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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.:
M.J.,
Plaintiff,
vs.
JEFFREY EPSTEIN and
SARAH KELLEN,
Defendants.
COMPLAINT
Plaintiff, M.J., by and through her undersigned counsel, sues the Defendants, Jeffrey
Epstein and Sarah Kellen, and alleges:
I. This is an action in an amount in excess of $15,000.00, exclusive of interest and costs and
is within the jurisdictional limits of this Court.
2. This Complaint is brought under a fictitious name in order to protect the identity of the
Plaintiff because this Complaint makes allegations of sensitive nature of offenses against a then
minor child.
3. At all times material to this cause of action, the Plaintiff, M.J. (hereinafter referred to as
"Plaintiff"), was a resident of Palm Beach County, Florida.
4. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence
located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida.
5. Defendant, Jeffrey Epstein, is currently a citizen of the United States Virgin Islands.
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6. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult
male born in 1953.
7. Defendant, Sarah Kellen, is currently a citizen ofNew York, where she currently resides.
8. At all times material, the Defendants Jeffrey Epstein and Sarah Kellen both owed a duty
unto Plaintiff to treat her in a non-negligent manner and to not commit or conspire to commit
intentional or tortious illegal acts against her.
FACTUAL ALLEGATIONS
9. At all times material, Defendant, Jeffrey Epstein, was an adult male, over 50 years old.
Defendant Epstein is known as a billionaire, yet even those closest to him, including family
members, long time employees and those that he considers his closest friends have no idea what
he does or did to earn money to support his lifestyle.
10. Defendant Epstein owns, directly or through nominee individuals used to conceal his
interests, a fleet of airplanes, motor vehicles, boats and a helicopter. He owns numerous
properties and homes, including a 51,000-square-foot mansion in Manhattan, a $30 Million
7,500-acre ranch in New Mexico, a 70-acre private island formerly known as Little St. James in
St. Thomas, U.S. Virgin Islands (he is alleged to have renamed this island Little St. Jeff's after
himself), a mansion in London, England, a home in Paris, France, and a mansion in Palm Beach
County, FL. The allegations herein primarily concern the defendant's conduct while at his
mansion in Palm Beach County, FL.
II. Defendant Epstein has a sexual preference and obsession for underage minor females,
specifically targeting female children age 12 to 17, and Defendant Epstein acts on that obsession
by luring underage minor females to him where he attempts to sexually molest and batter these
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underage minor females on an everyday basis, oftentimes 2 or 3 different underage minor
females on one day.
12. Sometime prior to 1998, Defendant Epstein devised a complex plan, scheme and criminal
enterprise to gain access to countless underage minor females, some as young as 12 years old, for
the purpose of coercing the minor females into various acts of sexual misconduct that he
committed upon them. His enterprise operated with a definite hierarchal structure with his
various employees/assistants and associates, including Defendant Sarah Kellen, Jean Luc Brunel,
Ghislaine Maxwell, Leslie Groff. Adriana Ross. Nadia Marcinkova, various housekeepers,
butlers and pilots, performing their respective roles to ensure the goals of the enterprise: operate
an organized and efficient system to maximize the number of underage minor females for
Defendant Epstein (and others) to sexually abuse and exploit while avoiding law enforcement
detection.
13. Defendant Epstein, with help from his assistants and associates, recruited and procured
underage minor females, lured them to one of his mansions, had the underage minor female
taken to a room to be alone with him, then he would appear naked or wearing only a towel and
sexually batter or otherwise sexually exploit the underage minor female. He would then pay the
underage minor female for the sex acts he committed against her (typically between $200 and
$300 per molestation session, or as his criminal enterprise commonly refers to it — per
"massage"). Prior to leaving, Defendant Epstein's assistant would get the phone number of the
underage minor female and input it into his computer system or otherwise keep it on file. He
would then offer the underage minor female to return to his house to make money in exchange
for him committing sexual acts against her, and he also typically informed her of another option -
make more money recruiting and procuring other underage minor females for him to sexually
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abuse. He would tell the underage minor female that he will pay her for each underage minor
female that she brings to him (again, typically between $200 and $300), and he encouraged, and
oftentimes forcefully demanded, her to bring him as many underage minor females as she was
able. Through this general pitch, Defendant Epstein created a vast pyramid of underage minor
females recruiting and procuring other underage minor females for his purpose of coercing these
underage females into sexual acts for money.
14. Defendants Epstein and Kellen and the criminal enterprise specifically targeted
underprivileged and economically disadvantaged children to sexually exploit and molest and
otherwise prey upon the vulnerabilities of these young girls.
15. It is unknown exactly how long Defendant Epstein's aforementioned criminal enterprise
operated, although information and belief indicates that it was continuously and actively in
operation from at least 1998 through Defendant Epstein's criminal arrest in 2006.
16. The complete list of underage minor females that were sexually abused by Defendant
Epstein over the years is believed to have been kept on a computer system controlled by
Defendant Epstein and accessible by several of his employees, including Defendant Sarah
Kellen. It is also known that much of the data regarding the names, addresses and whereabouts
of each underage minor female was input by one of his assistants, including Defendant Kellen.
17. Defendant Sarah Kellen was listed in the Federal Non-prosecution Agreement related to
Defendant Epstein's criminal plea on sex charges against minors as a criminal co-conspirator for
her role in the criminal activity that was committed by Defendant Epstein against many underage
minor females. She was employed by Defendant Epstein to maintain his schedule, arrange for
underage minor females to be with Defendant Epstein, maintain contact with the underage minor
females, schedule the underage minor females' transportation to and from Defendant Epstein's
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mansion, and greet the underage minor female at the house before taking her upstairs to be alone
with Mr. Epstein. Upon information and belief, Defendant Kellen remains employed by
Defendant Epstein and continues to work for Defendant Epstein in furtherance of the goals of the
criminal enterprise.
18. Defendant Epstein used his vast wealth and power to lure underprivileged minor females
to him, and to coerce them into prostitution once he was alone with the underage minor female.
He sexually battered, molested, committed lewd and lascivious acts upon and otherwise
exploited numerous underage minor females and then gave them money. So long as the
underage minor female followed his demands and advances, he assumed the role of a friend or
mentor or father figure to the minor female in an attempt to groom the minor female; however, if
any minor female resisted his sexual advances, Defendant Epstein became frustrated, angry and
threatening towards the underage minor. His intent was to groom each minor female into
engaging in sexual acts with him as well as to "work" for him, i.c. bring him other underage
minor females to sexually molest, batter and exploit. He was masterful in his exploitation and
grooming of these minor females with an additional intent of gaining trust and cooperation from
these minors to prevent any one of them from reporting his criminal acts to law enforcement.
Certain of his many co-conspirator associates, including Ghislane Maxwell and Jean Luc Brunel,
helped in this recruiting process by creating the impression that legitimate modeling
opportunities were available for the minor females.
19. Through information and belief, Defendant Epstein has been successful in luring
hundreds of underage minor girls to him for the purpose of him (and sometimes others) sexually
abusing them. He intentionally preys upon underage minor females that are middle school or
high school children who are not working prostitutes, and he takes pleasure in using his power
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and influence to coerce these minor females into acts of prostitution with him personally and
sometimes with his friends and associates as well, including but not limited to Ghislaine
Maxwell and Nadia Marcinkova.
20. Over time, Defendant Epstein fine-tuned his operation to further his goals of gaining
access to a greater number and variety of underage girls while avoiding detection by law
enforcement. He also provided the roadmap for his enterprise should the illegal sexual
exploitation of the enterprise be detected — he or the criminal enterprise would (and did) retain
legal representation for each criminal enterprise member who would instruct each member to
invoke his/her S'h amendment rights, they would hide behind the 5th amendment to avoid turning
over incriminating materials (i.e. computer system that logged information about the underage
sexual molestation victims, scheduling books, message pads, and tangible items such as vibrators
and dildos), they would destroy evidence and refuse all cooperation with law enforcement.
21. The plan and scheme was developed by Defendant Epstein, and he and his assistants and
associates carried it out with each underage minor female in a well-planned and ritualistic
manner; Epstein ran this criminal enterprise as an experienced Mob boss would run any
organized crime family — in a well-planned, organized, arrogant and ruthless manner, with
complete cooperation from his co-conspirator associates and underlings and an absolute
dedication to carrying out the illegal operations of the criminal enterprise.
