ase 9:08-cv-80893-KAM Rocument 1 Entered on FLSD Dockes 08/14/2008 FuPEapey 1 BAB 2 D.C. AUGUST 13, 2008 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CLERK US. DIST, CT. 5.0. OF FLA.- MIAMI careno: O8CV FOP93 Kimyer= 08-80893-Civ-MARRA/JOHNSON JANE DOE, Plaintiff vs. JEFFREY EPSTEIN, Defendant COMPLAINT Parties, Jurisdiction and Venue COMES NOW the Plaintiff, Jane Doe, and brings this Complaint against the Defendant, Jeffrey Epstein, and states as follows: 1. This is an action for damages in an amount in excess of $50,000,000.00, exclusive of interest and costs. 2. This Complaint is brought under a fictitious name in order to protect the identity of the Plaintiff, Jane Doe, because this Complaint makes allegations of sexual assault and child abuse of a then minor. 3. At all times material to this cause of action, the Plaintiff, Jane Doe, was a resident of Palm Beach County, Florida. 4. At all times material to this cause of action, the Defendant, Jeffrey Epstein, was a resident of the State of New York. 5. At all times material to this cause of action, the Defendant, Jeffrey Epstein, had a residence located in Palm Beach County, Florida. Page 1 of 11 Tori EFTA00234729

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08-80893+GiveMARR AAJONNS OMitered on FLSD Docket 08/14/2008 Page 2 of 12 ww 6. At all times material to this cause of action, the Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. This Court has jurisdiction of this action and the claim set forth herein pursuant to 28 U.S.C. §1332(a) as the matter in controversy exceeds $75,000.00, exclusive of interest and costs and is between citizens of different states. 8. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial part of the events or omissions giving rise to the claim occurred in this district. 9. At all times material, the Defendant, Jeffrey Epstein, owed a duty unto Plaintiff, Jane Doe, to treat her in a non-negligent manner and to not commit intentional or tortious or illegal acts against her. Factual Allegations 10. Upon information and belief, the Defendant, Jeffrey Epstein, has demonstrated a sexual preference and obsession for minor girls. He engaged in a plan, scheme, and enterprise in which he gained access to economically disadvantaged and other minor girls, such as the Plaintiff, Jane Doe, sexually assaulted these girls, and/or coerced them to engage in prostitution, and in return gave these minor girls money. 11. The Defendant's plan, scheme, and enterprise included an elaborate system wherein the then minor Plaintiff and other minor girls were brought to the Defendant, Jeffrey Epstein's residence by the Defendant's employees and assistants. When the assistants and employees left the then minor Plaintiff and other minor girls alone in a room at the Defendant's mansion, the Defendant, Jeffrey Epstein, himself would appear, remove his clothing, and direct the then minor Plaintiff to remove her clothing. He would then perform one or more lewd, Page 2 of 11 2oti2 EFTA00234730

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08-808923sGiveMARRAAONNS OMitered on FLSD Docket 08/14/2008 Page 3 of 12 lascivious, and sexual acts, including, but not limited to, masturbation, touching of the then minor Plaintiff's sexual organs, using vibrators or sexual toys on the then minor Plaintiff, and digitally penetrating the then minor Plaintiff. 12. The Plaintiff, Jane Doe, was first brought to the Defendant, Jeffrey Epstein’s mansion in early 2003, when she was a fourteen-year old in middle school. 13. The Defendant, Jeffrey Epstein, a wealthy financier with a lavish home, significant wealth, and a network of assistants and employees, used his resources and his influence over a vulnerable minor child to engage in a systematic pattern of sexually exploitive behavior. 14. Beginning in approximately February 2003 and continuing until approximately June 2005, the Defendant coerced and enticed the impressionable, vulnerable, and economically deprived then minor Plaintiff to commit various acts of sexual misconduct. These acts included, but were not limited to, fondling and inappropriate and illegal sexual touching of the then minor Plaintiff, sexual misconduct and masturbation of the Defendant, Jeffrey Epstein, in the presence of the then minor Plaintiff, and encouraging the then minor Plaintiff to become involved in prostitution; Defendant, Jeffrey Epstein, committed numerous criminal sexual offenses against the then minor Plaintiff including, but not limited to, sexual battery, solicitation of prostitution, procurement of a minor for the purposes of prostitution, and lewd and lascivious assaults upon the person of the then minor Plaintiff. 15. Defendant, Jeffrey Epstein, used his money, wealth and power to unduly and improperly manipulate and influence the then minor Plaintiff. 16. The acts referenced above in paragraphs 10 and 15, committed by Defendant, Jeffrey Epstein, against the then minor Plaintiff, Jane Doe, were committed in violation of Page 3 of 11 Soti2 EFTA00234731

