Case 9:08-cv-80993-KAM Document1 Entered on FLSD Docket 09/10/200 FILPAOE bi? _D.c. SEPT. 10, 2008 STEVEN M. LARIMORE UNITED STATES DISTRICT COURT SO oF Fun Mian SOUTHERN DISTRICT OF FLORIDA CASE NO.: JANE DOE NO. 7, 08-CV-80993-Hurley-Hopkins Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / COMPLAINT Plaintiff, Jane Doe No. 7 (“Jane” or “Jane Doe”), brings this Complaint against Jeffrey Epstein, as follows: Parties, Jurisdiction and Venue 1. Jane Doe No. 7 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 a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuant to 28 U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs; and (ii) is between citizens of different states. 6. Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because Plaintiff alleges a claim under the laws of the United States. This Court has supplemental HERMAN & MERMELSTEIN, P. A. www.hermaniaw.com EFTA00221172

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08-C¥-809932sHunley-Hopkins: = Entered on FLSD Docket 09/10/2008 Page 2 of 7 jurisdiction pursuant to 28 U.S.C. §1367(a) over all other claims set forth herein, which form part of the same case or controversy. 7. This Court has venue of this action pursuant to 28 U.S.C. §§1391(a) and 1391(b) asa substantial part of the events or omissions giving rise to the claim occurred in this District. Factual Allegations 8. At all relevant times, Defendant Jeffrey Epstein (“Epstein”) was an adult male, approximately 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. 9. 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, Jane Doe, then approximately 16 years old, fell into Epstein’s trap and became one of his victims. 10. 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. 11. Epstein’s scheme involved the use of young girls to recruit underage girls. | sg a Palm Beach Community College student from Loxahatchee, Florida recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. HEE 8p information and belief, generally sought out economically disadvantaged HERMAN & MERMELSTEIN, P. A. www.hermaniaw.com 20t7 EFTA00221173

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I Cee 08-C¥-80993+Hdurley-Hopkins = Entered on FLSD Docket 09/10/2008 Page 3 of 7 underage girls from western Palm Beach County who would be enticed by the money being offered - generally $200 to $300 per “massage” session - and who were perceived as less likely to complain to authorities or have credibility if allegations of improper conduct were made. This was an important element of Epstein’s plan. 12. __ Epstein’s plan and scheme reflected a particular pattern and method. The underage victim would be brought to Epstein’s mansion, where she would be introduced oO Epstein’s assistant. ae... then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. The girl would then find herself alone in the room with Epstein, who would be wearing only a towel. He woulddirect he rigl to give him a massage. Epstein would then perform one or more lewd, lascivious and sexual acts, including masturbation and touching the girl’s vagina. 13. Consistent with the foregoing plan and scheme, when Jane Doe was 16 years old, she was recruited iim to give Epstein a massage for monetary compensation. Jane was brought to Epstein’s mansion in Palm Beach. Once there, Jane was introduced oS who led her up the flight of stairs to the room with the massage table. In this room, Jane was directed by Epstein to give him a massage. During this massage, Epstein sexually assaulted Jane and masturbated. Epstein then paid Jane money. 14. Jane returned on many occasions to the Palm Beach mansion to provide Epstein with massages for money. On those occasions, Epstein engaged in sexual contact and activity with Jane, which included, among other things, Epstein touching Jane’s breasts, placing a vibrator on her vagina and masturbating himself. This sexual abuse continued over a period of approximately 18-24 months. HERMAN & MERMELSTEIN, P. A. www.hermaniaw.com Sot7 EFTA00221174

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SSIS~S'TS=— a iit, Case 9:08-cv-80993-KAM Document1 Entered on FLSD Docket 09/10/2008 Page 4 of 7 15. As a result of these encounters with Epstein, Jane experienced confusion, shame, humiliation and embarrassment, and has suffered severe psychological and emotional injuries. COUNT I Sexual Assault and Battery 16. Plaintiff Jane Doe repeats and realleges paragraphs | through 15 above. 17. Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane Doe, creating a reasonable fear of imminent peril and sexual assault. 18. Epstein intentionally inflicted harmful or offensive sexual contact on the person of Jane Doe. 19. _ Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein’s acts were intentional, unlawful, offensive and harmful. 20. Epstein’s plan and scheme in which he committed such acts upon Jane Doe were done willfully and maliciously. 21. Asadirect 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. 7 demands judgment against Defendant Jeffrey Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this Court deems just and proper. COUNT II Intentional Infliction of Emotional Distress 22. Plaintiff Jane Doe repeats and tealleges paragraphs | through 15 above. 23. _ Epstein’s conduct was intentional or reckless. HERMAN & MERMELSTEIN, P. A. www.hermaniaw.com EFTA00221175

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I LL ett Case 9:08-cv-80993-KAM Document 1 24. —_ Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds of decency. 25. Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury that caused or were likely to cause Jane Doe’s mental or emotional health to be significantly impaired. 26. _ 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 distress and damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing severe emotional distress to Jane Doe. 27. 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. 7 demands judgment against Defendant Jeffrey Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this Court deems just and proper. COUNT Ill oercion and Enticement to Sexual Activi in Violation of 18 U.S.C. §2422 28. Plaintiff Jane Doe repeats and realleges paragraphs | through 15 above. 29. Epstein used a facility or means of interstate commerce to knowingly persuade, induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or sexual activity for which any person can be charged with a criminal offense. 30. Epstein’s acts and conduct are in violation of 18 U.S.C. §2422. 31. Asaresult of Epstein’s violation of 18 U.S.C. §2422, Plaintiff has suffered personal injury, including mental, psychological and emotional damages. HERMAN & MERMELSTEIN, P. A. www.hermaniaw.com Entered on FLSD Docket 09/10/2008 Page 5 of 7 EFTA00221176

