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MySpace.com - Female - LOX =I, Florida - www.myspace.cona Page 1 of 13
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EFTA00257028
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EFTA00257029
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EFTA00257030
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EFTA00257031
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EFTA00257038
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EFTA00257039
MySpace.com - - 17 - Female - LOX =I, Florida - www.myspace.co Page 13 of 13
02003-2008 myspace.com. all rights reserved.
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EFTA00257040
Florida D.A.V.I.D. Individual Summary Page Page 1 of 2
STATE OF FLORIDA
Department of Highway Safety & Motor Vehicles
Driver And Vehicle Information Database (DAVID)
I DIGITAL IMAGES ARE FtESTHic IED TO LAW ENFORCEMENT USE PURSUANT TO
S. 322.142(4), FLORIDA STATUTES - IMAGES INCLUDE PHOTOGRAPHS AND SIGNATURES
Individual Summary Page
DI. ID Number Stows
VALID
Pia A . ,
All Addresses On File
Date of Birth Sex Height '.iate Of Birth
6'00 Florida
Restrictions Endorsements
Issue Date Duplicate Expiration Date
05-30-06 Date 03-23-13
SSN Prtrm IJilmhor
Conditional Messages: MOTORCYCLE TEMPORARY PERMIT UNTIL: AFE DRIVER
Law enforcement officers may continue to accept the insurance card indicating Property Damage only, as also including PIP%
until June 30. 2008.
Vehicle Information
Acquired
Record VIN 1.9e Color Body Make Reg
Date
ALUMINUM/
View TRUCK TRUCK DODGE 08-31-05
SILVER
View MOTORCYCLE RED MOTORCYCL ' HONDA U7-I8-07
river License Transactions
Transaction Issue
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Date Date
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05-30- 05-31-06
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06 18:25:23
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00 17:47:22 Chan e/CIPS
04-29-05
04-28-05
00:06:53
I II I II 1
hups://www.hsmv.flejn.net/serviet/DLSummary 1/2512008
EFTA00257041
Florida D.A.V.I.D. Individual Summary Page Page 2 of _
06-20- 10-24-03 Duplicate Nnne Lost
UU 15:56:05
03-23-01 Replacement
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00
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EFTA00257042
EFTA00257043
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.:
JANE DOE NO. 1, by and through
ot3- 80069
JANE DOE's FATHER as parent and natural
guardian, and JANE DOE's FATHER, and
JANE DOE's STEPMOTHER, individually, CiV-MARIA
Plaintiffs, IAMISTRAIE JUDGE
vs. 1OHNSON
FILED by D.C.
INTAKE
JEFFREY EPSTEIN,
Defendant. JAN 2 4 2008
0CLELArttcRENuCE.8.. IADisTADDO.G.TX.
S.D. OF FLA.. PT. LAUD.
COMPLAINT
Plaintiff, Jane Doe No. 1 ("Jane" or "Jane Doe"), by and through Jane Doe's Father as parent
and natural guardian, and Jane Doe's Father and Jane Doe's Stepmother, individually, bring this
Complaint against Jeffrey Epstein, as follows:
Parties, Jurisdiction and Venue
1. Jane Doe is a citizen and resident of the State of Florida. She is a minor under the
age of 18 years.
2. Jane Doe's Father brings this action individually and as parent and natural guardian of
Jane Doe. Jane Doe's Father is a citizen and resident of the State of Florida.
3. Jane Doe's Stepmother brings this action individually. Jane Doe's Stepmother is a
citizen and resident of the State of Florida.
4. This Complaint is brought under fictitious names to protect the identity of the Minor
Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
HERMAN St MERMELSTEIN, P. A. www.hermanlaw.com
EFTA00257044
minor.
5. Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
6. This is an action for damages in excess of $50 million.
7. 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.
8. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial
part of the events or omissions giving rise to the claim occurred in this District.
Factual Allegations
9. 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. Thomas and Palm Beach,
FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach.
10. 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 2005, Jane Doe, then 14 years old, fell into Epstein's trap and became one
of his victims.
11. 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.
12. An integral player in Epstein's Florida scheme was a Palm Beach
HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com
-2-
EFTA00257045
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, Ms. Robson 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 Ms. Robson to bring
one or more underage girls to the residence. Ms. Robson, 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.
13. Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at
Epstein's mansion, Mr. Robson would introduce each victim to Epstein's assistant,
who gathered the girl's personal information, including her name and telephone number. Ms. Kellen
would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition
to other furnishings. There were photographs of nude women lining the stairway hall and in the
bedroom. Ms. Kellen would then leave the girl alone in this room, whereupon Epstein would enter
wearing only a towel. He would then remove his towel, lay down naked on the massage table, and
direct the girl to remove her clothes. He then would perform one or more lewd, lascivious and
sexual acts, including masturbation and touching the girl's vagina with a vibrator.
14. Consistent with the foregoing plan and scheme, Ms. Robson recruited Jane Doe to
give Epstein a massage for monetary compensation. Ms. Robson brought Jane to Epstein's mansion
in Palm Beach. Jane was introduced to who led her up the flight of stairs to the room
with the massage table. She was alone in the room when Epstein arrived wearing only a towel. He
HERMAN 5, MERMELSTEIN, P. A. www.hermanlaw.com
-3-
EFTA00257046
removed his towel, and laid down naked on the massage table. He demanded that Jane remove her
clothes. In shock, fear and trepidation, Jane complied, removing her clothes except for her
underwear. Epstein then sexually assaulted Jane.
15. After Epstein had completed the assault, he left the room. Jane was then able to get
dressed, leave the room and go back down the stairs. She then met Ms. Robson again who brought
Jane home. Jane was paid $300 by Epstein. Ms. Robson was paid $200 by Epstein for bringing Jane
to him.
16. As a result of this encounter with Epstein, the 14-year old Jane experienced
confusion, shame, humiliation, embarrassment and the assault sent her life into a downward spiral.
COUNT I
Sexual Assault
17. Plaintiff Jane Doe by and through her Father, as parent and natural guardian, repeats
and realleges paragraphs 1 through 16 above.
18. Epstein tortiously assaulted Jane Doe sexually in or about 2005.
19. 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.
20. 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, by and through her Father, as parent and natural guardian,
deniands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive damages,
costs, and such other and further relief as this Court deems just and proper.
HERMAN & MERMELSTEIN, P. A. vtnivw.hermanlaw.com
-4-
EFTA00257047
COUNT II
Intentional Infliction of Emotional Distress
21. Plaintiffs Jane Doe by and through her Father, as parent and natural guardian, Jane
Doe's Father and Jane Doe's Stepmother, individually, repeat and reallege paragraphs 1 through 16
above.
22. Epstein's conduct was intentional or reckless.
23. Epstein's conduct was outrageous, going beyond all bounds of decency.
24. Epstein's conduct caused severe emotional distress not only to Jane Doe, but also to
her parents, Jane Doe's Father and Jane Doe's Stepmother. Epstein knew or had reason to know that
his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe's
parents.
25. As a direct and proximate result of Epstein's intentional or reckless conduct, Jane
Do; Jane Does' Father and Jane Doe's Stepmother have suffered and will continue to suffer severe
mental anguish and pain.
WHEREFORE, Plaintiffs Jane Doe by and through her Father, as parent and natural
guardian, Jane Doe's Father and Jane Doe's Stepmother demand 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 HI
Loss of Parental Consortium
26. Plaintiff Jane Doe's Father repeats and realleges paragraphs 1 through 16 above.
27. Epstein's tortious conduct is the direct and proximate cause of damages to Jane Doe's
Father, consisting of parental loss of comfort, companionship and society and healthcare costs
HERMAN & MERMEI-STEIN, P. A. whrw.hermanlaw.com
-5-
EFTA00257048
associated with the treatment of Jane.
28. Jane Doe's Father experienced and will continue to experience great mental anguish,
pain and suffering from the time that Defendant's tortious conduct occurred.
WHEREFORE, Plaintiff Jane Doe's Father demands judgment for loss of consortium
damages, costs and such other and further relief as this Court deems proper.
JURY TRIAL DEMAND
Plaintiffs demand a jury trial in this action.
Dated: January ‘211, 2008 Respectfully submitted,
HERMAN & MERMELSTEIN, P.A.
Attorneys for Plaintiffs
18205 Biscayne Blvd.
Suite 2218
Miami, Florida 33160
Tel: 305-931-2200
Fax: 305-931-0877
By:
Je M. Herman
[email protected]
Florida Bar No. 521647
Stuart S. Mermelstein
[email protected]
Florida Bar No. 947245
Adam D. Horowitz
Florida Bar No. 376980
ahorowitz@hennaniawsom
HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com
-6-
EFTA00257049
Billionaire investor sued for alleged sexual assault of teen Page 1 of 3
HOME' SARASOTA VENICE MANATEE EAST MANATEE CHARLOTTE NORTH PORT ENG
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WEST PALM BEACH, Fla. -- Mother woman is suing a New York
Too nation
Southern Residents billionaire, claiming he sexually assaulted her when she was underage.