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Case 9:08-cv-80893-KAM Document1 Entered on FLSD Docket 08/14/2008 Page 4 of 12 w numerous criminal State and Federal statutes condemning the sexual exploitation of minor children, prostitution, sexual performances by a child, lewd and lascivious assaults, sexual battery, contributing to the delinquency of a minor and other crimes., specifically including, but not limited to, those crimes designated in 18 USC §2241, §2242, §2243, §2421, and §2423, criminal offenses outlined in Chapter 800 of the Florida Statutes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §39.01, and §827.04. 17. The above-described acts took place in Palm Beach County, Florida at the residence of the Defendant, Jeffrey Epstein. Any assertions by the Defendant, Jeffrey Epstein, that he was unaware of the age of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual exploitation and abuse of a minor child. The Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of the Plaintiff, Jane Doe's minority. 18. | The above-described acts were perpetrated upon the person of the then minor Plaintiff regularly and on dozens of occasions. 19. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, the Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution. 20. As a condition of that plea, and in exchange for the Federal Government not prosecuting the Defendant, Jeffrey Epstein, for numerous federal offenses, Defendant, Jeffrey Epstein, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would Page 4 of 11 EFTA00234732

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Case 9:08-cv-80893-KAM Document1 Entered on FLSD Docket 08/14/2008 Page 5 of 12 ed have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less”. 21. The Defendant, Jeffrey Epstein, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged in this Complaint, and must effectively admit liability to the Plaintiff, Jane Doe. COUNTI Sexual Exploitatio’ | nd/or Sexual Assault of a Minor 22. The Plaintiff, Jane Doe, repeats and realleges paragraphs | through 21 above. 23. Defendant, Jeffrey Epstein, tortiously assaulted Plaintiff, Jane Doe, sexually on dozens of occasions between approximately February 2003 and approximately June 2005, and further sexually exploited her and contributed to her delinquency during that time. Defendant's acts were outrageous, egregious, intentional, unlawful, offensive and harmful. 24. The sexual assaults were in violation of the numerous state and federal statutes described in paragraph 16 above, and the assaults and acts of exploitation were committed by Defendant, Jeffrey Epstein, willfully and maliciously. 25. Asa direct and proximate result of Defendant, Jeffrey Epstein’s assaults on the Plaintiff, Jane Doe, the Plaintiff has in the past suffered, and will in the future suffer, physical Page 5 of 11 EFTA00234733

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Case 9:08-cv-80893-KAM ooument 1. Entered on FLSD Docket 08/14/2008 Page 6 of 12 injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, Jane Doe, will in the future suffer additional medical and psychological expenses. The Plaintiff, Jane Doe, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, Jane Doe, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, Jane Doe, demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, punitive damages, 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 II Cause of Action Pursuant to 18 2255 26. The Plaintiff, Jane Doe, adopts and realleges paragraphs 1 through 25 above. 27. The allegations contained herein in Count II are a separate and distinct legal remedy. 28. Asacondition of the 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, additionally entered into an agreement with the Federal Government to the following: “Any person, who while a minor, was a victim of an offense enumerated in Page 6 of 11 EFTA00234734

