JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80232-Marra- STEVEN N. LARIMORE CLERK U.5. DIST. CT. S.O. Of FLA. • MIAMI ### COMPLAINT Plaintiff, Jane Doe No.3 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey Epstein, as follows: ## Parties, Jurisdiction and Venue - 1. Jane Doe 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 her when she was aminor. - 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 Allegations 7. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52 years old. 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... 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 a sexual preference and obsession for underage minor girls. He engaged in aplan 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 2004-2005, Jane Doe, then 16 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 1. An integral player in Epstein's Florida scheme was a Palm Beach Community College student from Loxahatchee, Florida. She recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's plan, would be contacted when Epstein was planning to be at his Palm Beach residence or soon after he had arrived there. Epstein or someone on his behalf directed to bring one or more underage girls to the residence. , upon information and belief, generally sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas 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. Upon arrival at Epstein's mansion, the victim would be brought to the kitchen. She would then be led up aflight of stairs to abedroom that contained a massage table in addition to other furnishings. Once the girl was alone in this room, Epstein would enter wearing only atowel to cover his private area. He then would lay down on the massage table and perform one or more lewd, lascivious and sexual acts, including masturbation and touching the girl sexually. 1. Consistent with the foregoing plan and scheme, recruited Jane Doe to give Epstein a massage for monetary compensation. brought Jane to Epstein's mansion in Palm Beach. Jane was led up the flight of stairs to the room with the massage table. She was alone in the room when Epstein arrived wearing atowel to cover his private parts. He laid down on the massage table, and sexually assaulted Jane Doe during the massage. In addition, Jeffrey Epstein masturbated during the massage. 1. After Epstein had completed the assault, he left the room. Jane was then able to leave the room and go back down the stairs. She then met again who brought Jane home. Jane was paid \$200 by Epstein. was also paid by Epstein for bringing Jane to him. 1. As aresult of this encounter with Epstein, the 16-year old Jane experienced trauma, shock, confusion, shame, humiliation and embarrassment. ### COUNT I Sexual Assault 15. Plaintiff Jane Doe repeats and realleges paragraphs I through 14 above. 01. Epstein tortiously assaulted Jane Doe sexually in or about 2004-2005. Epstein's acts were intentional, unlawful, offensive and harmful. 01. Epstein's plan and scheme in which he committed such acts upon Jane Doe were done willfully and maliciously. IS. This sexual assault was in violation of Chapter 800 of the Florida Statutes, which recognizes as acrime the lewd and lascivious acts committed by Epstein upon Jane. 19. As adirect 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, PlaintiffJane Doe, 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. Plaintiffs Jane Doe repeats and realleges paragraphs 1 through 14 above. 01. Epstein's conduct was intentional or reckless. 01. Epstein's conduct was outrageous, going beyond all bounds of decency. 01. 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. 01. As adirect 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, PlaintiffJane Doe 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: March A ., 2008 Respectfully submitted, HERMAN & MERMELSTE1N, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 By Jeffrey M. Herman ihennanehermanlaw.corn Florida Bar No. 521647 Stuart S. Mermelstein smermelstein@hermanlaw.com Florida Bar No. 947245 Adam D. Horowitz Florida Bar No. 376980 ahorowitzehermanlaw.com The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing, and service of pleading or other papers as required by law, except as provided bylocal 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.) 1(a) PLAINTIFFS JANE DOE NO. 3, (b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF PALM BEACH COUNTY (EXCEPT IN U.S. PLAINTIFF CASES) DEFENDANTS JEFFREY EPSTEIN COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT NEW YORK (IN U.S. PLAINTIFF CASES ONLY) (c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER) Herman & Mermeistein, PA., 18205 Biscayne Blvd., Suite 2218, Miami, FL 33160, (305) 931-2200 (d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH ## II. BASIS OF JURISDICTION (PLACE AN X ONE BOX ONLY) - O 1 U.S. Government 0 3. Federal Question Plaintiff (D S. Government NO a Pally) O 2. U.S Government X 4. Oiveralty Defendant (Indicate Citizenship of Parties in Item - III) ATTORNEYS (IF KNOWN) 61:0 PrA/ 2n2 32 - 1O9O1-A1s III. CITIZENSHIP OF PRINCIPAL PARTIES PLACE AN X IN ONE BOX FOR PLAINTIFF (For Diversity Case Only) AND ONE FOR DEFENDANT PTF DEF PTF DEF Incorporated of Principal Place of O 4 O 4 Citizen of This State X1 01 Buarness in This Stale Cazon of Another State O 2 x 2 Citizen or Subject of a Foreigl Country 0 3 O 3 Incorporated and Rrtnc/pal Place of O 5 O 5 Business in Another State Foreign Nation O 6 CI 6 #### IV. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE. DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY.) DIVERSITY ACTION UNDER 28 U.S.C. §1332(a) FOR SEXUAL ASSAULT IVa. j\_ days estimated (for both sides) to try entire case V. NATURE OF SUIT (PLACE AN X IN ONE BOX ONLY) | A CONTRACT | A TORTS | B FORFEITURE PENALTY | A BANKRUPTCY | A OTHER STATUS | | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | | |

PERSONAL INJURY

310 Airplane
315 Airplane Product Liability
320 Assault, Libel & Slander
330 Federal Employers' Liability
335 Damage
345 Vehicle Product Liability
350 Motor Vehicle
355 Motor Vehicle Product Liability
360 Other Personal Injury

PERSONAL PROPERTY

372 Other Fraud
371 Truth in Lending B
380 Other Personnel Property Damage
385 Property Damage Product Liability

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A PROPERTY RIGHTS

820 Copyrights
830 Patent
840 Trademark

| | | A REAL PROPERTY | A CIVIL RIGHTS | B PRISONER PETITIONS | A LABOR | A FEDERAL TAX SUITS | | | | | | | VI. ORIGIN x1. Original 0 2. Removed from 0 3. Remanded from 0 4. Refilled 0 6. Multidistrict Litigation 0 7. Appeal to District Judge from Proceeding State Court Appellate Court 0 5. Transferred from another district (Specify) Magistrate Judgment VII. REQUESTED IN COMPLAINT CHECK IF THIS IS A O CLASS ACTION DEMAND O Check conplaint: JURY DEMAND: O UNDER F.R.C.P. 23 VIII. RELATED (See Instructions): (SEE ATTACHED) CASE(S) IF ANY JUDGE KENNETH A. MARRA Jane Doe 2 v. Jeffrey Epstein DOCKET NUMBER 08-CV-80119-MARRAIMM DATE 3 - 4 -.4) Y SIGNATURE OF ATTORNEY OF RECORD Date Pald: Wfp: 54/az/col