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_S_ ea Case 9:08-cv-80993-KAM Document1 Entered on FLSD Docket 09/10/2008 Page 6of7 32. Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a reasonable attomeys’ fee. WHEREFORE, Plaintiff Jane Doe No. 7 demands judgment against Defendant Jeffrey Epstein for all damages available under 18 US.C. §2255(a), including without limitation, actual and compensatory damages, costs of suit, and attorneys’ fees, and such other and further relief as this Court deems just and proper. JURY TRIAL DEMAND Plaintiff demands a jury trial in this action on all claims so triable. Dated: September | 0 , 2008 Respectfully sul By: Jeffrey M. Herman (FL Bar No. 521647) jherman@hermanlaw.com Stuart S. Mermelstein (FL Bar No. 947245) ssm@hermanlaw.com Adam D. Horowitz (FL Bar No. 376980) ahorowitz@hermanlaw.com HERMAN & MERMELSTENN, P.A. Attorneys for Plaintiff 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: 305-931-2200 Fax: 305-931-0877 HERMAN & MERMELSTEIN, P. A. www. hermaniaw.com EFTA00221177

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, Orig woh 08-C-V-80993;HuHeKAKOPKINS, GML COVERBISIMEEED Docket 09/10/2008 Page 7 of 7 The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing, and service of pleading or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of the Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) Wa) PLAINTIFFS DEFENDANTS JANE DOE NO. 7, JEFFREY EPSTEIN (b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT NEW YORK ORANGE COUNTY (IN U.S. PLAINTIFF CASES ONLY) (EXCEPT IN U.S. PLAINTIFF CASES) (c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER) | ATTORNEYS (IF KNOWN) Herman & Mermelstein, P.A., 18205 Biscayne Blvd., Suite 2218, Miami, FL 33160, (305) 931-2200 (d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH Il. BASIS OF JURISDICTION ill. CITIZENSHIP OF PRINCIPAL PARTIES PLACE AN X IN ONE BOX FOR PLAINTIFF (PLACE AN X ONE BOX ONLY) (For Diversity Case Only) AND ONE FOR DEFENDANT PTF DEF PTF DEF Incorporated of Principal Place of Q4 04 0 1. US. Government X 3, Federal Question Citizen of This State o1 01 Business in This State Plaintiff (U.S. Government Not a Party) Citizen of Another State 92 02 Incorporated and Principal Placeot OS O5 Citizen or Subject of a Foreign County 23 03 " Business in Another State Foreign Nation o6 O86 0 2. US. Government O 4. Diversity ™ {Indicate Citizenship of Parties in Item IV. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE. DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY) ACTION FOR SEXUAL ASSAULT UNDER 18 U.S.C. §2422 AND STATE LAW Va. _5_ days estimated (for both sides) to try entire case V. NATURE OF SUIT (PLACE AN X IN ONE BOX ONLY) | © 10reuance PERSONAL INJURY s s 310 Acptane 3 3888 D140 Megotatte instrument r ot Racketeer fluenced and Judgnent Compe Orgaresncns 7S) Mecicare Act Selec Senace O 182 Recovery o! Detmsed ‘Student Loans (Exct Excrange 355 Motor Veticie Product Liataty 0370 Omer Fraud XX 380 Ofer Personas injury O37) Trin Lending 8 O40 One Posonne 833 | Property Damage om to Alcon oo Ad O06 pA (1988) Ld Foeeatm of hommaion Act 0 682 Brack Lung (23) 900 Appeal of Foe Oetarmnaton 0 663 DieC/DIvew (40549) Unoer Equal Access © 0.864 SSO Tee xv natin 0865 RS) (405)) GC 880 Constiuaonalty of Sue Stueses OC S10 Menons to Vacate Sentence rabeas Comes O S0Geners” D870 Tams (US Planet or Defendant) OSTt RS Thed Panty 28 USC 7600 x1. Original 0 2. Removed from 013. Remanded from 4. Refilled 06. Multidistrict Litigation O7. Appeal to District Judge from Proceeding State Court Appellate Court 7 5. Transferred from another district (Specify) Magistrate Judgment Vil. REQUESTED CHECK IF THIS ISA 0 CLASS ACTION DEMAND $ © Check YES only if demandedin X YES IN COMPLAINT O UNDER F.R.C.P. 23 int: JURY DEMAND: ONO Vill. RELATED (See Instructions): (SEE ATTACHED) CASE(S) IF ANY Jane Doe 2 v. Jeffrey Epstein JUDGE KENNETH A. MARRA DOCKET NUMBER 08-CV-80119-MARRA-JOHNSON Jane Doe 3 v. Jeffrey Epstein JUDGE KENNETH A. MARRA DOCKET NUMBER 08-CV-80232-MARRA-JOHNSON Jane Doe 4 v. Jeffrey Epstein JUDGE KENNETH A MARRA DOCKET NUMBER 08-CV-80380-MARRA/JOHNSON JUDGE KENNETH A MARRA DOCKET NUMBER 08-80381-CiV-_ Jane Doe 5 v. Jeffrey Epstein FOR OFFICE USE ONLY: Receipt No. yNrreD STATES DISTRICT COURT Se Date Paid: Miifp: REV. 9/94 EFTA00221178