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Case 9:08-cv-80893-KAM Rocument 1. Entered on FLSD Docket 08/14/2008 Page 7 of 12 w Title 18, United States Code, Section 2255, will have the same rights to proceed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein’s attorneys with a list of individuals whom it was prepared to name in an indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining evidentiary burdens if any a Plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less”. 29. The Plaintiff, Jane Doe, was 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, pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein, and the United States Government. 30. Pursuant to the agreement, the Defendant, Jeffrey Epstein, is in the same position as if he had been tried and convicted of the sexual offenses committed against the Plaintiff, Jane Doe, and as such he must effectively admit liability unto the Plaintiff, Jane Doe. 31. As a direct and proximate result of the offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, the Plaintiff, Jane Doe, has in the past suffered, and will in the future suffer, physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and Page 7 of 11 EFTA00234735

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Case 9:08-cv-80893-KAM eocument 1 Entered on FLSD Dockst 08/14/2008 Page 8 of 12 psychological expenses and the Plaintiff, Jane Doe, will in the future suffer additional medical and psychological expenses. The Plaintiff, Jane Doe, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, Jane Doe, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, Jane Doe, demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, punitive damages, 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 It Intenti nfliction of Emotional Distress 32. The Plaintiff, Jane Doe, adopts and realleges paragraphs | through 25 above. 33. The Defendant, Jeffrey Epstein’s conduct towards the then minor Plaintiff was intentional and reckless. 34. The Defendant, Jeffrey Epstein, deliberately and recklessly inflicted mental suffering upon the then minor Plaintiff. 35. | The Defendant, Jeffrey Epstein’s conduct was outrageous in character, and so extreme in degree, going beyond all bounds of decency. 36. The Defendant, Jeffrey Epstein’s intentional, deliberate and reckless conduct caused severe emotional distress to the Plaintiff, Jane Doe. Defendant, at the time he committed these numerous sexual assaults on Plaintiff, Jane Doe, had a specific intent to harm the then minor Plaintiff and his conduct did so harm the Plaintiff. Page 8 of 11 EFTA00234736

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Case 9:08-cv-80893-KAM ooument 1. Entered on FLSD Docks" 08/14/2008 Page 9 of 12 37. Asa direct and proximate result of the Defendant, Jeffrey Epstein’s intentional and reckless conduct, the Plaintiff, Jane Doe, has in the past suffered and in the future will continue to suffer physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and the Plaintiff, Jane Doe, will in the future suffer additional medical and psychological expenses. The Plaintiff, Jane Doe, has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, Jane Doe, will continue to suffer these losses in the future. WHEREFORE, the Plaintiff, Jane Doe, demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, punitive damages, 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 IV Civil Remedy for Criminal Practices 38. The Plaintiff realleges paragraphs 1 through 25 above. 39. The allegations contained herein in Count IV are a separate and distinct legal remedy. Page 9 of 11 EFTA00234737

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Case 9:08-cv-80893-KAM Rooument 1 Entered on FLSD Docket, 08/1 4/2008 Page 10 of 12 40. The Defendant, Jeffrey Epstein, participated in an enterprise, or conspired or endeavored to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 41. | The Defendant, Jeffrey Epstein, participated in this pattern of criminal activity by engaging in at least two of the following acts of criminal misconduct with the same or similar intents, results, accomplices, victims, and methods of commission within a five year period: (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; (b) Acts of battery in violation of Florida Statutes Chapter 784; (c) Commercial sexual exploitation of a child in violation of Florida Statutes §827.071. 42. Under the Defendant, Jeffrey Epstein's plan, scheme, and enterprise, the Defendant, Jeffrey Epstein, paid employees and underlings to repeatedly find and bring him minor girls in order for the Defendant to solicit, induce, coerce, entice, compel or force such girls to engage in acts of prostitution and sexual misconduct. 43. The Plaintiff, Jane Doe, was the victim of the Defendant, Jeffrey Epstein's plan, scheme, and enterprise. The Plaintiff, Jane Doe, was called on the telephone and transported by various individuals to the Defendant, Jeffrey Epstein's residence, where she was placed in a room along with the Defendant, enticed to commit acts of prostitution, battery, and sexual exploitation. The Defendant, Jeffrey Epstein, conspired with his assistants and employees and various adults and minor children in order to accomplish his enterprise of seeking out, gaining access to, and exploiting minor children such as the Plaintiff, Jane Doe. Page 10 of 11 EFTA00234738

