Civil complaint against Jeffrey Epstein alleging sexual abuse of a minor, filed 2009

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UNITED STATES DISTRICT COURT¶

SOUTHERN DISTRICT OF FLORIDA¶

CASE NO.: 09-CV-80802-Marra-Johnson¶

JANE DOE NO. 8,¶

VS.¶

Plaintiff,¶

JEFFREY EPSTEIN,¶

Defendant.¶

COMPLAINT¶

Plaintiff, Jane Doe No. 8 (“Jane” or “Jane Doe”), brings this Complaint against Jeffrey Epstein, as follows:¶

Parties, Jurisdiction and Venue¶

1. Jane Doe No. 8 (“Jane Doe”) 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, and presently serving a prison sentence in Palm Beach County, Florida for, inter alia, solicitation of prostitution and solicitation of minors to engage in prostitution.

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;

MERMELSTEIN & HOROWITZ, P. A.¶

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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 jurisdiction pursuant to 28 U.S.C. §1367(a) over all other claims set forth herein which form part of the same case or controversy.

7. This Court has venue of this action pursuant to 28 U.S.C. §§1391(a) and 1391(b) as a substantial part of the events or omissions giving rise to the claim occurred in this District.

Factual Allegations¶

8. At all relevant times, Defendant Jeffrey Epstein (“Epstein”) was an adult male in his early 50’s. 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.

9. 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 2001, Jane Doe, then approximately 16 years old, fell into Epstein’s trap and became one of his victims.

10. 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.

11. Epstein’s scheme involved the use of young girls to recruit underage girls. These underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation

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in his Palm Beach mansion. Epstein, upon information and belief, generally sought out economically disadvantaged underage girls from 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.¶

12. Epstein’s plan and scheme reflected a particular pattern and method. The underage victim would be brought or directed to Epstein’s mansion, where she would be led up a flight of stairs to a room 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 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.

13. Consistent with the foregoing plan and scheme, Jane Doe was recruited by another girl, who told her that she could make some money, but did not tell her what was involved. At all relevant times, the girl who recruited Jane Doe was acting on behalf of and as agent for Epstein. Jane was contacted by this girl by telephone. Jane was then picked up and brought to Epstein’s mansion in Palm Beach. Once there, she was led up the flight of stairs to the room with the massage table. Epstein came into the room and directed Jane to remove her clothes and give him a massage. Jane was frightened and felt trapped. As directed by Epstein, Jane removed her clothes. Epstein then during the massage touched Jane on her breasts and vagina, and he grabbed her hand and placed it on his penis. Epstein masturbated himself during the massage. Epstein then left money for Jane.

14. As a result of this encounter with Epstein, Jane experienced confusion, shame, humiliation and embarrassment, and has suffered severe psychological and emotional injuries.

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24. Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury that caused or were likely to cause Jane Doe’s mental or emotional health to be significantly impaired.

25. 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.

26. 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, psychological and emotional injuries and los of enjoyment of life. .

WHEREFORE, Plaintiff Jane Doe No. 6 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¶

27. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.

28. 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.

29. 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.

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30. 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 criminal offenses including violations of Florida Statutes §§798.02 and 800.04 (including subsections (5), (6) and (7) thereof).

31. Epstein’s acts and conduct are in violation of 18 U.S.C. §2422.

32. As a result of Epstein’s violation of 18 U.S.C. §2422, Plaintiff has suffered personal injury, including mental, psychological and emotional damages.

33. Plaintiff hired Mermelstein & Horowitz, P.A. (f/k/a Herman & Mermelstein, P.A.), in this matter and agreed to pay them a reasonable attorneys’ fee.

WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey Epstein for all damages available under 18 U.S.C. §2255(a), including without limitation, actual and compensatory damages, costs of suit, and attorneys’ fees, and such other and further relief as this Court deems just and proper.¶

JURY TRIAL DEMAND¶

Plaintiff demands a jury trial in this action on all claims so triable.¶

Dated: May 27, 2009¶

Respectfully submitted,¶

By:¶

Stuart S. Mermelstein (FL Bar No. 947245)¶

ssm@sexabuseattorney.com¶

Adam D. Horowitz (FL Bar No. 376980)¶

ahorowitz@sexabuseattorney.com¶

MERMELSTEIN & HOROWITZ, P.A.¶

Attorneys for Plaintiff¶

18205 Biscayne Blvd., Suite 2218¶

Miami, Florida 33160¶

Tel: 305-931-2200¶

Fax: 305-931-0877¶

MERMELSTEIN & HOROWITZ, P. A.¶

www.sexabuseattorney.com¶

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