EFTA00257462.pdf

EPsalleh) clVD... EFTA00257462  Supplemental Report File# 2600 Date: 03-11-04 Case #: Target: E stien, Jeffe Detective: Brief: Epstien asks girl to take off clothes-during-message. 03-11-04 File # 2600 On 03-05-04, completed an intel regarding a last name unknown, who was giving a message to Jeffery Epstein at stated that several times Epstien asked her to take off her top or her pants. She refused. ontacted the police department later that day and wanted to make a complaint. She also said that she would work with police. I contacted on 03-06-04 at 11:00 p.m. and introduced myself then told her that I would contact her at a later date. On 03-11-04, I left a message for to call me regarding the Epstien incident. Her phone number is Investigation Continues EFTA00257463  PALM BEACH POLICE DE] ANENT FILE . DATE: INTELLIGENCE REPORT CASE #: CONFIDENTIAL (Y/N): OFFICER NAME: I.D. # SUBJECT NAME: ( AST)E7Keift) (FIRST) eFFe (M.I. DATE OF BIRTH: RACE:LOA:46- SOURCE NAME: (LAST) IRST (M.I.) CONTACT INFORMATION (TELEPHONE) EVALUATION OF SOURCE: RELIABLE LIABLE UNEVALUATED X SOURCE IDENTIFICATION: PRIVATE CITIZEN ›C LAW OFFICER • OTHER CRIMINAL SOURCE GOVT AGENCY INFORMATION ACQUIRED BY: PERSONAL KNOWLEDGE NEWS MEDIA HEARSAY/RUMOR DOCUMENTS INFORMATION: el ayLize smiwe,e 1 e'xeee r //; Ae AL/ L/e 01, 4.Q1)fibciew tu/K ago-477h 411 tainEW luu) a (4Zo 40A-00.,( VaaoviwAs Rig A-9 azeavv., 47,1$46ctoa-ce INF RMATION CONTENT: Va I l FIED U RIFIED. EXPLAIN PARTIALLY RIFIED SIMILAR INFO FILED EVALUATED BY SUPERVISOR (INITIALS): RECOMMENDED FOLLOW-UP BY SUPERVISOR: DETECTIVE TO VERIFY SOURCE TO VERIFY ANALYZE AND EVALUATE FILE ONLY DISSEMINATION: OCVAN LIFT. BUREAU PATROL ALL EFTA00257464 PALM BEACH POLICE DE, .4TMENT FILE . DATE: INTELLIGENCE REPORT CASE #: CONFIDENTIAL (Y/N): OFFICER NAME. I.D. # SUBJECT NAME: ASTe .../ (FIRST) ati-F1?-P DATE OF BIRTH: (4)1.- RACE: SEX: SOURCE NAME: (LAST) (FIRST) ( M. I . ) CONTACT INFORMATION (TELEPHONE) EVALUATION OF SOURCE: RELIABLE UNRELIABLE UNEVALUATED 5( SOURCE IDENTIFICATION: PRIVATE CITIZEN Y... LAW OFFICER OTHER CRIMINAL SOURCE GOVT AGENCY INFORMATION ACQUIRED BY: PERSONAL KNOWLEDGE NEWS MEDIA HEARSAY/RUMOR DOCUMENTS INFORMATION CONTENT: VERIFIED UNVERIFIED 5C- EXPLAIN PARTIALLY VERIFIED SIMILAR INFO FILED EVALUATED BY SUPERVISOR (INITIALS): RECOMMENDED FOLLOW-UP BY SUPERVISOR: DETECTIVE TO VERIFY SOURCE TO VERIFY ANALYZE AND EVALUATE FILE ONLY DISSEMINATION: OCVAN DET. BUREAU PATROL ALL EFTA00257465 EFTA00257466 EFTA00257467 • Supplemental Report Filth 2600 Date: 03-1 1-04 Case #: Target: E stien Jeffery Detective: Brief: Epstien as s girl to take off clothes-during-a-message. 03.11-04 • File # 2600 On 03-05-04, completed an Intel regarding last name unknown, who was giving a message to Jeffery Epstein ate stated that several times Epstien asked her to take off her top or her pants. She refused. contacted the police department later that day and wanted to make a complaint. She also said that she would work with police. I contacted on 03-06-04 at 11:00 p.m. and introduced myself then told her that I would contact her at a later date. On 03-11-04, 1 left a message for to call me regarding the Epstien incident. Her phone number i Investigation Continues EFTA00257468 PALM BEACH POLICE DE! ATMENT FILE DATE: INTELLIGENCE REPORT CASE #: CONFIDENTIAL (Y/N): OFFICER NAME: I.D. # SUBJECT NAME: ( AST)E4;TE/A) (FIRST)JeFFk DATE OF BIRTH: add —21'5 RACE: Ltitnir SEX: a-64 SOURCE NAME: (LAST) IRST (M.I. ) CONTACT INFORMATION (TELEPHONE) EVALUATION OF SOURCE: RELIABLE ELIABLE UNEVALUATED X SOURCE IDENTIFICATION: PRIVATE CITIZEN ›C LAW OFFICER OTHER CRIMINAL SOURCE GOVT AGENCY INFORMATION ACQUIRED BY: PERSONAL KNOWLEDGE NEWS MEDIA HEARSAY/RUMOR DOCUMENTS INFORMATION: on itee 03-405-o V Ar/S51.0 An1/12 r4ge)...ateX,a_74:e‘ dllZ ria A di 2;edzie4e/A, 74 al 4eifti edfilie/d_rb termi cold/cps Ch CvLrigyute., ege04776 eultitW /lea% ed-11-e /Lev lath mvemif tUlkt2loi5416z. 0 gLeaste INF RMATION CONTENT: VERIFIED 11 UN RIFIED & . EXPLAIN PARTIALLY VtRIFIED SIMILAR INFO FILED EVALUATED BY SUPERVISOR (INITIALS): RECOMMENDED FOLLOW-UP BY SUPERVISOR: DETECTIVE TO VERIFY SOURCE TO VERIFY ANALYZE AND EVALUATE FILE ONLY DISSEMINATION: OCVAN DET. BUREAU PATROL re • a...