22. Defendant Epstein frequently traveled between his various mansions and either he or an
authorized agent would call to inform a recruiter, assistant, or scheduler at his next destination as
to his arrival time. His scheduler, usually Defendant Sarah Kellen, would then contact an
underage minor female and schedule her to be at Defendant Epstein's mansion or to bring
another underage minor female to his mansion at a particular time. Once the minor female was
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brought to Defendant Epstein's residence, she was greeted at the door of the mansion and lead
inside by one of Defendant Epstein's employees, oftentimes Defendant Sarah Kellen.
23. Defendant Sarah Kellen would lead the underage minor female up to Defendant Epstein's
room and leave the underage minor alone in the room. Defendant, Jeffrey Epstein, himself would
then appear naked or wearing only a towel. He would then demand a massage and during the
massage he would attempt, usually successfully, to perform one or more lewd, lascivious, and
sexual acts, including, but not limited to, masturbation, touching of the underage minor female's
sexual organs, coercing or forcing the underage minor female to perform sex acts with him,
using vibrators or sexual toys on the underage minor female, coercing the underage minor female
into sexual intercourse with himself or others, and digitally penetrating the underage minor
female. He would then give the Plaintiff money for engaging in this sexual activity.
24. Consistent with Defendants Epstein and Kellen's foregoing scheme or plan, in or around
the summer of 2002, Plaintiff, an economically poor and vulnerable child, was told by another
one of Epstein's underage minor sex abuse victims, that she could make $300 cash by giving an
old man a massage on Palm Beach.
25. Plaintiff's then minor acquaintance (also a sexual abuse victim of Epstein) telephoned
Defendant Epstein and scheduled for Plaintiff to go to Defendant Epstein's house to give him a
massage. During that call, Defendant Epstein himself got on the phone and spoke with Plaintiff
MJ and asked her personally to come to his mansion in Palm Beach.
26. Plaintiff then took a taxicab to Defendant Epstein's mansion and was greeted by
Epstein's top assistant, Defendant Sarah Kellen.
27. Defendant Kellen, in furtherance of the scheme to exploit Plaintiff, escorted Plaintiff
upstairs to Defendant Jeffrey Epstein's large bathroom, where Defendant Kellen set up the
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massage table and showed Plaintiff different massage lotions to use. Defendant Kellen then left
Plaintiff alone in the room. Plaintiff was alone in Defendant Epstein's bathroom until Defendant
Jeffrey Epstein emerged wearing only a towel.
28. Defendant Epstein then walked to the massage table that was already open in the room.
He lied face down on the table and told Plaintiff to start massaging him, at which time he
engaged in a conversation with Plaintiff. During the conversation, Defendant Epstein asked
Plaintiff her age and she told him she had recently turned 16.
29. Consistent with all of Defendant Epstein's known underage minor female victims,
Plaintiff had no massage experience whatsoever and she informed him of that, and Defendant
Epstein began instructing Plaintiff on how he liked his massage.
30. After approximately 15 minutes, Defendant Epstein turned over onto his back, and he
commanded Plaintiff to massage his chest.
31. Defendant Epstein then suddenly removed his towel and his penis was already erect. He
then commanded Plaintiff to remove her shin and bra and to begin "pinching his nipples" as he
began masturbating with his right hand.
32. As he was masturbating, Defendant Epstein began fondling Plaintiffs breasts.
33. Defendant Jeffrey Epstein, while masturbating with his right hand, reached out his left
hand and grabbed Plaintiff's vagina and butt over her clothes. Plaintiff pushed Defendant's hand
away and told him repeatedly not to touch her like that. Epstein was persistent in his attempt to
grab Plaintiff's vagina and continued to grab her vagina and butt on multiple occasions after she
told him not to.
34. Defendant Epstein continued to masturbate his exposed penis until he ejaculated in front
of the then minor Plaintiff.
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35. Plaintiff was shocked and embarrassed by the events and Defendant Epstein talked to her
to persuade her that everything he was doing with he was normal.
36. Epstein paid Plaintiff $300 for allowing him to grope her and masturbate in her presence.
37. Plaintiff returned to Epstein's home on approximately 20 occasions. On each occasion
Epstein grabbed Plaintiff's bare breasts, exposed his penis, masturbated and ejaculated in
Plaintiff's presence, and paid her $300 each time.
38. Defendant Epstein coerced Plaintiff into acts of prostitution, preying on her low
economic status and troubled upbringing, complimenting Plaintiff for being "special" to him and
having a "very pretty body" and making promises to Plaintiff such as — he told Plaintiff that if
she graduated high school, then he would buy her a computer, something that she wanted yet
could not afford.
39. On multiple occasions Defendant Epstein pressured Plaintiff to bring him other underage
minor females to abuse; he told Plaintiff that he would pay her $300 for each girl she brought
him, but Plaintiff refused to bring other girls.
40. Defendant Epstein told Plaintiff that he would pay her more money if she would give him
oral sex and that he would pay her $600 for actual sexual intercourse. Plaintiff refused.
41. Defendant Epstein personally called Plaintiff at least five times to tell her when she
should be at his house to "work" or give him a "massage" (Epstein's criminal enterprise's
learned code words for paying minors for Epstein and others to interact with them sexually).
42. Every other time (approximately 15) Defendant Kellen called to inform Plaintiff of the
date and time when she needed and was expected to be at Epstein's mansion to "work".
43. The acts referenced above, committed by Defendant, Jeffrey Epstein, against the then
minor Plaintiff were committed in violation of numerous State and Federal criminal statutes
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condemning battery, assault and the exploitation of minor children, contributing to the
delinquency of a minor and other crimes, specifically including, but not limited to, those criminal
offenses outlined in Chapters 796, 800, and 827 of the Florida Statutes, as well as those
designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §796.09, §39.01, §450.151,
and §827.04.
44. The above-described acts took place in Palm Beach County, Florida at the residence of
the Defendant, Jeffrey Epstein. Any assertions by Defendants, Jeffrey Epstein and Sarah Kellen,
that they were unaware of the age of the then minor Plaintiff are belied by their actions and
rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual
exploitation and abuse of a minor child. The Defendants, Jeffrey Epstein and Sarah Kellen, at all
times material to this cause of action, knew and should have known of the Plaintiffs minority as
Plaintiff specifically told Epstein her age and Defendant Epstein and criminal organization has a
history of seeking out underage minor children to sexually abuse. In fact, one primary goal of
the organization is to sexually abuse females who are under the age of 18, and oftentimes
Defendant Epstein has turned away females (i.e. refused to engage in sexual acts with them) for
being "too old" once she reaches 18 years of age, and he has reprimanded girls for bringing him
other girls who are over the age of majority.
45. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, Defendant
Epstein entered pleas of "guilty" to various Florida State crimes related to his exploitation of
minors for sex.
46. As a condition of that plea and in exchange for the Federal Government entering into a
Non-Prosecution Agreement with Defendant Epstein, wherein the Federal Government agreed to
effectively stay any prosecution of Jeffrey Epstein, Sarah Kellen and other criminal co-
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conspirators Nadia Marcinkova and Leslie Groff, Defendant Epstein agreed to admit that
approximately 40 underage minor females, whose names were provided to Defendant Epstein,
were his victims. Plaintiff was not included in that list as she moved away from the West Palm
Beach area in part to escape from Epstein, and she has lived in fear of Epstein and his
organization and has not yet been contacted by law enforcement.
47. Beginning in or about June 2008 and continuing to the present time, defendant Epstein
has been aware he faces significant financial liability for his sexual offenses, both to MJ and to
many other similarly-situated girls whom he abused. MJ and these other girls are creditors of
Epstein, in that have filed and can file tort actions against him under both Florida and Federal
laws. Accordingly, Epstein has conveyed substantial assets and property into the names of other
persons and into overseas bank accounts and other financial institutions. These assets and
properties could have been attachable and used to pay the debts owed to MJ and to the other girls
that Epstein has abused.
48. As an example of the fraudulent conveyances that Epstein has attempted, in
approximately October 2009, Epstein placed his personal 727 aircraft up for sale, with the intent
that the proceeds of that sale would be hidden so that MJ and other creditors of Epstein would
not be able to secure payment from that substantial asset.
49. While Epstein is clearly distinct from the criminal enterprise that he oversees that asset,
as well as his other airplanes and helicopters and other assets, have been used continuously and
repeatedly to further the interest and endeavors of Epstein and his criminal enterprise.
50. As another example of the fraudulent transfers that Epstein has made, Epstein has titled a
Ford F-I50 Truck in the name of Larry Visoki (Epstein's personal pilot). Visoski was unaware
that the truck was titled in his name when he was questioned under oath in a deposition.
