UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA April 14, 2008 STEVEN M. LARIMORE CLERK U.S. 01ST. CT. S. O. OF FLA. • MIAMI CASE NO.: 08-CV-80380-Hurley- JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. # COMPLAINT Plaintiff, Jane Doe No. 4 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey Epstein, as follows: # Parties, Jurisdiction and Venue - 1. Jane Doe No. 4 is acitizen and resident of the State of Florida, and is sui juris. - 2. This Complaint is brought under afictitious 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 acitizen 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 asubstantial part of the events or omissions giving rise to the claim occurred in this District. ### Factual Alleeations 7. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52 years old. Epstein is afinancier and money manager with asecret clientele limited exclusively to billionaires. He is himself aman of tremendous wealth, power and influence. He maintains his principal home in New York and also owns residences in New Mexico, and Palm Beach, FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach. 1. Upon information and belief, Epstein has asexual 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 2002-2003, Jane Doe, then approximately 15 years old, fell into Epstein's trap and became one of his victims. 1. 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. S. 1. Epstein's scheme involved the use of young girls to recruit underage girls.- \_, aPalm Beach Community College student from Loxahatchee, Florida recruited girls ostensibly to give a wealthy man amassage for monetary compensation in his Palm Beach mansion. The young girls would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there..\_, 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. 1. Epstein's plan and scheme reflected a particular pattern and method. The underage victim would be brought to the kitchen entrance of Epstein's mansion, where she would be introduced to, Epstein's assistant. would then bring the girl up aflight of stairs to abedroom that contained a massage table in addition to other furnishings. There were photographs of nude women lining the stairway■ **and in the bedroom. The girl would then find herself alone in the room with Epstein, who would be wearing only atowel. 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, when Jane Doe was approximately 15 years old, she was recruited by to give Epstein a massage for monetary compensation. Jane was brought to Epstein's mansion in Palm Beach, to the kitchen entrance. 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 remove her clothes and give him a massage. Jane initially kept her panties and bra on, and complied with Epstein's instructions. Jane was paid by Epstein for this massage.** **13. Jane returned on many occasions to the Palm Beach mansion to provide Epstein with massages. On those occasions, Epstein engaged in sexual contact and activity with the minor Jane, which included, among other things, directing Jane to remove all her clothes, masturbating during the massage, and digitally penetrating Jane's vagina. Jeffrey Epstein often used avibrator on the minor Jane during the massage. This sexual abuse continued for approximately three years.** **14. As aresult of these encounters 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. 4 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. 4 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: April 551-12008 Respectfully submitted, HERMAN & MERMELSTEIN, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-93 By: Jeffrey M. Herman iherman@hermanlaw.com Florida Bar No. 521647 Stuart S. Mermelstein smermelstein@herrnanlaw.com Florida Bar No. 947245 Adam D. Horowitz Florida Bar No. 376980 ahorowitzahermanlaw.com The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing, and service papers 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.) I(a) PLAINTIFFS\ JANE DOE NO. 4, DEFENDANTS\ JEFFREY EPSTEIN APR 14 2008 (b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF\ MARION COUNTY\ (EXCEPT IN U.S. PLAINTIFF CASES) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF CONFIRMED ARMORE PLAINTIFF DIST. OF CONFIRMED ARMORE PLAINTIFF DIST. OF FLA. FT. LAUD. (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 9:08 CV 80380 - Hurley Apt time ## II. BASIS OF JURISDICTION AND ONE BOY |

1. U.S. Government

Plaintiff

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3. Federal Question

(U.S. Government Not a Party)

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2. U.S. Government

Defendant

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4. Diversity

(Indicate Citizenship of Parties in Item III)

| ### III. CITIZENSHIP OF PRINCIPAL PARTIES (For Diversity Case Only) | Citizen of This State | X 1 | 2 | | --------------------------------------- | --------------------------------------- | ------------------------------------- | | Citizen of Another State | 2 | 2 | | Citizen or Subject of a Foreign Country | 3 | 3 | PLACE AN X IN ONE BOX FOR PLAINTIFF\ AND ONE FOR DEFENDANT PTF DEF\ Incorporated of Principal Place of 4 4 IV. CAUSE OF ACTION\ DO NOT CITE ILLIDENTITY DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY.)\ **DIVERSITY ACTION UNDER 28 U.S.C. §1332(a) FOR SEXUAL ASSAULT** **IVa. 5 days estimated (for both sides) to try entire case** ### V. NATURE OF SUIT (PLACE AN X IN ONE BOX ONLY) VI. ORIGIN\ x 1 Original 1. Proceeding      2. Removed from      3. Remainded from      4. Appeal to District Judge from Appeal to District Judgment 1. Transferred from another district      6. Magistrate Judgment VII. REQUESTED\ IN COMPLAINT CHECK IF THIS IS A\ UNDER F.R.C.P. 23 CLASS ACTION      DEMAND \$ Check YES only if demanded in complaint: **JURY DEMAND:** VIII. RELATED CASE(S) IF ANY (See Instructions): Jane Doe 2 v. Jeffrey Epstein\ Jane Doe 3 v. Jeffrey Epstein (SEE ATTACHED) JUDGE KENNETH A. MARRA\ JUDGE KENNETH A. MARRA DOCKET NUMBER 08-CV-80119-MARRA-\ DOCKET NUMBER 08-CV-80232-MARRA- DATE 4/14/08 SIGNATURE OF ATTORNEY OF RECORD *SMA* UNITED STATES DISTRICT COURT\ S/F 1-2\ REV. 9/94 542749