• A-4 EFTA00257469  PALM BEACH POLICE DE, .(TMENT FILE .. DATE: INTELLIGENCE REPORT CASE #: CONFIDENTIAL (Y/N): OFFICER NAME I.D. # SUBJECT NAME: AST3FPS77.1/A) DATE OF BIRTH: /9,1.-- (FIRST) 41-e eFet (M.I.) E- RACE: SEX: SOURCE NAME: (LAST) (FIRST) ( M. I . ) CONTACT INFORMATION (TELEPHONE) EVALUATION OF SOURCE: RELIABLE UNRELIABLE UNEVALUATED c SOURCE IDENTIFICATION: PRIVATE CITIZEN ‘,0C., LAW OFFICER OTHER CRIMINAL SOURCE GOVT AGENCY INFORMATION ACQUIRED BY: PERSONAL KNOWLEDGE NEWS MEDIA HEARSAY/RUMOR DOCUMENTS pip cx-rp-44C :hoz 74 3- 2/-0 xtee-t IN Sta kinJefa ff—e-1 516 `6./ev.1 ,&/-04C 4-RA0_,-,14 INFORMATION CONTENT: VERIFIED UNVERIFIED s)(". EXPLAIN PARTIALLY VERIFIED SIMILAR INFO FILED EVALUATED BY SUPERVISOR (INITIALS): RECOMMENDED FOLLOW-UP BY SUPERVISOR: DETECTIVE TO VERIFY SOURCE TO VERIFY ANALYZE AND EVALUATE FILE ONLY DISSEMINATION: OCVAN DET. BUREAU PATROL _ ALL EFTA00257470  • « r Palm Beacher Jeffrey Epstein faces new lawsuit alleging sexual battery Page 1 of 1 ■ swat Reneu • Your Subscription ParniffelangallOte ttn let SKINT SIMI RterileatatylawS @site Oweb I OCOZTI2rX Frt.« July II 2006 Aitritti How I NEWS I SOCIETY I BUSINESS I ARTS FASHION I MR/ARIES I OPINION I LIFESTYLES SHINY SHOTS I ADVERTISE CONTACT US NEWS Ardeerustmern Religion I Archie« Featured Vehicles Palm Beacher Jeffrey Epstein faces new lawsuit alleging sexual battery Dream Car find it at RearnBeachDailyNevistOM ClIck-2-Listen Luxury Can find them at PaimeeachDanyNowscom lausaCault and 4 al RaIMBsacleaftyNevis.com Sunday. JAy 13. 2008 View Al Featured Vehicle:, Another laasiit has been fled against Palm Reacher Jeffrey Epstein. The complaint, Ned Thursday in Palm Beach County Circuit Court. charges Epstein with sexual battery and conspiracy. It alleges that Epstein and two assistants solicited the plaintiff. called Jane Dee Ii, from June or July 2004 through February 2005 to provde massages, which led to sexual activity. The plaintiff. represented • by West Palm Beach lawyer licit° Garcia, is seeking a Jury trial. The complaint does not list a specific amount for damages. Months agO. two ether women Med federal nits against Epstein alleging that he sexualy assaulted them when they were teens. A third woman feed suit In state couN. On Arne 30. Epstein. 55, was sentenced to 18 months in the Palm Beach County Jail after pleading guilty to soliciting underage gide for prostitution. The arrest followed an 11-rnonth investigation by Palm Beach police irto allegations that Epstein gave five underage girls money foe massages and sometimes sex at his home. After he serves his term. Epstein will be under house arrest fa 12 months. Relina ncc 1300,000 for Only 0 44/Month $300,000 Mortgage for ally $9G5/month. Saw: SLOWS - No obligation. wwaimmetoarereffune cons Seelestay:s_Mortgagejtates Calculate Your New Mortgage Payment. gee Rates- No Credit Check Reg. vany.LoworbbStilloccm Et9fin_PASS_Ond Saw, Sasegg_S $150,000 mortgage for $483fmonth. Compare up to 4 free Qur'an. aww.pckamorteactcom MITIIIIRFELEcheerp grectuegLOntiOr Get a Degree In as Few as 2 Yrs- Graduate rafter with Online Classes. wn-a.0asse1SAcan Ads tor Yahoo! By using this service you accept the terms of our Visitor Agreement. Copyright 2007 Palm Beach Daly News. Al nghls reserved. The Palm Beach Orly News Privacy Policy l About INs site I Write to us [YASUO (c.2.0 