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51. In approximately 2009, Defendant Epstein purchased a $68,000 Land Rover and
registered it in Visoski's name with the intent to hide this asset from MJ and other creditors.
52. In approximately 2009, Defendant Epstein purchased a Mercedes-Benz 2005 by wiring
funds to Visoski and then placing the car in Visoski's name.
53. In approximately 2009, Defendant Epstein bought a Jaguar X-Type 2005 so that he
(Epstein) would have another car around Palm Beach available for his friends to use and then
placed the car in Visoski's name.
54. In approximately September 2009, Visoski attempted to sell a Ferrari owned by Epstein
for $159,000. Epstein intended for the sale to hide the value of this Ferrari and prevent MJ and
other creditors from recovering from him.
55. Epstein is concealing substantial assets through a new corporation, Shmitka Air, Inc.,
whose representative is Larry Visoski. In September 2010, Epstein attempted to sell a 1999 Bell
Helicopter for approximately $1,900,000. This sale was an attempt to prevent MJ and other
creditors from recovering from him.
56. Epstein is also concealing substantial assets through an entity known at JEGE, Inc. He is
currently attempting to sell an aircraft for $10,000,000 through that entity in an attempt to
prevent MJ and other creditors from recovering from him.
57. Through information and belief, Epstein and/or his criminal enterprise provides the
financial support for his various employees, co-conspirators, other criminal enterprise members
and associates.
58. In addition to Epstein's various houses, he owns or controls other condominiums,
including approximately 8 to 10 units at 301 East 66 Street, in New York City, where certain of
his or his Criminal Enterprise associates live or reside, including Jean Luc Brunel, Nadia
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Marcinkova, Sarah Kellen, and at times various underage minor girls are stashed at this location
as well.
59. Defendant Epstein has numerous overseas contacts and accounts and sophistication in
international business transactions. He previously served as a trader at Bcar Steams and founded
his own financial management firm, J. Epstein and Col. (later called Financial Trust Co.) located
on his private island in the U.S. Virgin Islands where, until his recent incarceration, according to
him he allegedly managed the assets of billionaire clients.
60. After extensive investigation into Epstein's employment history, including questioning of
Epstein's family, those whom Epstein considers friends and longtime employees of Epstein, the
only known client of Epstein was Limited, Inc. Founder Leslie Wexner, although it is believed
that even that relationship has been severed. No other legitimate means of income have been
reported.
COUNT I
BATTERY AGAINST DEFENDANT EPSTEIN
61. Plaintiff M.J. adopts and =lieges paragraphs I through 60 above.
62. In the summer of 2002, just after Plaintiff turned 16 years old, Defendant Epstein
committed battery against Plaintiff when he intentionally touched intimate areas of her body and
person in an offensive manner while she was a minor child.
63. Defendant Epstein intentionally touched Plaintiff MJ's private areas multiple times
against the will of MJ.
64. Defendant Epstein's tortious commission of battery upon Plaintiff was done willfully.
65. As a direct and proximate result of the offenses committed by Defendant Epstein against
the then minor Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain
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and suffering, emotional distress, psychological and psychiatric trauma, mental anguish,
humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of
life, invasion of her privacy and other damages associated with Defendant's manipulation and
leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and
psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
income in the future, and loss of proper and complete education. These injuries are permanent in
nature and Plaintiff MJ will continue to suffer these losses in the future.
WHEREFORE, Plaintiff MJ demands judgment against Defendant Epstein for
compensatory damages, punitive damages and such other relief as this Court deems proper and
hereby demands trial by jury on all issues triable as of right by a jury.
COUNT II
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
AGAINST DEFENDANT EPSTEIN
66. The Plaintiff adopts and realleges paragraphs 1 through 60 above.
67. Defendant Epstein's extreme and outrageous conduct towards the then minor Plaintiff
was intentional and reckless.
68. Defendant Epstein acted with the intent to cause severe emotional distress or with
reckless disregard for the high probability of causing severe emotional distress.
69. As a direct and proximate result of the offenses committed by Defendant Epstein against
the then minor Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain
and suffering, emotional distress, psychological and psychiatric trauma, mental anguish,
humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of
life, invasion of her privacy and other damages associated with Defendant's manipulation and
leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and
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psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
income in the future, loss of proper and complete education. These injuries are permanent in
nature and Plaintiff MJ will continue to suffer these losses in the future.
WHEREFORE, Plaintiff M.J. demands judgment against Defendant Epstein for
compensatory damages, punitive damages and such other relief as this Court deems proper and
hereby demands trial by jury on all issues triable as of right by a jury.
COUNT III
CONSPIRACY TO COMMIT TORTIOUS ASSAULT OR BATTERY AGAINST
DEFENDANT SARAH KELLEN
70. The Plaintiff adopts and realleges paragraphs I through 60 above.
71. Defendant Kellen is one of Defendant Epstein's top assistants, as referenced previously
in this Complaint. Defendant Epstein, Defendant Kellen and others reached an agreement
amongst and between them and otherwise conspired for the purpose of allowing Defendant
Epstein and others to commit the tortious and illegal acts described above against Plaintiff MJ.
72. Defendant Kellen aided, abetted and assisted Defendant Epstein in his organized scheme
and plan to sexually exploit Plaintiff and commit battery against her and/or commit or attempt to
commit numerous other crimes against her, including coercing her into prostitution.
73. Defendant Kellen conspired with Defendant Epstein to commit tortious and illegal
conduct against Plaintiff, and in furtherance of the conspiracy Kellen specifically engaged in
overt acts such as contacting Plaintiff MJ on many occasions, scheduling the then minor
Plaintiffs appointment for a "massage" knowing that Defendant Epstein was going to commit
battery against Plaintiff, attempt sexual battery against Plaintiff, and force her into prostitution
and otherwise did everything in her ability to conceal the illegal operation and refuse cooperation
with law enforcement.
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74. Additionally, Defendant Kellen greeted Plaintiff on the occasions when Plaintiff arrived
at Epstein's home and personally lead Plaintiff to Defendant Epstein's bathroom where Epstein
appeared for the purposes of committing crimes against Plaintiff.
75. Defendant Epstein's battery against Plaintiff was facilitated by Defendant Kellen and the
conspiracy resulted in the various aforementioned crimes being committed against Plaintiff MJ
as well as many other underage minor females.
76. As a direct and proximate result of Defendant, Sarah Kellen's, participation in the
aforementioned conspiracy, Plaintiff, MJ, she has in the past suffered and will in the future suffer
injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental
anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of
enjoyment of life, invasion of her privacy and other damages associated with Defendant's
manipulation and leading her into a perverse and unhealthy way of life. Plaintiff will incur
medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the
capacity to earn income in the future, loss of proper and complete education. These injuries are
permanent in nature and Plaintiff MJ will continue to suffer these losses in the future.
WHEREFORE, Plaintiff MJ demands judgment against Defendant Sarah Kellen for
compensatory damages, punitive damages and such other relief as this Court deems proper and
hereby demands trial by jury on all issues triable as of right by a jury.
COUNTS IV THROUGH XXIII
CAUSES OF ACTION AGAINST DEFENDANTS EPSTEIN AND KELLEN PURSUANT
TO IS USC 42255 IN VIOLATION OF VARIOUS ENUMERATED OFFENSES
CONTAINED WITHIN THAT FEDERAL STATUTE
77. Plaintiff, MJ, adopts and realleges paragraphs I through 60 above.
78. The allegations contained herein in Counts IV through XXIII are separate and distinct
legal remedies.
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79. As a condition of Defendant, Jeffrey Epstein's criminal plea, and in exchange for the
Federal Government not prosecuting the Defendant for numerous federal offenses, the
Defendant, Jeffrey Epstein, entered into a Non-Prosecution Agreement with the Federal
Government; that agreement governed not only Defendant Epstein's conduct but also the
conduct of his "co-conspirators" including Defendant Kellen as she played an essential and
criminal role in the commission of these offenses.
80. The Plaintiff, MJ, was in fact a victim of one or more offenses enumerated in Title 18,
United States Code, Section 2255, and as such asserts a cause of action against the Defendant,
Jeffrey Epstein, and against Defendant Kellen pursuant to this Section of the United States Code
and the agreement between the Defendant, Jeffrey Epstein, and the United States Government.