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Case 9:08-cv-80893-KAM Roument 1. Entered on FLSD Docket, 08/14/2008 Page 11 of 12 WHEREFORE, under the provisions of Florida Statutes Chapter 772, the Plaintiff, Jane Doe, demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, treble damages, costs and attorneys’ 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. Dated: August 12, 2008 Respectfully submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC Pao Brad Edwards Florida Bar #542075 be@bradedwardslaw.com Page 11 of 11 EFTA00234739

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| O6-ARGRS- Che ABR SOME Ob lore: on FLSD Docket 08/14/2008 | FIREQey1 2&B 12 D.C. TRONIC 35.44 (Rev. 208) CIVIL COVER SHEET Tiles cheon e hepaceintiotetir tone t the filing and service of pleadings or other p a UGUST 13, 2008 by local rules of court. This form, approved by the Judicial Conference of the United 1974, is required for the use of the Cle! the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) NOTICE: Attorneys MUST Indicate All Re-file I. (a) PLAINTIFFS DOE, JANE EPSTEIN, JEFFREY STEVEN M. LARIMORE CLERK U.S. OIST. CT. DEFENDANTS SO OF FLA LAM b) County of Residence of First Listed Plaintitt _ Palm Beach County of Residence of First Listed Defendant Palm Beach (b) ty — ee beach (EXCEPT IN U.S. PLAINTIFF CASES) (ON U.S. PLAINTIFF CASES ONLY) (c) Attorney's (Firm Name, Address, and Telephone Nomber) NOTE: IN LAND CONDEMNA BID eB OCATION OF THE TRACT Law Office of Brad Edwards & Associates,LLC LAND INVOLVED, FICED by D.C (@) Check County Where Action Arose: O MIAMI-DADE © MONROE OD BROWARD AM PALM BEACH O MARTIN O ~ LUCREEMEN NR WARMORE O OKEECHOBEE Dor ee otST. CT. LANDS Il, BASIS OF JURISDICTION (Pisce an “X™ in One Box Only) Il. CITIZENSHIP OF PRINCIPAL R FEET ve Box for Plant (For Diversity Cases Onty) and One Bos for Defendant) 0} US Government O 3 Feders! Question PTr DEF rrr DEF Pinimtiff (U.S. Government Not » Pany) Citizen of This Suaie s | © 1 Incorporated or Principal Place oO 4 Of of Business le This State 0 2 U.S. Government R4 Diversity Cisizen of Another Site =O 2 GO 2 lmcorporsied ond Precipal Place o s+ os Defendant (Indicate Citizenghip of Parties in Inem It) of Busineas In Another Sate OSc, POP i lL) fe Crdzen or Sublet ef o 3 © 35 Foreign Nation 9 ¢ oF ynery IV URE OF SUIT (risce an =x" in One Bh: O. ONTRA OR OD 110 Insurance PERSONAL INJURY PERSONAL INJURY 610 Agricultere © 422 Appeal 28 USC 158 1 400 State Reapportionment O 120 Marine 0 310 Airplane 362 Personal Injury - 620 Other Food & Drug © 423 Withdrawal 410 Antieust O 130 Miller Act 0 315 Airplane Product Med. Malpractice 625 Drwg Related Seizure 28 USC 157 OO 430 Banks aed Benking OD 140 Negotiable Instrumenc Liability 365 Personal Injery - of Propeny 21 USC 88! D 450 Commerce D 150 Recovery of Overpayment | 320 Assault, Libel & Prodvet Liability 630 Liquor Laws O 460 Deportation & Enforcement of Judgment Slander 368 