to remove her clothes. In shock, fear, and trepidation, Plaintiff partly complied, removing only her shirt and bra. When Defendant turned over, Plaintiff was afraid and embarrassed and she wanted to leave. Defendant repeatedly told her to relax and complimented her, saying that she had a nice body. Defendant then pulled Plaintiff closer to him. He began masturbating and then began fondling her breasts. He asked her to do more and mentioned more money, which she adamantly declined. Defendant continued masturbating until he ejaculated. Plaintiff next recalls that she received $200 and was transported by the procurer, whom she later learned received $200 for having brought her to Epstein’s mansion.¶
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Defendant thereafter lured the then minor Plaintiff to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003. The procurer made another appointment for her to return, but Plaintiff didn’t want to see Defendant. By having his assistants continue to contact Plaintiff and attempt to lure her to the mansion for other sexual acts, Defendant engaged in a continuous course of conduct that injured Plaintiff upon each instance of contact and/or abuse.
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In addition to the direct sexual abuse and molestation of the then minor Plaintiff, Defendant used his money, wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff to bring him another minor girl in a promised exchange for money. Rather than go herself, Plaintiff and the procurer took another girl there one time.
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As a result of these encounters with Defendant, Plaintiff, Jane Doe, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and
Podhurst Orseck, P.A.¶
25 West Flagler Street, Suite 800, Miami, FL 33130, Miami¶
6¶
- Fort Lauderdale
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other damages associated with Defendant’s controlling and manipulating her into a perverse and unhealthy way of life.¶
- Any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are be
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