81. Specifically, Defendants Epstein and Kellen:
(a) knowingly conspired with others known and unknown to use a facility or
means of interstate commerce to knowingly persuade, induce, or entice minor females,
including Plaintiff MJ, to engage in prostitution, in violation of title IS, United States
Code, Section 2422(b).
(b) knowingly and willfully conspired with others known and unknown to travel
in interstate commerce for the purpose of engaging in illicit sexual conduct with minors,
including Plaintiff MJ, as defined in 18 U.S.C. § 2423(f), with minor females, in violation
of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United
States Code, Section 2423(e);
(c) used a facility or means of interstate or foreign commerce to knowingly
persuade, induce, or entice minor females, including Plaintiff MJ, to engage in
prostitution; in violation of Title 18, United States Code, Section 2422(b);
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(d) traveled in interstate commerce for the purpose of engaging in illicit sexual
conduct, as defined in 18 U.S.C. § 2423(f), with minor females, including Plaintiff MJ; in
violation of Title 18, United States Code, Section 2423(b).
82. As a direct and proximate result of the aforementioned criminal offenses enumerated in
Title IS, United States Code, Section 2255, being committed against the then minor Plaintiff,
Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain and suffering,
emotional distress, psychological and psychiatric trauma, mental anguish, humiliation,
confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of life, invasion
of her privacy and other damages associated with Defendant's manipulation and leading her into
a perverse and unhealthy way of life. Plaintiff will incur medical and psychological expenses.
These injuries are permanent in nature and Plaintiff MJ will continue to suffer these losses in the
future. Plaintiff, M.J., has also incurred attorneys' fees.
83. With regard to each of the following counts, Plaintiff suffered personal injury, as outlined
above from the acts above, as a result of the violations of federal criminal law by Defendant
Epstein enumerated in paragraph 33, on approximately 20 occasions, and while the dates are not
all precisely documented or diaried by Plaintiff, Defendants Epstein and Kellen committed these
crimes and inflicted said injuries on or about the following dates:
COUNT IV August 2002
COUNT V September 2002
COUNT VI October 2002
COUNT VII November 2002
COUNT VIII December 2002
COUNT IX January 2003
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COUNT X February 2003
COUNT XI March 2003
COUNT XII April 2003
COUNT XIII May 2003
COUNT XIV June 2003
COUNT XV July 2003
COUNT XVI August 2003
COUNT XVII September 2003
COUNT XVIII October 2003
COUNT XIX November 2003
COUNT XX December 2003
COUNT XXI January 2004
COUNT XXII February 2004
COUNT XXIII March 2004
WHEREFORE, with regard to each and every one of these counts, Plaintiff, MJ,
demands judgment against Defendant, Jeffrey Epstein, for compensatory damages, loss of
income, a loss of the capacity to earn income in the future, attorney's fees, and such other and
further relief as this Court deems just and proper, and hereby demands trial by jury on all issues
triable as of right by a jury.
COUNT XXIV
Civil Remedy for Criminal Practices
84. Plaintiff realleges paragraphs I through 60 above and for the purposes of this count
incorporates and alleges the RICO Statement that has been filed contemporaneously herewith as
Exhibit "A."
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85. The allegations contained herein in Count XXIV are a separate and distinct legal remedy
brought pursuant to Florida Statute 772.104(1) and (2).
86. Defendant, Jeffrey Epstein, was associated with an enterprise, a group of individuals
associated in fact although not a legal entity, which was comprised of at least Defendant Jeffrey
Epstein, Sarah Kellen, Leslie Groff, Jean Luc Brunel, Ghislaine Maxwell, and Nadia Marcinkova
(and likely many other yet unknown persons); Defendant Epstein participated in this enterprise,
or conspired or endeavored to so participate, through a pattern of criminal activity in violation of
Florida Statutes §772.103(3)-(4), as further outlined in detail in the RICO statement filed with
this court.
87. This enterprise was separate and distinct from Epstein himself and had a definite
hierarchical structure. Epstein served informally but effectively as the leader, C.E.O. or "boss"
of this organization similar to the way an experienced mob boss runs his organized crime family,
directing his underlings how to recruit and procure underage girls for his sexual activities and the
sexual activities of others, developing the use of slang or code words to be used to discuss the
illegal activities of the organization, designing a plan or scheme to gain the cooperation of
underage minor females, developing methods and techniques to otherwise avoid detection from
law enforcement including making large charitable donations to law enforcement agencies,
powerful politicians, businessmen and world leaders, associating with powerful social people
and highly influential politicians and attorneys, gathering information to blackmail or extort
powerful people, devising a plan to attack the credibility and character of anyone that dare unveil
the illegal operations of the enterprise and to take an oath to remain silent and/or lie when
confronted by law enforcement about the illegal operations and activities of the criminal
organization. Epstein's key "lieutenant" in the local Palm Beach branch of the National
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organization was Kellen, who served as both his scheduler and a recruiter/procurer of the girls.
Marcinkova also served as a recruiter and helped Epstein satisfy his criminal sexual desires by,
on occasion, directly participating in sexual abuse and prostitution of the minor girls. Epstein
also used otherwise-legitimate business activities to help further the purpose of the criminal
enterprise. These apparently legitimate activities provided "cover" for Epstein and his associates
to commit the crimes. Epstein and his associates maintained the appearance of running an
upstanding investment business, as well as other legitimate businesses with connections to
modeling agencies and other powerful business and political people, to discourage the minor
girls from reporting the abuse to law enforcement. Ghislane Maxwell and Jean Luc Brunel
helped to provide "cover" by creating the impression that legitimate modeling opportunities were
available for the girls. There are many other known and unknown associates of the criminal
organization, that worked throughout the country and possibly internationally, who performed
functions to perpetuate the criminal activities of the organization.
88. Defendant Jeffrey Epstein participated in this enterprise through a pattern of criminal
activity in that he engaged in at least two incidents of criminal activity, as defined and required
in Florida Statute 772.102 and as described below, that have the same or similar intents, results,
accomplices, victims, or methods of commission and are not isolated incidents.
89. Defendant Jeffrey Epstein engaged in criminal activity by committing, attempting to
commit, conspiring to commit or soliciting, coercing or intimidating another person to commit
one or more of the following predicate acts as outlined and defined in Florida Statute 772.102:
(a) Procuring for prostitution, or causing to be prostituted, any person who is
under the age of 18 years in violation of Florida Statutes Chapter 796.03;
(b) Acts of battery in violation of Florida Statutes Chapter 784;
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(c) Forcing, compelling or coercing another to become a prostitute in
violation ofFlorida Statutes Chapter 796.04;
(d) knowingly recruiting, enticing, harboring, transporting, providing or
otherwise obtaining by any means a person, knowing that coercion would be used to
cause that person to engage in prostitution in violation of Florida Statutes Chapter
796.045;
(e) tampering with a witness in violation of Florida Statutes Chapter 914.22;
(f) altering, destroying, removing, or concealing records or documents or
other evidence with the purpose to impair its verity or availability in violation of Florida
Statutes Chapter 918.13;
(g) maintaining a place (or more accurately "places") for the purpose of
lewdness or prostitution; offering or securing another for the purpose of prostitution or
for some other lewd or indecent act; receiving persons into his Palm Beach mansion for
the purpose of prostitution or lewdness; directing, taking or transporting or agreeing to
direct take or transport persons to his Palm Beach mansion with knowledge or reasonable
belief that the purpose of such directing, taking or transporting was prostitution or
lewdness; all in violation of Florida Statutes Chapter 796.07.
90. The criminal acts of Defendant Epstein occurred repeatedly over a substantial period of
time and were not isolated events.
91. Under Defendant, Jeffrey Epstein's plan, scheme, and enterprise, Defendant, Jeffrey
Epstein, paid employees and underlings, including but not limited to Sarah Kellen, to bring him
minor girls to his Palm Beach mansion in order for the Defendant to solicit, induce, coerce,
entice, compel or force such girls to engage in acts of prostitution and sexual misconduct with
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Defendant Epstein and sometimes Nadia Marcinkova, and to otherwise commit acts of sexual
battery thereon, and further Defendant Epstein worked in concert as part of the enterprise with
those who were free to act independently and advance their own interests, including Ghislaine
Maxwell and Jean Luc Brunel, to obtain minor girls for sexual purposes.
92. Plaintiff, MJ, was the victim of Defendant, Jeffrey Epstein's plan, scheme, and enterprise
and was so injured by reason of his violations of the provisions of s. 772.104. Plaintiff, MJ, was
called
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.:
M.J.,
Plaintiff,
vs.