Assess Tornado Damage
University norms The unidentified woman says she was 16 when she was brought to
Smashed at Tenn Schen Jeffrey Epstein's Palm Beach mansion and paid $200 to give the
Death and Damage From money manager a massage. Instead, she claims he abused her.
Tornadoes
No Fatalities in Gas Plant The suit filed Wednesday in federal court is seeking more than $50
Fxolosion
million in damages from Epstein.
Too news
51058814defll31USPeSt
Jias troubled history with Another teenage girl made similar claims against Epstein in a lawsuit
WILLI fi led last month.
Sarasota County PlertInnc
chief drawing more fire Epstein also faces a felony charge of solicitation of prostitution. A
School nmierts mild start conviction could send him to prison for five years.
on hormwed dime
Risk issue worries Florida Epstein's attorney has denied the allegations, but did not return phone
insurance panel Adver
messages Wednesday.
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EFTA00257050
Billion4ire investor sued for alleged sexual assault of teen Page 2 of 3
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EFTA00257051
Billionaire investor sued for alleged sexual assault of teen Page 3 of 3
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EFTA00257052
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.:
JANE DOE NO. 2,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
COMPLAINT
Plaintiff, Jane Doe No. 2 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey
Epstein, as follows:
Parties, Jurisdiction and Venue
1. Jane Doe No. 2 is a citizen and resident of the Commonwealth of Virginia, 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.
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. §139I(a) as a substantial
HERMAN 5. MERMELSTEIN, P. A. www.hermanlaw.com
-I-
EFTA00257053
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. Thomas and Palm Beach,
FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach.
8. 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 2004-2005, Jane Doe, then approximately 16 years old, fell into Epstein's
trap and became one of his victims.
9. 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.
10. Epstein's scheme involved the use of young girls to recruit underage girls. (Upon
information and belief, the young girl who brought Jane Doe to Epstein was herself a minor victim
of Epstein, and will therefore not be named in this Complaint). Under Epstein's plan, underage girls
were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm
Beach mansion. The recruiter 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 would direct
the recruiter to bring one or more underage girls to the residence. The recruiter, 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
HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com
-2-
EFTA00257054
"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.
11. Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at
Epstein's mansion, the underage victim would be introduced to Epstein's assistant,
who gathered the girl's personal information, including her name and telephone number. Ms. Kellen
would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition
to other furnishings. There were photographs of nude women lining the stairway hall and in the
bedroom. 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,
including masturbation and touching the girl's vagina.
12. Consistent with the foregoing plan and scheme, Jane Doe was recruited to give
Epstein a massage for monetary compensation. Jane was brought to Epstein's mansion in Palm
Beach. Once at the mansion, Jane was introduced to who led her up the flight of
stairs to the room with the massage table. In this room, Epstein told Jane to take offher clothes and
give him a massage. Jane kept her panties and bra on and complied with Epstein's instructions.
Epstein wore only a towel around his waste. After a short period oftime, Epstein removed the towel
and rolled over exposing his penis. Epstein began to masturbate and he sexually assaulted Jane.
13. After Epstein had completed the assault, Jane was then able to get dressed, leave the
room and go back down the stairs. Jane was paid $200 by Epstein. The young girl who recruited
Jane was paid $100 by Epstein for bringing Jane to him.
14. As a result of this encounter with Epstein, Jane experienced confusion, shame,
HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com
-3-
EFTA00257055
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. 2 demands judgment against Defendant Jeffrey
Epstein for compensatory damages, punitive damages, costs, and such other and further reliefas 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.
HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com
-4 -
EFTA00257056
24.
Doe, has suffered and will continue to suffer severe mental anguish and pain. t
As a direct and proximate result of Epstein's intentional or reckless con ct, Jane
WHEREFORE, Plaintiff Jane Doe No. 2 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: February 2008 Respectfully submitted,
HERMAN & MERMELSTEIN, 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
[email protected]
Florida Bar No. 521647
Stuart S. Mermelstein
[email protected]
Florida Bar No. 947245
Adam D. Horowitz
Florida Bar No. 376980
ahorowitz@hennan law.com
HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com
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ℹ️ Document Details
SHA-256
7c8cb38ea1e859390a3d98c577edb66a9864e6886c83d40279a49f5811d878bd
Bates Number
EFTA00257027
Dataset
DataSet-9
Type
document
Pages
64
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