Asbestos Personal 640 RR. & Truck O 470 Racketeer influenced and © 15) Medicare Act © 320 Federal Employers” Injury Product 650 Airline Reps Corrupt Organizations © 152 Recovery of Defeated Liability Lisbility 660 Occupational O 480 Consumer Credit Stedent Loans D340 Marine PERSONAL PROPERTY Safety/Henteh O 490 Cabie/Sat TV (Exel, Veterans) 2 345 Marine Product 370 Other Fraed 690 Other D810 Selective Service © 153 Recovery of Overpayment Leability D 371 Trethin Lending [LABOR SOCIAL SECURITY 0 850 Securnties/Commoditien! of Veteran's Benefits 2 350 Motor Vehicle 380 Other Personal |G 110 Fair LaborStandards | 86! HIA (139Sf) Exchange © 160 Stockholders Swits © 355 Motor Vehicle Property Damage Act © 862 Black Lung (923) 875 Customer Chatlenge DF 190 Other Comenet Product Liabibity 385 Property Damage | 720 Labor/Mgmt Relations [C 863 DIWC/DIWW (405(g)) 12 USC 3410 2 195 Coniract Product Lisbility | 2% 360 Other Personal Predwct Lisbitity | 730 Labor/MgmtReporting | © 864 SSID Title XVI O 890 Other Statutory Actions OD 196 Franchise In) & Disclosere Act D 865 RS! (405(g)) O 891 Agriceturs! Acts [REAL PROPERTY so]. CIVIL RIGHTS _|._ PRISONER PETITIONS | | FEDERAL TAX SUITS ]© £92 Economic Stabilization Act D 210 Land Condemastion D 441 Votng D 870 Taxes (US. Plaintif! }© 893 Enviconmental Matiers © 220 Foreclosere © 442 Employment OD 791 Empl. Ret. Inc. Securit or Defendant) O 894 Exergy Allocation Act se A Ejecimem | 443 Hous Habeas Corpus: © B71 IRS—Thied Part tC) 4 AH Some Lao ; Acaswmotations $30 General” 26 USC 7609 #95 Freedom of Information Act © 245 Tort Product Lisbility 0 444 Welfare 535 Death Penalty DF 900 Appeal of Fee Determination © 290 All Other Real Property |]. TAS Amer. w/Disablies $40 Mandamus & Other] 400 Nanimyuauee Under Bqust Accom to Justice 5 446 Amer. w/Dusabities $50 Civil Rights co 46) Hebeas Corpen-Alien D 440 Other Civil Rights 555 Prison Condition 465 Otner temmigrecion a 9 Coenatenaity of See Vv. ORIGIN (Place an “X™ in One Box Only) - ‘Transferred from _ to District @1 Original © 2 Removed from O 3. Re-filed- OF 4 Reinstatedor 0 5 another district O 6 Multdisrict O 7 a Proceeding State Court (see VI below) Reopened ; Litigation Magistrate a) Re-filed Case OYES @NO b) Related Cases G YES ONO 08-801 19; 08-80232; VI. RELATED/RE-FILED | 1¢.. osructions 08-80380; 08-80381; CASE(S). second pagel JUDGE Kenneth A. Marra DOCKET NUMBER 08-80804: 08-80736 under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless 18 USC 2255 ~ Sexual Exploitation and Other Abuse of Child LENGTH OF TRIAL via _] 4 days estimated (for both sides to try entire case) VIII. REQUESTED IN) © CHECK IF THISIS A CLASS ACTION DEMAND $ 50,000,000 CHECK YES only if demanded in complaint Vil. CAUSE OF ACTIO COMPLAINT: UNDER F.R.C.P, 23 JURY DEMAND: @ Yes DO No soovet orm Kno Is thor & CORRECT TO SIGNATURE OF ATTORNEY OF RECORD DATE THE Bi : WLE! sf oS August 12, 2008 FOR OFFICE wy Zee AMOUNT B0 ——" RECENT # wn EFTA00234740