JEFFREY EPSTEIN and
SARAH KELLEN,
Defendants.
COMPLAINT
Plaintiff, M.J., by and through her undersigned counsel, sues the Defendants, Jeffrey
Epstein and Sarah Kellen, and alleges:
I. This is an action in an amount in excess of $15,000.00, exclusive of interest and costs and
is within the jurisdictional limits of this Court.
2. This Complaint is brought under a fictitious name in order to protect the identity of the
Plaintiff because this Complaint makes allegations of sensitive nature of offenses against a then
minor child.
3. At all times material to this cause of action, the Plaintiff, M.J. (hereinafter referred to as
"Plaintiff"), was a resident of Palm Beach County, Florida.
4. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence
located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida.
5. Defendant, Jeffrey Epstein, is currently a citizen of the United States Virgin Islands.
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6. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult
male born in 1953.
7. Defendant, Sarah Kellen, is currently a citizen ofNew York, where she currently resides.
8. At all times material, the Defendants Jeffrey Epstein and Sarah Kellen both owed a duty
unto Plaintiff to treat her in a non-negligent manner and to not commit or conspire to commit
intentional or tortious illegal acts against her.
FACTUAL ALLEGATIONS
9. At all times material, Defendant, Jeffrey Epstein, was an adult male, over 50 years old.
Defendant Epstein is known as a billionaire, yet even those closest to him, including family
members, long time employees and those that he considers his closest friends have no idea what
he does or did to earn money to support his lifestyle.
10. Defendant Epstein owns, directly or through nominee individuals used to conceal his
interests, a fleet of airplanes, motor vehicles, boats and a helicopter. He owns numerous
properties and homes, including a 51,000-square-foot mansion in Manhattan, a $30 Million
7,500-acre ranch in New Mexico, a 70-acre private island formerly known as Little St. James in
St. Thomas, U.S. Virgin Islands (he is alleged to have renamed this island Little St. Jeff's after
himself), a mansion in London, England, a home in Paris, France, and a mansion in Palm Beach
County, FL. The allegations herein primarily concern the defendant's conduct while at his
mansion in Palm Beach County, FL.
II. Defendant Epstein has a sexual preference and obsession for underage minor females,
specifically targeting female children age 12 to 17, and Defendant Epstein acts on that obsession
by luring underage minor females to him where he attempts to sexually molest and batter these
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underage minor females on an everyday basis, oftentimes 2 or 3 different underage minor
females on one day.
12. Sometime prior to 1998, Defendant Epstein devised a complex plan, scheme and criminal
enterprise to gain access to countless underage minor females, some as young as 12 years old, for
the purpose of coercing the minor females into various acts of sexual misconduct that he
committed upon them. His enterprise operated with a definite hierarchal structure with his
various employees/assistants and associates, including Defendant Sarah Kellen, Jean Luc Brunel,
Ghislaine Maxwell, Leslie Groff. Adriana Ross. Nadia Marcinkova, various housekeepers,
butlers and pilots, performing their respective roles to ensure the goals of the enterprise: operate
an organized and efficient system to maximize the number of underage minor females for
Defendant Epstein (and others) to sexually abuse and exploit while avoiding law enforcement
detection.
13. Defendant Epstein, with help from his assistants and associates, recruited and procured
underage minor females, lured them to one of his mansions, had the underage minor female
taken to a room to be alone with him, then he would appear naked or wearing only a towel and
sexually batter or otherwise sexually exploit the underage minor female. He would then pay the
underage minor female for the sex acts he committed against her (typically between $200 and
$300 per molestation session, or as his criminal enterprise commonly refers to it — per
"massage"). Prior to leaving, Defendant Epstein's assistant would get the phone number of the
underage minor female and input it into his computer system or otherwise keep it on file. He
would then offer the underage minor female to return to his house to make money in exchange
for him committing sexual acts against her, and he also typically informed her of another option -
make more money recruiting and procuring other underage minor females for him to sexually
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abuse. He would tell the underage minor female that he will pay her for each underage minor
female that she brings to him (again, typically between $200 and $300), and he encouraged, and
oftentimes forcefully demanded, her to bring him as many underage minor females as she was
able. Through this general pitch, Defendant Epstein created a vast pyramid of underage minor
females recruiting and procuring other underage minor females for his purpose of coercing these
underage females into sexual acts for money.
14. Defendants Epstein and Kellen and the criminal enterprise specifically targeted
underprivileged and economically disadvantaged children to sexually exploit and molest and
otherwise prey upon the vulnerabilities of these young girls.
15. It is unknown exactly how long Defendant Epstein's aforementioned criminal enterprise
operated, although information and belief indicates that it was continuously and actively in
operation from at least 1998 through Defendant Epstein's criminal arrest in 2006.
16. The complete list of underage minor females that were sexually abused by Defendant
Epstein over the years is believed to have been kept on a computer system controlled by
Defendant Epstein and accessible by several of his employees, including Defendant Sarah
Kellen. It is also known that much of the data regarding the names, addresses and whereabouts
of each underage minor female was input by one of his assistants, including Defendant Kellen.
17. Defendant Sarah Kellen was listed in the Federal Non-prosecution Agreement related to
Defendant Epstein's criminal plea on sex charges against minors as a criminal co-conspirator for
her role in the criminal activity that was committed by Defendant Epstein against many underage
minor females. She was employed by Defendant Epstein to maintain his schedule, arrange for
underage minor females to be with Defendant Epstein, maintain contact with the underage minor
females, schedule the underage minor females' transportation to and from Defendant Epstein's
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mansion, and greet the underage minor female at the house before taking her upstairs to be alone
with Mr. Epstein. Upon information and belief, Defendant Kellen remains employed by
Defendant Epstein and continues to work for Defendant Epstein in furtherance of the goals of the
criminal enterprise.
18. Defendant Epstein used his vast wealth and power to lure underprivileged minor females
to him, and to coerce them into prostitution once he was alone with the underage minor female.
He sexually battered, molested, committed lewd and lascivious acts upon and otherwise
exploited numerous underage minor females and then gave them money. So long as the
underage minor female followed his demands and advances, he assumed the role of a friend or
mentor or father figure to the minor female in an attempt to groom the minor female; however, if
any minor female resisted his sexual advances, Defendant Epstein became frustrated, angry and
threatening towards the underage minor. His intent was to groom each minor female into
engaging in sexual acts with him as well as to "work" for him, i.c. bring him other underage
minor females to sexually molest, batter and exploit. He was masterful in his exploitation and
grooming of these minor females with an additional intent of gaining trust and cooperation from
these minors to prevent any one of them from reporting his criminal acts to law enforcement.
Certain of his many co-conspirator associates, including Ghislane Maxwell and Jean Luc Brunel,
helped in this recruiting process by creating the impression that legitimate modeling
opportunities were available for the minor females.
19. Through information and belief, Defendant Epstein has been successful in luring
hundreds of underage minor girls to him for the purpose of him (and sometimes others) sexually
abusing them. He intentionally preys upon underage minor females that are middle school or
high school children who are not working prostitutes, and he takes pleasure in using his power
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and influence to coerce these minor females into acts of prostitution with him personally and
sometimes with his friends and associates as well, including but not limited to Ghislaine
Maxwell and Nadia Marcinkova.
20. Over time, Defendant Epstein fine-tuned his operation to further his goals of gaining
access to a greater number and variety of underage girls while avoiding detection by law
enforcement. He also provided the roadmap for his enterprise should the illegal sexual
exploitation of the enterprise be detected — he or the criminal enterprise would (and did) retain
legal representation for each criminal enterprise member who would instruct each member to
invoke his/her S'h amendment rights, they would hide behind the 5th amendment to avoid turning
over incriminating materials (i.e. computer system that logged information about the underage
sexual molestation victims, scheduling books, message pads, and tangible items such as vibrators
and dildos), they would destroy evidence and refuse all cooperation with law enforcement.
21. The plan and scheme was developed by Defendant Epstein, and he and his assistants and
associates carried it out with each underage minor female in a well-planned and ritualistic
manner; Epstein ran this criminal enterprise as an experienced Mob boss would run any
organized crime family — in a well-planned, organized, arrogant and ruthless manner, with
complete cooperation from his co-conspirator associates and underlings and an absolute
dedication to carrying out the illegal operations of the criminal enterprise.
