Case 9:09-cv-80469-KAM Document 1 Entered on FLSD Docket 03/25/200! FILPAOe 1RB5 _ D.C. ° ECTRORIC Mar. 24, 2009 UNITED STATES DISTRICT COURT creven ss vamnaone SOUTHERN DISTRICT OF FLORIDA CLERK U.S. OIST. CT. S.0. OF FLA.- MIAMI 09-80469-Civ-RYSKAMP/VITUNAC JANE DOE II ) CASE NO.: ) Plaintiff, ) ) vs. ) ) JEFFREY EPSTEIN ) ) Defendants. ) / COMPLAIN 1. Plaintiff, JANE DOE Il, hereby sues JEFFREY EPSTEIN and [i | | and states: JURISDICTION AND VENUE 2. This is an action for damages in excess of $75,000, exclusive of interests, costs and attorney's fees. 3. Venue is proper in this Court as all acts occurred in Palm Beach County and all parties reside and/or do business herein. PARTIES 4. Ms. DOE Il is a natural person residing in Palm Beach County, Florida. During the events giving rise to this claim, she was a minor but has now reached majority. She files this suit under a pseudonym to protect her privacy because the acts alleged occurred while she was a minor. SCANNED lots EFTA00222808

--=PAGE_BREAK=--

09-80469-CiveRY SKA MR/METIUNAGered on FLSD Docket 03/25/2009 Page 2 of 5 5. Defendant EPSTEIN is a natural person, who is an adult, and who resides and/or does business in Palm Beach County, Florida, and who committed the acts alleged within the jurisdiction of Palm Beach County, Florida, within the boundaries of the United States District Court in and for the Southern District of Florida. Defendant is a natural person, who is an adult, believed to reside in the State of New York, but who committed the acts alleged within the jurisdiction of Palm Beach County, Florida, within the boundaries of the United States District Court in and for the Southern District of Florida. 6. Defendant EPSTEIN is believed to now be incarcerated in the Palm Beach County Jail for crimes committed that are related to and/or similar to the claims in this case. FACTS 7. Defendant EPSTEIN was, at all times relevant to this action, a part time resident of Palm Beach County, Florida. All acts complained of herein occurred at his estate residence in the Town of Palm Beach, Florida. 8. Defendant EPSTEIN has a history of enticing young women, who are minors (under 18 years of age), and soliciting them to engage in prostitution for his own sexual gratification. 9. Defendant EPSTEIN, in agreement with two (2) persons he employed for this purpose, Re: : Defendan{. conspired with these other two, and others, to solicit young women of the type Defendant EPSTEIN preferred, blonde, attractive in appearance, and younger than 18 years of age, to provide ll 10. Defendants EPSTEIN anal entered into a criminal conspiracy to solicit young women or including the Plaintiff, here in Palm Beach County. 205 EFTA00222809

--=PAGE_BREAK=--

09-80469:CiueRY SKAMRIMETU NAGéred on FLSD Docket 03/25/2009 Page 3 of 5 11. From about June, 2003 until on or about February, 2005, Defendants EPSTEIN andpersuaded, induced, or enticed the Plaintiff to come to Defendant EPSTEIN’s home and provide Defendant EPSTEIN with “massages” which escalated into etween Defendant EPSTEIN and the Plaintiff designed to fulfill his unnatural sexual desires for young women or even younger girls who were minors. These acts included Defendant EPSTEIN’s request that he wanted the encounter to be like a PF Defendant EPSTEIN would script lines for the Plaintiff to say, including calling out his name and requestin Defendant EPSTEIN would pay the Plaintiff a fee of $200 on 42. Defendant EPSTEIN Be Plaintiff was a minor, causing personal injury to her. 13. In violation of 18 U.S.C. §2422(b),Defendants EPSTEIN and [lll knowingly persuaded, induced, or enticed the Plaintiff to engag (i when the Plaintiff was under the age of 18, approximately on or about the following dates that Plaintiff can document based on payments received: 6/16/03, 7/2/03, 4/9/04, 6/7/04, 7/30/04, 8/30/04, 10/9/04, 10/12/04, 10/30/04 and 11/9/04. In addition, Plaintiff believes that there were as many as 10 to 20 other occasions during this time frame that Defendant EPSTEIN solicited her and procured her 7, all during the time that she was a minor. Sots EFTA00222810

