EPSTEIN
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Court Records Doe No. 8 v. Epstein, No.
==================== DOCUMENT: Court Records__Doe No. 8 v. Epstein, No. 909-cv-80802 (S.D. Fla. 2009)__001.txt ====================
METADATA_SOURCE: Court RecordsDoe No. 8 v. Epstein, No. 909-cv-80802 (S.D. Fla. 2009)
METADATA_FILENAME: 001.pdf
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May 28, 2009
09-CV-80802-Marra-Johnson
Case 9:09-cv-80802-KAM Document 1 Entered on FLSD Docket 05/28/2009 Page 1 of 7
JANE DOE NO. 8,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.:
I
----------------
COMPLAINT
FILED by VT
D.C.
ELECTRONIC
STEVEN M. LARIMORE
CLERK U.S. DIST. CT.
S. D. OF FLA.· MIAMI
Plaintiff, Jane Doe No. 8 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey
Epstein, as follows:
Parties, Jurisdiction and Venue
1.
Jane Doe No. 8 ("Jane Doe") 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
mmor.
3.
Defendant Jeffrey Epstein is a citizen and resident of the State of New York, and
presently serving a prison sentence in Palm Beach County, Florida for, inter alia, solicitation of
prostitution and solicitation of minors to engage in prostitution ..
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;
MERMELSTEIN & HOROWITZ, P. A.
www.sexabuseattorney. corn
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Case 9:09-cv-80802-KAM Document 1 Entered on FLSD Docket 05/28/2009 Page 2 of 7
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
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) as a
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 in his
early 50's. 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 2001, 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. These
underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation
MERMELSTEIN & HOROWITZ, P. A.
www.sexabuseattorney.com
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Case 9:09-cv-80802-KAM Document 1 Entered on FLSD Docket 05/28/2009 Page 3 of 7
in his Palm Beach mansion. Epstein, upon information and belief, generally sought out economically
disadvantaged underage girls from 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.
12.
Epstein's plan and scheme reflected a particular pattern and method. The underage
victim would be brought or directed to Epstein's mansion, where she would be led up a flight of
stairs to a room 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 would then
remove his towel and lie naked on the massage table, and direct the girl to remove her clothes.
Epstein would then perform one or more lewd, lascivious and sexual acts.
13.
Consistent with the foregoing plan and scheme, Jane Doe was recruited by another
girl, who told her that she could make some money, but did not tell her what was involved. At all
relevant times, the girl who recruited Jane Doe was acting on behalf of and as agent for Epstein.