22. Defendant Epstein frequently traveled between his various mansions and either he or an
authorized agent would call to inform a recruiter, assistant, or scheduler at his next destination as
to his arrival time. His scheduler, usually Defendant Sarah Kellen, would then contact an
underage minor female and schedule her to be at Defendant Epstein's mansion or to bring
another underage minor female to his mansion at a particular time. Once the minor female was
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brought to Defendant Epstein's residence, she was greeted at the door of the mansion and lead
inside by one of Defendant Epstein's employees, oftentimes Defendant Sarah Kellen.
23. Defendant Sarah Kellen would lead the underage minor female up to Defendant Epstein's
room and leave the underage minor alone in the room. Defendant, Jeffrey Epstein, himself would
then appear naked or wearing only a towel. He would then demand a massage and during the
massage he would attempt, usually successfully, to perform one or more lewd, lascivious, and
sexual acts, including, but not limited to, masturbation, touching of the underage minor female's
sexual organs, coercing or forcing the underage minor female to perform sex acts with him,
using vibrators or sexual toys on the underage minor female, coercing the underage minor female
into sexual intercourse with himself or others, and digitally penetrating the underage minor
female. He would then give the Plaintiff money for engaging in this sexual activity.
24. Consistent with Defendants Epstein and Kellen's foregoing scheme or plan, in or around
the summer of 2002, Plaintiff, an economically poor and vulnerable child, was told by another
one of Epstein's underage minor sex abuse victims, that she could make $300 cash by giving an
old man a massage on Palm Beach.
25. Plaintiff's then minor acquaintance (also a sexual abuse victim of Epstein) telephoned
Defendant Epstein and scheduled for Plaintiff to go to Defendant Epstein's house to give him a
massage. During that call, Defendant Epstein himself got on the phone and spoke with Plaintiff
MJ and asked her personally to come to his mansion in Palm Beach.
26. Plaintiff then took a taxicab to Defendant Epstein's mansion and was greeted by
Epstein's top assistant, Defendant Sarah Kellen.
27. Defendant Kellen, in furtherance of the scheme to exploit Plaintiff, escorted Plaintiff
upstairs to Defendant Jeffrey Epstein's large bathroom, where Defendant Kellen set up the
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massage table and showed Plaintiff different massage lotions to use. Defendant Kellen then left
Plaintiff alone in the room. Plaintiff was alone in Defendant Epstein's bathroom until Defendant
Jeffrey Epstein emerged wearing only a towel.
28. Defendant Epstein then walked to the massage table that was already open in the room.
He lied face down on the table and told Plaintiff to start massaging him, at which time he
engaged in a conversation with Plaintiff. During the conversation, Defendant Epstein asked
Plaintiff her age and she told him she had recently turned 16.
29. Consistent with all of Defendant Epstein's known underage minor female victims,
Plaintiff had no massage experience whatsoever and she informed him of that, and Defendant
Epstein began instructing Plaintiff on how he liked his massage.
30. After approximately 15 minutes, Defendant Epstein turned over onto his back, and he
commanded Plaintiff to massage his chest.
31. Defendant Epstein then suddenly removed his towel and his penis was already erect. He
then commanded Plaintiff to remove her shin and bra and to begin "pinching his nipples" as he
began masturbating with his right hand.
32. As he was masturbating, Defendant Epstein began fondling Plaintiffs breasts.
33. Defendant Jeffrey Epstein, while masturbating with his right hand, reached out his left
hand and grabbed Plaintiff's vagina and butt over her clothes. Plaintiff pushed Defendant's hand
away and told him repeatedly not to touch her like that. Epstein was persistent in his attempt to
grab Plaintiff's vagina and continued to grab her vagina and butt on multiple occasions after she
told him not to.
34. Defendant Epstein continued to masturbate his exposed penis until he ejaculated in front
of the then minor Plaintiff.
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35. Plaintiff was shocked and embarrassed by the events and Defendant Epstein talked to her
to persuade her that everything he was doing with he was normal.
36. Epstein paid Plaintiff $300 for allowing him to grope her and masturbate in her presence.
37. Plaintiff returned to Epstein's home on approximately 20 occasions. On each occasion
Epstein grabbed Plaintiff's bare breasts, exposed his penis, masturbated and ejaculated in
Plaintiff's presence, and paid her $300 each time.
38. Defendant Epstein coerced Plaintiff into acts of prostitution, preying on her low
economic status and troubled upbringing, complimenting Plaintiff for being "special" to him and
having a "very pretty body" and making promises to Plaintiff such as — he told Plaintiff that if
she graduated high school, then he would buy her a computer, something that she wanted yet
could not afford.
39. On multiple occasions Defendant Epstein pressured Plaintiff to bring him other underage
minor females to abuse; he told Plaintiff that he would pay her $300 for each girl she brought
him, but Plaintiff refused to bring other girls.
40. Defendant Epstein told Plaintiff that he would pay her more money if she would give him
oral sex and that he would pay her $600 for actual sexual intercourse. Plaintiff refused.
41. Defendant Epstein personally called Plaintiff at least five times to tell her when she
should be at his house to "work" or give him a "massage" (Epstein's criminal enterprise's
learned code words for paying minors for Epstein and others to interact with them sexually).
42. Every other time (approximately 15) Defendant Kellen called to inform Plaintiff of the
date and time when she needed and was expected to be at Epstein's mansion to "work".
43. The acts referenced above, committed by Defendant, Jeffrey Epstein, against the then
minor Plaintiff were committed in violation of numerous State and Federal criminal statutes
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condemning battery, assault and the exploitation of minor children, contributing to the
delinquency of a minor and other crimes, specifically including, but not limited to, those criminal
offenses outlined in Chapters 796, 800, and 827 of the Florida Statutes, as well as those
designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §796.09, §39.01, §450.151,
and §827.04.
44. The above-described acts took place in Palm Beach County, Florida at the residence of
the Defendant, Jeffrey Epstein. Any assertions by Defendants, Jeffrey Epstein and Sarah Kellen,
that they were unaware of the age of the then minor Plaintiff are belied by their actions and
rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual
exploitation and abuse of a minor child. The Defendants, Jeffrey Epstein and Sarah Kellen, at all
times material to this cause of action, knew and should have known of the Plaintiffs minority as
Plaintiff specifically told Epstein her age and Defendant Epstein and criminal organization has a
history of seeking out underage minor children to sexually abuse. In fact, one primary goal of
the organization is to sexually abuse females who are under the age of 18, and oftentimes
Defendant Epstein has turned away females (i.e. refused to engage in sexual acts with them) for
being "too old" once she reaches 18 years of age, and he has reprimanded girls for bringing him
other girls who are over the age of majority.
45. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, Defendant
Epstein entered pleas of "guilty" to various Florida State crimes related to his exploitation of
minors for sex.
46. As a condition of that plea and in exchange for the Federal Government entering into a
Non-Prosecution Agreement with Defendant Epstein, wherein the Federal Government agreed to
effectively stay any prosecution of Jeffrey Epstein, Sarah Kellen and other criminal co-
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conspirators Nadia Marcinkova and Leslie Groff, Defendant Epstein agreed to admit that
approximately 40 underage minor females, whose names were provided to Defendant Epstein,
were his victims. Plaintiff was not included in that list as she moved away from the West Palm
Beach area in part to escape from Epstein, and she has lived in fear of Epstein and his
organization and has not yet been contacted by law enforcement.
47. Beginning in or about June 2008 and continuing to the present time, defendant Epstein
has been aware he faces significant financial liability for his sexual offenses, both to MJ and to
many other similarly-situated girls whom he abused. MJ and these other girls are creditors of
Epstein, in that have filed and can file tort actions against him under both Florida and Federal
laws. Accordingly, Epstein has conveyed substantial assets and property into the names of other
persons and into overseas bank accounts and other financial institutions. These assets and
properties could have been attachable and used to pay the debts owed to MJ and to the other girls
that Epstein has abused.
48. As an example of the fraudulent conveyances that Epstein has attempted, in
approximately October 2009, Epstein placed his personal 727 aircraft up for sale, with the intent
that the proceeds of that sale would be hidden so that MJ and other creditors of Epstein would
not be able to secure payment from that substantial asset.
49. While Epstein is clearly distinct from the criminal enterprise that he oversees that asset,
as well as his other airplanes and helicopters and other assets, have been used continuously and
repeatedly to further the interest and endeavors of Epstein and his criminal enterprise.
50. As another example of the fraudulent transfers that Epstein has made, Epstein has titled a
Ford F-I50 Truck in the name of Larry Visoki (Epstein's personal pilot). Visoski was unaware
that the truck was titled in his name when he was questioned under oath in a deposition.