--=PAGE_BREAK=--

Case 9:09-cv-80469-KAM Document1 Entered on FLSD Docket 03/25/2009 Page 4of5 14. Plaintiff seeks damages for personal injury in accordance with 18 U.S.C. §2255(a) for each of ne forth above for which Defendants solicited her, $150,000 for each violation, for a total range of damages between $1.5 million dollars to $4.5 million dollars, jointly and severally, and a reasonable attorney's fees and costs, as permitted by the statute. 15. Defendant EPSTEIN has made an agreement with the United States Attorney's Office to not contest liability for claims brought exclusively pursuant to 18 U.S.C. §2255, in exchange for avoiding federal prosecution under 18 U.S.C. §2422(b), which provides a sentence of 10 years for each violation of the law. WHEREFORE, Plaintiff demands judgment in her favor, and a jury trial on all issues So triable as of right. GAP CIA LAW FIRM, P. A. = - = F Telephone: Telecopier: Date: z| alo% EFTA00222811

--=PAGE_BREAK=--

09-80469-GCiv-RY¥SKAMPAATUNAC Entered on FLSD Docket 03/25/200 ‘4S 447 (Rev. 2/08) The JS 44 civil coyersheet and the by local rules of court. This form, the civil docket sheet, (SEE INST! I. (a) PLAINTIFFS JANE DOE II (b) County of Residence of First Listed Plaintiff PALM BEACH (EXCEPT IN U.S, PLAINTIFF CASES) (¢) Attomey’s (Firm Name, Address, and Telephone Number) GARCIA LAW FIRM, P.A. 224 DATURA STREETM SUITE 900 WEST PALM BEACH, FL 33401 9 1) US. Government Pleinnft 32 US. Goverament Defeadam D 110 inserance 120 Marine fe] 5 130 Miller Act F] J 140 Negotiable Instrument 3 150 Recovery of Overpayment [0 & Enforcement of Jedgment D ISI Medicare Act o 7 152 Recovery of Defesited Stedent Loans a (Exel, Veterans) a 3 153 Recovery of Overpayment of Veteran's Benefits 9 1 160 Stockholders’ Suits = 190 Other Comtact 17 195 Contact Product Liability | mw 3196 Franchise F 210 Land Condemaation © 220 Foreclosure J 230 Rent Lease & Ejectment 2 240 Torts te Land F245 Tort Prodvct Liability 3 290 All Other Real Property 5 J 5 VI. RELATED/RE-FILED CASE(S). VIL CAUSE OF ACTIO VIII. REQUESTED IN COMPLAINT: ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE (4) Check County Where Action Arose: 9 MIAMI. DADE Il, BASIS OF JURISDICTION CIVIL COVER SHEET information contained herein neither replace pplemen approved by the Judicial Conference ofthe United tates in RUCTIONS ON THE REVERSE OF THE FORM.) i the filing and service of pleadi DEFENDANTS JEFFREY EPSTEIN AND (NUS LAND INVOLVED Attomeys (if Known) JACK A. GOLDBERGER, PALM BEACH 9 MARTIN S MONROE 9 BROWARD (Place an “X™ in One Box Only) (For Diversity Cases Only) oF 5 Federal Question PTF DEF {U.S Government Not a Party) Citizen of This State 2 1 a1 34 Diversity Citizen of Another Stee 9 2 (Indicate Citizenship of Marties in Item 111 V Citizes of Subjectof2 = 3 3 Foreign September 1974, is required for the use of NOTICE: Attorneys MUST Indicate All Re-filed County of Residence of First Listed Defendant ROBERT D. CRITTON, ESQ. OST LUCIE J INDIANRIVER 3 OKEECHOBEE Il, CITIZENSHIP OF PRINCIPAL PARTIESvriace FILPAQE SIDBS D.C. ELECT! Mar. 24, 