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Court Records Doe No. 103 v. Epstein, No
==================== DOCUMENT: Court Records__Doe No. 103 v. Epstein, No. 910-cv-80309 (S.D. Fla 2010)__001.txt ====================
METADATA_SOURCE: Court RecordsDoe No. 103 v. Epstein, No. 910-cv-80309 (S.D. Fla 2010)
METADATA_FILENAME: 001.pdf
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Case 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 1 of 19
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
Civil Action No. ----
10-80309
JANE DOE No. 103,
Plaintiff,
V.
JEFFREY EPSTEIN,
Defendant.
I
----------------
COMPLAINT AND DEMAND FOR JURY TRIAL
t11119"'al611 ~31~1,6
seated
FILED by tb D.C.
FEB 2 3 2010
STEVEN M. LARIMORE
CLERt< U '3 DIST CT
S. D. ot FU. - MIAMI
Plaintiff, Jane Doe No. 103 ("Plaintiff'), brings this Complaint against Defendant, Jeffrey
Epstein ("Defendant"), and states as follows:
PARTIES, JURISDICTION, AND VENUE
1.
At all times material to this cause of action, Plaintiff was a resident of Palm Beach
County, Florida.
2.
This Complaint is brought under a fictitious name to protect the identity of
Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse of a then
mmor.
3.
At all times material to this cause of action, Defendant owned a residence located
at 358 El Brillo Way, Palm Beach, Palm Beach County, Florida.
4.
Defendant is presently a citizen of the United States Virgin Islands. Pursuant to
the plea agreement entered by the Defendant in state court and the sentencing which occurred on
June 30, 2008, Defendant is currently under community control in Palm Beach County, Florida.
Sealed
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 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 2 of 19
5.
Defendant is an adult male born on January 20, 1953.
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 was an adult male spanning the ages of 45 and 55
years old. Defendant 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 he1.icopter, and a Boeing
727, as well as a fleet of motor vehicles. Until his incarceration pursuant to the plea entered and
sentencing, which occurred on June 30, 2008, he maintained his principal place of residence in
the largest dwelling in Manhattan, a 51,000-square-foot eight-story mansion on the Upper East
Side. 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
the U.S. Virgin Islands, a mansion in London's Westminster neighborhood, and another
residence in the Avenue Foch area of Paris. The allegations herein concern Defendant's conduct
while at his lavish residence in Palm Beach and numerous other locations both nationally and
internationally.
9.
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.
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 9:10-cv-80309-KAM Document 1 Entered on FLSD Docket 03/09/2010 Page 3 of 19
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.
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 underage girls. 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 other minor girls, some as young as