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51. In approximately 2009, Defendant Epstein purchased a $68,000 Land Rover and
registered it in Visoski's name with the intent to hide this asset from MJ and other creditors.
52. In approximately 2009, Defendant Epstein purchased a Mercedes-Benz 2005 by wiring
funds to Visoski and then placing the car in Visoski's name.
53. In approximately 2009, Defendant Epstein bought a Jaguar X-Type 2005 so that he
(Epstein) would have another car around Palm Beach available for his friends to use and then
placed the car in Visoski's name.
54. In approximately September 2009, Visoski attempted to sell a Ferrari owned by Epstein
for $159,000. Epstein intended for the sale to hide the value of this Ferrari and prevent MJ and
other creditors from recovering from him.
55. Epstein is concealing substantial assets through a new corporation, Shmitka Air, Inc.,
whose representative is Larry Visoski. In September 2010, Epstein attempted to sell a 1999 Bell
Helicopter for approximately $1,900,000. This sale was an attempt to prevent MJ and other
creditors from recovering from him.
56. Epstein is also concealing substantial assets through an entity known at JEGE, Inc. He is
currently attempting to sell an aircraft for $10,000,000 through that entity in an attempt to
prevent MJ and other creditors from recovering from him.
57. Through information and belief, Epstein and/or his criminal enterprise provides the
financial support for his various employees, co-conspirators, other criminal enterprise members
and associates.
58. In addition to Epstein's various houses, he owns or controls other condominiums,
including approximately 8 to 10 units at 301 East 66 Street, in New York City, where certain of
his or his Criminal Enterprise associates live or reside, including Jean Luc Brunel, Nadia
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Marcinkova, Sarah Kellen, and at times various underage minor girls are stashed at this location
as well.
59. Defendant Epstein has numerous overseas contacts and accounts and sophistication in
international business transactions. He previously served as a trader at Bcar Steams and founded
his own financial management firm, J. Epstein and Col. (later called Financial Trust Co.) located
on his private island in the U.S. Virgin Islands where, until his recent incarceration, according to
him he allegedly managed the assets of billionaire clients.
60. After extensive investigation into Epstein's employment history, including questioning of
Epstein's family, those whom Epstein considers friends and longtime employees of Epstein, the
only known client of Epstein was Limited, Inc. Founder Leslie Wexner, although it is believed
that even that relationship has been severed. No other legitimate means of income have been
reported.
COUNT I
BATTERY AGAINST DEFENDANT EPSTEIN
61. Plaintiff M.J. adopts and =lieges paragraphs I through 60 above.
62. In the summer of 2002, just after Plaintiff turned 16 years old, Defendant Epstein
committed battery against Plaintiff when he intentionally touched intimate areas of her body and
person in an offensive manner while she was a minor child.
63. Defendant Epstein intentionally touched Plaintiff MJ's private areas multiple times
against the will of MJ.
64. Defendant Epstein's tortious commission of battery upon Plaintiff was done willfully.
65. As a direct and proximate result of the offenses committed by Defendant Epstein against
the then minor Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain
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and suffering, emotional distress, psychological and psychiatric trauma, mental anguish,
humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of
life, invasion of her privacy and other damages associated with Defendant's manipulation and
leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and
psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
income in the future, and loss of proper and complete education. These injuries are permanent in
nature and Plaintiff MJ will continue to suffer these losses in the future.
WHEREFORE, Plaintiff MJ demands judgment against Defendant Epstein for
compensatory damages, punitive damages and such other relief as this Court deems proper and
hereby demands trial by jury on all issues triable as of right by a jury.
COUNT II
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
AGAINST DEFENDANT EPSTEIN
66. The Plaintiff adopts and realleges paragraphs 1 through 60 above.
67. Defendant Epstein's extreme and outrageous conduct towards the then minor Plaintiff
was intentional and reckless.
68. Defendant Epstein acted with the intent to cause severe emotional distress or with
reckless disregard for the high probability of causing severe emotional distress.
69. As a direct and proximate result of the offenses committed by Defendant Epstein against
the then minor Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain
and suffering, emotional distress, psychological and psychiatric trauma, mental anguish,
humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of
life, invasion of her privacy and other damages associated with Defendant's manipulation and
leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and
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psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
income in the future, loss of proper and complete education. These injuries are permanent in
nature and Plaintiff MJ will continue to suffer these losses in the future.
WHEREFORE, Plaintiff M.J. demands judgment against Defendant Epstein for
compensatory damages, punitive damages and such other relief as this Court deems proper and
hereby demands trial by jury on all issues triable as of right by a jury.
COUNT III
CONSPIRACY TO COMMIT TORTIOUS ASSAULT OR BATTERY AGAINST
DEFENDANT SARAH KELLEN
70. The Plaintiff adopts and realleges paragraphs I through 60 above.
71. Defendant Kellen is one of Defendant Epstein's top assistants, as referenced previously
in this Complaint. Defendant Epstein, Defendant Kellen and others reached an agreement
amongst and between them and otherwise conspired for the purpose of allowing Defendant
Epstein and others to commit the tortious and illegal acts described above against Plaintiff MJ.
72. Defendant Kellen aided, abetted and assisted Defendant Epstein in his organized scheme
and plan to sexually exploit Plaintiff and commit battery against her and/or commit or attempt to
commit numerous other crimes against her, including coercing her into prostitution.
73. Defendant Kellen conspired with Defendant Epstein to commit tortious and illegal
conduct against Plaintiff, and in furtherance of the conspiracy Kellen specifically engaged in
overt acts such as contacting Plaintiff MJ on many occasions, scheduling the then minor
Plaintiffs appointment for a "massage" knowing that Defendant Epstein was going to commit
battery against Plaintiff, attempt sexual battery against Plaintiff, and force her into prostitution
and otherwise did everything in her ability to conceal the illegal operation and refuse cooperation
with law enforcement.
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74. Additionally, Defendant Kellen greeted Plaintiff on the occasions when Plaintiff arrived
at Epstein's home and personally lead Plaintiff to Defendant Epstein's bathroom where Epstein
appeared for the purposes of committing crimes against Plaintiff.
75. Defendant Epstein's battery against Plaintiff was facilitated by Defendant Kellen and the
conspiracy resulted in the various aforementioned crimes being committed against Plaintiff MJ
as well as many other underage minor females.
76. As a direct and proximate result of Defendant, Sarah Kellen's, participation in the
aforementioned conspiracy, Plaintiff, MJ, she has in the past suffered and will in the future suffer
injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental
anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of
enjoyment of life, invasion of her privacy and other damages associated with Defendant's
manipulation and leading her into a perverse and unhealthy way of life. Plaintiff will incur
medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the
capacity to earn income in the future, loss of proper and complete education. These injuries are
permanent in nature and Plaintiff MJ will continue to suffer these losses in the future.
WHEREFORE, Plaintiff MJ demands judgment against Defendant Sarah Kellen for
compensatory damages, punitive damages and such other relief as this Court deems proper and
hereby demands trial by jury on all issues triable as of right by a jury.
COUNTS IV THROUGH XXIII
CAUSES OF ACTION AGAINST DEFENDANTS EPSTEIN AND KELLEN PURSUANT
TO IS USC 42255 IN VIOLATION OF VARIOUS ENUMERATED OFFENSES
CONTAINED WITHIN THAT FEDERAL STATUTE
77. Plaintiff, MJ, adopts and realleges paragraphs I through 60 above.
78. The allegations contained herein in Counts IV through XXIII are separate and distinct
legal remedies.
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79. As a condition of Defendant, Jeffrey Epstein's criminal plea, and in exchange for the
Federal Government not prosecuting the Defendant for numerous federal offenses, the
Defendant, Jeffrey Epstein, entered into a Non-Prosecution Agreement with the Federal
Government; that agreement governed not only Defendant Epstein's conduct but also the
conduct of his "co-conspirators" including Defendant Kellen as she played an essential and
criminal role in the commission of these offenses.
80. The Plaintiff, MJ, was in fact a victim of one or more offenses enumerated in Title 18,
United States Code, Section 2255, and as such asserts a cause of action against the Defendant,
Jeffrey Epstein, and against Defendant Kellen pursuant to this Section of the United States Code
and the agreement between the Defendant, Jeffrey Epstein, and the United States Government.