littp://www.palinbeachdailynews.com/news/content/news/webBrief Epstein0711.html 7/11/2008 EFTA00257471 - Not an Official Document Page I of 3 Report Selection Criteria Case ID: Docket Start Date: Docket Ending Date: Case Description Case ID: Case Caption: JANE DOE II V JEFFREY EPSTEIN Division: Filing Date: Thursday , July 10th, 2008 Court: CA - CIRCUIT CIVIL Location: MB - MAIN BRANCH Jury: Y-Jury Type: OC - OTHER CIRCUIT Status: PE - PENDING Related Cases No related cases were found. Case Event Schedule No case events were found. Case Parties rSeq Expn Assoc Type ID Name Date 1 PLAINTIFF JANE DOE II Aliasesj none 2 ATTORNEY Aliases: none 3 DEFENDANT EPSTEIN, JEFFREY Aliases: none DEFENDANT Aliases: none I I II II I II Ithp://courtcon.co.palm-beach.fLus/pls/jiwp/ckpublic_my_doct.cp_dktrpt_docket_report?... 7/11/2008 EFTA00257472  - Not an Official Document Page 2 of 3 5 L [JUDGE AE Aliases: none DcicW Entries Docket Number [Docket Type I Book and Page No. Attached To: 00000 - ADDITIONAL COMMENTS Filing Date: j 10-JUL-2008 Filing Party: Disposition Amount: Docket Text: OWES $65.00 800FF - CAFF Filing Date: 10-JUL-2008 Filing Party: JANE DOE II, Disposition Amount: [Docket Text: none. LE - PENDING Filing Date: 10-JUL-2008 Filing Party: Disposition Amount: Docket Text: none. [CPT - RECEIPT FOR PAYMENT Filing Date: 10-JUL-2008 Filing Party: JANE DOE II, Disposition Amount: Docket Text: A Payment of -$256.03 was made on receipt CMP - COMPLAINT Filing Date: 10-JUL-2008 Filing Party: JANE DOE II, Disposition Amount: Docket Text: —I none. 2 CCS - CIVIL COVER SHEET http://courtcon.co.palm-beach.fl.us/p1s/jiwpick_public qry_doct.cp_dktrpt_docket_report?... 7/11/2008 EFTA00257473 - Not an Official Document Page 3 of 3 'Filing Date: II10-JUL-2008 Ifiling Party: JANE DOE II, Disposition Amount: Docket Text: none. 3 SMIS - SUMMONS ISSUED Filing Date: 10-JUL-2008 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: SM-08-119679 4 SMIS - SUMMONS ISSUED Filing Date: 10-JUL-2008 Filing Party: Disposition Amount: Docket Text: RCPT - RECEIPT FOR PAYMENT Filing Date: 11-JUL-2008 Filing Party: JANE DOE II, Disposition Amount: Docket Text: A Payment of -$65.00 was made on receipt http://courtcon.co.palm-bcach.fl.us/p1s/jiwp/ck_public qry doct.cp_dktrpt_docket_report?... 7/11/2008 EFTA00257474 Header - blur, Pagel of • 1 0 1 44" 14.147 k • (I 1 • & Comptroller http://courtcon.c.o.palm-beacklualpliljiwpIck_public_cpy main.cp heedet?title_phrasec... 7/11/1008 EFTA00257475 C Page 1 of 1 ►,Search Home ► New Search ► Report Selection ► Case Description ► Related Cases ► event Schedule ► Case Parties ► pocket Entries (c) Copyright 1998 Affieated Computer Systems. Inc. ACS and gie ACS logo are registered ttadematlm. CcurtConnect is a trademark of ACS. This contains trade secrets and is subject to a confielenlialty agreement. The unauthorized possessicck use. reproduction, distribution. display. or disclosure of Ns material or the information contained herein is prohibited. Al rights reserved. Uset Accepts/Agrees to Disclaimer Not for official use. . http://courtcon.co.palm-beach.fl.us/pls/jiwpick_public qry_doct.cp_dktrpt_toc?backto=P... 7/114008 EFTA00257476  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, cl■.MARRA Plaintiffs, MAOIST vs. JEFFREY EPSTEIN, Defendant. 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 & MERMELSTEIN, P. A. www.hermantaw.com -1- EFTA00257477 .e 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 S MERMELSTEIN, P. A. www.hermanlaw.com -2- EFTA00257478 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, n 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. 13. Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at Epstein's mansion, would introduce each victim to , Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. 