2009 or other papers a: Clerk STEVEN M. LARIMORE CLERK U.S. DIST. CT. D0. OF FLA,» MIAMI PALM BEACH PLAINTIFF CASES ONLY) NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT ESQ. HIGHLANDS “X" ie One Box for Plaintiff and One Box for Defendant) PTF oDEF Incorporated or Principal Place 7 4 94 of Business In This State Incorporated ond Principal Place 3 $ 3 § Of Business In Another State Foreign Nation 5 6 36 PERSONAL INJURY PERSONAL INJURY |9 610 Agricuture 400 Stare Reapportionment 310 Airplane D 362 Personal Injury. 1 620 Other Food & Drag 410 Antitrust 315 Airplane Product Med. Malpractice [0 625 Drug Related Seizure 430 Banks and Banking Linbitity 9 of Property 21 USC 881 450 Commerce 320 Assault, Libel & D 630 Liquor Laws 460 Deportation Slander fs) D 640 RR. & Treck 470 Racketeer Influenced and 330 Federal Employers* Injery Product DF 650 Airline Regs 1 430 Patent Corrupt Organizations Liability Liability 3 660 Occupational D 840 Trademark J 480 Consemer Credit 340 Marine PERSONAL PROPERTY Safety/Health 3 490 CableSat TY 343 Marine Product 3 370 Other Fraud 1D _690 Other J 810 Selective Service Liability D371 Trath in Leading L___—CLABOR —Ss«dY’ ‘socuAL SECURIIY 3 450 Securities Commodities! 350 Motor Vehicle D380 Other Personal 3 710 Fair Labor Standards D 861 HIA (139SM) Exchange 355 Motor Vehicle Act © 862 Black Lung (923) 3 #75 Customer Challenge Product Liability o 3 720 LaborM gmt. Relations [5 863 DIWC/DIWW (405(g)) USC 340 360 Other Personal 1 730 LaborM gmt Reporting & Disclosure Act 510 Motions to Vacate 1 790 Other Labor Litiganon D 864 SSID Title XVI OD 870 Taxes (U.S. Plaintitt 890 Other Statutory Actions 891 Agricultural Acts 892 Economic Stabilization Act 893 Environmental Matters yest Sentence oF Defendant) 894 Energy Allocation Act ing! b © 871 IRS—Third Party Accommodations 26 USC 7609 895 Freedom of Information Act 444 Welfare D535 Death Penalty 445 Amer. w/Disabitines 462 Nateralizanon Employment J 540 Mandamus & Other] 0 Application 446 Amer. w/Disabilities Other 440 Other Civil Rights 463 Habeas Corpus-Alicn Detainee 465 Other Immigration Actions $50 Civil Rights 555 Prison Condition (See instrections second pagey JUDGE Cite the U.S. Civil Statute under which you are filing and Wnte a Brief Statement o Cause (Do not cite jurisdictio diversity): 18 U.S.C, §2422(b) LENGTH OF TRIAL via days estimated (for both sides to try entire case) © CHECK IF THIS IS A CLASS ACTION PEMAND $ UNDER F.R.C.P, 23 {) /) iia EY OF RECORD Y — V We FOR OfFiCe USE ONLY AMOUNT [7] a, 900 Appeal of Fee Determination Under Equal Access to Justice 950 Constitutionality of State Statutes Vv. ORIGIN (Place an “X" in One Box Only) to District V1 Original © 2 Removedfrom 1 3. Re-filed- O 4 Reinstatedor ( § Trasstorred from 0 6 Multidistrict 7 {eae fom Proceeding State Court {see VI below) Reopened (specify) Litigation aoa a) Re-filed Case OYES ONO b) Related Cases ES ONO DOCKET NUMBER & 108 -cv -PA64 Aqqwy statutes unless CHECK YES only if demandgdin complaint: JURY DEMAND: WYes F No DATE March 19, 2009 4, ECEIPT « %, 1FP EFTA00222812