81. Specifically, Defendants Epstein and Kellen:
(a) knowingly conspired with others known and unknown to use a facility or
means of interstate commerce to knowingly persuade, induce, or entice minor females,
including Plaintiff MJ, to engage in prostitution, in violation of title IS, United States
Code, Section 2422(b).
(b) knowingly and willfully conspired with others known and unknown to travel
in interstate commerce for the purpose of engaging in illicit sexual conduct with minors,
including Plaintiff MJ, as defined in 18 U.S.C. § 2423(f), with minor females, in violation
of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United
States Code, Section 2423(e);
(c) used a facility or means of interstate or foreign commerce to knowingly
persuade, induce, or entice minor females, including Plaintiff MJ, to engage in
prostitution; in violation of Title 18, United States Code, Section 2422(b);
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(d) traveled in interstate commerce for the purpose of engaging in illicit sexual
conduct, as defined in 18 U.S.C. § 2423(f), with minor females, including Plaintiff MJ; in
violation of Title 18, United States Code, Section 2423(b).
82. As a direct and proximate result of the aforementioned criminal offenses enumerated in
Title IS, United States Code, Section 2255, being committed against the then minor Plaintiff,
Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain and suffering,
emotional distress, psychological and psychiatric trauma, mental anguish, humiliation,
confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of life, invasion
of her privacy and other damages associated with Defendant's manipulation and leading her into
a perverse and unhealthy way of life. Plaintiff will incur medical and psychological expenses.
These injuries are permanent in nature and Plaintiff MJ will continue to suffer these losses in the
future. Plaintiff, M.J., has also incurred attorneys' fees.
83. With regard to each of the following counts, Plaintiff suffered personal injury, as outlined
above from the acts above, as a result of the violations of federal criminal law by Defendant
Epstein enumerated in paragraph 33, on approximately 20 occasions, and while the dates are not
all precisely documented or diaried by Plaintiff, Defendants Epstein and Kellen committed these
crimes and inflicted said injuries on or about the following dates:
COUNT IV August 2002
COUNT V September 2002
COUNT VI October 2002
COUNT VII November 2002
COUNT VIII December 2002
COUNT IX January 2003
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COUNT X February 2003
COUNT XI March 2003
COUNT XII April 2003
COUNT XIII May 2003
COUNT XIV June 2003
COUNT XV July 2003
COUNT XVI August 2003
COUNT XVII September 2003
COUNT XVIII October 2003
COUNT XIX November 2003
COUNT XX December 2003
COUNT XXI January 2004
COUNT XXII February 2004
COUNT XXIII March 2004
WHEREFORE, with regard to each and every one of these counts, Plaintiff, MJ,
demands judgment against Defendant, Jeffrey Epstein, for compensatory damages, loss of
income, a loss of the capacity to earn income in the future, attorney's fees, and such other and
further relief as this Court deems just and proper, and hereby demands trial by jury on all issues
triable as of right by a jury.
COUNT XXIV
Civil Remedy for Criminal Practices
84. Plaintiff realleges paragraphs I through 60 above and for the purposes of this count
incorporates and alleges the RICO Statement that has been filed contemporaneously herewith as
Exhibit "A."
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85. The allegations contained herein in Count XXIV are a separate and distinct legal remedy
brought pursuant to Florida Statute 772.104(1) and (2).
86. Defendant, Jeffrey Epstein, was associated with an enterprise, a group of individuals
associated in fact although not a legal entity, which was comprised of at least Defendant Jeffrey
Epstein, Sarah Kellen, Leslie Groff, Jean Luc Brunel, Ghislaine Maxwell, and Nadia Marcinkova
(and likely many other yet unknown persons); Defendant Epstein participated in this enterprise,
or conspired or endeavored to so participate, through a pattern of criminal activity in violation of
Florida Statutes §772.103(3)-(4), as further outlined in detail in the RICO statement filed with
this court.
87. This enterprise was separate and distinct from Epstein himself and had a definite
hierarchical structure. Epstein served informally but effectively as the leader, C.E.O. or "boss"
of this organization similar to the way an experienced mob boss runs his organized crime family,
directing his underlings how to recruit and procure underage girls for his sexual activities and the
sexual activities of others, developing the use of slang or code words to be used to discuss the
illegal activities of the organization, designing a plan or scheme to gain the cooperation of
underage minor females, developing methods and techniques to otherwise avoid detection from
law enforcement including making large charitable donations to law enforcement agencies,
powerful politicians, businessmen and world leaders, associating with powerful social people
and highly influential politicians and attorneys, gathering information to blackmail or extort
powerful people, devising a plan to attack the credibility and character of anyone that dare unveil
the illegal operations of the enterprise and to take an oath to remain silent and/or lie when
confronted by law enforcement about the illegal operations and activities of the criminal
organization. Epstein's key "lieutenant" in the local Palm Beach branch of the National
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organization was Kellen, who served as both his scheduler and a recruiter/procurer of the girls.
Marcinkova also served as a recruiter and helped Epstein satisfy his criminal sexual desires by,
on occasion, directly participating in sexual abuse and prostitution of the minor girls. Epstein
also used otherwise-legitimate business activities to help further the purpose of the criminal
enterprise. These apparently legitimate activities provided "cover" for Epstein and his associates
to commit the crimes. Epstein and his associates maintained the appearance of running an
upstanding investment business, as well as other legitimate businesses with connections to
modeling agencies and other powerful business and political people, to discourage the minor
girls from reporting the abuse to law enforcement. Ghislane Maxwell and Jean Luc Brunel
helped to provide "cover" by creating the impression that legitimate modeling opportunities were
available for the girls. There are many other known and unknown associates of the criminal
organization, that worked throughout the country and possibly internationally, who performed
functions to perpetuate the criminal activities of the organization.
88. Defendant Jeffrey Epstein participated in this enterprise through a pattern of criminal
activity in that he engaged in at least two incidents of criminal activity, as defined and required
in Florida Statute 772.102 and as described below, that have the same or similar intents, results,
accomplices, victims, or methods of commission and are not isolated incidents.
89. Defendant Jeffrey Epstein engaged in criminal activity by committing, attempting to
commit, conspiring to commit or soliciting, coercing or intimidating another person to commit
one or more of the following predicate acts as outlined and defined in Florida Statute 772.102:
(a) Procuring for prostitution, or causing to be prostituted, any person who is
under the age of 18 years in violation of Florida Statutes Chapter 796.03;
(b) Acts of battery in violation of Florida Statutes Chapter 784;
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(c) Forcing, compelling or coercing another to become a prostitute in
violation ofFlorida Statutes Chapter 796.04;
(d) knowingly recruiting, enticing, harboring, transporting, providing or
otherwise obtaining by any means a person, knowing that coercion would be used to
cause that person to engage in prostitution in violation of Florida Statutes Chapter
796.045;
(e) tampering with a witness in violation of Florida Statutes Chapter 914.22;
(f) altering, destroying, removing, or concealing records or documents or
other evidence with the purpose to impair its verity or availability in violation of Florida
Statutes Chapter 918.13;
(g) maintaining a place (or more accurately "places") for the purpose of
lewdness or prostitution; offering or securing another for the purpose of prostitution or
for some other lewd or indecent act; receiving persons into his Palm Beach mansion for
the purpose of prostitution or lewdness; directing, taking or transporting or agreeing to
direct take or transport persons to his Palm Beach mansion with knowledge or reasonable
belief that the purpose of such directing, taking or transporting was prostitution or
lewdness; all in violation of Florida Statutes Chapter 796.07.
90. The criminal acts of Defendant Epstein occurred repeatedly over a substantial period of
time and were not isolated events.
91. Under Defendant, Jeffrey Epstein's plan, scheme, and enterprise, Defendant, Jeffrey
Epstein, paid employees and underlings, including but not limited to Sarah Kellen, to bring him
minor girls to his Palm Beach mansion in order for the Defendant to solicit, induce, coerce,
entice, compel or force such girls to engage in acts of prostitution and sexual misconduct with
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Defendant Epstein and sometimes Nadia Marcinkova, and to otherwise commit acts of sexual
battery thereon, and further Defendant Epstein worked in concert as part of the enterprise with
those who were free to act independently and advance their own interests, including Ghislaine
Maxwell and Jean Luc Brunel, to obtain minor girls for sexual purposes.
92. Plaintiff, MJ, was the victim of Defendant, Jeffrey Epstein's plan, scheme, and enterprise
and was so injured by reason of his violations of the provisions of s. 772.104. Plaintiff, MJ, was
called