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. 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. 14. 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 introduced to MM., 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 & MERMELSTEIN, P. A. www.hermanlaw.com -3- EFTA00257479 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 again who brought Jane home. Jane was paid $300 by Epstein. 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 I 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. Asa 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, PlaintiffJane 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. www.hermanlaw.com -4- EFTA00257480  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 Do; 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 Doe, 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 III 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 S MERMELSTEIN, P. A. vAvw.hermanlaw.com -5- EFTA00257481 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 924, 2008 Respectfully submitted, HERMAN & MERMELSTEIN, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: - - By: Florida Bar No. NIS HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com -6- EFTA00257482 r. 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 ofthis action and the claims set forth herein pursuant to 28 U.S.C. § I332(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 S. MERMELSTEIN, P. A. www.hermanlaw.com -I - EFTA00257483 0 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- EFTA00257484 "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. IM 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 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 off her 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 of time, Epstein removed the towel and rolled over Epstein 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 - EFTA00257485 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 ai MERMELSTEIN, P. A. www.hermanlaw.com -4- EFTA00257486  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. 2 demands judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and further reliefas 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. Attorneysfor Plaintiffs 18205 Biscayne Blvd. Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 By: HERMAN E. MERMELSTEIN, P. A. www.hermanlaw.com -5 - EFTA00257487 a. ---- ea. FILED b$. ELOURCAM March 5, 2008 UNITED STATES DISTRICT COURT CLERK 0 olsr. cr. ;..o. or ru. • Wog SOUTHERN DISTRICT OF FLORIDA CASE NO.: JANE DOE NO. 3, 08-CV-80232 Plaintiff, vs. JEFFREY EPSTEIN, Defendant. 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 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 her when she was 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 S75,000, 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 a substantial part of the events or omissions giving rise to the claim occurred in this District. HERMAN & MERMELSTEIH, P. A. vAvw.hermanlaw.com -1 - loft EFTA00257488  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 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. 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 HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com -2- EFTA00257489 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 victim would be brought to the kitchen. She would then be led up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. Once the girl was alone in this room, Epstein would enter wearing only a towel to cover his private area. He then would lay down on the massage table and 12. 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 a towel to cover his private parts. He laid down on the massage table, aniz . In addition, Jeffrey Epstein during the massage. 13. 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. 14. As a result of th