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Court Records Doe No. 102 v. Epstein, No
==================== DOCUMENT: Court Records__Doe No. 102 v. Epstein, No. 909-cv-80656 (S.D. Fla. 2009)__001.txt ====================
METADATA_SOURCE: Court RecordsDoe No. 102 v. Epstein, No. 909-cv-80656 (S.D. Fla. 2009)
METADATA_FILENAME: 001.pdf
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Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 1 of 27
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
JANE DOE No. 102,
09-80656
Plaintiff,
vs.
JEFFREY EPSTEIN,
Civil Action No. ----
CIV-RYSKAMP
MAGISTRATE JUDGE
VITUNAC
FILED by 1:JS
D.C.
INTAKE
MAY - 1 2009
/.·
STEVEN M. LAl-llMORE
CLERK U.S. DIST. CT
L
S.D. OF FLA MIAMI
COMPLAINT AND
Defendant.
DEMAND FOR JURY TRIAL
I
-------------------
COMPLAINT AND DEMAND FOR JURY TRIAL
Plaintiff, Jane Doe No. 102, brings this Complaint against Defendant, Jeffrey Epstein,
and states as follows:
PARTIES, JURISDICTION, AND VENUE
1.
At all times material to this cause of action, Plaintiff, Jane Doe No. 102, was a
resident of Palm Beach County, Florida.
2.
This Complaint is brought under a fictitious name to protect the identity of
Plaintiff, Jane Doe No. 102, because this Complaint makes sensitive allegations of sexual assault
and abuse of a then minor.
3.
At all times material to this cause of action, Defendant, Jeffrey Epstein, had a
residence located at 358 El Brillo Way, Palm Beach, Palm Beach County, Florida.
4.
Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is
currently incarcerated in the Palm Beach County Stockade.
5.
At all times material to this cause of action, Defendant, Jeffrey Epstein, was an
adult male born in 1953.
Podhurst Orseck, P.A.
West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
www.podhurst.com
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 2 of 27
6.
This Court has jurisdiction over this action and the claims set forth herein
pursuant to 18 U.S.C. § 2255.
7.
This Court has venue of this action pursuant to 28 U.S.C. § 1391(b), as a
substantial part of the events giving rise to the claim occurred in this District.
STATEMENT OF FACTS
8.
At all relevant times, Defendant, Jeffrey Epstein, was an adult male, spanning the
ages of 45 and 55 years old. Epstein is known as a billionaire financier and money manager with
a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth, power,
and influence. He owns a fleet of aircraft that includes a Gulfstream IV, a helicopter, and a
Boeing 727, as well as a fleet of motor vehicles. Until his incarceration, he maintained his
principal place of residence in the largest home in Manhattan, a 51,000-square-foot eight-story
mansion on the Upper East Side. Upon information and belief, he also owns a $6.8 million
mansion in Palm Beach, Florida, a $30 million 7,500-acre ranch in New Mexico he named
"Zorro," a 70-acre private island known as Little St. James in St. Thomas, U.S. Virgin Islands, a
mansion in London's Westminster neighborhood, and a home in the Avenue Foch area of Paris.
The allegations herein concern Defendant's conduct while at his lavish homes and/or numerous
other locations both nationally and internationally.
9.
Upon information and belief, Defendant has a sexual preference for underage
minor girls. He engaged in a plan, scheme, or enterprise in which he gained access to countless
vulnerable and relatively economically disadvantaged minor girls, and sexually assaulted,
molested, and/or exploited these girls, and then gave them money.
10.
Beginning in or around 1998 through in or around September 2007, Defendant
used his resources and his influence over vulnerable minor girls to engage in a systematic pattern
of sexually exploitative behavior.
Podhurst Orseck, P.A.
West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
www.podhurst.com
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 3 of 27
11.
Defendant's plan and scheme reflected a particular pattern and method.
Defendant coerced and enticed impressionable, vulnerable, and relatively economically less
fortunate minor girls to participate in various acts of sexual misconduct that he committed upon
them. Defendant's scheme involved the use of underage girls, as well as other individuals, to
recruit other underage girls. Upon information and belief, Defendant and/or an authorized agent
would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach
residence. His assistants would call economically disadvantaged and underage girls from West
Palm Beach and surrounding areas who would be enticed by the money being offered and who
Defendant and/or his assistants perceived as less likely to complain to authorities or have
credibility issues if allegations of improper conduct were made. The then minor Plaintiff and